This Privacy Policy describes the types of information gathered by Proximity Labs Ltd  (“Proximity”, “us” or “we”) in the process of providing www.proximity.dev and the data, services, information, tools, functionality, updates and similar materials (collectively, the “Website”), how we use the information, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information, and our efforts to protect the information you provide to us through the Website.

By using the Website (and/or providing information to us via an intake form or otherwise), you agree to allow us to process information in accordance with this Privacy Policy. 

This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Website or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy, or other method of legal acceptance, means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

This Privacy Policy may be subject to the provisions of the EU General Data Protection Regulation ("EU GDPR"), the UK General Data Protection Regulation (“UK-GDPR”, and together with the EU GDPR, the “GDPR”), and other applicable privacy laws. Under the GDPR, Proximity is a data Controller. If you are an individual located in the United Kingdom, Northern Ireland, the European Economic Area, or Switzerland (collectively, and for the purposes of this Privacy Policy, the “EEA”), you are a Data Subject with certain protected privacy rights concerning your Personal Data.  We will take commercially reasonable steps to maintain compliance with GDPR. Your Personal Data may identify you as a person, and thus may be referred to in this Privacy Policy as Personally Identifiable Information ("PII").

1. Who Collects Your Information On Our Website?

Under the GDPR, Proximity is what is known as a “Controller” of the Personal Data that you provide us with. We collect information from you on the Website, and we are responsible for protection of your information.

2. What Information Does Proximity Collect?

A. Personal Information.  We may collect certain personal information about you, which may be supplied when you use the Website, when you submit information such as through a contact form, and from third parties. The types of personal information we collect and save include:

• Name, physical or mailing address, email address, Telegram ID; 

• Location-based information; and

• Technical information collected in our logs, such information may include standard web log entries that contain your IP address, browser history, page URL, and timestamp.

You may provide us with information when you interact with us through email or through other use of the Website. We may retain such information in order to provide you with services and to resolve any issues that may arise.

B. Non-personal Information.  Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, applications downloaded, search terms entered, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Website may use other commonly used information-gathering tools. 

If non-personal information is paired to any of your PII, we will treat the non-personal information as if it were also PII.

C. Aggregate Information.  We may also collect anonymous, non-identifying and aggregate information, the date and time of any request you make, your language preference, pages you visit, the referring website, the website you go to immediately after visiting our Website, and the domain name of your Internet service provider.

3. Why Is My Information Being Collected?

We accept and gather information to provide the Website to you. We need to collect your personal information so that we can respond to your requests for information or to be added to our email lists, enforce our Terms of Service, and otherwise provide the Website. We also collect aggregate information to help us better design the Website. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Website, calculate usage levels, and otherwise provide services to you.

4. How Do We Use the Information We Collect?

A. We use the personal information you provide for the purposes for which you have submitted it, including:

• Internal Uses. We may use your PII to respond to your inquiries and to provide you with the Website and services.

• Communicating With You About Our Services. We may use your PII to send you information that may be of interest to you.

• Sending Administrative and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account information and your other PII; (b) provide you with information regarding the Website; (c) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (d) provide you with information on our other services and products, or promotions related to the Website or our other services and products.

B. We may use anonymous information that we collect to improve the design and content of our Website, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Website is used. We may use any anonymous, aggregate information, which may include or be based on your information, without restriction.

5. Do We Share Your Personal Information?

We will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons, organizations, or service providers with whom we contract to carry out internal operations or business activities, which includes exchanging information with other companies and organizations for fraud protection, spam and malware prevention, and providing you with the Website and our services.

We may share anonymous information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer your personal information to a third party, or our successor-in-interest, in connection with, or as the result of, an acquisition, sale, merger, reorganization or bankruptcy involving our company.

6. How Can You Access And Control Your Information?

If you submitted information to us through the Website, you may revise your information by sending us an email to legal@proximity.dev. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request to do so. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections, or removing your information. 

7. How Do We Store and Protect Your Information?

We have physical, electronic, and managerial procedures in place to safeguard the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems. We retain and store your PII until you request us to remove it from our servers. We store our logs and other technical records indefinitely.

8. How Do We Use Analytics Technologies?

We may collect certain information about your equipment, browsing actions, and patterns from you when you access the Website using a variety of technologies. This information may be used for maintaining or improving the quality of the Website, as well as providing overall general statistics related to the use of the Website.

The Website does not respond to browser do-not-track signals.

9. Collection of Information by Others.

This Privacy Policy is only applicable to our Website and not third-party websites to which we may provide links or our service providers. Please check the privacy policies of these other websites and our service providers to learn how they collect, use, store and share information that you may submit to them or that they collect. You may view the privacy policies of some of our providers at Jotform and Framer. 

10. ‘EEA’ Privacy Rights.

If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject.  The GDPR requires that we, in our capacity as a Controller, have a legal basis to process your PII.  

A. We process your PII under one or more of the following legal bases: 

• Processing is necessary for our legitimate interests (or those of a third party) and your interests, and fundamental rights do not override those interests.

• To perform the contract that we are about to enter with you (e.g., our Terms of Service).

• To comply with a legal obligation.

• We have your consent to do so.

B. Under the GDPR, as a Data Subject you have certain rights. They are:

• The right to be informed. This is your right to be informed about what we are processing, why, and who else the data may be passed to.

• The right of access. This is your right to see what data about you is held by us.

• The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.

• The right to be forgotten. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.

• The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.

• The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.

• The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.

• Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Website does not engage in automated decision making and profiling. 

  
  

You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at legal@proximity.dev. 

11. Children and Young People’s Information.

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the Children's Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. If you believe that your child under 13 has gained access to our Site without your permission and provided PII to us, please contact us at legal@proximity.dev and we will make efforts to delete the child’s information in accordance with COPPA.

12. California Privacy Rights

California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at legal@proximity.dev with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your information; at a minimum, your name and email if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

13. Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at legal@proximity.dev.