Privacy Policy for Mobile Applications

This privacy policy (the “Policy”) governs your use of the software application StratOSS Mobile (“Application”) for mobile devices that was created by Accanto Systems Oy (“Accanto Systems”, “us”, “our” or “we”).

This Policy describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our Application(s) provided on a mobile platform (for example, iOS and Android) and related services (collectively, the “Services”).

Please note that the scope of this Policy is limited to information collected or received by us through your use of the Services. Accanto Systems is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.

By using the Application and any other Services, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Services.

What information does the Application obtain and how is it used?

User Provided Information

When you use the Application and the Services, you generally provide (a) transaction-related information, such as when you activate a trial code or make a speed test; and (b) information you provide us when you contact us for help.

Automatically Collected Information

In addition, if you have enabled the Active Monitoring function, the Application collects for the service quality purposes certain information automatically, including, but not limited to, the network quality information, the type of mobile device you use, your mobile devices unique device ID, your mobile operating system, the type of mobile Internet browsers you use. You can opt-out the Active Monitoring by setting the Active Monitoring option to “OFF” in application settings.

If you have not explicitly enabled a specific trial code provided by Accanto Systems Oy the Application does not obtain any end user information. In case you have explicitly enabled a trial code in the application settings we may collect also personal data including, but not limited to: (i) your IMSI, and (ii) your IMEI code.

Use of the Information

We may use the above data to (i) gather statistics on network and service accessibility, service retainability, integrity, and application level performance; (ii) detect technical errors causing degradations in service quality; (iii) improve our Services and the Application; and (iv) contact you.

Does the Application collect precise real time location information of the device?

The Application collects information about the cell-ID of your mobile device. In addition, if you have enabled the function in device platform settings, the device platform given location is also collected.

Collected location information is used for building a geographical view on network and application performance and correlated collected statistics to network resources like network cells, identified by cell-IDs.

Do third parties see and/or have access to information obtained by us?

We will share your information with third parties only in the ways that are described in this Policy.
We may engage other companies and individuals to perform services on our behalf. Example of these services include analyzing data as well as improving of our Services and the Application. These agents and service providers may have access to your personal information in connection with the performance of services for Accanto Systems.
We may disclose and share User Provided and Automatically Collected Information:

• based on your consent; or
• as required by law or regulation, such as to comply with a subpoena, or based on a request from a competent authority or similar legal process; or
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; orwith our trusted services providers, who have agreed to adhere to the rules set forth in this Policy.

We may also publish aggregated or de-personalized data based on our users’ information (such as statistics) provided that such information does not identify you.

What are my opt-out rights?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

You can also opt-out the Active Monitoring function by setting the Active Monitoring option to “OFF” in application settings.

Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

You have the right of check what kind of personal data has been collected by us. Upon your request, we will modify, remove or supplement any incorrect, unnecessary, incomplete or outdated data. You may have your data updated, removed and/or checked by contacting us at below contact details.

Children

We do not use the Application to knowingly solicit data from or market to children under the age of 18. If you believe we have inadvertently collected such data, do contact us so we can remove such data.

External links

Our Services may contain links to external sites and link content from external third party sources. Please note that the use of such third-party sites or content is subject to the privacy policies and usage terms of the third party in question instead of our own terms and we do not have control or assume any liability over such content.

Security

We are concerned about safeguarding the confidentiality of your information. All of your data is protected in accordance with generally acceptable industry standards and although no system is 100% secure, we take reasonable steps to safeguard your data from unauthorized access. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

This Policy may be updated from time to time for any reason. You are advised to consult this Policy regularly for any changes, as continued use is deemed approval of all changes. Upon any updates to this Policy the “last updated” date will be modified respectively.

If this Policy is changed in a manner that materially alters your rights or obligations under this Policy, we will use reasonable efforts to notify you of the change. For example, we may send a message to your email address, or generate a pop-up or similar notification when you access the Application for the first time after such changes are made.

Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Policy now and as amended by us. “Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information.

By using the Application and our Services, you agree that we may process your data outside the country where you live in (for example if you are an EU citizen, outside the EU or the European Economic Area). This can happen if, for instance, the service provider of our hosting services or analytical services is located outside your country. In such cases, we will take steps to ensure that your personal data is processed lawfully and in accordance with this privacy policy. If you do not accept your data being transferred, please refrain from using the Application and any of the Services.

Contact us

The data controller is Accanto Systems Oy, having its address at Hämeenkatu 20, 15110 Lahti, Finland, business ID 2135391-3.

If you have any questions regarding privacy while using the Application and our Services, or have questions about our practices, please contact us directly by sending an email to privacy@accantosystems.com or through www.accantosystems.com