Effective date: April 29, 2020

URegimen Privacy Policy

  1. What does this Privacy Policy cover and to whom does it apply?

This Privacy Policy (“Policy”) describes how we at Dodona Bulgaria EOOD, a company incorporated under the laws of Republic of Bulgaria having its seat and registered address: in Bulgaria, Pazardzhik 4400, 66 Odrin Str., registered in the Commercial Register in the Registry Agency under UIC: 203449714, email: hello@uregimen.com, website: http://dodonabulgaria.com (“Dodona,” “we,” “us,” “our”) collect and process your personal data in relation to providing you with access to and the enabling you to use URegimen as defined in the End-User License Agreement for URegimen (“Terms”/ “Agreement”) http://uregimen.com/terms. We comply with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”/”GDPR”). Please read carefully the following Policy. 

Remember that your use of URegimen is always subject to the Terms, which incorporate this Policy. If you disagree with the Terms and/or the present Policy, please discontinue the use of URegimen and delete your user account. Any terms we use in this Policy without defining them have the definitions given to them in the Terms, and where no such definition is given therein – the definitions given in the applicable legislation.

We may collect and process personal data regarding the following natural persons (“you,” “your”, “data subject”): Natural persons who have downloaded, installed and use URegimen.

NOTE: This Policy does not apply to the processing of personal data in connection with the provision of services by the respective app store provider (Apple and Google) in compliance with their terms and conditions, for example regarding downloading and installing URegimen as well as regarding in-app purchases. For more information about their personal data processing practices please refer to your app store provider privacy notices (Apple and Google).

You understand that through your use of URegimen and/or by clicking “I CONFIRM THAT I HAVE READ THE PRIVACY POLICY” (or similar button) you declare that you have been informed about the content of this Policy and the way Dodona Bulgaria EOOD processes personal data as data controller.

URegimen is intended only for persons that have reached the full legal age. We do not knowingly collect or solicit personal data from anyone under the full legal age or knowingly allow such persons to use URegimen. If you are under the full legal age, please do not attempt to use URegimen, to register an user account or submit any information about yourself to us. In the event that we learn that we have received personal data from a person under the full legal age, we will delete that information as quickly as possible unless we find it necessary to temporarily store such information in order to comply with legal obligations, binding legal orders or to establish, exercise or defend a legal claim. If you believe that we might have any information from or about a child under the full legal age, please contact us at: legal@uregimen.com.

  1. What personal data do we collect?

Personal data is any information that relates to you and through which you can be identified (“personal data”). Processing personal data (“processing”) is any action or set of actions that may be performed with the personal data by automatic or other means.

2.1. Opening user account

You will need to sign-up and open a user account in order to use URegimen. After you download and install URegimen you will be asked to complete the registration process.

When signing-up for a user account you must provide the following mandatory information:

  • email address as username; and
  • password;

We also store information whether you have accepted the Terms and acknowledged that you have read and understood this Policy. Your password is stored only in encrypted format and we are not able to see it and/or decrypt it.

2.2. Using URegimen

(i) When using URegimen, the following information about you is being stored both locally on your device and remotely on our servers:

  • Your username (email) and a user ID number which is a unique number used by our database to identify your user account.
  • Information whether you have purchased URegimen Premium or whether you are using the free version. When you are using URegimen Premium you receive a token associated with your account as an authentication key for access to a secure server for downloading URegimen Premium resources.
  • You may also submit information about your age and gender (sex) as well as your body measures: weight, height, waist, thigh, upper arm, neck. We store this information as well as body measures’ history associated with your account. Based on this information URegimen calculates your recommended maximum kcal intake per day.
  • We also store information about the starting and ending date of your regimen, information about when you would like to have your first meal for the day, and whether you have completed the tutorials for using your account, recipes, workouts and welcome brief.

This information is necessary to maintain your user account and to ensure that your are able to use URegimen.

(ii) Furthermore, there is information which is being stored and processed only locally on your own device. These are the photos you can add to trace your progress (e.g. before-after photos), your current kcal intake per day as well as your meals’ history. This information is fully and solely under your control and cannot be accessed or otherwise processed by us.

2.3. Feedback

When you provide feedback, submit requests, complaints, bug reports and in case of other types of correspondence, we will process the personal data and the other content that you provide in the correspondence with us so that we can effectively respond to your request, complaint, or other communication. We will also process information on the status of your feedback, request, complaint or other communication and the result from its processing by us.

2.4. Access rights

URegimen requires notification access to ensure the proper function of URegimen. Before you use URegimen the first time, we will request permission for notification.  

To use the feature to add photos so you can trace your progress URegimen requires photo access rights (e.g. access to your gallery). We will request this permission for you to be able to select and add photos to URegimen. However, we will not get access to these photos – they will remain fully under your control and will be processed only locally on your own device.

