Athena App House

Privacy Policy

Last Updated: Sept 11, 2024

Introduction

Welcome to Athena App House (“we,” “our,” or “us”). At Athena App House, we respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website and use our applications, including Shwe Network, and tell you about your privacy rights and how the law protects you.

1. Important Information and Who We Are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how Athena App House collects and processes your personal data through your use of our websites and mobile applications.

Data Controller

Athena App House Company Limited is the data controller and responsible for your personal data. 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

  • Full name of legal entity: Athena App House Company Limited
  • Email: athenaapphouse@gmail.com
  • Phone: +95 9 366 2620 83
  • Address: 729, Myint Mo Street, 26 Quarter,
    Dagon (North) Township, Yangon, Myanmar. ( 11421 )

2. The Data We Collect About You

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, date of birth.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, 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 websites and applications.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and applications.
  • Location Data includes your current location disclosed by GPS technology when you use location-enabled services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

3. How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Create an account on our applications;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us feedback or contact us.

Automated technologies or interactions

As you interact with our website and applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks, and search information providers.

4. 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; 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; and where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We use your personal data for several purposes. We collect and process Identity and Contact data to register you as a new customer, which is necessary for performing our contract with you. When processing and delivering your orders, we may use your Identity, Contact, Financial, Transaction, and Marketing and Communications data, both to perform our contract with you and for our legitimate business interests. To manage our relationship with you, we process your Identity, Contact, Profile, and Marketing and Communications data, which helps us perform our contract with you, comply with legal obligations, and serve our legitimate interests. We enable app features by processing your Identity, Contact, Profile, Usage, and Location data, based on our contract with you and our legitimate interests. For business administration and protection, we use your Identity, Contact, and Technical data to serve our legitimate interests and comply with legal obligations. To deliver relevant content and advertisements, we process your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical data, which serves our legitimate interests. Finally, we analyze Technical and Usage data to improve our website, products, services, marketing, customer relationships, and experiences, which is necessary for our legitimate interests.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Myanmar government agencies and regulators who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

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.

6. International Transfers

Some of our external third parties may be based outside Myanmar, so their processing of your personal data will involve a transfer of data outside the country. Whenever we transfer your personal data out of Myanmar, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Myanmar.

7. 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.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill 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 unauthorized 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,