Privacy and Cookies Policy
Effective Date: 1st January 2020
Last Modified: 22nd April, 2021
I. About TTMM
TTMM sp. z o.o. is a limited liability company founded by Albert Salamon, the creator of TTMM line of products for Fitbit, iOS and Android.
TTMM is committed to protect Personal Data and comply with applicable laws to ensure its security. This Privacy Policy will provide you information on how we collect your Personal Data, how we use it and how we keep it secure with regard to using our Site and our products and services.
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This Policy sets out the following:
. what Personal Data we collect and process when you interact with our Site,
. where we obtain your Data from,
. what we do with your Data,
. how we store your Data,
. to whom we transfer or disclose your Data,
. how we deal with your Data protection rights,
. how we comply with data protection rules.
TTMM is the Data controller of all of your Personal Data that is collected and processed when you use the Site.
In case you have questions regarding our policy, do not hesitate to contact us.
II. Glossary
Below you will find an explanation of the basic terms used in this Privacy Policy.
“Applicable laws” means all the laws and regulations relevant to the collection, processing and storage of data, especially all the data protection laws and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
“TTMM” or “we” or “us” or “our” means TTMM Spółka z ograniczoną odpowiedzialnością (Limited Liability Company) with its registered office in Warsaw, Poland, address: ul. Williama Heerleina Lindleya 16, 02-013 Warsaw, entered into the register of entrepreneurs of the National Court Register (Krajowy Rejestr Sądowy), kept by the District Court of the capital city of Warsaw in Warsaw, XII Commercial Division of the National Court Register (Sąd Rejonowy dla m.st. Warszawy w Warszawie, XII Wydział Gospodarczy Krajowego Rejestru Sądowego) under KRS number: 0000789113, Tax Identification Number (NIP): 7010928954, share capital of 5 000 PLN (in words: five thousand Polish zlotys).
“Cookies” means small text files stored in a web browser by a website or by an ad server. By storing certain information in a cookie, those web browsers, ad servers, and explicitly our Site are able to remember your preferences and recognize websites visited and/or web browsers used from one visit to another.
“Legal Grounds” means the legal basis for the collection, processing and storage of your Personal Information.
“Log Data” means information that is automatically reported by your browser each time you access our Site and which is sent by your web browser that our servers automatically record. Log Data may include information such as your browser type, web requests, domain names or pages viewed.
“Personal Data” or ”Data” means any Information relating to an identified or identifiable person as defined in Article 4 (1) of the GDPR.
“Site” means TTMM’s website www.ttmm.is.
“You” means an individual that uses the Site.
III. Cookies, Log Data and Similar technologies
When you interact with our Site, we may also collect information from your activities on our Site through the usage of Cookies and Log Data.
By using those technologies we aim to use this information for the purpose of analytics and monitoring of the effectiveness of our performance, including the collection of the aggregate Site usage data (such as the overall number of Site visitors or pages viewed).
a.
The Information mentioned above may include:
b.
Information about your interactions with the Site;
Technical information about your computer hardware and software that may include URL information, your IP address (to determine your general geographic location, so that we can provide location-specific content to you), cookie data, the types of devices you are using in order to access our Site, device Ids or identifiers, device attributes, network connection type, browser type, language, internet service provider, clickstream data, access times, the files viewed on our Site.
Cookies: We may collect Data from other sources, through the use of ,”cookies”. A cookie is a small text file stored on your computer that contains information that helps the website to identify and track the visitor. Cookies do not contain viruses nor occupy space on your hard drive.
We use two types of cookies “session cookies” and cookies that are saved permanently on your computer. Session cookies are never stored permanently on your computer and disappears when you close the session. When you visit the Site, our web server assigns your browser a unique identifier string so as not to confuse you with other visitor. The second type of cookies save file permanently on your computer and this is used to track how visitors move around on the website. This is only used to offer visitors better services and support. The text files can be deleted. The information stored on your computer is only a unique number, without any connection to personal information.
To opt out of cookies, you can alter the settings on your internet browser to accept or reject a Site from using cookies. This may affect functionality of the Site.
We use tracking software system to monitor customer traffic patterns and Site usage to help us develop the design and layout of websites. This software does not enable us to capture any of your Personal Data. Your Personal Data will not be shared, sold, rented or disclosed other than as described in this Privacy and Cookies Policy.
