Privacy Policy for Somano App

Effective Date: 10th November 2021

1. What this Privacy Policy covers

This Privacy Policy (hereinafter, the Policy) covers any information about users of our products and services (hereinafter, "You") that may include personal data as defined by applicable laws and regulations (hereinafter, “Personal information”), which SOMANO ONLINE, may obtain when you use any of the Somano Online websites or mobile apps (jointly referred to as, the “Services”), and as well as during the performance of any contract or agreement Somano Online concludes with you in relation to your using the Services.

2. What is the purpose of this Policy

Privacy and security of your Personal information are very important to us. When you use the Sites and/or Services, Somano Online processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.

As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:

(a) why and how your Personal information is collected and used (also, "processed") by Somano Online when you access the Sites or Services.

(b) Somano Online's role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed.

(c) what instruments you may use to limit the amount of Personal information collected by Somano Online; and

(d) what your rights are in relation to the above processing.

3. What type of Personal information is collected by Somano Online

Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your Somano Online user account or without logging in. When you are logged in to your Somano Online user account as you are using the Sites or Services, Personal information collected by Somano Online may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by Somano Online in your user account. Somano Online does not verify Personal information provided by you unless otherwise provided in the Terms of Use or License Agreement of relevant Services, and does not decide the its credibility or whether you have the legal capacity required. However, Somano Online assumes that the information you provide is true, sufficiently complete and up-to-date.

Personal information collected by Somano Online when you access, interact with or operate the Sites and/or Services includes:

i) information provided by you when you register (create) a user account, such as your name, email and mobile phone number.

ii) You location information. Allow only while using the app: We may collect location information when the app is visible on your screen or when you have requested a delivery and during the delivery. This also applies if you are the delivery driver. You can enable/disable Somano online to collect location data from your mobile device through your device settings, which can be accessed through the Settings > Privacy > Location menu.

iii) Usage data: We collect data about how users interact with our services. This includes dta such as access dates and times, app features or page viewed, app crashes and other system activity.

4. What are the legal basis for processing your Personal information and the purposes of it

Somano Online is not allowed to process your Personal information if it does not have a valid legal ground. Somano Online will therefore only process your Personal information if:

i) the processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services

ii) the processing is necessary to comply with our legal or regulatory obligations.

iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of Somano Online and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy.

Examples of such 'legitimate interests' referred in (iii) immediately above are:

(a) to better understand how you interact with our Sites and/or Services.

(b) to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users; and

(iv) for specific purposes or if consent is required under the applicable laws and regulations, we may ask your consent for processing of your Personal information. In those jurisdictions in which consent is the legal basis, you provide such consent by agreeing to use our Sites and/or Services. We hereby inform you, and you hereby acknowledge, that you have no legal obligation to provide us with any Personal Information when you use the Sites or Services, and the provision of it is solely based on your free will. However, you are aware that without the provision of Personal Information, we will not be able to provide you with Services and your use of the Sites will be limited.

Somano Online always processes your Personal information for a specific purpose and only processes Personal information, which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:

i) to provide you with access to your user account, including your email and history of usage of our Services or applications, if you have an account for these Services.

ii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application.

(iii) to protect your rights and the rights of Somano Online.

5. How Somano Online protects your Personal information

In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those Somano Online employees whose professional tasks require using this information. To protect your Personal Information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal Information. They are also required to follow all technical and organizational security measures protecting your Personal Information.

Somano Online has also implemented adequate technical and organizational measures to protect Personal Information against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure, or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of art of the technology, their cost of implementation, the risks presented by the processing, and the nature of Personal Information.

6. How long do we store your Personal information

Somano Online will only keep your personal information for as long as it is necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements.

Unless otherwise legally required or agreed, the emails and documents, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.

If you wish to have any Personal information removed from our databases, you can have it removed via your Somano Online account or by sending an email to kjmfum1@gmail.com and requesting all your Personal Information to be deleted from our database.

7. Your rights

If it is provided by applicable law, you have a right of access to your Personal Information as processed by Somano Online under this Policy.

If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.

If it is provided by applicable law, you also have the right to:

i. learn the information about you that Somano Online stores.

ii. request the erasure of your Personal Information or certain parts of it, as well as withdraw consent to the processing of the Personal information

iii) request the restriction of the processing of your Personal information;

iv) Somano Online will honor any such requests or objections as required under applicable law.

To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.

In the case where you use the Services, the transfer of Personal Information is carried out with your consent expressing your free will and your interest, (in particular, on the ground of an agreement with you) and it is not an obligation by law.

To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of the absence of a special function in the user account interface please send an email to kjmfum1@gmail.com to address the issue.

If you are not satisfied with how Somano Online processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with Somano Online’s response, you have the right to make a complaint to the competent data protection authority.

8. Updates to this Policy

This Policy may be subject to amendments. Somano Online shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.

Somano Online undertakes not to introduce significant changes, impose additional obligations, or reduce your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the somano online app and may also be notified via other channels (e.g. by email) if you have provided us with your contact details.