Introduction
This is the privacy policy of Etobico j.d.o.o. (“we”, “us” or “our”). We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our SPEEECHROUTE Delays mobile application (“App”) or visit www.speechroute.com (“our website”) and will tell you about your privacy rights and how the law protects you.

We are Etobico j.d.o.o., a company registered in Croatia, Zagreb with company number 83107192936. Through SPEECHROUTE Delays mobile application software (“App”), we provide the service of processing the audio signal of speech in order to enhance speech fluency for individuals who stutter.

Purpose of this privacy policy
Under data protection legislation, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data and how to exercise them. This information is provided in our Privacy Policy, and it is important that you read that information.
Our website and the App are not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller
Etobico j.d.o.o. is the controller of, and has responsibility for, personal data collected about you through our website and the App.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details
For further details please email us at: support@speechroute.com
If you are a data subject in the European Economic Area (“EEA”), you have the right to make a complaint at any time to your supervisory authority for data protection issues (in the United Kingdom (“UK”) this is the Information Commissioner’s Office (“ICO”) (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
Our website and the App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you
Personal data, or personal information, under UK and EU legislation, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We primarily use your data provided by app stores (e.g., Apple App Store, Google Play), but we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of purchases.
• Technical Data includes an internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and the App.
• Profile Data includes orders made by you, feedback and survey responses (you may provide to us what is considered to be Special Categories of Personal Data through certain surveys, as discussed below).  
• Profile Data includes orders made by you, feedback and survey responses (you may provide to us what is considered to be Special Categories of Personal Data through certain surveys, as discussed below).  
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered to be personal data in law as this data will not directly or indirectly reveal your identity. No single individual’s information can ever be seen because all personal data is made anonymous and aggregated with at least five other users of the App.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with access to the website and/or App). In this case, we may have to cancel your account with us, but we will notify you if this is the case at the time.

How is your personal data collected?
We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email or through the App.
• Automated technologies or interactions. As you interact with our website and App, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Technical Data, for example from analytics providers such as Google based outside the UK and EU.
  • Contact, Financial and Transaction Data from providers of technical and payment services such as Stripe, Inc. based outside the UK and EU.
  • Identity Data, Usage Data, and Contact Data from mobile application providers, such as Google and Apple.

How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you, for example to provide you with access details to the website and the App.
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (for example, to manage our records and to develop, and improve the appeal of, our website and the App).
• where we need to comply with a legal or regulatory obligation.

Please see the Glossary at the end of this privacy policy to find out more about the types of lawful basis that we will rely on to process your personal data.

Cookies
Our website and the App do not currently use cookies but may do in the future. If we do begin to use cookies we will bring this to your attention.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data
You agree that we have the right to share your personal information with selected third parties including:

• business partners, suppliers and sub-contractors, including data storage centres, for the performance of any contract we enter into with them or you; and
• analytics and search engine providers that assist us in the improvement and optimisation of our website and the App.

We will disclose your personal information (although we will disclose only the minimum amount of information necessary) to third parties:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• if Etobico j.d.o.o. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Etobico j.d.o.o., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please either use the functionality on the App (if applicable), or contact us using the details provided above. You can request an electronic copy of the information you have provided to us through the App or the deletion of your personal data by contacting us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Glossary
Lawful Basis:
“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.