Privacy Policy

This Privacy Policy sets out how we, Mirror 3D Lab, a limited liability company duly registered under the laws of the Republic of Cyprus, with Registration Number ΗΕ 395983 and registered office address at Alexandrou Papagou, 79, 8027, Paphos, Cyprus(the “Company”, “we,” “us,” or “our”), collect and process personal data of the users of the mobile application “Darefore” for the purpose of monitoring, correcting and analysing in real-time the body posture during a cycling ride. (“you”/ “your”).

This Privacy Policy includes all the information the Company must provide to you as “data subject” under the GDPR and applicable law, in relation to the collection, use and disclosure of your personal data by the Company for the purpose of using the “Darefore ” App by explaining:

    1. Who we are
    2. What personal data we collect about you
    3. How we Collect your personal data
    4. How we use your personal data
    5. How we store your personal data
    6. Who can access your personal data
    7. Retention periods
    8. Transfers to third countries
    9. Your rights
    10. Changes to Privacy Policy

This Privacy Policy applies only where and to the extent that the Company may be considered as “controller” in relation to the processing of your personal data under the provisions of Regulation (EU) 2016/679 (“GDPR”) and applicable law, including Law 125(I)/2018 and any relevant guidelines issued by the Office of the Commissioner for Personal Data Protection in Cyprus.

Please note that the Company has no control over and is not responsible for any third-party websites, plug-ins or applications which may be accessible through links from our application. Clicking on those links may allow third parties to collect or share data about you. Third party websites are responsible for providing their own privacy policies and notices which you will need to consider before you submit any personal data to such third-party websites.

By using our Darefore  App and providing your personal data to us, you agree to the processing of your personal data in accordance with this Privacy Policy.

  1.  

1. Who we are

Mirror 3D Lab is a Company offering services that include the development of mobile phone applications, research on innovation technologies, Virtual and Augmented Reality applications, digital assets for game development, 3D scanning and modeling. We are based in Paphos, Cyprus and our offices are situated at Alexandrou Papagou 79, 8027 Paphos, Cyprus.

We recognise and value the trust that individuals place in us when they provide us with their personal data, and we are committed to ensuring the confidentiality and protection of any personal data entrusted to us. All our partners, associates and employees are provided with the appropriate training for handling personal data securely and in accordance with the law. We also ensure that all business partners and external service providers we work with comply with their respective legal obligations and apply the same high standards when it comes to the protection of personal data and privacy.

2. What personal data we collect about you – User Privacy

We collect the following personal data that is necessary for the purpose of allowing you to create a user’s account and track your aerodynamic cycling posture in real-time through our Darefore App. These include: 

    1. Basic personal details such as your full name, gender and age
    2. Contact information such as email address, etc,
    3. Other personal details, such as height, weight, FTP (Functional Threshold Power) and LTHR (Lactate Threshold Heart Rate).
    4. Location data (with your consent), indicating the geographical position of your device, including data relating to:
        1. the latitude and longitude of your device;
        2. the time the location information was recorded

Background Location

  •  – Your background location data is captured during outdoor rides and is used to calculate the distance covered in a certain time period, and then calculate the speed. Using this information, the app can calculate the average speed for each different position held by the cyclist which is crucial for the app. To record the background location, you must give your consent in the relevant dialog that appears in the first use. If you choose to save the ride data, then the location information is also stored. If you choose to delete a saved ride, then all data including the recorded location information is deleted. While you use the app to record a long outdoor ride on the bicycle that may last for hours, you may close the app to save your phone battery and protect your screen. This is the reason the app accesses the background location.

We do NOT share any personal (including location data) or other user information with any third party.

We will process all your personal information lawfully, fairly, and in a transparent manner at all times.

We do not make any decisions concerning you based solely on automated decision-making processes or profiling.

3. How we collect your personal data

We collect or receive your personal data in the following ways: 

    1. Directly from you, when registering as a user of the Darefore App.
    2. By monitoring use of the Darefore and other third-party devices connected to the Darefore App.

4. How we use your personal data

We collect and process your personal data only for the purposes that we are permitted to do so by applicable law and in particular (depending on our relationship with you):

4.1. To Comply With Our Contractual Obligations Towards You: 

    • To allow you to create a user profile,

    • To monitor body posture during a cycling ride,

    • To track your aerodynamic cycling posture in real time,

    • To record all ride’s data, accessing the background location for outdoor rides

    • To provide you with ride records and statistics.

Your location is captured during the ride and used to estimate the distance covered and then calculate the speed. Using this information, we can analyse the average speed for each different position held by the cyclist which is crucial for our application. To record the background location, you must give your consent in the relevant dialog that appears in the first use. If you choose to save the ride data, then the location information is also stored. If you choose to delete a saved ride, then all data including the recorded location information, is deleted.

