Last modified: February, 2019
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.
II. INFORMATION WE PROCESS
There are two general categories of information we can process.
II.1 Information that you submit
We process the following personal information about you when you use the App. 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 App and perform the requested services.
- 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.
II.2 Information That Is Processed Automatically
When you use 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. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all the requested services and features of the App.
We use third-party automatic data processing technologies to analyze certain information sent by your device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties process your personal data, that might be collected by their own means (not through our App). Due to the fact that some of our third parties (such as MoPub) declare themselves controllers for the purposes of the GDPR, any information request regarding your personal data should be directed to such third parties.
- Information related to your device. When you use a mobile device (tablet / phone / smartwatch) 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:
- type of your mobile device and operational system version which is installed on your mobile device;
- region information of your mobile device;
- region associated with your SIM card;
- Internet Protocol (“IP”) address;
- Identity For Advertisers / Advertising ID which is 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 make a request to access the App. It can also be provided when the App is installed on your device. When you use 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 use 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. Processing information through automatic data processing technologies starts automatically when you start using the App.
III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
Our mission is to constantly improve our App 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 information that you submit and information that is processed automatically to provide you with all requested services.
(b) To improve, test and monitor the effectiveness of our App. 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 App.
(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 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 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 App. 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 parties in order to provide us with necessary infrastructure for delivery and improvement of our services:
|Adjust GmbH||Analytics service provider||Germany||https://www.adjust.com/terms/privacy-policy/|
|Apple Inc.||Cloud storage provider (for iOs devices)||U.S.A.||https://www.apple.com/lae/privacy/|
|Appodeal Inc.||Analytics / ad management service provider||U.S.A.||https://www.appodeal.com/home/privacy-policy/|
|Box Inc.||Cloud storage provider||U.S.A.||https://www.box.com/legal/privacypolicy|
|Dropbox Inc.||Cloud storage provider||U.S.A.||https://www.dropbox.com/help/security/privacy-policy-faq|
|Evernote Corporation||Cloud storage provider||U.S.A.||https://evernote.com/intl/ru/privacy/policy|
|Facebook Inc.||Analytics / ad management service provider||U.S.A.||https://www.facebook.com/privacy/explanation|
|Google Inc.||Cloud storage (for Android devices) / analytics service provider||U.S.A.||https://policies.google.com/privacy?hl=en|
|Microsoft Corp.||Cloud storage provider||U.S.A.||https://privacy.microsoft.com/en-US/|
|Twitter Inc.||Analytics / ad management service provider||U.S.A.||https://twitter.com/ru/privacy|
|Yandex LLC||Cloud storage / analytics service provider||Russia||https://yandex.com/legal/privacy/|
In case you want to learn more about these services and their privacy options (including opt-out) please consult the correspondent websites and privacy policies. We are not responsible for any usage of your personal data by the abovementioned third parties in violation of our instructions.
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, 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:
- 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 provide 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 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 App, 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.
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 App 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
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 as it is needed to provide services of the App. 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 where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).
- Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which we use your personal information.
Please bear in mind that we ensure the above mentioned rights only with respect to the information that you submit.
Please note that you can opt-out of marketing tracking by choosing:
- option "Limit Ad Tracking" on your iOs device in Settings/ Privacy/ Advertising;
- option “Opt out of Ad Personalization” on your Android device in Settings/ Google/ Ads.
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 (in accordance with 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 apply to your situation.
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 App, you can contact us at through email or contact form displayed 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 verification of 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
Our representative in EU: ALBINA GULEVICH APOLSKAYA, 205, Holland Park Avenue, W11 4XB, London, e-mail: firstname.lastname@example.org