Effective as of September 10, 2021

When you use Woman app, we are responsible for maintaining and protecting your personal information with your permission. Our policy as a company is to take every step to ensure that individual user's data and privacy rights are protected. The primary purpose of our Privacy Policy is to provide a clear understanding of what data we collect, how it is used and shared, and how you can control it.

We recommend that you read this Privacy Policy in full along with our Terms of Use, but here are a few key takeaways we hope you will find useful:

The data that serves you
When you use Woman app, we may collect your Personal Data and use it to improve the user experience, such as increasing the accuracy of predictions, personalizing the insights you get, etc. For research activities we use only de-identified or aggregated data, which can not be associated with you.

You can contribute to the growth of Woman app
Provided we receive your consent, we may use technical information about you (your unique technical identifier, age group, subscription status, and the fact of application launch) for promotion purposes to reach more people like you. You can always withdraw your consent to share this data.

Your data is safe with us
Your employer, your insurance company, even your relatives-  none of them will ever know about the symptoms you log or the information you get in Woman app until you tell them. We take all reasonable and appropriate measures to protect your Personal Data from loss, theft, misuse or unauthorized access.

We protect the privacy of children
That is why you should be at least 13 to use Woman app. We do not intentionally collect information about children, and we do not allow people to use the App if they are younger than 13. 

You can freely talk to us
We believe in transparent and open dialogue, so we strongly encourage you to contact us via our dedicated email if you have questions about this policy, how we collect or process your Personal Data, or anything else related to our privacy practices.

Introduction

This Privacy Policy explains how Woman app collects, stores, uses, transfers and shares  Personal Data from our users (“you”) in connection with:

  • Woman app mobile application, 

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you through the App. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to accept changes to the Privacy Policy explicitly. Please review our Website and the App for the latest updates on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

Personal Data and information we collect from you

General Information. When you sign up to use the App, we may collect Personal Data about you such as:

  • Name;
  • Email address;
  • Gender;
  • Date of birth;
  • Password or passcode;
  • Place of residence and associated location information;
  • ID (for limited purposes).

Health and Well-being. When you use the App, you may choose to provide personal information about your health and well-being such as:

  • Menstrual cycle dates;
  • Various emotions related to your menstrual cycle and health;
  • Other information about your health (including sexual activities);

When you access or use the App, we may automatically collect the following information:

Device Information:

  • Hardware model;
  • Information about the operating system and its version;
  • Unique device identifiers (e.g. IDFA);
  • Mobile network information;
  • Device storage information.

Location Information:

  • IP address;
  • Time zone;
  • Information about your mobile service provider.

App usage data, including, among others:

  • Frequency of use;
  • Areas and features of our App you visit;
  • Your use patterns generally;

How we use your Personal Data

As any compliant organization we will not collect and use your Personal Data without letting you know or having any reasons for that whatsoever. So, for any purpose of processing your Personal data we need to have some valid ground, or so-called “legal basis”. 

Depending on a case, we will process your Personal data based on the following legal basis:

  • Your consent. Your permission to process the Personal Data that you provide to us on the registration screen or at any other appropriate moment if necessary; 
  • Your contractual relations with us. We may need to process some Personal Data for making the App and its services available for access, installation and further use;
  • Legitimate interest. We may process some of your personal data to pursue commercial interests and wider societal benefits;
  • Legal obligation. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.     

Principles of processing

Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate consent. 

No sale of Personal Data. We will never sell, rent, or disclose your Personal Data. We may share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this Privacy Policy.

Your privacy rights

It does not matter what country or region you come from. We are committed to providing you vast privacy rights for your Personal Data.

What rights?

Correction of Personal Data

If you believe that your Personal Data is inaccurate, you have a right to contact us and ask us to correct such Personal Data. 

Restriction of Processing

You also have a right to request that the processing of your Personal Data be restricted, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.

Information rights and access to your Personal Data 

The App gives you the ability to access Personal Data within the App. You have a right to request information about what Personal Data we have about you, to access all your Personal Data and receive a copy of it, including in a structured and portable form (.json). 

Erasure of your Personal Data

You may ask us to erase your  Personal Data, if you withdraw your consent to processing, if you believe such processing is not compliant with applicable law and in some other cases. Please be aware that erasing some Personal Data may affect your App experience. 

Right to object to the processing of your Personal Data

In some cases you can object to the processing of your Personal Data, for example, if we process it under legitimate interest basis by contacting us at hello@tooly.mn.

How to exercise your privacy rights

Сontact us at hello@tooly.mn to exercise any of your privacy rights. 

Retention of your Personal Data

When you use the App

We will retain your Personal Data as long as your account is active or needed to provide you Services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can erase your Personal Data in accordance with the Privacy Policy.

After you stop using the App

If you choose to delete the App or deactivate your account, or your account becomes inactive for a while, we will retain your Personal Data for a reasonable period in case you decide to re-activate the Services. 

You should be aware that we may retain certain Personal Data and other information after your account has been terminated or deleted as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If the user is under 18 years old

If you are under the age of 18, read this privacy policy with your parents or guardians and ask them if you have any questions. Parental consent is required when submitting personal information.