Google Analytics. Our Site uses those cookies that are small text information stored on your end device (e.g. computer, tablet, smartphone) that can be read by the Google LLC’s IT system (third party cookies) in connection with our use of Google Analytics software. Google Analytics is an online tool for analyzing website statistics that automatically collects information about your use of the Site. We do not identify Site’s users with this software, and use of it is for statistical purposes only. Detailed information on how Google uses user data is available at: https://policies.google.com/technologies/partner-sites.
We have activated IP anonymization. Your IP address is shortened before forwarding. Only in exceptional cases is the full IP address transferred to a Google LLC server in the United States and shortened there. The anonymized IP address provided by your browser as part of Google Analytics is generally not combined with other Google LLC data. During the first visit to the Site, you are shown information on the use of cookies. You can prevent the recording of Personal Data collected by cookies regarding your use of the Site as well as the processing of this Personal Data by installing the browser plug-in located at the following address: https://tools.google.com/dlpage/gaoptout. If you are interested in the details related to Data processing within Google Analytics, you can read also the explanations prepared by Google: https://support.google.com/analytics/answer/6004245.
Some cookies are deleted after the end of the web browser session, i.e. after closing (so-called session cookies). Other cookies are stored on your end device and allow your browser to be recognized the next time you visit the site (persistent cookies).
The use of both types of cookies is based on our legitimate interest (Article 6 (1) (f) of the GDPR), consisting in proper operation of the Site, creating statistics and analyzing them in order to optimize the Site. User and event Data associated with cookies is stored by Google Analytics on Analytics servers for a period of 14 (fourteen) months. After the end of the period, stored Data will be automatically deleted once a month.
Log Data. Using the Site involves sending queries to the server on which the Site is stored. Each query directed to the server is saved in the server’s logs. Logs include, among others Your IP address, server date and time, information about the web browser and operating system you are using. Logs are saved and stored on the server.
The data saved in the server logs are not associated with specific person using the site and are not used by us to identify you. Server logs are only additionally used to operate the site, and their content is not disclosed to anyone except those authorized to operate the server.
Opt-out. Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. However, please note that certain features of our Site may not work if you delete or disable some types of cookies. Some third parties may use cookies and other technologies. We recommend that you read their privacy policy.
The help function in your preferred browser should provide you with the correct information. Some browsers provide helpful cookie guides:
IV. Personal Data we collect, Purposes, Legal Grounds for Data Processing and Retention Periods
We collect Information about you through your use of Site (please read section III. Cookies, Log Data and Similar Technologies) or when you contact us, for example via email or social media (in this case we may collect your name, surname, email address, basic profile info and other information you provide us with). Therefore if you send us and email with a request or questions regarding our products we will answer your questions, but we will not process your Personal Data for any further use.
In some cases we may we process your Data regarding payments (please see section VII. Purchase transactions).
We will only process your Personal Data if we have a legal basis to do so, which will depend on the reasons for which we have collected and needed to use your Personal Data.
Your Data may be used for the following purposes:
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- Customer service communication (Article 6 (1) (b) of the GDPR): to manage our relationship with you as our customer in order to perform the agreement concluded between us;
- Administrative (Article 6 (1) (f) of the GDPR): we use your Data for statistical and marketing analysis, system testing, customer surveys, maintenance and development;
- User service communication (Article 6 (1) (f) of the GDPR): to answer your queries when you use an email contact or social media contacts.
We will not retain your Data for longer than necessary. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the Personal Data, the purposes for which we process it, and whether we can achieve those purposes through other means.
As stated in section III. Cookies, Log Data and Similar Technologies, user and event Data associated with cookies is stored by Google Analytics on Analytics servers for a period of 14 (fourteen) months. After the end of the period, stored Data will be automatically deleted once a month.
With regard to the customer service communication we may store your Data as long as needed to pursuing claims or defending against claims in relation to concluded agreement (therefore for the duration of the agreement and for the period of limitation of claims after its expiry). However with regard to the user service communication if you do not concluded agreement with us, we may store our correspondence for 3 (three) months from the last message in the correspondence. If you use your social account to leave us comments, they shall be available for the duration of the relevant profile.
