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BYZANTINE APPS PRIVACY NOTICE

Last Updated: July 27, 2023

Byzantine Apps, LLC, a Georgia limited liability company (“Byzantine,” “we,” “us,” and “our”), provides this privacy notice (“Privacy Notice”) to explain how we or others collect, use, store, and share information about individuals in two different contexts (we refer to such individuals  as “you,” “your,” and “yourself”): (1) visitors to this website located at byzantineapps.io and any other website on which this Privacy Notice is allowed to be posted or linked (such individuals, “Visitors”, and such websites collectively, the “Site”); and (2) End Users of Byzantine’s owned and operated mobile applications (“Byzantine Apps” or “Apps”).  This Privacy Notice also explains how we enable certain third parties to collect information directly from End Users of our Apps, as well as certain choices you may have regarding how we use information about you and rights you may have to access or correct such information.

If you are located in the European Economic Area (EEA), Switzerland or the United Kingdom and would like to review your rights under the EU GDPR or the UK GDPR (collectively referred to in this Privacy Notice as the “GDPR”), please go to Section 5 of this Privacy Notice. If you are a resident of California or Virginia, or certain other states, you may review your rights under your state laws at Section 7 of this Privacy Notice.

Below, we explain certain terms that we will use in this Privacy Notice that may make it easier to understand:

â—Ź     SDK or Software Development Kit: An SDK is a block of computer code owned by certain Third Party Data Collectors that we can integrate with our apps to enable those Third Party Data Collectors to collect certain data, which is often useful to the mobile advertising and other data industries.

â—Ź     Third Party Data Collector:  A third party that (1) owns or operates an SDK that is integrated with one or more Byzantine Apps and (2) directly collects information from End Users of the Apps through integration of such SDK.

â—Ź     Visitors: Individuals who visit or use our Site.

â—Ź     End Users: Individuals who download and use one or more of the Byzantine Apps on their Device.

â—Ź     Devices: Internet-connected mobile devices such as Apple iPhones that use iOS or Samsung Galaxy devices that use Google’s Android OS.

â—Ź     Byzantine Apps or Apps: Mobile applications owned and operated by Byzantine, including WTForecast and Backseat Navigator.

â—Ź     Advertising ID: A unique alphanumeric string randomly assigned by operating system manufacturers to each Device. Advertisers may use this ID to serve your Device more personalized advertising.  Examples of Advertising IDs include iOS IDFAs and Android Advertising IDs.

â—Ź     Installation ID: A unique alphanumeric string randomly assigned by certain Apps to a Device but which is not used for advertising purposes.

â—Ź     App Tracking Transparency/Opt-Out of Interest Based Ads: Features on iOS or Android Devices that allows users to disable or limit the Apps’ ability to access the Advertising ID on your Device.

1. Summary: Who is Byzantine?

Byzantine’s primary business is the ownership and operation of mobile applications.  We also maintain websites related to the mobile applications that we offer.  As described further below, we typically do not collect any personal information from End Users of the Byzantine Apps, but we do facilitate collection of such information by Third Party Data Collectors.  Additionally, we may collect certain personal information that Visitors to our Site may choose to provide.

2. Information Collection

A. Information We Collect Through Our Apps

We do not directly collect personal information from End Users of our Apps.  However, we may collect or receive certain aggregated, deidentified, or anonymous data related to usage of our Apps, primarily for the purpose of troubleshooting problems, reviewing how our Apps are being used by End Users, and other analytical or internal purposes.  A full description of our use of this data can be found in Section 4 below.  Additionally, we enable certain third party vendors to collect aggregated, deidentified, or anonymous information regarding usage of our Apps for the purpose of providing analytic reports to us, e.g., regarding the frequency and cause of one or more Apps crashing.

B. Information Third Party Data Collectors Collect Through Our Apps

We allow certain, authorized Third Party Data Collectors to collect data (including personal information) directly from End Users of our Apps, via integration of these third parties’ SDKs into the Apps.  (In other words, we facilitate the Third Party Data Collector’s collection of certain information from you, but we do not receive or have access to the information they collect.)  When you use an Byzantine App that has integrated with a third party SDK (whether you are actively using the App or allowing it to run in the background), the Third Party Data Collector can collect information through or about your Device.  The information that may be collected by Third Party Data Collectors includes some or all of the data elements listed below.  However, you should visit each Third Party Data Collector’s privacy policy for complete details on what information they collect and how they use such information.  Please see Section 2.C for instructions on how to access such privacy policies.

a.    Precise Location Information:

â–      Specific geolocation of the Device, usually described by latitude-longitude coordinates compiled through GPS features of the SDK, WiFi connection information, cell tower triangulation and other methods.

