DATA PRIVACY NOTICE (SERVICES)

1. Introduction

This is GM Europe Limited (hereafter also “Service Provider“, “us“, “we“ or “GM Europe”) Data Privacy Notice for the processing of personal data of Users of our Services.

Data privacy is of utmost importance to us. This notice aims to inform our Users on the instances in which GM Europe collects and uses personal information and on the Users’ rights they enjoy in this regard (under the EU General Data Protection Regulation).

This Privacy Notice may be changed over time. You are advised to regularly review the Privacy Notice for possible changes. This Privacy Notice was last changed on [March 2020]. You can store or print this Privacy Notice by using the buttons at the top of this page.

2. When does this privacy Notice apply?

This Privacy Notice is applicable to the processing by GM Europe of all personal data of its Users while using the GM Europe Pray subscription services (before and hereafter also “Services”).

3. Who is responsible for your personal data?

The controller for the processing of your personal data is

GM Europe Limited
4 V.Dimech Street, Floriana, FRN 1504, Malta
Company register: Floriana, Malta; Company number C 97607 Telephone: 087 056 9284
E-Mail: pray@helpu.io

4. For which purposes do we process your personal data?

   1. For purposes of providing the Services

      1. What does this purpose entail?

If you wish to make use of one of our Services, we process personal data that you make available to us in order to provide you with these Services.

2. On what legal basis do we process personal data for this purpose?

The processing is necessary for the performance of the contract concluded with you or in order to take steps at your request prior to entering into such contract. The provision of the data is a contractual requirement to enter into a contract. If you don’t provide the necessary personal data, no contract can be concluded and you cannot use our Services.

3. Which personal data do we process for this purpose?

For this purpose, we process your telephone number, your IP address and the handset type of the device you are using.

4. How long do we retain your personal data for this purpose?

We retain your personal data for as long as it is necessary to provide you with our Services or to process users’ complaints or requests relating to the Services, and as long as it is required by law. In addition, we retain the personal data for as long as it is necessary for any establishment, exercise or defence of legal claims.

2. For billing purposes

   1. What does this purpose entail?

If you enter into a contract with us to use our service, we process personal data to charge the corresponding fee. For the purpose of billing the fee via your mobile phone bill, we transmit your personal data to your mobile service provider (either directly or through our technical payment service provider).

2. On what legal basis do we process personal data for this purpose?

The processing is necessary for the performance of the contract to which you are party. The provision of the data is a contractual requirement to enter into a contract. If you don’t provide the necessary personal data, no contract can be concluded, and you cannot use our Services.

3. Which personal data do we process for this purpose?

For this purpose, we process your telephone number.

4. How long do we retain your personal data for this purpose?

We retain your personal data for as long as it is necessary for billing purposes and as is required by law (especially due to retention periods under tax law). In addition, we retain the personal data for as long as it is required for any establishment, exercise or defence of legal claims.

3. To answer your questions

   1. What does this purpose entail?

If you get in touch with us via our support email addresses, we will use your personal data in order to reply and answer your questions.

2. On what legal basis do we process personal data for this purpose?

The processing is necessary for the purposes of the legitimate interests pursued by us and you. Your interest is to get the information you request, and our interest is to answer the requests of our Users or potential Users.

3. Which personal data do we process for this purpose?

For this purpose, we process your name, contact details, your correspondence with us with regard to your question and all other personal data which are necessary to answer your question.

4. How long do we retain your personal data for this purpose?

We retain your personal data for as long as it is necessary to answer your request and as is required by law. In addition, we retain the personal data for as long as it is required for any establishment, exercise or defence of legal claims.

5. Who has access to your personal data?

   1. Access to your personal data by third parties

The following third parties have access to your personal data where relevant for the provisioning of their products or services to GM Europe:

• Mobile Service Providers (Vodacom – for Users from South Africa)

• SMS messaging companies

• Customer Service companies: FSP Global

• Amazon Web Services, Inc., 410 Terry Avenue North Seattle WA 98109, United States (all User data is stored in Frankfurt, Germany)

If your personal data are transferred to a recipient in a country that does not provide an adequate level of protection of personal data, GM Europe Limited will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these third parties.

In other cases, your personal data will not be supplied to third parties, except when required by law.

2. The use of your personal data by data processors

When a third party processes your personal data solely following GM Europe’s instructions, it acts as a “data processor”. In line with the requirements of the EU General Data Protection Regulation, we enter into an agreement with such data processors concerning the processing of personal data. In this agreement we include, at a minimum, the obligations and safeguards to ensure that your personal data are adequately protected.

6. How are your personal data secured?

GM Europe has taken adequate safeguards to ensure the confidentiality and security of your personal data. In particular, GM Europe has implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing.

7. Questions or requests for access, MODIFICATION, Rectification, erasure, restriction, data portability or objection?

The EU General Data Protection Regulation grants you a number of rights. You can request access (Art 15 GDPR), rectification (Art 16 GDPR), erasure (Art 17 GDPR), restriction (Art 18 GDPR), data portability (Art 20 GDPR) or objection (Art 21 GDPR) of the data that GM Europe processes about you at any time by sending a request to:pray@helpu.ioif you are a User from South Africa.

Users can cancel their account through our portal if they have an active account. If they want to process their data outside of that, they will have to email customer service at the emails provided.
Should you have any questions regarding the processing of your personal data, please contact pray@helpu.ioif you are a User from South Africa.

If you feel that we do not comply with the applicable privacy rules you also have the right to lodge a complaint with a competent data protection authority: