MOMZIE PRIVACY POLICY

This privacy policy has been drafted on: 2nd May 2016
This privacy policy has been modified latest on: 24th May 2018

1. Purpose of Privacy Policy

Protecting your privacy according to applicable law is important to Momzie. Accordingly, Momzie is providing this Privacy Policy to explain Momzie’s practices regarding the collection, use and disclosure of personal data that you share with Momzie. Any personal data that you share with Momzie is subject to this privacy policy in effect at the time of collection of that data.

Momzie may, however, modify this privacy policy from time to time as explained in Section 21.

If you have any questions about this privacy policy, please email Momzie at: info@momzieapp.net.

The provision of personal data is voluntary. If you do not provide the data that is marked as obligatory, Momzie might not be able to provide you with the Momzie service or that may result in a declined level of the Momzie service. For example, your profile might not be shown to as many users nearby as it would be otherwise shown, because users can use different filtering options.

2. Registrar

Momzie Oy, Business ID 2720441-7 (”Momzie”)
Address: Liljantie 50, 62165 TIISTENJOKI, Finland
email: info@momzieapp.net
The contact details may be amended from time to time without your consent.

3. Name of Register

Name of the register is Momzie service’s user register.

Some Momzie service’s services might require specific terms for processing of personal data. You are informed of those terms and your consent is asked in connection with your usage of the services.

4. Age limit

You have to be at least 16 old to be eligible to register an account to the Momzie service.

It is allowed but not required to upload pictures of your children. Restrictions apply, see more from Momzie’s Terms of Use.

Please note that the Momzie service is, for coyness reasons, meant for moms or moms-to-be only. The use of the Momzie service is thus restricted to women only, and women only are eligible to register a user account

5. Person in charge of register matters

Name: Hanna Lilja
Address: Liljantie 50, 62165 TIISTENJOKI
Email: hanna.lilja@momzieapp.net

The name and contact details may be amended from time to time without your consent.

6. Content of register

(a) When you sign up to the Momzie service or create your account through Facebook, your give Momzie the permission to receive and store the following data from your Facebook account: first name and last name, data in open profile public fields filled in by you (mandatory), gender (mandatory), over 16 years old (mandatory), pictures (optional), date of birth (mandatory), email address (optional).

(b) When you create your user profile, Momzie will ask you to provide your hometown and nationality (optional), data in open fields filled in by you (optional), and the gender and birthday/due date of all your children (mandatory for minimum one child / pregnancy). The Momzie service requires one identifiable profile picture in your user profile (mandatory, next five pictures optional).

(c) your first name(s) and last name;

(d) your email address;

(e) other contact information given by you;

(f) other personal data given by you;

(g) your gender;

(h) your date of birth;

(i) you acknowledge and agree that if you provide personal data belonging to so called “special categories of personal data” (such as revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation), you agree that Momzie and its subcontractors are allowed to process such personal data as described in this privacy policy;

(j) the content (for example texts, conversations, messages, comments and photographs) or other information which you submit to the Momzie service, link to the Momzie service or otherwise make available via the Momzie service;

(k) Momzie will also ask your permission to collect your location information from your device before you can start using the Momzie service. Momzie will collect your location information only when you’re using the Momzie service. If you choose not to give your location information, you might not be able to benefit from all functionalities of the Momzie service and/or the location-based merchant deals advertised in the Momzie service;

(l) your browsing in the Momzie service and your clicks on the advertisements in the Momzie service and otherwise in the Momzie service;

(m) the following types of data received from Momzie’s advertiser network: Uniform Resource Locator ("URL") of the page from which you land on the Momzie service and URL of the page which you visit after leaving the Momzie service;

(n) information from Momzie’s cooperation partners whether you have purchased their products or services that have been advertised in the Momzie service or otherwise by Momzie. The information can include the price and time of your purchase and the products and/or services in question; and

(o) your feedback or your participations in opinion polls or competitions managed in the Momzie service.

7. Purpose of use of register

Purpose of Use

The personal data is used for the following purposes which, unless otherwise set out below, are necessary for the performance your contract with Momzie or in order to take steps prior to entering into the contract:

(a) to verify your eligibility to use the Momzie service;

(b) Momzie will use your children’s birthday to show your children’s age(s) up-to-date in your public profile. Your children’s age will be shown in months (under 1 year-old) or in years (over 1 year-old) in your public profile.

(c) provide the Momzie service;

(d) taking care of user service and user relationship management;

(e) troubleshoot and provide user support;

(f) accomplish administrative tasks and manage your account;

(g) contact you in relation to the Momzie service;

(h) the data can be compared, segmented and analyzed in order to give you information, offers or recommendations regarding Momzie’s own or its cooperation partners’ products and services, based on your consent and in other situations allowed by law. Analysis can be made from your browsing and clicking history and devices used by you. Momzie can compare and analyze for these purposes also data collected by using cookies (according to Momzie’s cookies policy accepted by you) and the Traffic Data as described in Section 12) together with the personal data;

(i) marketing by Momzie of products and services of Momzie or its cooperation partners, based on your consent and in other situations allowed by law;

(j) the information received by Momzie from Momzie’s cooperation partners on whether you have purchased their products or services advertised in the Momzie service or otherwise by Momzie, is used by Momzie to analyze the payments or other financial arrangements between Momzie and Momzie’s cooperation partners. The legitimate interests pursued by Momzie is the legal basis for processing of the personal data for this purpose;

(k) direct marketing and newsletters, based on your consent and in other situations allowed by law;

(l) to develop products and services and Momzie’s operations. The legitimate interests pursued by Momzie is the legal basis for processing of the personal data for this purpose;

(m) if processing is necessary for compliance with legal obligations to which Momzie is subject;

(n) to enforce Momzie’s agreements with you, including our Terms of Use and this privacy policy;

(o) if processing is necessary in order to protect your vital interests; or

(p) taking care of regulated personal data obligations of Momzie.

a) “Consent”. Consent to the processing is the legal basis for processing of personal data to the extent mentioned above in subsection “Purpose of Use”. If you withdraw a consent given to the processing of personal data when the legal basis of processing is “consent”, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

b) “Compliance with legal obligations” is the basis for processing of the personal data to the extent mentioned above in subsection “Purpose of Use”.

c) “The legitimate interests pursued by Momzie” is the basis for processing of the personal data to the extent mentioned above in subsection “Purpose of Use”. Momzie has considered that Momzie’s legitimate interests are not overridden by your interests or fundamental rights. Such legitimate interests exist for example as otherwise Momzie cannot provide the basic Momzie Service free of charge to you.

8. Regular sources of personal data

(a) enquiry from you when creating the user account;

(b) When you sign up to the Momzie service or create your account through Facebook, from Facebook;

(c) when you use the Momzie service;

(d) When you make changes to your profile in Momzie;

(e) when you contact Momzie;

(f) URL data from Momzie’s advertiser network (please see Section 6);

(g) data from third parties who perform comparison, segmenting and analysis services on Momzie’s behalf;

(h) information from Momzie’s cooperation partners whether you have purchased their products or services that have been advertised in the Momzie service or otherwise by Momzie; and

(i) data through contact and other forms and when you give answers to polls and competitions.

9. Disclosure through Momzie Service

(a) User Profile and Location Information

The public user profile, including your location information if you have allowed Momzie to track your location, can be viewed by other users of the Momzie service.

The public user profile includes the information you have provided to the Momzie service directly or through Facebook (such as your Facebook photos and/or any additional photos you upload), first name, age, approximate number of miles away from the other user’s location, data in open fields filled in by you, age and gender about your children and your hometown.

Before publishing your public user profile and any time later, you may preview your public user profile as it is shown to other users. You may edit your public user profile in the Momzie service at any time.

If you hide your public user profile, the user profile is not shown to other users of the Momzie service in the friend search. If you thereafter participate in conversations in public groups or private channels, the group participants (in case of public groups) and the other participants of the conversations (in case of private channels) can however see your hidden public user profile. Also, your friends can always see your hidden public user profile.

If you hide your public user profile, you are not able to search for other users in the Momzie service either.

Even if you delete your user profile, your conversations in public groups and in private channels are not removed. Your first name (as the author of the message) will be still visible along with the earlier conversations.

(b) Public Groups

In public groups, the basic information of the groups is visible to all users of the Momzie service: title (mandatory), unique reference (i.e. #name of group) (mandatory), text description of the group (voluntary) and photo (voluntary).

Each user of the Momzie service can share a link to a public group also outside of the Momzie service. Then the recipient of the link i.e. a person who is not a user of the Momzie service, can see the said basic information of the group. Only members of the public group can see the conversations and other content in the public group.

Public Groups cannot be changed to private channels later.

(c) Private Channels (private groups)

In private channels, the basic information of the groups is visible to all users of the channel: title (mandatory), unique reference (i.e. #name of group) (mandatory), text description of the group (voluntary) and photo (voluntary).