â–      Dwell time within or in proximity to points of interest (i.e., the length of time your Device stayed at one place).

â–      Altitude, bearing, and speed.

b.    Relative Location Information:

â–      Bluetooth Low-Energy (BLE) sensors, or beacons,

â–      Information obtained from the Internet of Things (IoT) devices.

â–      Near-field Communication (NFC)

â–      Certain third party SDKs may be capable of receiving signals from each of the above technologies that indicate the proximity of a Device. For example, certain brick-and-mortar stores use beacons that sense when a Bluetooth-enabled Device is in proximity to the beacon (i.e., when a Device user enters the store). Retail locations, sports arenas, restaurants, museums and other similar businesses may also use beacons.

c.    Advertising IDs or Installation IDs

d.    Timestamps (that may include time and date)

e.    Device Event Information:

â–      App or system crashes

â–      System crashes

â–      Device settings

f.      Device Usage Information

â–      Type of device (e.g., Samsung Galaxy S21)

â–      Operating system (OS) information (e.g., iOS 14.5)

â–      System settings (e.g., enabled/disabled status for Location Services)

â–      Time zone

â–      Mobile carrier

â–      IP address

â–      Names and/or identifiers for Apps on your Device integrated with SDK

â–      User agent (i.e., a characteristic string that lets servers and network peers identify the application, operating system, vendor, and/or version of the Device)

g.    Network Information

â–      VPN status

â–      Network protocols employed

â–      Device connectivity information (e.g., how a device connects to a network) and signal strength

â–      Network information such as mobile network code and mobile country code

C. How Third Party Data Collectors Use Information Collected Through Our Apps

The Third Party Data Collectors who collect information through our Apps may use such information in the manner set forth in their respective privacy policies.  Generally, these Third Party Data Collectors may use information collected from or about End Users or Devices to (a) to customize and measure ads in apps and other advertising; (b) for app and user analytics; (c) for disease prevention and cybersecurity; (d) for market, civic or other research regarding aggregated human foot and traffic patterns; and (e) to generate proprietary pseudonymized identifiers tied to the information collected for the above purposes. 

We contractually prohibit Third Party Data Collectors from using or selling any of the SDK Data:

(i)            for any unlawful tracking or unlawful surveillance;

(ii)             collected from or about End Users or Devices located in the US, EEA, or UK to law enforcement agencies or to any governmental agency, to be used for a law enforcement purpose, except to the extent strictly necessary (and then redacted to the greatest extent possible) to comply with a judicial or other governmental order;

(ii)       to promote any illegal product or engage in any illegal purpose; to associate any End User, Device or individual to create profiles or inferences related to social networks, health status or ailments, sexual orientation or activity, political activity or beliefs, or religious convictions;

(iii)          to associate any End User, Device or individual with any venue that is related to medical care, substance abuse or rehabilitation, mental health, family planning or pregnancy (or pregnancy termination);

(iv)         for purposes related to political campaigns or fundraising; 

(v)           to make decisions about any individual’s eligibility for employment, health care, credit or insurance, or for any other purpose that is covered by the Fair Credit Reporting Act; or

(v)           in a manner that violates applicable laws or any privacy policy posted by the Third Party Data Collector.

For more information regarding how Third Party Data Collectors use and share information collected via our Apps, please review each third party’s privacy policy, available at the links below:

â—Ź     Outlogic:  https://outlogic.io/privacy/

â—Ź     Umlaut:  https://tacs.c0nnectthed0ts.com/policy1/data_privacy.html

â—Ź     Opensignal:  https://www.opensignal.com/privacypolicy-for-crowdsourcedata