4.2. Pursuing A Legitimate Interest:

Generally, to receive payment for our services, to ensure the security and health of our staff and premises, to monitor the App to ensure a smooth and seamless operation and that any software issues will be resolved, etc.

4.3. Any Other Purpose Specified By You And/ Or With Your Consent:

Where your prior consent is required under applicable law, you will be presented with a relevant consent form in relation to any such use and you may withdraw your consent at any time.

You do not have an obligation to provide us with your personal data. If, however, you do not do so we may not be able to provide you with our services.

5. How we protect your personal data

We use third parties who provide Information Technology services to us which are relevant to the electronic storage of and access of your data to the extent this is necessary for the purpose of allowing us to provide our relevant services to you and generally to ensure that our legitimate interests are duly protected.

While we recognise that the storage and transmission of information, especially over the internet, cannot be guaranteed to be secure from intrusion by third parties, for the storage and security of your personal data the Company takes all the necessary physical, technical and organisational measures to protect personal data from unauthorised access, use, disclosure, alteration or destruction and to ensure that the processing is carried out in accordance with the law and the GDPR (access control, antivirus, firewalls, encryption, etc).

Information stored on our service providers’ servers is only accessed and used subject to strict security policies and standards agreed with them, to ensure the confidentiality of personal data.

6. Who can access your personal data

Within the Company, your personal data is accessible only to those who need to access it for the purposes specified in paragraph 4 above, with a duty of confidentiality.

Outside the Company, recipients of your personal data may include subcontractors, agents and third-party service providers, such as Information Technology and related service providers who provide technical services such as software development, installation and maintenance, cloud storage services, file backup, recovery and continuity, etc.

For the purposes of compliance with our legal or regulatory requirements, external recipients of your personal data may also include regulatory authorities or law enforcement agencies in connection with enquiries, proceedings, or investigations anywhere in the world.

We choose our associates and external service providers very carefully, after carrying out all necessary checks and obtaining sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of this GDPR and applicable law.

To the extent any other third parties are considered “controllers” under the GDPR any processing of your personal data carried out by them is not under our control and we are not responsible for and do not endorse or monitor their content or privacy policies (if any).

Your location information is stored on the servers of third-party cloud storage service providers in encrypted form.

7. Retention periods

We keep your personal data only for as long as necessary to fulfill the purposes for which it was collected or any other relevant permitted purpose (subject to legitimate interest or regulatory requirements), or-in the case of consent-until you withdraw your consent.

After this period, your personal data will be irreparably destroyed.

8. Transfers to third countries

If your personal data will be transferred to entities or other third parties whose headquarters or place of business is not located in the European Union (EU) or the European Economic Area (EEA), we ensure before forwarding the data, that outside of legally permitted exceptional cases pertaining to the recipient (reasons of public interest or recipient’s consent), an appropriate level of data protection exists (e.g. through an adequacy decision of the European Commission or through the use of Standard Contractual Clauses approved by the European Commission for these purposes, after due assessment of the law and the practice of the third country).

9. Your rights

In accordance with the GDPR and applicable data protection laws, you may have the following rights in relation to the personal data that we hold about you:

    1. Right of Access: the right to require further details from us on how we use your personal data and a copy of any personal information in our possession,
    2. Rectification: the right to require us to update or correct any personal data in our possession,
    3. Erasure: the right to require us to delete any personal data in our possession, subject to any legitimate interest of statutory obligations we may have,
    4. Restriction: the right to require us to restrict the processing of your personal data and limit the way we use it in certain circumstances and for a particular reason (such as contesting the accuracy of the information, the lawfulness of the purpose, etc),
    5. Right to Object: the right to object to any processing on grounds relating to your particular situation, unless we have legitimate grounds which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims,
    6. Withdrawal of Consent: Where processing is based on consent, you have the right to withdraw your consent so that we stop carrying out such processing.

You may exercise any of the above rights by contacting us by email at support@darefore.com.

If you wish to complain about the way we may have handled your personal information, you may contact us at the above email address and telephone number. We will examine your complaint and contact you to try and resolve the matter.

If you still feel that your personal information has not been handled appropriately according to the law, you can submit your complaint with the Office of the Commissioner for Personal Data Protection in Cyprus. 

10. Changes to Privacy Policy

We may change and update our Privacy Policy from time to time in the future. You are encouraged and advised to review it when you visit our website to stay informed of how we are collecting and using your personal data.

This Privacy Policy was last updated in December 2023. 

0
    Your Cart
    Your cart is emptyReturn to Shop