This mobile application is owned by Haltian Oy, registered at Yrttipellontie 1D3, 90230 Oulu, FINLAND (“Haltian”). The application is developed and released in collaboration with Proximi.io Proximity Platform, registered as Navture Apps Oy, registered office at Hämeentie 31, 00500 Helsinki, FINLAND (“Proximi.io”).

1. Acknowledgement: By using this mobile application, you enter into this Privacy policy and End User License Agreement with Haltian. The mobile application is aimed to be used in connection with the Haltian Empathic Building solution. The application is free to download and use also as a separate product.
2. Scope of License: You are granted a non-transferable license to use the Virtual Tag for EB mobile application on any compatible mobile device you own or control.
3. Data Processing and Privacy: The aim of the mobile application is to collect location data from your device to be used as a part of the Empathic Building solution. Location data may be collected through a combination of technologies, such as Bluetooth, GPS and WiFi information. Location data is also collected in the background, when the application is not in use. You may always enable and disable the application’s location collection for the Empathic Building solution by using the on/off toggle in the mobile application. The location data is not connected to your personal Empathic Building profile before you connect your mobile application to your profile in the Empathic Building portal by writing the Virtual Tag ID generated by the application in the matching field. The data processor in this mobile application and the Empathic Building solution is Haltian. Proximi.io is a sub-processor of the data. The following information is sent from the mobile application to Proximi.io cloud:
   • Coordinates (lat, long) and other location-related information
   • Device build information (model, brand, screen size, operation system version, operating system language etc.)
   • Information on application and SDK version
   • Virtual Tag ID and other user identifiers used in the system
   
   Any personally identifiable coordinate information is only used in Proximi.io server processing memory for maximum 1 hour. This information is not stored to Proximi.io database. The location data is transmitted securely from Proximi.io API to Haltian API. Proximi.io uses sub-processors for sending automatic push notifications and for collecting crash reports. The sub-processor in both components is Google. The data transferred to Google is contained to minimum, and only an installation-specific identifier is sent to Google in both cases. Google may undertake processing under any of their servers (also outside of EU), but all processing is happening under GDPR and Privacy Shield agreements By default, the Virtual Tag ID and other device identifiers endure the lifetime of the app installation. You can regenerate the IDs linked to their position data through a button in the mobile application whenever you want to. In case you ever want to stop using the service, you can uninstall the application. Haltian and Proximi.io will also comply with all GDPR and other legal requirements on end user access to data collected about them, right to modify data and right to have their data deleted. All such requests should be posed via Haltian.
4. Maintenance and Support: All maintenance and support for the application is provided by Haltian.
5. Warranty and product claims: When the mobile application is used on its own, separate from the Empathic Building solution, no warranties are given about its performance or functionality, apart from its conformity to any applicable legal or regulatory requirement. No compensation for claims, losses, liabilities, damages, costs or expenses attributable to any failure of the application is provided. When you use the mobile application as a part of the Empathic Building solution, the warranty agreed to in your Empathic Building agreement applies.
6. Intellectual Property Rights: Haltian and Proximi.io are the sole owners of any intellectual property rights connected to the mobile application and the use of the mobile application.
7. Legal Compliance: You must represent and warrant that you are not located in a country that is subject to a U.S. Government or European Union embargo, or that has been designated by the U.S. Government or European Union as a “terrorist supporting” country; and you are not listed on any U.S. Government or European Union list of prohibited or restricted parties.
8. Third Party Beneficiary: You acknowledge and agree that Google and their subsidiaries, are third party beneficiaries of the EULA, and that, upon the End-User’s acceptance of the terms and conditions of the EULA, they will have the right (and will be deemed to have accepted the right) to enforce the EULA against the End-User as a third party beneficiary thereof.
9. Contact Name and Address: questions, complaints or claims with respect to the Virtual Tag mobile application should be directed to Haltian, Yrttipellontie 1D3, 90230 Oulu, FINLAND, info@haltian.com.

Mobile application and indoor positioning provided by Proximi.io.
Empathic Building solution provided by Haltian
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