Privacy Policy

We believe you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. The types of information we collect depends on how you use our Products. We want to empower you to make the best decisions about the information that you share with us.

That’s the basic purpose of this Privacy Policy.

You should read this policy in full, but here are a few key things we hope you take away from it:

Massira is public and Post anonymous or not are immediately viewable and searchable by anyone around the world. You can also use Massira under a pseudonym if you prefer not to use your name.

When you use Massira, even if you’re just looking at Post, we receive some personal information from you like the type of device you’re using and your IP address. You can choose to share additional information with us like your email address, phone number, and a public profile. We use this information for things like keeping your account secure and showing you more relevant Posts, Categories you will be interested in, health practitioners, events, and ads.

You can also always contact us at [email protected] to get the information you have shared on Massira.

In addition to the information you share with us, we use your Massira, content you’ve read, Liked, shared or Comment, and other information to determine what topics you’re interested in, your age, the languages you speak, and other signals to show you more relevant content and improve the app to make sure you have the best experience. We give you transparency into that information, and you can modify or correct it at any time.

We protect the privacy of children, that is why you should be at least 18 to use Massira (16 for EU residents). We do not intentionally collect information about children, and we don’t allow people to use the App if they are younger than 18 (16 for EU residents). Moreover, some of the App functions may be limited to users that are younger than 18.

If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you. You can contact us at any time.

Information You Share With Us

We require certain information to provide our services to you. For example, you must have an account in order to upload or share content on Massira. When you choose to share the information below with us, we collect and use it to operate our services

Basic Account Information

You don’t have to create an account to use some of our service features, such as searching and viewing public Massira profiles or Post. If you do choose to create an account, you must provide us with some personal data so that we can provide our services to you. On Massira this includes a display name (for example, “Massira Official”), a username (for example, @MassiraOfficial), a password, and an email address or phone number. Your display name and username are always public, but you can use either your real name or a pseudonym, even anonymous name. You can also create and manage multiple Twitter accounts, for example to express different parts of your identity.
Permitting us to access third party information can help you to maximize your App experience, and we will handle any such third-party information in full accordance with this Privacy Policy.

Information We Collect Automatically

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

  • Device Information: We collect information about the mobile device you use to access the App, including the hardware model, information about operating system and its version, unique device identifiers and mobile network information.
  • Location Information: We collect your IP address, time zone, and information about your mobile service provider, which allows us to infer your general location.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information about your use of the App, such as frequency of use, which areas and features of our App you visit and your use patterns generally, engagement tracking with particular features, etc. To collect this information, we may send cookies to your mobile device or computer. Cookies are small data files stored on your hard drive or in device memory. See more in our Cookie Policy.

We may use third-party tools like Appsflyer that provide us some of your attribution data that we further utilize to customize and personalize the App for you. We may also use such data for statistical purposes and analytics.
If the information covered by this Section is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as “Personal Data”. We use pseudonymization for particular types of Personal Data. Please bear in mind that provisions of Section 3 do not apply to pseudonymized Personal Data.

Your Consent

By creating a profile in the App, you explicitly consent that:

  • WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.
  • PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT CREATION PROCESS INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA (E.G. YOUR NAME AND EMAIL ADDRESS), AND YOUR HEALTH DATA (E.G. BODY MEASUREMENTS, PHYSICAL ACTIVITY AND OTHERS). DEPENDING ON THE DATA YOU PROVIDE, IT MAY ALSO CONTAIN INFORMATION ABOUT YOUR GENERAL HEALTH (E.G. WEIGHT, BODY TEMPERATURE, AND OTHERS).
  • WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES UNLESS OTHERWISE IS PROVIDED BY THIS PRIVACY POLICY.

PLEASE NOTE THAT WE WILL NEVER SHARE YOUR EXACT AGE OR ANY DATA RELATED TO YOUR HEALTH WITH ANY THIRD PARTIES.

