Effective Date: [11/25/2019]

GDPR Privacy Statement

Introduction

Best Apps, LLC. (“Best Apps,” “we,” “us,” or “our”), owner and operator of GFX and ShirtApp conducts business and collects Personal Data(as defined below) from individuals located within the European Economic Area (“EEA”). This Privacy Statement explains how Best Apps uses the Personal Data that we collect from individuals located within the EEA (“EEA Individuals,” “you,” or “your”) in accordance with the General Data Protection Regulation 2016/679 (the “GDPR”), and implementing legislation. Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Policy or, if not defined herein or in the Privacy Policy, the GDPR. To the extent of any conflict between this Notice and the rest of our Privacy Policy, this Notice shall control only with respect to EEA Individuals and their Personal Data, and to the extent of such conflict.  Please see our Privacy Policy [here]. 

Data Controller

[Best Apps, LLC] is the controller of Personal Data collected regarding EEA Individuals through the Websites, Apps, or the Services. This Notice describes our general privacy and security practices in connection with your Personal Data. For our contact information, see the section in our general Privacy Statement headed “Contact Us”.

Personal Data

The term “Personal Data” as used in this Privacy Statement means any data relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data,   an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Purpose of Processing 

Personal Data may be gathered through a visitor’s use of our Website, Apps, and Services (1) voluntarily by the visitors for the purposes of purchasing our products, or (2) through our use of cookie, web beacons, and other such technologies. 

Best Apps will process EEA Individuals’ Personal Data for the following purposes: 

• To provide user personalization and more relevant features or content;
• To maintain standards in conformance with our Terms of Use;
• To process, fulfill and manufacture your order, including sharing with third parties for these purposes;
• For fraud detection and prevention;
• To respond to customer inquiries and provide support;
• To understand and improve the user experience through leveraging of analytics and metrics;
• Direct marketing (e.g., special offers, deals, sweepstakes, etc.) that may be of interest to you, such as through our newsletter and advertisements (including advertisements from third parties);
• To comply with applicable law and enforce our rights (e.g., intellectual property rights, prevent suspicious or potentially illicit activities, enforce our Privacy Policy or Terms and Conditions); and
• As otherwise described or expanded upon within this Notice (and, to the extent not conflicting, our Privacy Policy) or at the time of collection.

Cookies, web beacons, and other technologies refer to small amounts of data, which may include a unique identifier, which are sent to your browser from a website and stored on your device. Read more about how we use cookies in our Cookie Policy.

Legal Basis of Processing 

Best Apps’ legal basis for processing an EEA Individual’s Personal Data will depend on the context in which we collect such data and our relationship with such EEA Individual. Primarily, Best Apps processes EEA Individuals’ Personal Data (1) as necessary for the performance of a contract to which such EEA Individual is a party or in order to take steps at the request of such EEA Individual prior to entering into a contract (e.g., providing our services, fraud detection and prevention), (2) pursuant to Best Apps’ legitimate interest in certain processing activities, which Best Apps has determined are not overridden by the interests and fundamental rights and freedoms of EEA Individuals given such EEA Individuals’ relationship with, and expectations of, an e-commerce platform (e.g., customer support, more relevant content and marketing), (3) where Best Apps has your consent (which may be withdrawn at any time), and (4) as needed for compliance with applicable law.

Categories of Personal Data

 We process the following data when provided voluntarily by our website visitors: 

• First Name
• Last Name
• Email Address
• Photographs
• Location
• Unique Device Identifier
• Telephone Number

We also process automatically-gathered Personal Data as described in the [Insert link to BEST APPS' GFX PRIVACY POLICY FOR GFX AND SHIRTAPP].

Recipients of Your Personal Data

We may use various service providers to assist in managing our website, communications, marketing and analytics, these service providers may change from time to time.  Note that our service providers have entered into contracts with us that restrict what they can do with your Personal Data. If you would like specific information about our service providers who have received your Personal Data, please contact us at [privacy@best.gd] and we will provide that information to you.

Information Regarding the Transfers of Personal Data Outside of the European Economic Area (EEA)

Best Apps is headquartered in the USA, which is where we process and store Personal Data collected through our Services. We safeguard your Personal Data by treating it in accordance with this GDPR Privacy Notice.  We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Data. 

Your Rights to Access, Correct, Restrict or Delete Your Personal Data and Object to Processing

You have the right to request access to your Personal Data, to have your Personal Data corrected, restricted or deleted, and to object to our processing of your Personal Data.  You also have the right of data portability, which means that you can request that we provide you (or a third party you designate) with a transferable copy of Personal Data that you have provided to us.  Your rights may be subject to various limitations under the GDPR.  If you wish to exercise any of these rights, or if you have any concerns about our processing of your Personal Data, please contact us in any of the ways listed in the section “How to Contact Us” in our general Privacy Notice. 

The Right to Lodge a Complaint with a Supervisory Authority

You have the right to file a complaint concerning our processing of your Personal Data with your national data protection authority. The EU Commission has a list here:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Data Storage

Best Apps stores EEA Individuals’ Personal Data outside the EEA, including within the USA. 

Fees

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Statement. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Updates to This Privacy Policy 

We may change this Privacy Policy. The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Websites, Apps, and the Services, as applicable. Your use of the Websites, Apps, or the Services, as applicable, following these changes means that you accept the revised Privacy Policy

Contact Us

If you have any questions about your Personal Data or this policy, or if you would like to make a complaint about how Best Apps processes your Personal Data, please contact Best Apps by email at privacy@best.gd