â—Ź     AerisWeather:  https://www.aerisweather.com/privacy/

â—Ź     Mapbox:  https://www.mapbox.com/legal/privacy

â—Ź     Facebook SDK:  https://www.facebook.com/privacy/policy

â—Ź     Google Play Services:  https://policies.google.com/privacy

â—Ź     Firebase:  https://firebase.google.com/support/privacy

â—Ź     AppLovin:  https://www.applovin.com/privacy/

â—Ź     AdSense:  https://policies.google.com/privacy

â—Ź     InMobi:  https://www.inmobi.com/privacy-policy

â—Ź     Ad4Game:  https://a4g.com/privacy

â—Ź     Meta Audience Network:  https://www.facebook.com/privacy/policy

â—Ź     Verve:  https://pubnative.net/privacy-notice/

â—Ź     AdColony:  https://www.adcolony.com/privacy-policy/

â—Ź     Smaato, Inc:  https://www.smaato.com/privacy/

â—Ź     Unity Ads:  https://unity.com/legal/privacy-policy

â—Ź     Taboola, Inc:  https://www.taboola.com/policies/privacy-policy

D. Information Byzantine Collects from Site Visitors

Visitors can generally browse our Site without submitting any information.  However, Visitors may choose to submit information via a “Contact Us” form, through our support email addresses (including support@byzantineapps.io and privacy@byzantineapps.io), or other voluntary means (such as submission of a request to exercise rights under applicable privacy laws).  We only collect the information that Visitors choose to provide.  Please see Section 2.E below for a description of how we use such information.

E. How We Use Information We Collect From Visitors to this Site or End Users of the Apps

We may use information we collect about Visitors to our Site or End Users of our Apps for our corporate and internal purposes, including:

  1. To improve, maintain and operate our existing Site and Apps and develop new ones.  For example, we may review how you use or Site or Apps and use that information to troubleshoot issues and adjust things to improve your experience.
  2. To communicate with Visitors, including to offer Visitor support for the Site. For example, we may use your personal information solely for purposes of replying to your questions when you use the “Contact Us” form on the Site or send us an email at support@byzantineapps.io.
  3. Market research.
  4. Direct marketing in accordance with applicable law.
  5. For human resource purposes.
  6. To detect, investigate, and prevent misuse of our Site or Apps or other illegal activities and to protect the rights and property of Byzantine, its customers, and others.
  7. To respond to data subject requests.

As stated previously, we only collect (1) information that Visitors to our Site choose to provide and (2) aggregated, deidentified or anonymous information related to usage of our Apps (which information does not identify an individual End User or Device).  We may share such information with other parties, as follows:

  1. With Our Affiliates:

â—‹     In the event we establish a subsidiary or otherwise become affiliated with another company, we may share any information that we have collected with those entities.

  1. In Relation to Legal Proceedings or Process:

â—‹     We may share information we have collected when we have a legal obligation to do so. This may include compliance with a binding court order, exercising, establishing or defending Byzantine’s legal rights, or those of our customers or any other third party, or in good faith to comply with the requirements of any applicable law or legal process.

â—‹     Similarly, we may disclose any information we have collected as required to respond in good faith to legal process, including subpoenas (whether civil or criminal), court orders or search warrants.

  1. To Investigate Malfeasance and to Defend Ourselves or Third Parties:

â—‹     We may share information to assist us in enforcing our legal rights, our Terms of Service, or other policies as applicable, or to investigate any potential violation of the same. We may also share information to investigate any potential violations of the law, to defend ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).

  1. In Relation to a Corporate Transaction:

â—‹     If a third party seeks to acquire or actually acquires our business or assets in whole or in part, we may disclose information we have collected in connection to that transaction (including, without limitation, during due diligence that may be undertaken in advance of possible sales).

The Third Party Data Collectors who collect information through our Apps may share the information as described in their own privacy policies.  Please see Section 2.C for instructions on how to access such privacy policies.

F. User Choices & Opt-Out Tools

You can manage the way that we and third parties use information collected from or about you as described below:

  1. Browser Settings: You may adjust the privacy and security settings of your web browser to change how your browser uses cookies.  At this time, our Site does not place or use cookies.
  2. Opting Out of Interest Based Advertising via NAI or DAA: You can opt out tailored advertising on mobile devices by companies that participate in the Network Advertising Initiative or the Digital Advertising Alliance by visiting the NAI’s opt-out page or the DAA’s Consumer Choice Page. Residents of the EEA, UK and Switzerland may refer to www.youronlinechoices.com. The opt-out tools provided on these industry pages are generally based on cookie technologies.  As such, if you delete your cookies (or change or update your web browser), you will need to repeat the opt out process. While our Site does not currently use cookie technology, we are providing this information because we may partner with businesses to tailor ads for our Site or Apps that do. Further, the Third Party Data Collectors may use information they have collected from our Apps to match identifiers across devices – such as to tie a mobile Advertising ID by common IP address to a browser-based cookie ID.
  3. Device Settings: You can limit the collection of your Advertising ID from your Device through certain device settings, as described below. 