How We Use Your Personal Data and Information

We may use your information, including your Personal Data, for the following purposes

  • to analyze, operate, maintain and improve the App, to add new features and services to the App;
  • to customize the content you see when you use the App
  • to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;
  • to customize product and service offerings and recommendations to you, including third-party products and offerings (except data from Apple HealthKit and Google Fit);
  • to verify your identity;
  • to send you technical notices, updates, security alerts and support and administrative messages;
  • for billing (invoicing), account management and other administrative purposes, if applies;
  • to respond to your comments, questions and requests and provide customer service;
  • to monitor and analyze trends, usage and activities in connection with our App;
  • solely with respect to information that you mark for sharing, for Company promotional purposes (except data from Apple HealthKit and Google Fit);
  • to link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in training of neural networks, artificial intelligence, as well as for any other automated decision-making processing);
  • for scientific and academic research purposes; and
  • for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

We will not use the information gained through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.

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 in accordance with Section 2 of this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy (“data minimization principle”).

Your Rights

Modification, correction and erasure You are able to modify, correct, erase, and update your Personal Data by writing us at [email protected]

Access

You have a right to access your Personal Data you insert into the App and ask us about what kind of Personal Data we have about you. You can do this by using the app settings or by writing us at [email protected]

EU Residents

Individuals residing in the countries of the European Union have certain statutory rights in relation to their personal data introduced by the General Data Protection Regulation (the “GDPR”). Subject to any exemptions provided by law, you may have the right to request access to Personal data (including in a structured and portable form), as well as to seek to update, delete or correct Personal data:

  • Rectification of Personal Data and Restriction of Processing. You are responsible for ensuring the accuracy of your Personal Data that you submit to Massira. Inaccurate information will affect your experience when using the Massira Web Sites and tools and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have the right to contact us and ask us to correct such Personal Data by contacting us at [email protected] You shall also have the right to request restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.
  • Access to your Personal Data and Data Portability. The App gives you the ability to access and update Personal Data within the App and your account settings. You shall have the right to request information about whether we have any Personal Data about you, to access your Personal data (including in a structured and portable form) by simply writing us at [email protected]
  • Erasure of your Personal Data. If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your Personal Data, or in cases where the processing of your Personal Data does not otherwise comply with the GDPR, you have the right to contact us and ask us to erase such Personal Data as described above. You can simply write us at [email protected] Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.
  • Right to object processing of your Personal Data. You can object processing your Personal Data and stop us from processing your Personal data, simply write us at [email protected] Please be aware that erasing some Personal Data inserted by you may affect your possibility to use the App and its features.
  • Notice about automated decision-making. We use automated decision-making tools (e.g. neural networks) that process your Personal Data in order to provide you proper Services (for example, predictions of your cycle). Normally, such automated decision-making works more precisely, if you insert more Personal Data about your cycle, symptoms, physical activities that our neural networks can work with. Our neural networks process this information in order to track particular dependencies and correlations in your cycles and symptoms and provide you more personalized information about your cycle and its predictions.
  • Notification requirements. We commit to notify you within a reasonable period of time and your data protection authority within the timeframe specified in applicable law (72 hours) about any personal data breaches in the App.
  • Data Protection Authorities. Subject to GDPR, you also have the right to (i) restrict our use of Personal Data and (ii) lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with GDPR.

Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights described in this section are exercised by an actual Personal Data subject or an authorized person.

Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems – this is due to the size and complexity of the systems we use to store data.

Retention of Your Personal Data

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 the purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can remove your Personal Data as specified in Section 3 of this Privacy Policy.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

If you choose to delete the App, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze

Personal Data You Direct to Share with Third-Party

You can direct us to share data from the App with other parties. For example, you can permit us to share data with other health apps and services like Google Fit and Apple HealthKit. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings.

We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern the processing of your Personal Data. For example, for the EU residents’ Personal Data we make reasonable efforts to ensure that such third parties are GDPR compliant and have GDPR compliant privacy policies in place.

Security

We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:

  • Pseudonymization and tokenization of certain categories of your Personal Data;
  • Encryption of your Personal Data in transit and in rest;
  • Systematic vulnerability scanning and penetration testing;
  • Protection of data integrity;
  • Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosure, unauthorized access, alteration, destruction, misuses of your Personal Data.
  • Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake privacy audit in case of Company’s merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in this Privacy Policy.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Children’s Privacy

General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 18 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 18. If you are aware of anyone under 18 using the App, please contact us at [email protected] and we will take required steps to delete such information and (or) delete her account.