When we no longer need your Personal Data, we will securely erase it. We will also consider if and how we can minimize over time the scope of Personal Data that we use, and if we can anonymize your Personal Data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
V. No collection of Personal Data through TTMM’s applications
We do not collect any Personal Data via the TTMM’s apps, the clock faces apps, as well as the utility apps. You acknowledge that TTMM may collect and use anonymized technical data and related information gathered to facilitate the provision of software updates, product support, and other services to you (if any) related to the TTMM’s product. TTMM may use this information to improve its products or to provide services or technologies to you.
However TTMM’s partners, which applications you also use, may collect and use information personally identifying you (e.g. location data). Therefore TTMM encourages you to read their relevant privacy statements regarding processing of your Data. In accordance to the above, you can find the privacy policy of Fitbit, Inc. here: https://www.fitbit.com/us/legal/privacy-policy#info-we-collect.
VI. Social media:
The Site uses plugins and other social tools provided by social network administrators such as Facebook, Twitter and Instagram.
By displaying the Site containing such a plug-in, your browser will establish a direct connection to the servers of social network administrators (service providers). The content of the plugin is transmitted by the respective service provider directly to your browser and integrated with the Site. Thanks to this integration, service providers receive information that your browser has viewed the Site, even if you do not have a profile with a given service provider or are not currently logged in to it. This information (along with your IP address) is sent by your browser directly to the server of the given service provider (some servers are located in the USA) and stored there.
If you have logged in to one of the social networking sites, then this service provider will be able to directly assign a visit to the Site to your profile on the given social networking site.
If you use a given plugin, e.g. by clicking on the “Like” or “Share” button, the relevant information will also be sent directly to the server of the given service provider and stored there.
In addition, this information will be published on the respective social network and will appear to people added as your contacts. The purpose and scope of Data collection and their further processing and use by service providers, as well as the possibility of contact and your rights in this regard and the ability to make settings to protect your privacy are described in the privacy policy of individual service providers, e.g.:
Facebook – https://www.facebook.com/legal/FB_Work_Privacy,
Instagram – https://help.instagram.com/519522125107875?helpref=page_content,
Twitter – https://twitter.com/en/privacy.
If you do not want social networking sites to match the Data collected during visits to the Site directly to your profile on a given website, then before visiting our Site you must log out of your social media account. You can also completely prevent the plugins from loading on the page using the appropriate extensions for your browser, e.g. script blocking.
VII. Purchase transactions
Payments for our products can be made via Apple payment and Google Pay. This process is encrypted and secure and we don’t get access to any Personal Data form the transaction.
Payments for our products can also be made via KiezelPay. In this case we have access to sales console and your payment data (name, surname, country).
Please note that such payment service providers you use may collect from you and process your Data on their own in order to perform such payment services. Such third-party service providers have their own privacy policies in respect to the Personal Data they collect for your purchase-related transactions. Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy and Cookies Policy.
For these providers, we recommend that you read their privacy policies, so that you can understand the manner in which your Personal Data will be handled by these providers.
VIII. Security information
TTMM clock faces use Bluetooth, GPS, Wi-Fi and health data for proper functioning of the clock faces. TTMM and TTMM-S app uses the right of access to your Bluetooth and Wi-Fi to communicate with the Fitbit app and to transfer TTMM clock faces from the Fitbit server onto your Fitbit Versa smartwatch. GPS and Internet are used to retrieve weather information based on your location (charges for data download onto your smartphone may apply according to your providers fares). Health data is used to present information about the completed steps, distance, burnt calories, active time, heart rate and floors. The TTMM clock faces do not store any Personal Data nor does it transmit any Personal Data outside of the Fitbit Versa smartwatch.
We follow strict procedures in the storage and disclosure of your Personal Data, and to protect it against accidental loss, destruction or damage. The Data you provide to us is protected using SSL (secure socket layer) technology, which is a method of encrypting Personal Data and credit card details so that they can be securely transferred over the Internet. After a transaction, your private data (credit cards, social security numbers, financials, etc.) will not be stored on our servers.
Only qualified and authorized employees are permitted to access Personal Data, and they may do so only for permitted business functions.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your Personal Data. Our security procedures mean that we may request proof of your identity before we disclose Personal Data to you.
