Updated: 05 September 2022
2. Collection of your personal information and how we use it
2.1 You may find below the personal data categories and the purposes of such collection and (or) processing which we arrange.
|the purpose we process your personal data||categories of personal data we use||legal basis for the processing||the term of storage|
|to provide you with access to our application||
- google account ® data
- automatically collected data as:
- access to camera, microphone
- device or apps history
- wi-fi connection
- storage data
|safety and security||- google account ® data||legitimate interest||as long as our application is installed on your devices|
- google account ® data
- automatically collected data
|communications on our behalf||
- google account ® data
- user’s details (email address, name, surname, etc.)
|marketing||- automatically collected data||legitimate interest||as long as our application is installed on your devices|
|compliance with legal obligations||- automatically collected data||legitimate interest||as long as our application is installed on your devices|
|research and development||- automatically collected data||legitimate interest||as long as our application is installed on your devices|
2.2 Please note, as you obtain the access to the App by your Google Account, your personal data can be collected by Google, to read more please follow the link
2.3 We neither keep, nor store these types of data for our servers.
2.4 We need your consent to provide you with further access to our Application. Also, we want to ensure safe work of the Application and to be compliant with law. We won’t collect or process your Personal Data until obtaining your consent. Your consent may not always mean your specific actions. If you continue to use our Application, you are deemed to have agreed to the terms and conditions specified in this Policy.
3. Legal basis for use of your personal information
3.1.1 our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Service of our App); or
3.1.2 you have provided us with your consent to do so. This applies in relation to the advertising and marketing materials delivered via our apps that are tailored to you and your preferences. You can control and withdraw your consent at any time .
3.1.3 where 3.1.1. or 3.1.2. does not apply, our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
run, grow and develop our business including funding our business by use of advertising revenues;
3.1.4 - operate, maintain and improve our App and our marketing optimisation efforts;
3.1.5 If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details.
4. How and why we share your personal information with others
Third party advertising
4.1 We want to make sure that our advertising and marketing is relevant and interesting to you and our other customers. To achieve this, we use third-party advertising and technology companies to serve advertising and/or provide aggregated data to assist in serving advertising when you visit or use our App. This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our App.
4.2 The third party advertising companies may collect, store and use data by integrating cookies and other tracking software on our App. The relevant data collected by these third parties may include:
4.2.1 (a) data about your device, location and use of our App, including IP address, a unique device ID, geo-location details and your User ID that we have assigned to you;
4.2.2 (b) data which you provide to us when using our App, including information on your interaction with advertising and certain technical information.
4.3 These third party advertising companies may collect and use your data to provide you with targeted advertising that is relevant to you and your preferences with your consent. You can control and withdraw your consent to this targeted advertising at any time on our App by deleting it from your device. If you do not provide or withdraw your consent to receive targeted advertising that is relevant to you and your preferences, then we will still serve you advertising when you visit or use our App but this will no longer be tailored to you or your preferences.
4.4 In some cases these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
Other third parties
4.5 We may share your personal information with the following third parties or categories of third parties:
4.5.1 the OS providers of your device, or the providers of the platform from which you downloaded our App(s), in order to verify purchases you make and provide in-app purchase opportunities.
4.6 We may share your personal information with our group apps where it is in our legitimate interests to do so:
4.6.1 to enable them to provide customer support to you; or
4.6.2 for internal administrative and management purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
4.7 We may also disclose your personal information to third parties:
4.7.1 where it is in our legitimate interests to do so to run, grow and develop our business:
4.7.2 if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
4.7.3 in order to establish, exercise, enforce, or defend our terms of service or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
4.7.4 to protect our rights, property, or safety, our staff, our users or other persons.
4.8 We may also disclose and use anonymised, aggregated reporting and statistics about users of our App for the purpose of internal reporting or other reporting purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
4.9 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
5. How long we store your personal information
5.1 We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
6. Your rights
6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [email protected] at any time. You have the following rights:
6.1.1 Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area ("EEA").
6.1.2 Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
6.1.3 Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us.
6.2 We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details in section 10.
6.2.1 Right to restrict use of your information. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us.
6.3 We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.
6.3.1 Right to data portability. You have a right to ask us to provide your personal information to a third party provider of services.
6.4 This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
6.4.1 Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
6.5 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
6.6 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
7.1 You must be aged 16 or over to use our App and/or to purchase services through it. Our App is not directed to children younger than this and we do not knowingly collect any personal information from children younger than this.
7.2 If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our App, or from any other source, then we will delete that information as soon as possible.
7.3 Please contact us at [email protected] if you are aware that we may have inadvertently collected personal information from a child below the age of 16.
8. Your Rights under the CCPA
8.1.1 The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
8.1.2 The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
8.1.3 The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. We do not sell your Personal data but you have the rights to obtain an additional confirmation of this to your direct request.
8.1.4 The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
18.104.22.168 The categories of Personal Data collected
22.214.171.124 The sources from which the Personal Data was collected
126.96.36.199 The business or commercial purpose for collecting or selling the Personal Data
188.8.131.52 Categories of third parties with whom We share Personal Data
184.108.40.206 The specific pieces of Personal Data we collected about You (if any)
8.1.5 The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
8.1.6 The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
220.127.116.11 Denying goods or services to You
18.104.22.168 Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
22.214.171.124 Providing a different level or quality of goods or services to You
126.96.36.199 Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
8.2 Exercising Your CCPA Data Protection Rights
8.2.1 In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email us.
8.2.2 We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
8.3 Do Not Sell Your Personal Information
8.3.1 We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.
8.3.2 If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by deleting the App from your device.
8.4 Your California Privacy Rights (California Business and Professions Code Section 22581)
8.4.1 California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
8.4.2 To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
8.4.3 Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
9. Risks and how we keep your personal information secure
9.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.
9.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organizational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our App. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.
9.3 Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our App or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.
11. Further questions and how to make a complaint
11.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact us at [email protected]. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.