Age limitation for EU residents. Due to the requirements of the GDPR you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow the use of the App by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at [email protected] and we will take steps to delete such information and (or) delete her account.
Courses. You must be at least 18 years old to use the Courses

Third Party Links

Although the App may contain links to third party websites or services, we are not responsible for the privacy policies and/or practices on those third-party websites or services. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service.

Privacy of Payments

To process payments for particular features and functions of the App we may engage third-party payment providers.

For example, we use Apple and Google for processing of payments in connection with our subscriptions offered on App Store and Google Play. Please note that we never collect and we are not responsible for the collection or security of banking, financial, and payment information. Such information is processed and stored by Apple and Google only. These companies can be contacted through their websites: Apple and Google

To process the payments in Courses we utilize Stripe, a payments platform provided by Stripe, Inc. We may share your user ID with Stripe in order to track the payment status – whether or not your purchases were completed. We do not see or collect any financial or banking data when it is being submitted to Stripe to complete the payment, and we do not have any control over the use of this information. Any use of that information is governed by your agreement with Stripe and subject to Stripe’s Privacy Policy.

Email Communications

We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so, certain exclusions may apply to the residents of some countries regarding an active opt-in for any email communications from us. We may ask such users to provide their consent for any such communications at the registration screen

countries regarding an active opt-in for any email communications from us. We may ask such users to provide their consent for any such communications at the registration screen

In such communications, we may also use surveys to receive your answers and feedback on various topics. Such information given by you via such surveys is processed by us for the purposes set forth in this Privacy Policy.

In order to provide communication services, we engage third-party service providers to carry out such newsletter services, surveys or notifications campaigns. Currently, we engage the following third-party services: SendGrid. SendGrid is an email automation platform provided by SendGrid, Inc (USA). We use SendGrid to reach more of our users with our newsletters, surveys and notifications. We may transfer your email address and some personalized texts to SendGrid. SendGrid will never use your email address and personalized texts except sending our messages and notices to you. We store your email addresses and personalized texts via SendGrid and you can request us to delete them from SendGrid platform in accordance with Section 3 of this Privacy Policy. SurveyMonkey. SurveyMonkey is an online survey software provided by SurveyMonkey Inc. (USA). SurveyMonkey surveys may be incorporated in messages that you receive from us. In accordance with our instructions SurveyMonkey collects the answers of the surveys and transfers them back to us together with your IP address. Use of such service allows us to understand your needs better and receive your feedback about Massira. You can always request us to delete your answers and IP from SurveyMonkey platform in accordance with Section 3 of this Privacy Policy. You can find the privacy policies of these services on their websites. These companies are compliant with the EU-US Privacy Shield Framework that ensures that European data privacy requirements are met.

International Personal Data Transfers

General. The Company is based in the United States and the information we collect is governed by U.S. law. Please be advised that U.S. law and laws of other countries may not offer the same protections as the law of your jurisdiction.

In addition, you agree that information collected through the App may be stored and processed in Canada, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of information outside of your country.

EU and Swiss residents. Please bear in mind that we may transfer your Personal Data to the United States which data protection is not deemed adequate under applicable data protection law.

However, we comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles (the “Principles”), the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit privacyshield.gov.

Complaints and Dispute Resolution. In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at [email protected] or mailing address:

Massira Technologies Ltd
19 Banana St, Accra, Ghana

We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the following link for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Arbitration. You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident. The arbitration option may not be invoked if the individual’s same claimed violation of the Principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which the individual was a party; or (3) was previously settled by the parties.

U.S. Federal Trade Commission Enforcement. Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Data Protection Officer

To communicate with our Data Protection Officer, please email at [email protected]..

Contact Us

If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at:

Massira Technologies Ltd

19 Banana St, Accra, Ghana Email: [email protected]

Effective: Dec 25, 2020