Privacy Policy

BeDry Bladder Diary Web and Mobile Application; BeDry website services

Effective date: February, 24, 2024

Be Dry Ltd. (“us”, “we”, or “our”) operates the BeDry Bladder Diary application (the “Application”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Application and the choices you have associated with that data.

We use your data to provide and improve the Application. By using the Application, you agree to the collection and use of information in accordance with this policy.

This document can be printed for reference by using the print command in the settings of any browser.

Types of Data collected

Google Analytics

Personal Data: Trackers; Usage Data
Data is collected when visiting the landing page

Upon registration

Personal Data: email address; date of birth (optional); first and last name (optional); gender (optional)

When creating a profile

Personal Profile Data: date of birth; first and last name; last name, gender, body weight

During the use of the application, we store the following data related to the created profile:

Date of the last use of the application
Urination: date, time and volume of urination, level of urge, whether urination occurred in a diaper or during the night, comments regarding the urination event
Drinking: date, time, and volume of drinking, comments regarding the drinking event
Display instruction preferences: whether the user wants to see user instructions when starting a diary or questionnaire
Preferred language of the application
Desired username used for receiving the shared reports

During registration for webinar or counseling

Personal Data: email address; first and last name

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Owner and Data Controller

Owner and Data Controller
- Budi suh d.o.o. (Be Dry Ltd.)
  Ul. hrastova 58a
  HR-10000 Zagreb
  Croatia
Owner contact email: support@bedry.app

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Our servers where all data is stored are located in the European Union.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

At any time, Users can edit and delete all data or request download of the Data through the user profile in the application or on the website or by contacting support.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside European Union and choose to provide information to us, please note that we transfer the data, including Personal Data, to the European Union and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. To find out more about the place of processing of such transferred Data, Users can request details about the processing of Personal Data.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics and Contacting the User.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics
- The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Upon registration
- Personal Data is used in our applications and on websites for sending non-marketing emails to manage the user account in the following cases: registration confirmation, forgotten password, change password, download user data, delete user data, account expiration, privacy policy or terms of use changes, similar content for managing your user account.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

We store your data for a maximum of ten years after the last use of the application with your user account. Once the retention period expires, User account and Personal Data shall be deleted. In case you wish to stop the data deletion, you will be notified in time. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period. At any time, you can edit, download, or delete all your data through your user profile in the application or on the website.

Further information about data access

We provide access to all the stored Data for the user account at any time. With the stored Data, User can do the following:

edit: at any time, User can edit all the Data stored for the account
download: User can download all the Data we have stored for the account by contacting the Application support email
delete: User can delete the user account and all related data

Further information on how to delete account and all related data

In User Account Settings choose Delete Account to delete the User account and all related data. Using this option, deleting the user account is irreversible. All settings, profiles, diaries, and reports made in this user account will be deleted. Shared reports will no longer be accessible to other users.

Detailed information on the protection of the User’s Data

User’s Data is stored in a secure database and is only accessible to a limited number of employees with special access rights to such systems. They are contractually obligated to maintain the confidentiality of data, and their access to data is logged and can be audited.

The transfer of data between the application and the server and between the server and the database is protected by Secure Socket Layer (SSL) technology, using certificates issued by the root certificate issuer.

The web servers located int the European Union are regularly updated with the latest security patches.

Is Data shared with the Third-parties?

We will never share, sell, trade, or otherwise transfer your Personal Data or the Data you have recorded. Within the Application, the User has the option to share data about a specific recorded profile with other Users of the application or unregistered individuals in the form of a report and content of the recorded diary. The User can withdraw consent for sharing at any time.

We use our owned email servers to send email messages to the Users to ensure that they are sent securely and reliably. We will explicitly ask you if you want to receive updated and marketing emails related to our business.

Non-personal, anonymous user data managed by the cookies may be provided to other parties for analytical purposes. These data are completely anonymous and cannot be linked to personal data, even in the event of a system breach because we simply never store data in a way that would allow such linking, not even with ourselves.

How does our website handle ‘Do Not Track’ signals? We respect ‘Do Not Track’ signals, do not track, and do not set third-party cookies when the ‘Do Not Track’ (DNT) mechanism is set in the browser.

Third-Party Links

We may occasionally share third-party products or services in our application or on our website. Third-party websites have a separate and independent privacy policy. Therefore, we do not assume any responsibility for the content and activities of these linked sites. However, we strive to protect the reputation of our website, and any feedback about these linked websites is welcome.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: February 24, 2024