For iOS devices:

â—Ź      Go to Settings > Privacy > Advertising

â—Ź      Turn on Limit Ad Tracking

For Android devices:

â—Ź      Go to Settings > Google Settings > Ads

â—Ź      Depending on your Device, either turn off Ad Personalization or turn on Opt Out of Interest-Based Ads

  1. Third Party Opt-Out: You may limit the ways the authorized Third Party Data Collectors use certain information they have collected by submitting an opt-out request through their respective opt out form that is typically accessible in the third party’s privacy policy.  Please see Section 2.C for instructions on how to access such privacy policies.
  2. Our Marketing Emails: If you receive marketing or promotional emails from us, you may opt out of receiving those messages by following the “unsubscribe” instructions contained in them, or by emailing us with your request at privacy@byzantineapps.io. If you opt out of our marketing and promotional messages, you may still receive transaction- or service-related emails about your business relationship with us.

3. Security

We use commercially reasonable administrative, technical, and physical safeguards to protect our physical infrastructure as well as in our computer systems, databases, and communications networks. These measures are intended to protect our systems (and the information contained therein) from loss, misappropriation, misuse, alteration or disclosure.  No method of electronic transmission or storage is perfectly secure, however, so we cannot guarantee the security of information we collect with absolute certainty.

4. Cross-Border Data Transfers

Information we and our authorized third parties collect may be stored and processed by us in the European Union, the United Kingdom, and the United States. When you use the Site or our Apps, the information we collect may be stored in or (if applicable) transmitted to the United States. Privacy laws in the United States and laws in certain other countries regarding the processing of personal information may not be as robust as those in your country.

5. General Data Protection Regulation (GDPR)

GDPR is a data protection law that applies to individuals located within the European Economic Area and Switzerland (under the EU GDPR) and in the United Kingdom (under the UK GDPR).  Pursuant to the GDPR, we are required to provide certain information about the processing of “Personal Data” of users in European Economic Area, the United Kingdom, and Switzerland who choose to provide such information when visiting our Site.  “Personal Data” generally refers to data that identifies or is capable of identifying a particular person directly or indirectly though their Device.  Names, addresses, cookie IDs, Advertising IDs, Installation IDs, and precise location information are common examples of “Personal Data.”

If you have any questions about Byzantine’s data practices in the context of the GDPR, you may contact our Data Protection Officer by emailing your questions to privacy@byzantineapps.io.

The representations and information we provide below, which are applicable only to individuals located in the EEA, the UK and Switzerland, are provided for purposes of compliance with the GDPR. Please do not rely on the information below if you are not located in one of those regions.  All capitalized terms used in this Section but not defined elsewhere in this Privacy Notice have the means set forth in the EU GDPR or UK GDPR, as applicable.

  1. Legal grounds for processing your Personal Data: Under the GDPR, we must disclose the legal bases we rely on to process Personal Data that you choose to provide when visiting our Site. Byzantine’s legal bases for processing Personal Data for the purposes we describe in Section 2.E, above, include:

â—‹     Consent . We rely on your consent to provide our Services that use precise location information related to other Personal Data. We also rely on your consent to store and access information on your Device (e.g., Advertising IDs and Installation IDs). Our reliance on consent is in turn often in reliance on compliance steps required of and taken by our data suppliers and by Clients that use the Services. These steps are intended to confirm that your consent is collected in compliance with the GDPR and passed on to Clients and business partners such that we only facilitate the collection of data in compliance with the law. We may rely on your consent to process Personal Data in other circumstances as well. When we do so, we will follow applicable laws pertaining to providing and withdrawing consent. We also attempt to obtain consent for certain of our clients to process Personal Data. These Clients, in turn, may be independent data controllers as to data in their own possession and control.

â—‹     Legitimate interest. We may rely on legitimate interest as a legal basis for processing Personal Data in some cases. We may do so when we use Personal Data for purposes of maintaining the security of our services (including to detect and prevent fraud or to facilitate the detection and correction of bugs or other errors) or use Personal Data provided by Site Visitors to respond to their inquiries. We also rely on legitimate interest when we analyze user activity on our Site or Apps.

