Last updated on 08/22/2023
The company Kwit, SAS with a capital of 50.010 €, registered in the Strasbourg Trade and Companies Register under number 819 528 597, having its registered office at 31, rue du Fossé des Treize, 67000 Strasbourg, France, represented by Mr. Geoffrey KRETZ, in his capacity as President (hereinafter "Kwit" or "we"), is committed to protect and respect your privacy when using its mobile applications ("Applications" or "the App" or "Sobero") and its website ("Site") https://sobero.app (collectively, the "Platform").
We have drafted this privacy policy (hereinafter the "Policy") to transparently inform you of how data that directly or indirectly identifies you (the "Personal Data") is processed by Kwit as a Data Controller.
1. Processing of your Personal Data:
We collect three categories of information:
• Information that you provide directly;
• Information we collect when you use the Platform;
• Information collected via cookies.
a. Information you provide directly:
• When using our Platform, you may be asked to provide information that is considered Personal Information.
• When you create your account with an email address, you provide us with your email address and a password so we can authenticate you and secure your data. We do not store this password, which is only used for account creation.
• When you register via our Applications, we ask you to tell us the gender with which you identify yourself, your year of birth, your goal (to quit or cut down), your former alcohol-related habits (behavior, quantity, type of alcohol and price), the goal you set for yourself, your level of readiness to change, your level of confidence in changing and the importance of changing and why you want to change to build your user profile, as well as the pseudonym with which we can address you.
• When you use our Applications, we save every activity you do and keep your content reading history. This data is kept because it is necessary to personalize your experience in the application.
• When corresponding with us, the data entered will be transmitted to us, such as the email address used, the content of the message, the technical identifier of your account, or any other data you may send us.
• When using a contact form on our Site, you provide us with a contact name, email and/or phone number to reach you, the company you represent, and the number of people employed by it, followed by a comment if you wish to send us a message.
We offer subscriptions on our Platform. When you make a payment on the Platform, we process your payment through third-party payment services such as app stores available on mobile platforms or Stripe through our Site. The service used may collect certain financial information required for compensation on behalf of Kwit, such as your name, email address, mailing address, and other billing information.
When you leave a review of Sobero through the app stores or directly through the Platform, we reserve the right to highlight it by displaying your nickname, review, and rating. Thank you for your feedback which helps us to improve our services.
b. Information we collect when you use the Platform:
When you use our Platform, we collect information about how you use it to keep the Platform running and to improve your experience constantly.
• When you create your account via Google, we collect the bare minimum necessary to authenticate you, which is an email address.
• When creating your account via Apple, we collect the bare minimum necessary to authenticate you, which is an email address. In this case, you can choose to use an anonymized address.
• When you register via our Applications, we store technical data about the device you use (model, operating system version, and preferred language setting). We also keep the installed application version and the account creation date. It is done to be able to elaborate technical statistics on the use of the Platform, to know in which language to correspond with you, and to help us troubleshoot you if necessary. The account then created is associated with a unique technical identifier. The authentication method (via email, Apple, or Google) is preserved for any possible troubleshooting of the user. Another unique technical identifier associated with the device used is stored to save the theme chosen by the user on that same device or to set your preference for push notifications for that device.
• In case of an app crash, a report is automatically sent to inform us of the bug that just occurred. This report gives us your unique technical ID, the device's technical information, and the software version used. This data helps us to reproduce and correct possible errors in the Platform's software.
• Each time you log on to the Platform, we update the technical data of the software and the device used. Each new session is recorded specifically for each user. It is done to compile technical statistics on the use of the Platform, to know in which language to correspond with you, and to help us troubleshoot if necessary.
c. Information collected via cookies:
During each use of the Platform, we may collect, by applicable law, information about the devices on which you use our Platform or the networks from which you access it. For example, your IP addresses, connection data, types and versions of Internet browsers used, operating systems, data concerning your navigation on the Site and our Applications, the content you access or consult, or the advertising identifier of your device to help us measure the effectiveness of our advertising campaigns. One of the ways we do this is by using cookies.
A cookie is a small text file recorded and/or read by your browser or application, stored in the cookie directory of your device's hard drive (PC, laptop, or smartphone), and deposited by the websites you visit. It contains a unique and anonymous identifier.
The cookies we use are :
• Authentication cookies that allow you to access your personalized content and exempt you from having to provide your login and password each time you connect to our Platform
• Security cookies that will manage the payment process on our Site.
• Analytics and performance cookies allow us to recognize and count the number of visitors to our Site and Apps and collect information about how they are used. These cookies also allow us to measure the effectiveness of our marketing efforts. It will enable us to improve how our Site and Apps function and, more generally, the content of our Services.
These cookies come from third-party services that we do not control. The Site uses Google Analytics to measure its audience. You can obtain more information on this subject by following this link: www.google.com/analytics. The use of Google Analytics cookies is subject to your consent and can be deactivated at any time on the Site itself and in your browser settings.
