Privacy Policy
This Privacy Policy aims to inform you about the processing of your personal data when downloading and using the FishGround mobile application. Your privacy and the protection of your personal data are important to us, and we are committed to safeguarding them in accordance with this Privacy Policy (the "Policy"). The data controller adheres to the rights regarding the lawful processing of personal data in accordance with applicable European Union (EU) and local laws concerning privacy and data processing.
1. Data Controller
The data controller responsible for the collection, use, and disclosure of your personal data in accordance with this Policy is SIA “FishGround”, registration number 40203563081. If you have any questions regarding the Policy or the processing of your personal data, please contact us at the email address beta@fishground.com.
The data controller may update this Policy. We will notify you of any changes by posting the updated Policy in the application, where you can always find the most recent version.
2. Purpose and legal basis for processing personal data
Your personal data will be used solely for previously defined legitimate purposes, including providing services within the FishGround app, creating your User profile, communication, facilitating payments, and training algorithms and artificial intelligence (AI) to improve the accuracy of fish-catching predictions. Certain types of personal data, necessary for creating a user profile and using the services of the FishGround app, will be processed.
Your personal data is processed for the purposes of creating a user profile, providing the service and communication:
- Name
- Surname
- Contact details (phone number, e-mail)
- User authorisation (password)
- Pictures of the fish caught
In addition, we will process the following data to improve our AI and forecasts:
- Time and place where the fish was caught
- Weather observation
- Fish characteristics (type, size, weight, number)
Main applicable legal bases for processing personal data:
1. Consent (Article 6(1)(a) of the General Data Protection Regulation) - This applies to specific services that we provide based on your request. For instance, we may process your location data when you use the map feature in our mobile application.
2. Performance of a Contract (Article 6(1)(b) of the General Data Protection Regulation) - This applies to the sale of goods or provision of services when we enter into a contract with you, including distance contracts..
3. Our Legitimate Interests (Article 6(1)(f) of the General Data Protection Regulation) - This includes identifying specific users who purchase services offered by our application; ensuring communication with users; providing quality services and necessary support; retaining information about transactions conducted; and providing evidence for potential claims and legal proceedings.
To enhance the accuracy and efficiency of our services, we may use your personal data for profiling. Profiling involves the automated processing of your data to analyze, predict, and assess certain personal aspects, such as your location, fishing records, and other service-related features.
The purpose of profiling is to enhance the ability of our algorithms and artificial intelligence (AI) to predict fish-catching opportunities in specific locations and times, based on the data provided by you and other users.
Personal data used for profiling: We collect and analyze only data related to your fishing activities, such as the time and location of catches, weather conditions at the time of the catch, and specific details about the fish (type, size, weight).
Legal Basis for Profiling: We conduct profiling based on our legitimate interests in providing and enhancing the services we offer to users, as well as on your consent when you have agreed to our privacy policy.
3. Access to information
We implement appropriate measures to process your personal data in accordance with applicable laws and ensure that your personal data is not accessed by third parties without a legal basis for processing your data.
Access to your personal data may be granted only to the following individuals and organizations:
1. Our Employees and Authorised Personnel – Only those who need access to fulfill their job duties or tasks..
2. Data Processors – Only those who provide specific services, such as information system developers and maintainers, and only to the extent necessary for delivering these services.
3. Regulatory and Law Enforcement Authorities – Based on written requests or in accordance with legal requirements, such as police or municipal police officers, and authorized municipal representatives.
4. Third Parties – Only after a careful assessment to determine whether there is a legal basis for data transfer, such as auditors, project partners, courts, alternative dispute resolution bodies, and bankruptcy administrators.
4. Transfer of Personal Data to Countries Outside the European Union (EU) or the European Economic Area (EEA)
In providing our services, we do not transfer data to countries outside the EU or EEA.
5. Your Rights as a Data Subject
5.1. Right to Access Your Personal Data
You have the right to access your personal data that we process and to obtain information about how we handle your personal data. If the information provided in this Policy is not sufficiently detailed, you may contact us using the data controller’s contact information to request additional information about the processing of your personal data.
5.2. Right to Request Correction of Personal Data
If your personal data provided during registration has changed, or if you notice that the data we hold about you is inaccurate or incorrect, you have the right to request that this information be updated, corrected, or amended. To exercise this right, you can either update your personal data directly within the application or contact us using the communication methods outlined in this Policy to submit the current information so that we can make the necessary corrections or updates.
5.3. Right to Request Erasure of Data (Right to be Forgotten)
You may request the deletion of your personal data at any time. To do so, please contact us via the methods provided in this Policy or through the application. Upon request, we will delete all your personal data, but we will retain anonymized records of fishing data (such as time, location, fish type, etc.) that will no longer be linked to you personally.
Please note that the right to erasure does not apply in cases where we are legally obligated to process personal data under applicable laws or when data processing is necessary for archiving purposes, protecting our legitimate interests, or for the establishment, exercise, or defense of legal claims.
5.4. Right to Restrict Processing
You have the right to request the restriction of processing your personal data under certain circumstances.
5.5. Right to Data Portability
You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. Additionally, you may request that we transfer this data to another data controller, where technically feasible.
5.6. Right to Object
You have the right to object to the processing of your personal data if the processing is based on our legitimate interests. If you have any questions or concerns about our data processing practices, we encourage you to contact us first.
If you believe that we have not addressed your concerns adequately or if you believe we have violated your data protection rights, you have the right to lodge a complaint with the Data State Inspectorate.
6. Data Security
We implement the necessary technical and organizational measures to protect your personal data against unauthorized access, accidental or unlawful deletion, alteration, or disclosure. Our security measures include data encryption, access control systems, and regular security audits.
7. Retention of Personal Data
We retain your personal data only as long as necessary to achieve the purposes outlined in this Privacy Policy and in accordance with applicable laws.
The factors considered in determining the retention period for personal data include:
1. Fulfillment of Contractual Obligations: We retain personal data necessary for fulfilling contractual obligations until the contract is fully executed and any additional retention periods required, such as those related to limitation periods for claims, have expired.
2. Legal Requirements: We retain personal data for the duration required by relevant regulations in the Republic of Latvia.
3. Legitimate Interests: To demonstrate compliance and protect our legitimate interests, we retain personal data in accordance with the limitation periods established by the Civil Law and the Commercial Law of Latvia.
4. Consent: If processing is based on your consent, we retain your personal data until you withdraw your consent, unless there are other legally mandated retention periods.
When your personal data is no longer needed for the specified purposes, we will delete or anonymize it in accordance with applicable regulations.
8. Changes to the Privacy Policy
The data controller may make changes to this Policy. We will inform you of any changes by posting the relevant information in the application, where you can always find the latest version of the Policy.