â—‹     Contractual Agreements. In some cases our basis for processing Personal Data is that the processing is necessary pursuant to a contractual relationship we have entered into.

â—‹     Legal Obligations. We may process Personal Data when it is necessary for us to comply with our legal or regulatory obligations.

  1. Transfers of Personal Data: When we collect Personal Data in the EEA, UK, or Switzerland, and then transfer it outside of those jurisdictions, we take measures to ensure that such Personal Data is protected by appropriate safeguards.  In general, our transfers of Personal Data rely on Standard Contractual Clauses and Data Processing Agreements to safeguard that data where the GDPR or other European data protection laws require it. You may use the contact information below to request more information regarding how we safeguard your Personal Data and respect your privacy rights.

â—‹     How We Retain Personal Data: We generally retain Personal Data we collect for as long as is necessary for compliance with our legal obligations, dispute resolution, and to enforce our contracts. We may also retain information insofar as we have a legal or operational need to do so, for example, for purposes of auditing, corporate record-keeping, legal compliance, accounting, security and bug-prevention purposes.

  1. Rights of Data Subjects: Data Subjects have certain rights in connection with the Personal Data that data controllers process about them pursuant to the GDPR. These include the right to access Personal Data, the right to request correction of inaccurate Personal Data, the right to request the restriction of processing of Personal Data, the right to request deletion of Personal Data, and the right to object to processing of Personal Data. We describe these rights more fully below.

â—‹     Right to Access: You may contact us at privacy@byzantineapps.io in order to exercise your right to access Personal Data we process as a data controller. We will respond to your request by explaining the steps you must follow to access your Personal Data after we receive your request. Because we are required to verify the identity of the individual making a request before we provide access to Personal Data, we will evaluate requests to exercise certain rights to access Personal Data on a case-by-case basis. In conducting this evaluation, we may consider both (1) the effort involved in verifying whether Personal Data that we process actually pertains to the data subject making the request – and only to that data subject; and (2) any potentially negative consequences that may result from erroneously releasing Personal Data to an individual other than the data subject. We may also limit the amount or kind of Personal Data we will release in circumstances where we believe it is likely that the improper release of Personal Data would adversely affect the privacy rights and freedoms of the data subject. We will only honor requests for access to Personal Data for which we act as a data controller, as explained more fully in sub-section (d) below. Where we act as a processor for Personal Data on behalf of another entity (for example, our customers), you may contact that company instead of Byzantine to make a data access request.

â—‹     Right to Correct: You may exercise your right to correct Personal Data by contacting us using the contact information provided below.

â—‹     Right to Withdraw your Consent or Object to our Personal Data Processing:  You may use the opt-out methods described in Section 6 of this Privacy Notice to withdraw your consent for our processing of your Personal Data (when we are relying on your consent). If you withdraw your consent, we will stop processing your Personal Data within 30 days or fewer.

â—‹     Right to Request Deletion: You have the right to request that we delete Personal Data concerning you that we process as a controller. If you use the opt-out process described above, we will also delete your Personal Data. You may also contact us at privacy@byzantineapps.io to request that we delete your Personal Data.  We will provide further instructions on how you can exercise your right to deletion after we receive your email request. In certain circumstances we may keep copies of Personal Data in back-up files (or otherwise in inactive form), for certain of our internal purposes that are important to our business, including legal, auditing, accounting and billing, bug-detection and correction. We may keep such backups for as long as is necessary to fulfill those purposes.

â—‹     Right to Make Complaints: You have the right to lodge a complaint regarding our processing of Personal Data with a relevant data protection authority. If you have a complaint, please contact us first to allow us to assist you in resolving it.

  1. Byzantine may act as a data “controller” as defined in the GDPR in connection with the Personal Data we process when you provide it on this Site. We may also be deemed to act as an independent controller that enables certain Third Party Data Collectors who are controllers to directly collect Personal Data through their SDKs integrated with our Apps.  While we may be deemed to act as an independent controller, only such Third Party Data Collectors directly collect, have access to, and process your information.  Therefore, if you submit any requests or inquiries to us regarding information collected by one of these authorized third parties, we will forward such submittal to the appropriate Third Party Data Collector for fulfillment.

6. Children’s Data

We do not intend for our Site or Apps to be used in connection with minors under the age of 16, and we do not intentionally collect data from them. If you believe that we may have inadvertently collected of any such data, please use the contact information provided in Section 9 below to let us know.

