PRIVACY POLICY

Last updated: 24 September 2023

This Privacy Policy explains how your personal data is collected and processed by us when you use our mobile applications (the "App").

The App is a free to use (with optional in-app-purchases), and in order to maintain the high quality and a great experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.

We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.

COLLECTION OF INFORMATION

Information we collect automatically through the app

When you access or use the App, we automatically collect general information about you, including:

Information we collect from other sources

If you log into the App using a third party site or platform such as Facebook, Instagram, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.

You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:

If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.

USE OF INFORMATION - PURPOSE AND LEGAL BASIS

We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

Device-, and device identifiers are being processed:

Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.

Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").

To provide users that have given us consent to share their advertising IDs with our ad network partners (as further specified under “Sharing of Information”) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).

Our processing for the above purposes is based on your consent, see Article 6(1)(a) of the GDPR. You can always revoke your consent, which will have effect for the future.

STORAGE OF INFORMATION

Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with us has ceased.

SHARING OF INFORMATION

We disclose information about you to the following categories of recipients:

SOCIAL SHARING FEATURES

The App offers or can offer social sharing features and other integrated tools (such as the Facebook "Like" button), which let you share actions you take in our App with other media. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

CHILDREN

Use of the App is limited to users aged 13 years and above. In case you are located in a jurisdiction where permission to use the App is only granted if you are of an age older than 13 years, you need to be of at least that age. The App is not intended for children under the age of 13 years. However, in the European Economic Area (EEA) the above-mentioned age limit is 16 years. We do not knowingly collect or solicit personal data from children under the age of 13 years (or 16 years in the EEA).

TRANSFER TO THIRD COUNTRIES

In connection with the processing, we will in certain circumstances transfer your personal data to recipients outside the EEU. Such transfers will only take place for the specific purposes mentioned above under "USE OF INFORMATION - PURPOSE AND LEGAL BASIS", and we will ensure that the transfer is legal and safe. For any such transfers of personal data outside the EEU, either a decision from the Commission has determined that the third country ensures an adequate level of protection, or we will provide appropriate safeguards, in particular by entering into EU standard contractual clauses with the data importer. You can request a copy hereof by contacting us at the email address provided below.

TRANSFERS BASED ON SAFEGUARDS

Consequently, the transfers will only occur based on the following safeguards:

SECURITY

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

PUSH NOTIFICATIONS

We send push notifications or alerts to your mobile device to provide information, service updates, promotional communications, and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

SECURITY SAFEGUARDS

We take reasonable measures to protect your information from unauthorized access or against loss, misuse, or alteration by third parties. Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Furthermore, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

DO WE ACTUALLY "SELL" PERSONAL DATA?

We does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, We does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”Sharing of information“, to the third parties for business purpose as explained under “Use of information – purpose and legal basis”. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at [email protected] to exercise your right to withdraw your consent on sharing your personal data with third parties.

YOUR RIGHTS

Rights of EEU residents

We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Right to request access

You have the right to request access into the data that we are processing on you, including information about:

You can contact us to learn about the status of your personal data undergoing processing.

The right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of- interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.

Right to rectification

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.

The right to restriction

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

The right to withdraw consent

If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.

If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

Right to be informed

You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.

Right to disclosure

You can request us to disclose what personal data we have collected on you in the past 12 months.

We can assure you that our Privacy Policy is a relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.

You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.

Right to deletion

You can request us to delete the personal data we have collected on you in the past 12 months.

We fully recognize your right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for a certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech, or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.

Right to equal services and prices

California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

How to exercise my rights

If you wish to use any of the rights described above, you may contact us at any time by emailing us at [email protected].

CONTACT

Our app has the following contact information:

You may also contact your local data protection authority for unresolved complaints.