Last modified: January 2024
I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE
Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:
Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.
If you don’t want us to process your personal information any more please contact us firstname.lastname@example.org In most cases there is no way to maintain the App’s further operating without functional data therefore you will be advised to remove the Apps from your device.
If you don’t want us to share device identifiers and geolocation data with service providers please check your device settings to opt out.
To submit a verifiable consumer request for access, portability or deletion of personal data please contact us email@example.com. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California”.
When submitting a verifiable request, you should be ready to:
We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.
We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.
We will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.
Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.
SALE OF DATA
We do not sell any of your personal data to third parties.
II. INFORMATION WE PROCESS
There are several categories of information that can be processed.
We ask for and process the following information when you use the Apps. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the Apps and perform the requested services.
Information That Is Processed Automatically
On the basis of your permission we use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our Apps (Identity For Advertisers). Some integrated advertising or analytics tools (check Section IV to see the list of them) launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically once you allow our Apps to track your activity. You can withdraw your permission at any time - please check opt-out options in Section VIII below.
We may process some information about your device and your user behavior on the ground of our legitimate interest. This information falls within categories of data described above in Subsection “Information That Is Processed Automatically”, it is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We use this information for improving our Apps and giving our users the best experience.
Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our Apps). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).
Our e-commerce provider (Apple/Google) is responsible for billing, processing and charging for in-app purchases, handles your personal information and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information.
You may access the applicable “in-app” purchase rules and policies directly from the app stores.
III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
Our mission is to constantly improve our Apps and provide you with new experiences. As part of this mission, we use your information for the following purposes:
(a) To make our service available. We use functional information and information that is processed automatically to provide you with all requested services.
(b) To improve, test and monitor the effectiveness of our Apps. We use information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our Apps.
(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
(d) To communicate with you. We use the contact information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our Apps experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
IV. SHARING OF YOUR INFORMATION
Please note that while integrating external services we choose third parties that can assure they apply all necessary technical and organizational measures to protect user personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.
We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the Apps. We do not control or influence these third parties’ tracking technologies or how they may be used.
We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.
We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:
Analytics service provider
Ad management/analytics service provider
Ad management/analytics service provider
Analytics service provider
Firebase (Google LLC)
User authentication, analytics and marketing service provider
AI-generated content provider
To learn more information about applicable license terms with respect to User Content, visit https://openai.com/terms/
Our Apps may contain links to third-party websites/services or you may access the Apps from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our Apps, including the information or content contained within them.
We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
V. INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide our Apps to our Users around the world.
We and third-party organizations that provide automatic data processing technologies for our Apps or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.
This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the Apps, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
VI. HOW LONG WE USE YOUR PERSONAL DATA
We generally retain your personal information for as long as is necessary for performing the functional service of the Apps and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.
VII. EXERCISING YOUR RIGHTS
Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:
To exercise any of the rights described above, you can contact us firstname.lastname@example.org, Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.
VIII. HOW TO OPT OUT
Opt-out of marketing tracking
You can manage your activity tracking permissions. Inter alia, if you do not want third-party service providers to use the personalized ads on the basis of your interests please follow the instructions below:
For Apple: Go to Settings > Privacy & Security (or “Privacy” in earlier versions of iOS) > Tracking, then tap to turn off or turn on permission to track for a specific apps. You can also control whether apps can ask for permission to track your activity. If you do not
want to be asked for your permission, or do not want apps to access your device’s Advertising Identifier, go to Settings > Privacy & Security (or “Privacy” in earlier versions of iOS) > Tracking and then disable the “Allow Apps to Request to Track” switch. If you turn off "Allow Apps to Request to Track", you will not get prompts from apps that want to track your activity. Each apps that asks for permission to track while this setting is turned off will be treated as if you tapped “Ask App Not to Track”. Please find additional information here: https://support.apple.com/en-us/HT212025 or in the Settings > Privacy & Security (or “Privacy” in earlier versions of iOS) > Tracking section on your device. If you want to disable Apple’s ad targeting, go to Settings > Privacy & Security (or “Privacy” in earlier versions of iOS) > Apple Advertising, then set the “Personalized Ads” switch to the “off” position. Please find additional information here: https://support.apple.com/en-us/HT202074
For Google: Go to Settings > Privacy > Ads, then you can choose either to “Reset advertising ID” or to ”Delete advertising ID”.
If you choose to “Reset advertising ID”, your current ID will be replaced with a new one. Apps can still show you personalized ads, but for a while they may not be as relevant or interesting to you.
If you choose to ”Delete advertising ID”, your advertising ID will be deleted and a new one will not be assigned. You won't see ads based on this advertising ID. Apps can still show you ads, but they may not be as relevant or interesting to you.
The relevant instructions for some older versions of Android and other additional information can be found here: https://policies.google.com/technologies/ads?hl=en-US (see subsection “Advertising identifiers for mobile apps”).
Please mind that when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
Opt-out of Location Data Processing
If you do not want third-party service providers to use your precise location data, or street-level location information about you please follow the instructions below:
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about the security of our Apps, you can contact us: email@example.com.
X. CHILDREN’S PRIVACY
Our Apps is not intended for children under the age of eighteen (18). Therefore, we do not knowingly collect or solicit any personal information from children under eighteen (18). If you have not reached the age of majority or legal age in your jurisdiction (i.e. if you are between the ages of thirteen (13) and seventeen (17) years), your use of the Apps is possible only with the relevant consent and under the supervision of the holder of parental responsibility for you. No one under the age of thirteen (13) may provide any personal information to the Apps. If we learn that we have collected personal information from a child under the age of eighteen (18) without verification of the holder of parental responsibility for a child, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under eighteen (18) and data processing is carried out without the relevant consent of the holder of parental responsibility for a child, please contact us firstname.lastname@example.org
XII. HOW TO CONTACT US
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