7. Additional Information for Residents of California, Colorado, Connecticut, Utah or Virginia

California residents have certain privacy rights pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”), and Virginia residents have similar privacy rights under the Virginia Consumer Data Protection Act of 2019 (“VCDPA”), with respect to their personal information or personal data about them, Residents of Colorado, Connecticut or Utah will have similar rights on various effective dates during 2023 under either the Colorado Privacy Act (“CPA” effective July 1, 2023), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA” effective July 1, 2023), or the Utah Consumer Privacy Act (“UCPA” effective December 31, 2023)

Under the CCPA “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Similarly, under the VCDPA, “Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. When we use the term “personal information” in the following sections, we mean either your Personal Information under the CCPA if you are a California resident or your Personal Data under the VCDPA if you are a Virginia resident, or the similar definitions of Personal Data or Personal Information that apply if you are a resident of Colorado, Connecticut, or Virginia.

If you are a resident of any of these states, this section of the Privacy Notice applies to you insofar as we have collected personal information about you , or have sold such information. However, if you are not a resident of such a state, you should not rely on the information we provide in this section as it does not apply to you. The information we provide here supplements the information we provide in the other sections of this Privacy Notice.

As required by the CCPA and VCDPA, and other applicable state laws when they become effective, we describe the personal information we collect about residents of those states, and the purposes for which we may use it, in the following sections:

A. Categories of Personal Information We Collect; How We Use It; and How We Share with Third Parties

We may collect the categories of personal information about you described below. The table also describes the categories of third parties with whom we may share the categories of Personal Information specified. You may exercise your Right to Access in connection with any of the Personal Information Categories in the table below.

Personal Information Category

Information Sources

Categories of Third Parties with whom this Personal Information is Shared

Identifiers (including name, email address, Advertising ID, and other information you choose to submit, whether in connection with visiting our Site or submitting a request to exercise your rights under the CCPA) 

Visitors to our Site; individuals that submit a request to exercise rights under the CCPA

Our affiliates

Internet or Other Electronic Network Activity Information (e.g., information regarding a consumer or device’s interaction with a website or application)

Visitors to our Site

Our affiliates

 

B. Business Purposes for Collecting and Sharing Personal Information

Our purposes for collecting and sharing Personal Information are described below (with examples).  These details are also described in our Privacy Notice:

â—Ź     To Operate Our Site and Apps. We use personal information to:

a.    Enhance, test, update, and verify our own data and data-related services;

b.    Develop new products or services; or

c.    Operate, analyze, enhance, and secure our services.

â—Ź     Other Internal Business Purposes.

a.    Internal Research/Compliance:  We use personal information for internal research or operations, auditing, detecting and responding to security incidents, debugging, short-term and transient use, quality control, and legal compliance. Information we collect from our Site and Apps may be used for this purpose, among others.

b.    Sharing for Purposes of Legal Compliance:  We may share personal information with third parties for purposes of: (1) compliance with official legal process or a regulatory investigation (for example, a valid subpoena or court order); (2) enforcing our Terms of Service, this Privacy Notice, or other agreements, including investigation of suspected violations of the same; (3) responding to claims that certain content violates the rights of third parties; or (4) protecting the rights, property or personal safety of us (or our platform), our Clients, our affiliates, our agents, our platform users, or the general public. Similarly, we may share personal information with other entities to detect or prevent fraud, to prevent spam or malware, or other similar purposes.

c.    Sharing In Connection With a Corporate Transaction: In the event of a major corporate transaction (such as a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets), we may share personal information in connection with that transaction, including for purposes of associated due diligence.

d.    Sharing With Our Service Providers:  We may share any personal information we collect with our service providers.  Our service providers may include, for example, providers of: technology; support for our Clients; business operations; web or database hosting; billing; accounting; physical or information security; marketing and advertising; data management, validation, enhancement or hygiene; or providers that otherwise assist us with providing, developing, maintaining, or improving our Services.

e.    Aggregate Information: We may use personal information to create aggregate information, or may de-identify any personal information we collect to make it such that it cannot be linked to you or your device (“Aggregate or De-Identified Information”). We may use Aggregate or De-Identified Information for any purpose, including, but not limited to, for research and marketing purposes. We may also share Aggregate or De-Identified Information with third parties, who may include advertisers or marketers, promotional partners, our sponsors, or otherwise at our discretion.

