When we discuss personal data or personal information, we mean any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
For the GDPR, we are the data controller, unless otherwise stated.
II. INFORMATION WE PROCESS
There are two general categories of information we can process.
1. Information that you submit
We process the following personal information about you when you utilize the App. We only take information as low as your user profile details to grant you access and tracking your in-app purchase information.
- Authorization and/or Account Information. When you sign up for an account, we require your email.
- Other information Directly related to your use of the App, such as photos and documents you upload to the App. Upon your consent, we also may have access to your camera roll.
2. Information That Is Processed Automatically
When you utilize the App, some information about your device and your user behaviour may be processed automatically. This information 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. That information access can be through OS, e.g., iOS or Android OS, or through the third party, you have given access to your phone permission. As a company, we do not ask for any of your personal information other than user details for granting application access. We do not store or hold any of your documents, do not read them or fetch them.
We use third-party libraries, which are GDPR compliant, and we only use them to support customer app related questions and issues.
Information related to your device. When you utilize a mobile device (tablet/phone) to access our App, we may monitor one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. Device identifier enables generalized reporting or personalized content and ads by the third parties. What data can be processed:
1. Type of your mobile device and operational system version which is installed on your mobile device;
2. Region information of your mobile device;
3. Region associated with your SIM card;
4. Internet Protocol (“IP”) address;
5. Identity For Advertisers / Advertising ID, a string of numbers and letters that identifies your individual smartphone or tablet.
- Log file information. Log file information is automatically reported each time you request to access the App. It can also be offered when the App is installed on your device. When you utilize our App, analytics tools automatically record certain log file information, including time and date, when you start and stop using the App, and how you interact with the App.The App may utilize automated processing of your personal data, comprising profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, particularly to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements. Processing information through automatic data processing technologies initiates automatically when you start using the App.
III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
Our mission is to improve our App and provide you with new experiences constantly. As part of this mission, we utilize your information for the below purposes:
- To make our service available. We utilize information that you submit and information that is processed automatically to provide you with all requested services.
- To improve, test, and monitor the effectiveness of our App. We use information that is processed automatically to understand user behavior and trends better, detect potential outages and technical issues, operate, protect, enhance, and optimize our App.
- To offer you with interest-based (behavioral) advertising or other targeted content. We may utilize information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We offer personalized content and information to you, including online ads or other forms of marketing.
- To communicate with you. We use the information we have to communicate with you through newsletters, i.e., to send you marketing notifications, receive your feedback about our App 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
We will not sell or rent your personal data to any third parties. Still, 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 App. We do not control or influence these third parties’ tracking technologies or how they may be used.
We may even 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 think or believe will be of most interest to you.
Our App may contain links to third-party websites/services, or you may access the App 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 App, comprising the information or content contained within them.
We may disclose your personal information if needed for objective reasons, due to the public interest or other unforeseen circumstances:
- as required by law;
- when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
V. INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide our App to our users around the world.
We and third-party organizations that offer automatic data processing technologies for the App 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 US 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 specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of personal data protection your country does.
We try to make sure that the recipient of any personal data provides proper protection of the personal data received in accordance with the current legislation on the protection of such information. Using the App, you agree that we may transfer your personal data to any third country, a territory or specified sectors within that third country, or the international organization.
VI. HOW LONG WE USE YOUR PERSONAL DATA
We generally retain your personal information for as long as it is necessary to perform the App’s functional service and comply with our legal obligations. If you no longer want us to utilize 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 the information is necessary to comply with a 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
For the personal data we store and access you are entitled to address us regarding the following issues:
- Data Access and Portability. You can request copies of your personal information held by us.
- Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask us to correct change, update or rectify your data.
- Data Retention and Deletion. We generally retain data for as long as your account is in existence or needed to provide the App’s services. However, specific retention times can vary based on the context of the processing we perform and on our legal obligations. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account at any time. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations or have a legitimate interest in doing so (e.g., to prevent fraud and abuse and maintain and enhance security).
- option “Opt-out of Ad Personalization” on your Android device in Settings/ Google/ Ads.To opt-out of interest-based advertising, you can also visit https://youradchoices.com.Please mind when you opt-out of certain interest-based advertising, you may still continue to get contextual ads based on other non-personal information, like ads related to the content of other digital products you are utilizing.
Opt-Out of the Location Data Processing
Certain third-party advertising partners may gather precise location data or street-level location information about you (“Precise Location Data”). Your mobile device may allow you to opt-out of Precise Location Data collection as further described below.
- iOS 11 or later: In order to disable the collection of Precise Location Data on iOS, you may turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services.” Then choose the applicable App and set the “Share My Location” status to “Never.” Please see additional information here: https://support.apple.com/en-us/HT203033.
- Android 5.0 or later: In order to disable the collection of Precise Location Data on Android, you may turn location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location.” Then turn off the “Location” button.
US regional patterns:
Residents of the State of California (USA) have the right to request a list of all third parties to whom our App disclosed certain personal information (following the laws of the State of California) in the previous year for the purposes of direct marketing of such third parties. If you are a resident of the State of California and want to receive such a list, please contact us through email or contact form displayed below. When submitting a request, please include in the text of your appeal the wording “Your rights to maintain confidentiality in the state of California,” as well as your name, address, city, state, and zip code. In the text of your request, please provide us with sufficient information so that we can determine if the above requirements of the law applicable to your situation.
If you are located in the European Union, you may address our representative when you have questions on privacy problems or issues:
Albina Gulevich Apolskaya
Office: 35, 205 Holland Park Avenue, W11 4XB, London
The security of your personal information is highly vital 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. Our servers are highly secured and are stored and protected on AWS located in the USA.
We implement appropriate technical and organizational measures, which are designed and shaped to implement data-protection principles, like data minimization, in a better manner, and to integrate the needed safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, comprising 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 and safeguard 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 swiftly notify you in compliance with applicable law.
If you have any questions about our App’s security, you can contact us through the email mentioned below.
IX. CHILDREN’S PRIVACY
Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verifying parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
XI. HOW TO CONTACT US