Privacy policy

At Agung Digital Ideas Limited, protecting your privacy is a priority.

When you use the mydevicefinder.online platform (the “Platform”) and as part of the management of our contractual relations with our customers, we may collect personal data about you.

The purpose of this policy is to inform you about how we process such data in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and Law No. 78-17 of 6 January 1978 on data processing, data files and individual liberties (together the “Data Protection Act”).

1. Who is the data controller?

In connection with your use of the Platform, the data controller is Agung Digital Ideas Limited (the “Company”), a private company limited by shares incorporated under the laws of Cyprus, registered number HE 413677, having its registered office at Karpathou 11A 2302 Nicosia, Cyprus (“We”).

2. What data do we collect?

Personal data is data that enables an individual to be identified directly or by cross-checking with other data.

We collect personal data in the following categories:

Identification data (surname, first name, email address);
Data relating to your use of the Platform (downloaded files);
Connection data (connection logs, encrypted passwords);
Browsing data (IP address, browser, date and time of connection, browser used, operating system);
Economic and financial data (data relating to your bank cards);

Mandatory data is indicated when you provide us with your details. They are indicated by any means.

3. How do we collect data?

We have collected your data because you have provided it to us directly (e.g. by creating an account on our Platform).

4. On what legal grounds, for what purposes and for how long do we keep your personal data?

Objectives	Legal basis	Shelf life
Provide the services available on our Platform via your account	Execution of pre-contractual measures taken at your request and/or performance of the contract that you or your company have entered into with Us	When you create an account: your data is kept for the duration of your account. Your connection logs are kept for 6 months or 1 year. If your account is inactive for 1 year, your personal data will be deleted if you do not reply to our reactivation email. In addition, your data may be archived for evidential purposes for a period of 5 years.
Carrying out operations relating to the management of our customers, including subscriptions and monitoring the contractual relationship with our customers	Performance of the contract you or your company have with Us	Personal data is kept for the duration of the contractual relationship. In addition, your data (with the exception of your bank details) is archived for evidential purposes for a period of 5 years. Your credit card details are stored by our payment service providers. Data relating to the visual cryptogram or CVV2, written on your bank card, is not stored.
Create a file of customers	Our legitimate interest in developing and promoting our business	Data is kept for the duration of the contractual relationship.
Send newsletters, requests and promotional messages by email	Our legitimate interest in building customer loyalty and informing our customers of our latest news	The data is kept for 3 years from your last contact with Us.
Responding to your requests for information	Our legitimate interest in responding to your requests	Data is kept for a period of 1 year from the date of your last contact.
Comply with the legal obligations applicable to our business	Comply with our legal and regulatory obligations	Invoices are archived for 10 years. Data relating to your transactions (with the exception of bank details) is kept for 5 years.
To compile statistics (on browsing, the Site’s audience, etc.) and improve the Site’s functionalities by depositing audience measurement cookies.	Your consent	The data is kept for 2 years.
Managing requests to exercise rights	Our legitimate interest in responding to your requests and keeping track of them	If we ask you for proof of identity: we only keep it for the time needed to verify your identity. Once verification has been completed, the proof of identity is deleted. Information used to manage your requests to exercise your rights under the GDPR will be kept for 3 years from the date of the request.

5. Who will receive your data?

We will have access to your personal data:

(i) The staff of our company;
(ii) Our subcontractors: hosting service provider, newsletter sending service provider, audience measurement and analysis service provider, e-mail service provider, secure payment service provider, invoicing tool, cookie management tool;
(iii) Where applicable: public and private bodies, exclusively to meet our legal obligations.

6. Is your data likely to be transferred outside the European Union?

Your data is kept and stored for the duration of processing on AWS servers located in the European Union.

As part of the tools we use (see article on recipients concerning our subcontractors), your data may be transferred outside the European Union. The transfer of your data in this context is secured using the following tools:

or the data is transferred to a country that has been the subject of an adequacy decision by the European Commission, in accordance with Article 45 of the GDPR: in this case, the country in question provides a level of protection deemed sufficient and adequate to the provisions of the GDPR;
or the data is transferred to a country whose level of data protection has not been recognised as adequate for the purposes of the GDPR: in this case, such transfers are based on appropriate safeguards as indicated in Article 46 of the GDPR, tailored to each service provider, including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism.
or the data is transferred on the basis of one of the appropriate guarantees described in Chapter V of the GDPR.

7. What rights do you have over your data?

You have the following rights with regard to your personal data:

Right to information: this is precisely why we have drawn up this policy. This right is set out in Articles 13 and 14 of the GDPR.
Right of access: you have the right to access all your personal data at any time, in accordance with Article 15 of the GDPR.
Right of rectification: you have the right to rectify inaccurate, incomplete or obsolete personal data at any time in accordance with Article 16 of the GDPR.
Right to limitation: you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
Right to erasure: you have the right to demand that your personal data be erased, and to prohibit any future collection on the grounds set out in Article 17 of the GDPR.
Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of the applicable texts, in accordance with Article 77 of the GDPR.
The right to set out instructions for the storage, deletion and communication of your personal data after your death.
Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR states that you may withdraw your consent at any time. This withdrawal will not call into question the lawfulness of the processing carried out prior to the withdrawal.
Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to request that it be transferred to the recipient of your choice.
Right to object: under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Please note, however, that we may continue to process your data despite this objection, for legitimate reasons or to defend legal claims.

You can exercise these rights by writing to us using the contact details below. We may ask you to provide us with additional information or documents to prove your identity.

8. What cookies do we use?

To find out more about how cookies are managed, please consult our Cookie Policy.

9. Contact point for exercising your rights

Contact email: contact@mydevicefinder.online

Contact address: Karpathou 11A 2302 Nicosia, Cyprus

10. Changes

We may modify this policy at any time, in particular in order to comply with any regulatory, legal, editorial or technical developments. These modifications will apply from the date on which the modified version comes into force. You are therefore invited to consult the latest version on a regular basis.

Nevertheless, we will keep you informed of any significant changes to this confidentiality policy.

Entry into force: 12/08/2024