PURE’S PRIVACY POLICY

This privacy policy (“Privacy Policy”) applies to the use of the Pure website in its entirety, including all of our subpages, associated sites or pages (“Website”), and the PURE mobile and web app, which is accessible through browser on mobile phone, tablet computer and personal computer (“App”) (collectively, “PURE”), are operated by PWM Technologies Limited, 712 Tai Yau bldg 181 Johnston rd Wanchai, Hong Kong, HK 74786525 / RU TIN 9909635364 (“we”, “us”, “our”).

We are responsible for all information relating to an identified or identifiable natural and, where applicable, legal person (“Personal Data”) that we collect, process, and use during your use of PURE. We care deeply about protecting your privacy. We are committed to handling your Personal Data in accordance with applicable laws and to making PURE a service that people love and trust.

This Privacy Policy outlines how we process your Personal Data both in connection with PURE and otherwise.

1. What Personal Data do we collect?

a. When visiting the Website and/or App

When you visit the Website or App, we can process the following categories of Personal Data from you:

b. When using PURE

When you use PURE, you voluntarily provide us with certain information. When you create an account, add information to your user profile, or interact with us you make the choice to share information personal to you with us. In this way, we can process the following categories of your Personal Data:

We receive most of your Personal Data directly from you. To the extent permitted by applicable law, we can also obtain your Personal Data from publicly available sources or from public authorities and other third parties (e.g., service partners, internet analysis services)

2. How do we use your Personal Data?

We can use your Personal Data for the following purposes:

3. What legal basis do we rely on when processing your Personal Data?

We process your Personal Data based on the following legal bases:

4. Online tracking and analysis

a. Cookies

We use and may allow others to use cookies and similar technologies on PURE to recognize you and/or your device(s). You may read our cookie policy (see here) for more information on why we use them and how you can have better control over their use.

b. Analytics

We use analytics and research technologies on PURE to collect information about how visitors use PURE. For the analytics technologies that we use on our web platforms, you may read our cookie policy (see here) for more information on why we use them and how you can better control their use.

c. Log files

When using PURE, general access data is stored in a log file for the creation of statistics. We use this data for statistical and technical evaluations in anonymized form, for example to optimize the server infrastructure, to determine on which days there are particularly many accesses, or to draw conclusions about possible improvements to the user interface and functionalities. A personal evaluation of this data does not take place.

5. Social networks

There are links on our Website to our profiles on the following social networks:

If you click on the social network icons, you will automatically be redirected to our profile on the corresponding social network.

When you open a link to one of our profiles, a direct connection is established between your browser and the server of the relevant social network. This provides the network with the information that you have visited PURE with your IP address and accessed the link. If you access a link to a network while logged into your user account on the network in question, the content of PURE may be linked to your user account on the network, i.e., the network may link your visit originating from PURE directly to your user account on the social network. If you want to prevent this, you should log out from your account before clicking on the corresponding links. In any case, an association takes place when you log in to the relevant network after clicking on the link.

6. What Personal Data do we share with third parties?

We may transfer your Personal Data abroad to third parties that may be located in any country in the world (in particular in other countries in Europe, Hong Kong, and the USA). These countries may have different laws about data processing and, as the case may be, data protection laws that have been deemed inadequate by competent authorities to protect your privacy rights.

The data recipients are obliged to protect your Personal Data in accordance with the agreed contractual obligations and the applicable data protection laws. If the level of data protection in a country does not correspond to the Swiss or European level, we will contractually ensure that the protection of your Personal Data always corresponds to the level in Switzerland or the EU. For this purpose, we agree with the third parties on the EU standard clauses and, if necessary, implement additional technical and organizational measures.

In particular, we may disclose your Personal Data to the following categories of recipients:

7. What Personal Data do we receive from third parties?

By signing in PURE using your Facebook account you give permission to Facebook to share your email address, name and your profile picture with PURE. You have an option to manually opt-out of permission to allow Facebook sharing your email address with PURE, however this is only possible when an email is associated with your Facebook account.

By signing in to PURE using your Apple ID you give permission to Apple to share your Apple login, your name and your email with PURE. Apple is offering an option to hide your email, so you can keep your email address private but still receive messages from the App. To enable this, Apple will create a random email address, link it to your account on PURE and allow your personal email to stay private.

By signing in to PURE using your HUAWEI ID you give permission to HUAWEI to share with PURE your profile picture, your nickname or anonymised phone number/email address if no nickname is set, to link your HUAWEI ID and to share your email address. HUAWEI allows you to manually opt-out of sharing the email address.

By signing in PURE with your Google Account you give permission to Google to share your name, email address, language preference and with PURE.

Compiled data will be used in order to form your account on PURE. You can always manually withdraw your permission to access the data above by removing the PURE app from the Facebook settings, your Google account or from your Apple ID or by canceling authorization for HUAWEI ID. Data provided at the set up of the account using any of these third party services will still be accessible to PURE, even after you withdraw permission on these third party services. In order to remove our access to this data you will have to delete your PURE account. Your rights regarding, and setting options for protecting your privacy, can be found in the privacy notices of the providers:

8. How long do we retain your Personal Data?

We only retain your Personal Data for as long as it is needed for the purpose for which it was originally collected or as we are required to retain it under applicable laws and regulations or contractual agreements.

9. How do we secure your Personal Data?

We use appropriate technical and organizational security measures to protect Personal Data from loss, misuse, or alteration. Our employees and the service providers commissioned by us are contractually obliged to maintain confidentiality and to comply with the provisions of data protection law.

However, it is not possible for us to guarantee the absolute security of Personal Data. In this context, please note that data transmitted over an open network such as the Internet or an email service is openly accessible. We cannot guarantee the confidentiality of messages or content shared over these networks. Thus, Personal Data sent to us via open networks will not be subject to the same security measures as Personal Data contained within PURE.

10. Your rights

You have the following rights:

Please note that the above-mentioned rights are not absolute. These rights are subject to exceptions and their applicability is largely dependent on the legal basis we rely on in each case and the various circumstances of each specific request.

11. Children's policy

Users who are not at least 18 years old or older when explicitly required by applicable state laws (referred to as “minor/s” hereafter) are not permitted to use PURE. We do not knowingly collect Personal Data from minors.

We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children not to use PURE and thus not to provide Personal Data on PURE. If you have reason to believe that a minor has provided Personal Data to us, please contact us immediately and we will endeavor to delete that data from our databases.

12. Changes to this Privacy Policy

We may change this Privacy Policy to address changes in the legislation or on PURE. Changes to this Privacy Policy will take effect automatically after they are first posted on the Website or App.

13. Contact

If you would like to exercise any of your rights or if you have feedback, comments, or questions about data protection or this Privacy Policy please contact us by email at privacy@pure.app or by mail at alternatively provided postal address.

We also have a selected Data Protection Officer that can be contacted by email at dpo@pure.app.

Alternatively, you can write to:

PWM Technologies Limited
712 Tai Yau bldg 181 Johnston rd
Wanchai
Hong Kong

PURE’S PRIVACY POLICY