You can manage the given access rights and revoke them in the settings on your device. Please consult your operating system manufacturer (Apple and Google) for more information on how to do it.

  1. For what purposes and on what legal grounds do we process your personal data?

Dodona collects, uses, and processes the personal data described herein for the purposes provided in this Policy:

  • Conclusion and performance of the Agreement between you and Dodona:

We process the information provided within the registration process to perform your registration and to create and maintain your user-account, incl. to ensure that you are able to restore your user account when necessary (e.g. change of the device).

We also process all of your information specified in this Policy for activities related to the conclusion, amendment, performance and termination of the Agreement between you and Dodona as per our Terms and communication with you necessary for the performance of our Agreement and/ or for notifying you about changes in the Terms or other relevant for the use of URegimen issues.

  • Legitimate interests of Dodona to ensure the effective and secure functioning of URegimen: 

We may process all or some of the above-specified information for activities related to the maintenance and administration of the use of URegimen. This includes activities related to detection and prevention of malicious activities; detection and repair of technical or functionality related issues and prevention of unauthorized access to and/or use of URegimen.

  • Protecting and exercising the legitimate interests of Dodona or third parties:

Sometimes, we could process your information for activities related to establishment, exercise or defense of legal claims with regard to Dodona’s rights and legal interests, including by legal proceedings, and rendering assistance to other users and/or affected third persons in exercising and protecting their rights and legal interests or for consideration and resolution of received complaints, requests and other communications related to URegimen.

  • Fulfilment of Dodona’s legal obligations:

We may also be legally obliged to process all or some of the above-specified information for activities related to the performance of statutory obligations for the retention or provision of information to competent authorities; to notify you of circumstances related to your rights, etc.

  • Consent

We may also process your personal data based on your consent, to the extent and within the scope provided by you for purposes as sending you marketing and promotional communications regarding our products and/or services. When we process your personal data based on your consent, the processing will be only for the specific purposes for which you have consented to. Note, that consenting to such processing from your side is completely voluntary and such consent does not constitute a condition for you to use URegimen. You are free to withdraw such consent at any time. The refusal to consent or the withdrawal of the consent are not related to any negative consequences for you, except that we will not be able to process your personal data for the respective purposes (e.g. we will not be able to keep you informed about our products or services or our special offers which you may be interested to).  

  1. Will we share any of the personal data with third parties?

We may share your personal data with third parties as described below:

  • Where required by law – We disclose any of the personal data mentioned above if this is necessary to comply with applicable law or court order. In such cases we may disclose personal data to competent state and court authorities, auditors or other types of recipients provided by law;  
  • Where necessary for protection of the rights and legal interests of Dodona or third parties (such as our employees, contractors, other users etc.) – when your personal data is necessary to enforce or apply our Terms; to protect the rights, property, or safety of Dodona, our employees, our users, or our contactors, and/or to establish, exercise or defend a legal claim we may disclose your personal data to attorneys and legal consultants; bailiffs; notaries or persons performing similar public functions; competent authorities and courts;
  • Suppliers and subcontractors – We store your information using the cloud database service of mLab (https://mlab.com) operating on the Amazon Web Services (AWS, https://aws.amazon.com/) cloud platform for the Region Europe (Ireland) (eu-west-1). We share your information with them.

When working with such suppliers and subcontractors and they act as data processors on our behalf, we require them to strictly comply with our instructions, in accordance with this Policy, the Terms and the applicable data protection rules.

Some of our suppliers and service providers that we use act as data controllers and determine on their own or by virtue of the applicable law their own purposes to process personal data. For example, such providers are the electronic communications service and network providers that are necessary for the Internet connection and communications between us, Google and Apple who facilitate the distribution and download of URegimen through their app stores as well as the in-app purchases, etc. In such cases, we share personal data only to the extent that is necessary for the performance of the data processing purposes specified in this Policy and only as far as we have a respective legal basis for sharing that personal data.

  1. Information for persons within the EU

5.1. Transfers outside of the EU

If you are located in the territory of the EU, please be informed that, currently, we do not transfer your personal data to other persons located outside the EU (Recipients).

If we decide to transfer your personal data outside EU, we will inform you and will do so in compliance with the terms of this Policy and the GDPR this includes (i) transfer of data to Recipients located in countries, territories or part of specified sectors within such countries that are recognized by the European Commission as ensuring an adequate level of protection of the natural persons concerned; (ii) transfer in accordance with the EU-US Privacy Shield frameworks (for transfers to the US); transfers pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission and as an exception, derogations for specific situations provided for in the EU data protection law.