Please note to avoid sending Personal Data through insecure channels or networks. It is important for you to protect yourself against unauthorized access to your password and to your devices and under no circumstances share your password with anyone.
IX. Transfer and Disclosure of Personal Data
With regard to the processing related to collecting cookies or processing Personal Data in social media (comments, correspondence) TTMM may transfer Personal Data to a country outside of the European Economic Area (EEA), i.e. to the territory of United States of America for which the European Commission has adopted an adequacy decision (Privacy Shield).
The EU-U.S. Privacy Shield framework is a “partial” adequacy decision, as, in the absence of a general data protection law in the U.S., only the companies committing to abiding by the binding Privacy Shield principles benefit from easier Data transfers.
For the above reasons, in such cases your Personal Data will be transferred to the territory of USA in accordance with Applicable laws, with appropriate safeguards in place, only to Privacy Shield certified vendors (according to the EU Commission Decision 2016/1250) or by using standard contractual clauses adopted by the European Commission (EU Commission Decision on standard contractual clauses for the transfer of Personal Data to processors established in third countries under Directive 95/46/EC (the “Model Contract Clauses”), or based on other applicable transborder Data transfer mechanisms.
You may also learn more about:
Privacy Shield Program here https://www.privacyshield.gov/Program-Overview and here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
EU Commission Decision on standard contractual clauses for the transfer of Personal Data to processors established in third countries here https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087 and here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
TTMM may entrust Personal Data to trusted entities, which services it uses to ensure proper Software operation and its safety i.e. hosting providers, email providers or other IT services providers.
Safety, Legal Purposes and Law Enforcement. We may use and disclose the Data when we believe it is necessary: (i) under applicable law, and (ii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
X. Your Rights
TTMM will respect your legal rights to your Data.
Below you will find the description of your rights that you have under the law, and what TTMM does to protect those rights:
What TTMM does to protect your rights
The right to be informed
TTMM is publishing this Privacy Policy and Cookies Policy to keep you informed of what we do with your Personal Data. We strive to be transparent about how we use your Data.
The right of access
You have the right to access your Data. You have the right to request a copy of your Data that we hold about you by contacting us.
The right to rectification
The right to erasure
This is sometimes called ‘the right to be forgotten’. In some circumstances you have the right to the erasure of your Data without undue delay. Those circumstances include situations when: the Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the Data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
The right to restriction processing
In some circumstances you have the right to restrict the processing of your Data. Those circumstances are the following: you contest the accuracy of the Data; processing is unlawful but you oppose erasure; we no longer need the Data for the purposes of our processing, but you require Data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
The right to Data portability
TTMM must allow you to obtain and reuse your Personal Data for your own purposes in a safe and secure way without it affecting the usability of your Data. The Data must be held by us by consent or for the performance of an agreement and the processing is carried out by automated means.
The right to object
In certain circumstances, you have the right to object to the processing of your Personal Data where, for example, your Personal Data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your Personal Data, or if your Data is being processed for direct marketing purposes.
The right to withdraw consent
If you have given us your consent to process your Data but changed your mind later, you have the right to withdraw your consent at any time, and TTMM has to stop processing your Data unless TTMM has other Legal Ground for processing of your Data. The withdrawal of consent does not affect the compliance of the processing which was made on its basis before the withdrawal of consent.
The right to complain to a Supervisory Authority
XI. General Provisions
Contact: If you need any more information please contact with us through our Site: https://ttmm.is/contact/
Changes to the Policy: We may change this Privacy and Cookies Policy from time to time by updating this page.
Notice to Parents: If you are a parent or a guardian who knows or has otherwise discovered that your child under the age of 13 has submitted their Personal Data, or other information, to us without your consent, permission or authorization, do not hesitate to contact us. We will promptly remove your child’s Personal Data or other information from our system, cease the use of such Personal Data and direct any third party with access to it to do the same.
Other links. This Policy does not cover the links within the Site linking to other websites. Those websites are not governed by this Privacy and Cookies Policy, and if you have questions about how other websites use your Data, you’ll need to check that websites’ privacy statements.
Copyrights © 2013-2021 Albert Salamon. All rights reserved. TTMM and TTMM logo are registered trademarks of TTMM in European Union and other countries. All other trademarks are the property of their respective owners.