C. Rights and Choices of Certain US States Residents

If you are a resident of certain states you have the right under applicable data privacy laws to request (1) that we disclose what personal information we collect from you; (2) to delete such information; and (3) to opt out of our sale of their personal information. The states that provide these rights to their residents are California (under the CCPA), Colorado (under the CPA effective 7/1/2023), Connecticut (under the CTDPA effective 7/1/2023), Utah (under the UCPA effective 12/31/2023), and Virginia (under the VCDPA). These rights are subject to certain limitations, although you will not be discriminated against for exercising any of these rights. In certain circumstances, we may charge a reasonable fee to process your request to the extent permitted by law.

  1. Right to Opt-out of the Sale of Your Personal Information:

    2. â—‹     California or Virginia residents may opt out of the “sale” of their personal information. Colorado, Connecticut or Utah residents may opt out as well when their laws become effective. “Sale” is defined broadly by the CCPA, the CPA, and the CTDPA to include making personal information available in exchange for any “monetary or other valuable consideration.” “Sale” is defined under the UCPA and the VCDPA to mean the disclosure of personal data for “monetary consideration”. We do not “sell” personal information.  However, certain of our authorized third parties that directly collect End User information may sell information.  You can exercise your right to opt out of such sale by visiting the applicable third party’s privacy policy.  Please see Section 2.C above for information on how to access each third party’s privacy policy.

  1. Right to Request Deletion of Your Personal Information:

    2. â—‹     If we have collected personal information from you, you may request that we delete such personal information.  A request to delete is distinct from a request to “opt out” of our sale of your personal information.  You may contact us via email at privacy@byzantineapps.io or call us toll-free at +1-855-721-3550 to exercise this right.

    â—‹     If you choose to exercise your right to deletion, there are certain circumstances under which we many nevertheless retain personal information as permitted by law, such as:

    a.    To defend against fraudulent activity directed towards our business, systems, or users.

    b.    To detect and fix technical issues that affect existing system functions (e.g., for de-bugging).

    c.    As necessary for the protection of the free speech or other rights of us (or others).

    d.    To assist with law enforcement requests made pursuant to lawful process.

    e.    For certain scientific or historical research purposes.

    f.      For our own internal purposes, provided they are reasonably related to your relationship with us.

    g.    To comply with our legal obligations.

    â—‹     Please note that we require certain information in order to provide our Site and Apps to you. If you ask us to delete that information, it may prevent you from being able to access or use our Site or Apps.

  1. Right to Request Access to Your Personal Information:

    â—‹     California (under the CCPA) and Virginia (under the VCDPA) give their residents the right to request that we disclose both the categories and specific pieces of personal information that we collect, use, or sell. Colorado, Connecticut, and Utah will give their residents these rights also as those states’ data privacy laws become effective (the CPA and CTDPA on 7/1/2023 and the UCPA on 12/31/2023). We will comply with such requests if we can verify them to a legally sufficient degree. You may make such an access request by emailing us at privacy@byzantineapps.io with the subject line “CCPA Access Request” or by calling us toll-free at +1-855-721-3550.

    â—‹     We may be able to adequately verify access requests for certain information we have collected. However, and in line with certain guidance provided by the California Attorney General, we do not provide location data in response to access requests due to the fact that we are not able to verify to a reasonably high degree of certainty that the location data we have collected pertains to the individual making such a request, or whether either an individual with custody of a device — or the person making the request — is the rightful owner of the device to which the information we hold pertains. For example, it is not uncommon for a person to be in possession of another person’s phone temporarily (for example, a partner, friend or work colleague’s mobile phone or tablet), whether or not such temporary possession is authorized. We take this approach in order to avoid a scenario where such a person in temporary possession of a phone might obtain potentially detailed and sensitive information pertaining to the phone’s owner through a request for access. We also believe California law compels us to avoid a scenario like this. In addition, a recent study found that roughly 50% of mobile phones were not password protected at all, making the possibility of such “spoofing” a tangible risk. Further, we do not have other, more conventional means to confirm the identity of a device’s true owner because for consumer privacy reasons we do not collect information such as name, address or email address that could be used to do so.

    â—‹     If you do not wish location data associated with your device to be used in the ways we describe above, we suggest that you make a request to opt out of sales of your information as detailed above. You can find complete information about how to exercise your right to opt out by visiting this link: Your Privacy Choices and Opt-Out Rights.