Only members of the private channel can see the conversations and other content in the private channel. Please however see subsections (e) and (f) below.

(d) Private Conversations

If you exchange private conversations with your friend in the Momzie service, only you and your friend can see the conversations and other content in the private conversations. Please however see subsections (e) and (f) below.

(e) Content of Conversations

Please note that for the purpose of the provision of the Momzie service (such as to technically manage the Momzie service, develop the Momzie service or correct errors), Momzie or its subcontractors might be able to see the content of private conversations within the Momzie service. Momzie and its subcontractors are committed to secrecy with respect to such conversations and may not disclose them except if necessary to satisfy a requirement in any law or regulation.

(f) Actions of Others

Momzie cannot control the way others use or disclose your personal data or content. Even if your personal data or content, according to this privacy policy, would not become directly public, others might e.g. take screenshots of or store or print personal data or content and share it with third parties. Momzie is not liable for use or violations by third parties.

10. Regular transferees of data

Personal data is transferred to following third parties for the following purposes:

(a) to third parties, who process personal data on behalf of Momzie, such as IT-service providers and hosting service and data center providers.

(b) Personal data can be transferred if it is necessary to comply with legislation or requirements of authorities, to supervise and enforce Momzie’s legitimate interests or to detect, defend against or repair fraud or security or technical problems.

(c) The types of personal data to be transferred are at most those as defined in Section 6.

11. Transfer to countries outside EEA

Momzie does not transfer your personal data to countries outside the European Economic Area (EEA) and European Union (EU).

12. Processing of Traffic Data

“Traffic Data” means information associated with a legal or natural person used to transmit a message. The Traffic data is processed by Momzie in circumstances explicitly allowed by law and in the following circumstances:

(a) to the extent required for transmitting communications, the provision and usage of the Momzie service and taking care of information security. For this purpose, the following types of Traffic Data is processed: IP address, device identifier, the type of browser you are using, user ID, and information on browsing and using the Momzie service, as long as it is necessary to use the said Traffic Data for the said purposes;

(b) for technical development of the Momzie service and the Momzie products and services. For this purpose, the following types of Traffic Data is processed: IP address, device identifier, the type of browser you are using, user ID, and information on browsing and using the Momzie service, as long as it is necessary to use the said Traffic Data for the said purposes;

(c) automatically for statistical analysis, as the analysis cannot be made by any other means without undue difficulty. No individual natural person can be identified in the analysis;

(d) for the purpose of marketing Momzie’s and its cooperation partners’ products and services, to such an extent and for such a period of time as the marketing requires. You may cancel this consent at any time by notifying Momzie in writing or by email;

(e) for detecting, preventing or investigating any non-paying use of fee-based services or similar cases of misuse; and

(f) if necessary for the purpose of detecting, preventing or investigating a technical fault or error in the transmission of communications.

The Momzie service can include links to third party websites. Momzie is not liable for processing of personal data on those websites or by third parties.

14. Methods how register is secured

The personal data is secured by using the following methods and principles:

(a) locks at Momzie’s and its subcontractors’ premises;

(b) electrical surveillance systems of premises;

(c) firewall and anti-malware systems;

(d) professional knowledge of Momzie’s personnel;

(e) training of Momzie’s personnel;

(f) the content of the register is in electronic form except for temporary special occasions; and

(g) Momzie’s policies and guidelines relating to personal data matters.

15. Right of access

After having supplied sufficient search criteria, you have the right to get information on which data on you is being processed or information that no such data is being processed.

Where such personal data is being processed, Momzie will provide to you the legally required information. Momzie is not obligated to provide the information if Momzie demonstrates that it is not in a position to identify you.

Information provided is free of charge. Momzie may however charge a reasonable fee taking into account the administrative costs of providing the information or refuse to act on the request, if the request is manifestly unfounded or excessive, in particular because of their repetitive character.

You can exercise this right in the chat of the Momzie Service, while you are logged in to the Momzie Service. In case you cannot log in to the Momzie Service, please contact Momzie by email: info@momzieapp.net.

16. Right to data portability

At your request, if Momzie processes the personal data based on your consent or based on a contract with you and if the processing is carried out by automated means:

(a) Momzie shall provide you with the personal data which you have provided to Momzie, in a structured, commonly used and machine-readable format;

(b) at your request and if technically feasible, Momzie must transmit the personal data in the same format directly to another controller.

You can exercise this right in the chat of the Momzie Service, while you are logged in to the Momzie Service. In case you cannot log in to the Momzie Service, please contact Momzie by email: info@momzieapp.net.

