Effective Date: September 03, 2019
COLLECTION AND PROCESSING OF PERSONAL INFORMATION
When you use the Application, we collect certain personally identifiable information that can be used to identify you (“Personal Data”). We may ask you to provide the following Personal Data:
Information you give us: This is information about you that you give us by filling in your details when using our Application for the first time: name, gender, relationship status, place of birth, date of birth, time of birth, a line/shape model of your left and right palm and, if you lodge a customer query, your email address and any other information about yourself you choose to provide to use us when you lodge a customer query with us.
Information collected by technical resources: Information regarding appliances used, such as data on the type of hardware and/or software. This information includes your IP address, your browser type and language, information about your device, history of using other applications, access location and times, information on other apps installed on your device, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below), and the referring website address.
Device Information. These data include the operating system of your device (device type), your mobile device identifiers (device ID, advertising ID), resolution, version of the application, language, time zone, as well as IP address.
Information about Your Use of the Services. These data include information about your activity within the Application, such as achievements within the Services, actions taken within the Services, in-app purchases data (payment identification number, the type and amount of a product, its price in your local currency, date and time of the purchase), subscriptions, advertising that you click on. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Service. We also may include web beacons in advertisements or email messages to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the Service we offer our visitors and users to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
Cookies and local storage information. When you use our Service, we may assign your device one or more cookies to facilitate access to our Service and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on the Service, such as the web pages you visit, the time and date of your visits, the links you click, and the searches you conduct on our Service. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Service.
Login information. All information generated from your login onto our Service.
Your location (if your device settings are enabled to send it to us). These data include information about your country, state and city of your location.
User Inquiries Information. These data include all information you provide to us when addressing our support team or communicate with us in any other way.
Information collected by third parties: Some information might be collected by third party SDKs in the Application. They may collect your IP address, cookies, unique device identifiers and alike. We do not collect this information ourselves and it is collected by the relevant third parties as data controllers. This information is only shared so as to allow the Application to operat. If you do not want to share this information you should adjust your device privacy settings to “do not track”.
PROCESSING OF PAYMENT INFORMATION
Our Services include in-app purchases, e.g. subscriptions. If you want to make an in-app purchase, you may do this with the help of in-app payment system provided by the Application Platforms (either Google Play managed by Google Inc. or AppStore managed by Apple Inc.) and integrated in the Application. The in-app payment system is managed by the Application Platforms administrations or its authorized partners. Under no circumstances does the Company collect or process any information related to your payment instrument, such as bank card number, its validity term or your name as written on it.
SHARING OF PERSONAL DATA WITH THIRD PARTIES
For the purposes of analytics and advertising, we may use services and solutions provided by third parties. Such parties may process data on our behalf and the respective technical solutions represent a part of the Services. Any transfer of your Personal Data is based on a written agreement, and we make sure such a third party complies with the applicable data protection regulations. Such third parties process Personal Data in accordance with their own privacy policies.
In certain cases, we may transfer information about you to other third parties (for example, independent personal data controllers), if we are obliged or allowed to do so by applicable laws. If it is the case, we transfer such information while adhering to applicable personal data protection laws.
We also may transfer your Personal Data to a third party in the following cases:
The Service may permit interactions between the Service and a third-party website or service (e.g. Facebook, Twitter or alike), such as enabling you to "like" a product on our Service or "share" content to other websites or services. If you choose to "like" or "share" content on the Service or to otherwise post information from or via the Service to a third party's website, service, feature or application, that information will become public and the third party may have access to information about you and your use of our Service.
PURPOSES TO PROCESS PERSONAL DATA
We process Personal Data for the following purposes:
DURATION OF PERSONAL DATA PROCESSING
We retain all Personal Data for as long as you use the Application and 24 months after you stop using it. If you do not use the Application for 24 continuous months, we erase your Personal Data from our data base, as well as request the same erasure from any third party, whom your Personal Data may have been transferred to. We may erase your Personal Data earlier if we do not need to process such data anymore.
If it is legally required that we retain your Personal Data for longer period for whatever purpose as stated in the applicable law, we will retain your Personal Data for the period determined by the law. We will immediately erase your Personal Data after such period expires or if the legal duty to retain such Personal Data is repealed.
We may retain your Personal Data longer only in case such Personal Data have been duly anonymized. After anonymization the data are not considered Personal Data, as the end user (the data subject) is no longer identifiable.
Please, take into account that erasure of Personal Data is irretrievable. After your Personal Data have been erased, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
PERSONAL DATA OF CHILDREN
We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children's Online Privacy Protection Act ("COPPA") without such parental consent. In fact, if you are under 16 years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us by email at firstname.lastname@example.org
RIGHTS WITH REGARD TO YOUR PERSONAL DATA
Under the applicable data protection regulation, if you are a citizen of the EU and fall within the scope of a data subject, you are entitled to the following rights:
Right of access. You have the right to access your Personal Data, which we process;
Right to erasure (deletion). You have the right to ask us to completely delete your Personal Data;
Right to object. You have the right to object to processing of your Personal Data for the purpose of direct marketing;
Right to restriction of processing. Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679;
Right to data portability. You have the right to ask us to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
ADVERTISEMENT IN APPLICATION
We may show advertisements in the Application with the help of third-party advertising partners. We may integrate their technologies into the Application, which are then used by our partners to select the advertisements that meet your interests in the best way.
If you do not want to receive targeted advertisements, please, adjust settings of your device as instructed below.
PRIVACY SETTINGS ON YOUR DEVICE
If you want to adjust the privacy settings of your device, please, take the following steps:
iOS operating system: enable Limit Ad Tracking on iOS by opening “Settings,” then tapping on “Privacy,” then “Advertising”, and sliding the Limit Ad Tracking switch to “On”.
Android operating system: opt out of Ads Personalization on Android by opening “Settings”, then tapping “Google”, then “Ads”, then enable the switch next to “Opt out of Ads Personalization”.
COLLECTION AND PROCESSING OF PERSONAL DATA FOR ANALYTICAL PURPOSES
In order to analyze various aspects of the Application and its functioning, we need to collect and process certain information with regard to your interaction with the Application. Such information includes your location data, information about your device and advertising data. It may also comprise information about errors of the Services. For this purpose, we may use technologies and solutions provided by third parties – our analytical partners. We may integrate such technologies into the Application and our partners process the data on our behalf to provide us with analytics.
Processing data for analytical purposes is based on a legitimate interest of the Company – analyzing data about the Application for commercial purposes. Analytics helps us to provide better services to users, update and develop the Services. For example, we may use such information in order to fix errors of the Application, evaluate demographic composition of our users, determine what features to add to the Application or whether we need to translate it into another language.
SECURITY AND MONITORING
We incorporate commercially reasonable safeguards to help protect and secure your Personal Data. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Application and provide us with your information at your own risk.
NOTICE TO CALIFORNIA RESIDENTS
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:
Victoria House, 26 Main Street,
Gibraltar, GX11 1AA
Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
CONSENT TO TRANSFER
In order to provide our Services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred.
If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our Application and Related Services, users agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
Given the fact that technology will always innovate, we cannot estimate what the future functionalities of our Application will be. Therefore, your consent will also apply to the processing of your Personal Data and other information by new technologies and techniques, which fall within the original purpose of our Application.
OPTING OUT OF FUTURE COMMUNICATIONS
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Victoria House, 26 Main Street,
Gibraltar, GX11 1AA