1. THE FOREWORD.
If you have any questions about this Policy or about the processing of your personal data by the Application, please, do not hesitate to contact Us via e-mail address: [email protected]
2. PROCESSING OF YOUR PERSONAL DATA.
Under the article 4(1) of the Regulation 2016/679 of the European Union and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “General Data Protection Regulation” or “GDPR”), the “” means ” For the purposes of this Policy, the personal data hereinafter shall be referred to as the “data”.
When you use the Application, the following data are collected from you:
2.1 THE DATA, COLLECTED BY THIRD-PARTY SDK.
“SDK” means “software development kit” – the tools, provided by third parties, which are integral parts of this Application. Below you can find the list of SDKs integrated into this Application, what data from you they collect and why do We use a particular SDK.
2.1.1 APPSFLYER SDK.
We use the SDK, provided by AppsFlyer Inc., located at 100 First St. San Francisco, CA, 94105. This SDK collects the following data:
The Purpose of usage of Adjust SDK – We use Adjust SDK for the following purposes:
To find out more, please, follow https://www.appsflyer.com/legal/privacy-policy/.
Legal bases for this processing:
Article 6(1)(a) of the GDPR – you have given consent to the processing of your personal data for the purposes of this Policy;
Article 6(1)(f) of the GDPR – processing is necessary for the purposes of the legitimate interests pursued by Us.
2.1.2 ONESIGNAL SDK.
We use the SDK, provided by OneSignal., a U.S. company located at 2850 S Delaware St Suite 201, San Mateo, CA 94403. This SDK collects the following data:
Information about your interactions with this Application;
The Purpose of usage of OneSignal SDK – We use OneSignal SDK in order to:
To find out more, please, follow https://onesignal.com/privacy_policy.
2.1.3 FIREBASE ANALYTICS SDK.
In order to design and optimise the use of the Application in line with requirements, we use Firebase Analytics. User data is transmitted anonymously to Google Firebase in the USA (Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). On our behalf, Google Firebase evaluates the data the way you use the Application, as this data is necessary for us to ensure and further improve the stability and security of the Application. The data collected in this way is not merged with your other customer information, but is included in anonymous statistics. The legal basis for processing the data for this purpose is your consent in accordance with Art. 6 (1) lit. a GDPR.
You can find more information about the web analysis service used on the Google Firebase website https://www.firebase.com/terms/privacy-policy.html
Instructions on how to prevent the processing of your data by the web analysis service, in addition to revoking your consent, can be found here: https://firebase.google.com/docs/analytics/configure-data-collection
2.2 THE DATA YOU PROVIDE TO US.
Message data. When you contact Us via e-mail address [email protected] or via available means of communications, you may provide Us the information, that may fall within the definition of “personal data” under the GDPR:
The purposes of the processing:
Your Message data will be used solely for the purposes of your message. Examples include, but not limited to the following:
Legal bases for this processing:
2.3 HOW ELSE CAN WE USE YOUR DATA?
To develop this Application. Your data may be used for the following purposes:
Legal basis for this processing:
To comply with the applicable legislation. We may use your data in order to comply with a legal obligation to which We are subject.
Legal basis for this processing:
2.4 WHO ELSE CAN WE DISCLOSE YOUR DATA.
In addition to the providers of SDK, specified herein, your personal may be disclosed to the following recipients:
Our employees and employees of our affiliated companies. Our Application is developed and maintained by many people, including our employees and employees of our affiliated companies. Thus, your data may become available to them. Please note, that all these employees have signed proper agreements, that will oblige them to handle your data in strict compliance with this Policy.
Governmental authorities. We may share the data, collected from you, with the authorities of the country of our incorporation or with authorities of your jurisdiction if We are/will be obliged to do this under the applicable legislation.
3. HOW LONG SHALL WE STORE YOUR DATA?
We shall store your data for so long as is necessary for the purposes for which your data was collected. If applicable legislation may require additional storage period, this information shall be published in revised version of this Policy or notified to you (if applicable).
4. YOUR RIGHTS UNDER THIS POLICY.
Under the applicable data protection legislation, you have a number of the rights, that you may apply by sending a request to [email protected]. These rights are the following:
The right to access. You have the right to obtain from Us confirmation as to whether or not personal data concerning you are being processed, and, if We indeed process your personal data, to receive a copy of the personal data undergoing processing.
The right to rectification. You have the right to obtain from Us the rectification of inaccurate personal data concerning you (if applicable).
The right to erasure (“the right to be forgotten”). You have the right to have your personal data removed. This right shall be applied if: i) your personal data are no longer needed for the purposes, for which these data were collected; and ii) We do not need your personal data for the purposes of compliance with applicable legislation.
The right to object to processing. You have the right to object, on grounds relating to your particular situation, to processing of your personal data, if the grounds of this processing were necessary for the purposes of the legitimate interests pursued by Us. Additionally, you have the right to object to processing of your personal data for direct marketing purposes (if applicable).
The right to restriction of the processing. You have the right to obtain from Us the restriction of the processing of your personal data, in case if one of the following applies: a) you contested to the accuracy of the personal data – for a period enabling Us to verify the accuracy of the personal data; b) the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead; c) We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; d) you have objected to processing on the basis of your right to object pending to verification whether your legitimate grounds override those of Us.
The right to withdraw consent. If you previously consented to the processing of your data, you have the right to withdraw this consent at any time. It means that We shall stop processing of the personal data, for the processing of which the consent was required, starting from the date of the withdrawal. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
The right to data portability. You have the right to receive from Us the data, which were collected from you, in a structured, machine-readable format and have the right to transmit those data to another controller (simply, to another company). Nevertheless, this right applies only to the processing, which was carried out by automatic means.
Please note, that these rights are applicable with some restrictions:
5. PROCESSING OF CHILDREN`S DATA.
We do not knowingly process the data of individuals younger than eighteen (18) years old. If you are a parent or a guardian and you are aware that your child has provided Us with his/her data, please contact Us so that we will be able to take the necessary actions.
6. DATA TRANSFER OUTSIDE THE EU.
Our business is global, and some of our employees, affiliates and contractors may be located, incorporated and established in the jurisdictions outside the European Union. In some cases, these countries may not be recognized by the European Commission as the countries, that offers an adequate level of data protection. We warrant, that all our non-EU employees, affiliates and contractors have signed with Us proper Data Transfer Agreements, which obliges these employees, affiliates and contractors to process your data in accordance with this Policy. By agreeing to this Policy, you hereby agree to these transfers.
7. LINKS TO THE THIRD-PARTY SERVICES.
There are several places on our Application where you may click on a link directing you away from our Application to access other applications, websites or services that do not operate under this Policy (hereinafter “third-party services”). These third-party services may independently solicit and collect information, including personal data, from you and, in some instances, provide Us with information about your activities on those third-party services. We bear no liability for any outcome of your use of these services. We recommend you to inspect the privacy statements of all third-party services you visit by clicking on the “privacy” document prior to giving any data to these services.
8. CHANGES TO THIS POLICY.
We may change, amend or modify this Policy from time to time. If We do this, We will let you know by revising this Policy. By continuing to use our Application after Policy changes go into effect, you agree to be bound by the revised version of the document.