5.2. Rights regarding the processing of personal data. You have the following rights:

  • Right of information. This Policy aims to inform you in detail about the processing of your personal data by Dodona. 
  • Right of access. You are entitled to receive confirmation whether your personal data are being processed, to receive access to such data, as well as information about the processing and your rights.
  • Right of rectification. You are entitled to have your data rectified in case it is incomplete or inaccurate. Your data may be rectified by us upon your request.

NOTE: URegimen gives you the possibility to access and to change your data stored in your user account such as your age, gender (sex) etc. To do so, please select the features within URegimen.

  • Right of erasure. You have the right to ask for your data to be erased where one of the respective grounds provided by the Regulation applies.

NOTE: URegimen gives you the possibility to remove your account. If you do so, we will delete your data associated with your user-account and these cannot be restored anymore. To do so, please select Remove Account within URegimen.

  • Right of restriction of the processing. The Regulation provides for the possibility of restricting your personal data processing in case there are grounds for this as set forth therein.
  • Right of data portability. You have the right to receive the personal data you have provided, and which are related to you in a structured, commonly used, machine-readable format, and to use such data with another controller at your discretion, if the conditions provided for in the Regulation are present. 

NOTE: URegimen gives you the possibility to export your personal data in a text format to an email of your choice. To do so, please select Export Personal Data within URegimen. Note that you are not entitled to export shopping lists, meal history, training regimes, etc.  

  • The right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects concerning you or similarly significantly affects you unless there are grounds provided for in the applicable data protection legislation, as well as appropriate safeguards to protect your rights, freedoms and legitimate interests. No technology falling within this category is used within URegimen. 
  • Right to withdraw consent. You have the right to withdraw at any time your consent for personal data processing that is based on prior given consent. Such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.
  • Right to object. You have the right to object, in respect to data processed, based on legitimate interest. In the event of such an objection we will examine your request and, if justified we will comply with it. If we believe there are enough legal grounds for the processing or where it is necessary for establishing, exercising or defending legal claims we will inform you accordingly. 

Exercise of rights You can exercise these rights at any time by sending us a notice in writing via the contacts provided in this Policy or on the following email address: legal@uregimen.com. You can exercise some of your rights through the interface of URegimen as far as respective functionalities are available.

  • Right to lodge a complaint with a supervisory authority.  You have the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data concerning you infringes on the applicable data protection legislation. For more information, please refer here (https://edpb.europa.eu/about-edpb/board/members_en).
  1. How long do we store your personal data?

We apply the storage limitation principle, namely, we store personal data in minimal volume and for a period no longer than the necessary for the purposes for which they are processed, ensuring that they are stored securely and in compliance with the applicable legislation.

We store the categories of personal data listed above as follows:

Type of data

Storage period/criteria for its determination

Data provided with respect to the registration of user-account, information contained in statements and other documents and information relating to the conclusion and performance of the Agreement between us.

For the period of the duration of the contractual relationship between you and Dodona and up to the elapsing of the limitation period for civil law claims under the applicable legislation, unless longer retention period applies as per this Policy or the applicable legislation.

Information collected by URegimen, and/or provided by you when using URegimen.

Until deletion by you or until the removal of the user-account (whichever event is the earlier one).

Feedback, requests, complaints, bug reports and other types of correspondence.

For the duration of the contractual relationship with us, or until the completion of the correspondence and/or the final resolution of the correspondence related case, if there is no applicable contractual relationship; and

Up to the elapsing of the limitation period for civil law claims under the applicable legislation.

Server/ System logs and other automatically collected information (except for system logs that serve to prove the conclusion or performance of the Agreement between us.

Up to 1 /one/ year, unless for such data is determined a different storage period in this Policy

Notwithstanding the data retention periods set out above, it is possible that:

  • a specific legal dispute or procedure arises (e.g. litigation, arbitration, administrative proceedings, etc.), requiring the data to be retained after the retention periods have elapsed;
  • we receive a mandatory instruction from a competent public authority to preserve certain data/ content.

In such cases, the personal data will be preserved in accordance with the retention periods specified by the competent authority or until the final settlement of the dispute or proceedings before all instances, including the settlement of the respective execution proceedings as well as for the maximum period of time after the final settlement during which the respective dispute or proceedings may be reopened under the applicable law.

If any law or other legislative act requires the storage of the personal data for a period longer than the one specified above, the legally established longer term shall apply to their storage.

  1. What if you have questions about this Privacy Policy?

If you have any questions or concerns regarding our privacy policies or any other question related to the use of your personal data by Dodona, please send us a detailed message to legal@uregimen.com, and we will try to resolve your concerns.

  1. Changes of this Privacy Policy

We are constantly trying to improve URegimen and need to comply with all the changes in the applicable data protection legislation, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on http://uregimen.com/privacy, by sending you an email, and/or by some other appropriate means.