We also use third parties in our Applications, such as Firebase Authentication, to allow you to stay logged in without entering your login and password each session. Firebase Analytics and Amplitude are used to measure the use of the Applications and the effectiveness of our marketing efforts. Finally, we use SendinBlue to send you informational emails.
2. Purposes of processing your Personal Data
The processing of your Personal Data is justified for several purposes and has the following legal bases:
• The contract
• Legitimate interest
• Consent
• Legal obligation
a. Contract
The main reason why we may use your data is that without it, we would not be able to provide our services as described in our Terms of Use and, in particular, to allow you to self-monitor your alcohol consumption and to evaluate the evolution of this consumption and to manage, if necessary, the operations related to the management of payments.
b. Legitimate interest
Another important reason we need to process some of your information is that we seek to provide you with our services in the best possible way, to improve them continuously, to protect your Personal Data, to solve technical problems, to establish statistics, or to respond to your support requests.
c. Consent
In some cases, we ask for your consent before processing specific data.
For example, the processing of personal data that is carried out only after obtaining your consent (which can be withdrawn at any time) is as follows:
• On our Site, you choose whether or not to allow the use of analytics and performance cookies. You can change this choice in your browser and on the Site.
• In our Applications, we ask you if we can send you push notifications to keep you informed of your progress or new features.
• On the Platform, we ask you if we can use your email address to send you personalized offers and the Sobero newsletter.
• In our Applications, we ask you if we can use your data for scientific research purposes.
Each choice can be viewed and changed (subject to your right to opt-out) in the settings of the application, mobile device, browser, Site, or via a link in the emails sent.
d. Legal obligation
Finally, we may need to use your information to comply with the law, such as during a valid judicial requisition, when we need to take measures to protect our users, or to follow up on your request for access, rectification, and opposition rights or your other rights regarding your Personal Data.
3. Storage, protection, sharing, possible transfers of your Personal Data, and retention period
• Storage and protection
• Sharing
• Possible transfers of your data outside the European Union
• How long we keep your data
a. Storage and protection
As the protection of your information is of paramount importance to us, we require an adequate level of security according to the criteria of the GDPR for storing your data.
b. Sharing
Regarding sharing your data, it is straightforward: we do not share any of your Personal Data with anyone! Only authorized Kwit personnel will access your information only for support purposes or improve our Platform's services.
If you are using Sobero as part of a scientific study, only the person in charge will know your identity to preserve your anonymity. You will use to create your account an email address provided by the study manager, and we will not be able to identify you in any way. In this case, we may have to share this anonymous data with the study head so that the study can proceed as agreed, according to the conditions you will have accepted with this head.
c. Possible transfers of your data outside the European Union
Your Personal Data will not be transferred outside the European Union.
d. How long we keep your data
We keep your data only during the various applicable limitation periods.
Thus, we preserve your data as long as you use our Platform. If you stop using the Platform for 12 months, we will delete any information about you after that time, except for data strictly necessary to defend our rights during the statute of limitations for any action against Kwit.
At the same time, any information we may have anonymized may be preserved indefinitely.
Finally, cookies on your terminals are preserved for a maximum of 13 months.
We remind you that you have the right to request the modification and/or deletion of your information at any time for legitimate reasons. For more details on this subject, please refer to section 4. Your rights.
4. Your Rights
It is a priority for us that you keep control of your Personal Data. We want to remind you that you have the right to access, rectify, oppose, and define directives concerning the fate of your data after your death and delete your data, as well as the right to limit their processing and data portability.
To this end, a dedicated section in our Applications and on our Site allows you to modify your choices regarding the processing subject to your consent. A link is present in each email to enable you to unsubscribe from our newsletter. Finally, we respond to your data requests when you contact us by email at hello@sobero.app or by paper mail at the address: 31, rue du Fossé des Treize, 67000 Strasbourg, in France, addressed to Mr. Christophe DEHLINGER.
Finally, we remind you that if you consider, after having contacted us, that your rights on your data are not respected, you have the possibility of addressing a complaint in the event of failure with the applicable rules as regards the protection of the Personal Data, in front of authority of supervision such as the CNIL in France.
5. Children's privacy
Our services are designed for persons aged 15 years and older. Children under the age of digital majority in their country of residence must at least remain under the supervision and consent of their legal representatives. Otherwise, please do not attempt to use our Platform or Services.
If you believe that we may have processed information from minors, please notify us at hello@sobero.app so we can remove it.
6. Changes to the Privacy Policy
We may change this Privacy Policy at any time. When we do, we will notify you by email or directly through our Applications. Any changes will be effective immediately upon posting. The date of posting will be updated at the top of this Policy.
7. Any questions?
If you have any questions about this Policy, we are happy to answer any requests at hello@sobero.app.