  1. Our Collection of Sensitive Personal Information, and Your Rights to Limit Its Use:

    â—‹     Certain Personal Information that we collect and sell, such as precise geolocation of a person, household, or device, is considered “Sensitive Personal Information” under the data privacy laws of California (CCPA), Connecticut (CTDPA), and Virginia (VCDPA). We obtain the right to use and share this information, through the consent methods described in our Privacy Policy. California residents have the right to require a business to limit the use of their Sensitive Personal Information to only certain internal business purposes specified in the CCPA.

    â—‹     To limit the use of your Sensitive Personal Information, you may use either of the methods below:

    â—Ź      By visiting this link: Your Privacy Choices and Opt-Out Rights.

    â—Ź      By emailing your request to privacy@byzantineapps.io using a subject line that reads “California Limit SPI Use.”

  1. How to Exercise Your Rights and Submit a Verifiable Consumer Request:

    2. â—‹     To exercise your CCPA, CPA, CTDPA, UCPA, or VCDPA rights or learn more about how to do so, those residents may contact us using any of the following means:

    a.    Sending an email to privacy@byzantineapps.io.

    b.    With respect to access or deletion requests, by calling us toll-free at: +1-855-721-3550.

    â—‹     In certain circumstances, we may not disclose some personal information to you in response to an access request where doing so presents too great a risk to you or our business.  We may also withhold such information where we cannot verify your identity in connection to such personal information.

    â—‹     In the event we are not able to comply with your requests fully for any of the reasons described above, we will still explain the reasons why we could not fulfill your request. Certain consumers have the right to appeal our decision not to fulfill a request, and may do so by emailing our Chief Privacy Officer at appeals@byzantineapps.io with the subject line “Privacy Choices Appeal.”

  1. Right to Non-Discrimination:

    2. â—‹     If you elect to exercise your CCPA, CPA, CTDPA, UCPA, or VCDPA rights, we will not deny, charge different prices for, or provide a different level of quality of goods or services for that reason.

  1. Information Regarding Individuals Younger than 16 Years Old:

    2. â—‹     We do not knowingly collect personal information pertaining to minors younger than 16 years old who reside in California, Colorado, Connecticut, Utah, or Virginia. In the event we learn that we have collected personal information regarding such California residents, we will take reasonable steps to remove such information from our database (or we will obtain any legally required consents).

  1. Authorized Agents:

    2. â—‹     You may exercise your rights under CCPA, CPA, CTDPA, UCPA, or VCDPA, as described above by designating an agent to make requests on your behalf. If you choose to designate an agent, we will take steps to verify both (1) your identity; and (2) that your designated agent has been authorized to make a request on your behalf by providing us with a written authorization signed by you or a copy of a valid power of attorney.

8. In-App Purchases and Subscriptions

Back Seat Navigator and What The Forecast?!! include In-App Purchases and auto-renewable Subscriptions. Payment will be charged to your iTunes account once you confirm the purchase or subscription. The Purchase option allows you to own the app outright. Once purchased, no other purchase or subscription is necessary and the purchase never expires. The Subscription options automatically renew unless auto-renew is turned off at least 24-hours before the end of the current subscription period. Your account will be charged for renewal within 24-hours prior to the end of the current subscription period. You can manage your subscriptions and turn off auto-renewal by going to your Account Settings on the App Store after subscription.

9. Changes to This Privacy Notice

In the event we make material changes to this Privacy Notice that may affect you, we will post prominent notice of any such changes on our Site and/or Apps for not less than 30 days prior to the effective date of the changes. We suggest that you check this Privacy Notice frequently in order to stay informed of any such changes.

10. Contact Information

To ask questions about the information in this Privacy Notice or for more information about how we use information we collect, or to exercise any of the rights outlined in Section 5, you may contact us at:

privacy@byzantineapps.io

OR

Byzantine Apps, LLC
6050 Peachtree Pkwy
Ste 240-379
Norcross, GA 30092

OR

For EEA Residents: Please contact our EU Representative at eurep@byzantineapps.io. Alternatively, they can be reached by post (The DPO Centre, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2) or +353 1 631 9460. https://www.dpocentre.com/contact-us/

For UK Residents: Please contact our UK Representative at ukrep@byzantineapps.io.  Alternatively, they can be reached by post (The DPO Centre Ltd, 50 Liverpool street, London, EC2M 7PY) or +44 (0) 203 797 6340. https://www.dpocentre.com/contact-us/