Refering to personal data (or personal information) we mean any information of any kind relating to an natural person that has been identified or is identifiable.
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 physiological, mental, economic, physical, social or cultural status.
This Privacy policy applies to all users, and others who access the App (hereafter “Users”).
For the purposes of the GDPR (i.e. General Data Protection Regulation), we are the data controller.
PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS. BY ACCESSING OR USING THE APP, YOU AGREE TO PROCESSING OF YOUR PERSONAL DATA WHICH IS PROVIDED TO US IN LINE WITH THE TERMS OF THIS PRIVACY POLICY.
II. The information that we process
We can process 2 general categories of information.
2.1 Information that you submit:
The following personal information about you is what we ask for and collect from you when when you use the App. This information is necessary for the adequate performance of the agreement between you and us. It is impossible - without such information - to provide complete functionality of the App in order to perform the requested services.
Account and/or Authorization Information. We require certain information such as your email address or Facebook ID or Google ID – depending on the App settings, when you sign up for an account.
Content Information, i.e. video, pictures, photos, documents, audio files and other data that you upload when using the App.
We may use personal Information which you may fill in by yourself, when the App is designed for tracking your info, storing your records and/or managing them for your convenience and upon your explicit request.
2.2 Information that Is Processed Automatically
When you use the App, some parts of the information about your user behaviour and your device may be processed automatically. In almost all cases this information is non-personal, and we may access it only in aggregated form. We process this information on the ground to give our users the best experience and on the ground of our legitimate interest in improving our App. Otherwise we may not be able to provide you with all the requested services and features of the App.
From parties such as Google and Facebook, we use third-party automatic data processing technologies in order to analyse 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 supervise, respond or control for how the third parties providing your personal data your information process, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
What is the data that may be processed:
Advertising ID / Advertisers, type of device and model, (mobile) web browser type and version, MAC address and IMEI, IP address, account information (email etc), locale information, MCC (Mobile Country Code) information, the device’s operating system’s make and version, cookies and similar technologies, location and related data.
Processing information through automatic data processing technologies that we use starts automatically when you begin using our App. The App may use automated processing of your personal data, including profiling which means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular to analyse or predict aspects concerning your personal preferences, location, behaviour, interests or movements.
III. Our 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.
In general our mission:
(a) is to improve, monitor and test the effectiveness of our App. We use information that is processed automatically to better understand user trends and behaviour, detect technical issues and potential outages, to operate, improve, protect and optimize our App.
(b) is to provide you with interest-based (behavioural) 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 information and content to you, which can include online ads or other forms of marketing.
(c) is to make our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.
(d) is to prevent spam and fraud, to enforce law. We really want our App to be free of fraudulent content and spam so that you feel free and safe. We may use your information to detect, prevent and investigate fraud, potentially prohibited or illegal activities, security breaches, protect our tradename and trademarks and enforce our Terms of Use.
(e) is to communicate with you. We use the information that we have to communicate with you through blogs, newsletters, i.e. to receive your feedback about our App experience and to send you marketing notifications, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
If any new purposes for processing your personal data arise, then we will let you know we begin to process information on that other purpose by introducing the corresponding changes to this Privacy policy.
IV. Sharing of your information
We will share your information with third parties only in the ways that are described in this Privacy Policy.
We collect the following categories of your personal information and may share it to third parties: commercial information, identifiers, geolocation data, internet or other electronic network activity information and inferences drawn from these categories.
We will not sell or rent your personal data to third parties, but we may share your information from tools like log files, cookies, location data and device identifiers, 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 use one or more of the following third-party advertising services and analytics tools: Google AdWords; Flurry; AdMob; Apple SearchAds; Facebook; Adjust; AppsFlyer; Firebase; Fabric; ironSource; Mopub; Appcalibre ; OneSignal; Kochava ; Inmobi; Ogury, Applovin; Startapp. In case you want to learn more about the services and privacy options, please consult their websites and privacy policies.
Our App may use certain third-party service providers like Amazon Web Services (AWS) to enhance user experience. Use of third-party services may require us to submit your personal information to their servers that provide automatic data processing technologies for the App.
Our App may contain links to third-party services/ websites or you may access the App from a third-party site. We are not responsible for the privacy practices or the content 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 needed for objective reasons, due to public interest or in other unforeseen circumstances:
– 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;
– when required by law;
– if we are involved in an acquisition or merger or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
V. International data transfers
We work in the international space 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, US or other regions with laws governing data processing that may differ from England & Wales 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, insofar permitted by law where the data originate from.
This means that your personal information be anonymised or if not that it 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 a 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, or a territory or one or more specified sectors within that third country, or to the international organization.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
VI. How long we use your personal data
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, then you can request that we delete your personal information and close your account.
However, some data may still be stored for a certain time period if information is necessary to comply with legal obligation (audit, taxation, accounting) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.
VII. Exercising your rights
For the data, we store and access that you are entitled to address us regarding the following issues:
- 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 needed to provide the App. However, specific retention times can vary based on 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).
- Data Access and Portability. You can request copies of your personal information held by us.
- 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.
When your personal information that is processed automatically, then you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.
Please note that you can opt-out of marketing tracking by emailing the developer account.
VIII. Security
The security of your personal information is 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 appropriate and reasonable measures to protect personal information from loss, unauthorized access, disclosure, misuse, 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 in order 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 the applicable law.
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 the age of 18 years 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.
X. Changes to the privacy policy
This Privacy policy may change from time to time.
Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.
XI. How to contact us
If you have any questions about this Privacy Policy, please feel free to contact us at this email: me@florisgravendeel.com