Privacy Policy

UAB FlowTech Pro, with a registered office address at Lauru g. 36F, Vilnius, Lithuania (hereinafter referred to as the “Company”, “we”, “us”, “our”) values our customers and respects your privacy. This Privacy Policy describes the personal information we collect about you, collection purposes, and what we may do with the information.i

If you live in a country in the European Economic Area, for the purpose of this Privacy Policy we are a data controller and responsible for your personal data.

Where This Privacy Policy Applies

This Privacy Policy applies to the WallPepper app and other services operated by the Company. For simplicity, the Company refers to all of these as “services” or “app” in this Privacy Policy.

Information You Give Us

By agreeing to this Privacy Policy, you choose to give us certain information when using our services. This includes:

• To use certain features in our services within the WallPepper app, you may allow us to access your files and multimedia. Depending on your device, Apple will ask for your permission before allowing us to access these features.
• We may ask for your ideas and suggestions (“feedback”) about our services through surveys or other similar requests. You do not have to give us feedback, but if you do, you agree that we may use your feedback in any way.

Information We Receive from Others

In addition to the information you provide us directly, we receive information about you from others, including:

• Other Partners.

We may receive information about you from our partners, for instance where our ads are published on a partner's website or platform (in which case they may pass along details on a campaign's success).

• If you get WallPepper, Apple does not provide us with any personal information of the user (like name or email). Only anonymized data gets passed to the Company.

Information Collected When You Use Our Services

When you use our services, we collect information about which features you have used, how you have used them and the devices you use to access our services.

Usage Information

We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, time you spend in WallPepper, features you have been using, advertising that you click on).

Device Information

We collect information from and about the device(s) you use to access our services, including:

• Hardware and software information such as device type, app crashes, app version, operating system, advertising IDs, identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

Use of Information

The main reason we use your information is to deliver and improve our services. Additionally, we may use your information to help keep you safe and to communicate with you. The detailed explanation of the various reasons we use your information can be found below:

1. To improve our services and develop new ones

   We may develop new features and services (for example, we may decide to build a new feature further to requests or feedback received from users).

2. To communicate with you
   • We may communicate with you by postal mail, telephone and/or mobile devices (including through in-app advertising) about products or services that may be of interest to you either from us, our parent or subsidiary companies or other Third Parties;
   • We may contact you in case we need to verify your identity and deliver prizes in connection with contests and sweepstakes and in order to conduct surveys.
3. To prevent, detect and fight fraud or other illegal or unauthorized activities
   • We may analyze data to better understand and design countermeasures against these activities;
   • We may keep records of fraudulent activities to prevent recurrences.
4. To ensure compliance with law, which implies:
   • Compliance with legal requirements;
   • Assistance to law enforcement authorities;
   • Exercise of our rights within our Terms of Use.

   To Process Your Information as Described Above, We Rely on the Following Legal Basis:

   • Providing the services: in most cases we process your information to fulfill our obligations to you;
   • Exercise of our legitimate interests: we may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offers, and we process information for administrative, fraud detection and other legal purposes;
   • Consent: from time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time where indicated in the services or by contacting us at the address given at the end of this Privacy Policy.

   We May Transfer Your Information to Third Parties for the Following Purposes:

   • For their assistance to us in technical processing operations, such as data hosting and maintenance, finance, legal, HR and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings;
   • For legitimate business purposes, such as corporate audit, analysis and consolidated reporting as well as compliance with applicable law;
   • For corporate transactions.

   We may transfer your information if we are involved wholly, or in part, in a sale, acquisition, alienation, restructuring, reorganization, bankruptcy or other change of ownership or control.

   We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, investigation by law enforcement authorities or other legal requirements; (ii) in connection with actions of investigation, prevention, or taking other action regarding illegal activity, suspected fraud or other wrongdoings; or (iii) to protect the rights of property or safety of our company, our users, our employees, or others.

5. To enforce legal rights

   We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties and/or to comply with applicable law; (iii) to enforce our agreements or policies with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoings.

6. with your consent or at your request

   We may ask for your consent to share your information with Third Parties. In any such case, we will make it clear why we want to share the information.

How We Protect Your Information

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take measures to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security.

Information Relating to Children

Our services are intended for general audiences over the age of 4 years old. Provided that, parents or legal guardians should give the consent for children’s data processing. The age limit to receive consent is 18 years. If you believe that we may have your personal information under the age of parents’ consent, please contact us at info@wallpepper.org and we will promptly provide you this information or delete that personal information.

Your Rights

We want you to be in control of your information and be aware of your privacy rights. Depending on your location you may have some or all of the following rights in relation to how we use your personal information:

• Access: you may request access to your personal information and receive copies of it;
• Correction: you may have inaccurate/incomplete personal information corrected and updated;
• Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
• Deletion: in certain circumstances, you can request a right “to be forgotten” (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
• Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another controller);
• Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

If you wish to exercise any of these rights or object to our use of your information, please write to us at the address listed below, and we will consider your request in accordance with applicable law.

Keep in mind that we may reject requests for certain reasons including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For instance, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our services to you.

For your protection we may ask you to provide proof of identity before we can answer the above requests.

Data Transfers

Sharing of information sometimes involves cross-border data transfers. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live.

The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of the European Economic Area. We use these Model Clauses or other suitable safeguards to permit data transfers from the European Economic Area to other countries.

Data Retention

We retain your information on the principle of rationale, as long as it is necessary for the purposes set out in this Privacy Policy, and when it is needed to provide the services to you. We will also retain and use your information to the extent necessary:

• To comply with applicable law;
• To evidence our compliance with applicable law;
• If there are outstanding issues, claims or disputes requiring us to keep the relevant information until they are resolved; or
• If the information must be kept for our legitimate business interests, such as enforcing our terms or fraud prevention.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

Privacy Policy Changes

Because we are always searching for new and innovative ways to provide our services, this Policy may change over time. We will notify you of any material changes so that you have time to review the changes.

Official Data Protection

For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached by contacting info@wallpepper.org.

Contact Us

If you have questions about this Privacy Policy, you can contact us at:

• info@wallpepper.org
• LT-10150, Lauru g. 36F, Vilnius, Lithuania.

Without prejudice to any other rights you may have, if you are located in the European Economic Area, you also have the right to file a complaint against the Company with the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcij), which is the Company’s Lead Supervisory Authority.

Contact Details

A. Juozapavičiaus g. 6 / Slucko, g. 2 09310 Vilnius, Lietuva.

If you live in the European Economic Area, you may also file a complaint with your local data protection regulator.