17. Right to be forgotten

You have the right to have your personal data erased at your request if one of the following grounds applies:

(a) the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

(b) you withdraw consent on which the processing is based and where there is no other legal basis for the processing;

(c) you object to the processing in accordance with Section 20;

(d) the personal data has been processed unlawfully; or

(e) the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which Momzie is subject. However, Momzie does not have to erase the data based on above grounds to the extent Momzie still needs to process the data:

(f) for exercising the right of freedom of expression and information;

(g) for compliance with a legal obligation which requires processing by law to which Momzie is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(h) for reasons of public interest in the area of public health in accordance with legal requirements;

(i) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with legal requirements; or

(j) for the establishment, exercise or defence of legal claims.

You can exercise this right in the chat of the Momzie Service, while you are logged in to the Momzie Service. In case you cannot log in to the Momzie Service, please contact Momzie by email: info@momzieapp.net.

18. Right to restriction of processing

‘Restriction of processing’ means the marking of stored personal data with the aim of limiting its use in the future. If you request, Momzie must restrict processing in the following situations:

(a) the accuracy of the personal data is contested by you, for a period enabling Momzie to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;

(c) Momzie no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims; or

(d) you have objected to processing, but verification whether the legitimate grounds of Momzie override those of yours is still ongoing.

In the situations listed above, Momzie can only process the personal data:

(e) with your consent or for the establishment, exercise or defence of legal claims;

(f) for the protection of the rights of another natural or legal person;

(g) for reasons of important public interest of the Union or of a Member State; and

(h) to store the data.

You can exercise this right in the chat of the Momzie Service, while you are logged in to the Momzie Service. In case you cannot log in to the Momzie Service, please contact Momzie by email: info@momzieapp.net.

19. Rectification, period for which personal data is stored AND right to lodge complaint to supervisory authority

Momzie shall, at your request, without undue delay correct, erase or supplement personal data contained in its personal data register if the data is erroneous, unnecessary, incomplete or obsolete as regards the purpose of the processing, including by way of supplementing a corrective statement. You can exercise this right in the chat of the Momzie Service, while you are logged in to the Momzie Service. In case you cannot log in to the Momzie Service, please contact Momzie by email: info@momzieapp.net.

The personal data will be stored during the time period for which is necessary in relation to the purposes for which they are processed. Information regarding the contractual relationship is processed for the time until claims related to the contractual relationship expire. Main rule according to Finnish law for claims related to the contractual relationship to expire is three (3) years. Information regarding the contractual relationship can be processed for longer than the above-mentioned time period, if the personal data in question is necessary for the establishment, exercise or defence of legal claims.

You have the right to lodge a complaint to the supervisory authority. The contact details of the supervisory authority:

http://www.tietosuoja.fi/en/index/yhteystiedot.html
Office of the Data Protection Ombudsman
P.O. Box 800
FIN-00521 HELSINKI
FINLAND

Address:
Ratapihantie 9, 6rd floor
00520 HELSINKI
Tel: +358 29 56 66700 (exchange)
Fax: +358 29 56 66735
Email: tietosuoja@om.fi

20. Right to prohibit processing

You have the right to prohibit Momzie from processing your personal data for purposes of direct marketing.

You have the right not to be subject to a measure which produces legal effects concerning you or significantly affects you, and which is based solely on automated processing intended to evaluate certain personal aspects relating to you or to analyse or predict in particular your performance at work, economic situation, location, health, personal preferences, reliability or behaviour. At the moment Momzie Service does not use such measures.

You have the right to object, on grounds relating to your particular situation, to the processing of your personal data which is based on either of the following grounds for processing: (i) when the processing has been found necessary for the purposes of the legitimate interests of Momzie or (ii) when the processing has been found necessary in order to protect your vital interests. You, however, don’t have the right to object, if Momzie demonstrates compelling legitimate grounds for the processing which override your interests or fundamental rights and freedoms.

You can exercise these rights in the chat of the Momzie Service, while you are logged in to the Momzie Service. In case you cannot log in to the Momzie Service, please contact Momzie by email: info@momzieapp.net.

21. Amendment of privacy policy

Momzie may amend this privacy policy at any time by notifying you at least fourteen (14) days before the amendment. You accept the amended privacy policy if you continue to use the Momzie service after the amendment became in force or if you otherwise accept the amendments. If you do not accept the amended privacy policy, you might not be allowed to use the Momzie service or a part thereof.