Last updated: 06 September 2022
1.1. Your privacy and data security are extremely important forus. We are committed to the responsible management, protection and use of your personal information.
2.1. You may find below the personal data categories and the purposes of such collection and (or) processing which we arrange.
|the purpose we process your personal data||categories of personal data we use||legal basis for the processing||the term of storage|
|to provide you with access to our application||
- google account ® data
- automatically collected data as:
- access to camera, microphone
- device or apps history
- wi-fi connection
- storage data
|safety and security||- google account ® data||legitimate interest||as long as our application is installed on your devices|
- google account ® data
- automatically collected data
|communications on our behalf||
- google account ® data
- user’s details (email address, name, surname, etc.)
|marketing||- automatically collected data||legitimate interest||as long as our application is installed on your devices|
|compliance with legal obligations||- automatically collected data||legitimate interest||as long as our application is installed on your devices|
|research and development||- automatically collected data||legitimate interest||as long as our application is installed on your devices|
2.2. Please note, as you obtain the access to the App by your Google Account, your personal data can be collected by Google, to read more please follow the link
2.3. We neither keep, nor store these types of data for our servers.
2.4. We need your consent to provide you with further access to our Application. Also, we want to ensure safe work of the Application and to be compliant with law. We won’t collect or process your Personal Data until obtaining your consent. Your consent may not always mean your specific actions. If you continue to use our Application, you are deemed to have agreed to the terms and conditions specified in this Policy.
3.1. To improve and optimize the App.
3.1.1. To provide better Services to you, we have a legitimate interest to collect and process necessary data to:
126.96.36.199. Update and develop the App;
188.8.131.52. Develop and improve your experience;
184.108.40.206. Manage the relationship with you;
220.127.116.11. Customize your service experience;
18.104.22.168. Respond to your comments and questions and provide support to you;
22.214.171.124. Provide offers in the App as well as in other websites and services;
126.96.36.199. Send related information (e.g. updates, security alerts, support messages) to you.
3.2. To provide the App.
3.2.1. To provider the App, we process data necessary to:
188.8.131.52. Allow you to use the Apps; and
184.108.40.206. Operate the App;
220.127.116.11. Provide and deliver products and services that you request.
3.3. To carry out activities related to advertisements and marketing.
3.3.1. To may send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the App and with other users, and so forth.
3.3.2. We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.
3.3.3. Hence, we have a legitimate interest to process necessary data to deliver, target and improve our advertising and marketing materials;
3.3.5. We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the App or otherwise.
3.4. To secure the App.
3.4.1. Ensuring security in the course of performing the App is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.
3.4.2. In order to keep the App safe, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:
18.104.22.168. Analyze and monitor use of the App;
22.214.171.124. Prevent cheating, crime or fraud;
126.96.36.199. Take action against fraudulent or misbehaving users.
3.4.3. Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the App. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the App may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions, answers, comments, submissions that you post if any will be publicly available.
3.5. Designated Countries.
3.5.1. For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.
4.2. In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our App.
5.1. We provide you with the rights described below when you use our App. Please contact us at email@example.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:
5.1.1. Where denial of access is required or authorized by law;
5.1.2. When granting access would have a negative impact on other's privacy;
5.1.3. To protect our rights and properties; and Where the request is frivolous or burdensome.
5.2. Right to withdraw consent
5.2.1. If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
5.3. Right of access and rectification
5.3.1. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the App.
5.4. Right to erasure (the “Right to be Forgotten”)
5.4.1. You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
5.5. Right to restriction
5.5.1. You have the right to restrict our processing your personal information where one of the following applies:
188.8.131.52. You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the App, during the period necessary for us to verify the accuracy of your personal information;
184.108.40.206. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
220.127.116.11. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
18.104.22.168. You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
5.5.2. We will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
5.6. Right to object to processing
5.6.1. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
5.7. Right to data portability
5.7.1. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
5.8. Notification to third-parties
5.9. If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
5.10. Automated individual decision-making, including profiling
5.10.1. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
5.11. Right to lodge a complaint
5.11.1. If you believe we have infringed or violated your privacy rights, please contact us at firstname.lastname@example.org so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority
7.3. Your Right to Request for Information
7.3.1. As required by CCPA, you (or your authorized agent) have the right to request us to disclose information to you about how we collect, use and share your personal information over the past 12 months.These information include: the categories of personal information we collected; the categories of sources for personal information we collected; our business purpose for collecting that personal information; the categories of third parties with whom we share that personal information.
7.4. Your Right to Delete Information
7.4.1. Under the CCPA, you (or your authorized agent) have the right to opt out of having your information sold or shared. You (or your agent) have the right to request that we delete your specific personal information that we collected from you and retained, except in the following cases Such cases include:
22.214.171.124. We need your information to detect security incidents, protect against malicious, or illegal activity;
126.96.36.199. We need your information to identify and repair application errors that impair existing intended functionality; We need your information to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
188.8.131.52. We need your information to conduct internal uses that are reasonably aligned with your expectations based on your relationship with us;and other cases provided by CCPA and other California laws.
7.5. How You Exercise Your Rights
7.5.1. To exercise your rights described above, please submit a verifiable consumer request to us by email@example.com
7.5.2. Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for information twice within a 12-month period. A verifiable consumer request must: provide sufficient information that allows us to reasonably verify your identity and make us confirm we collected personal information about you. Describe your request with sufficient details that allows us to understand and respond to it.
7.5.3. We cannot respond to your request accurately if we cannot verify your identity.
7.6. How We Respond Your Request
7.6.1. We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period by email or other electronic means.
7.6.2. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
7.7.1. We will not discriminate against you for exercising any of your CCPA rights. Such discrimination include: denying you our services; charging you different prices or rates for our services; providing you a different level or quality of our services; suggesting that you may receive a different price or rate for services or a different level or quality of services.
7.8. Data collection instructions for minors
7.8.1. The App does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions. For users aged 13~16, they have the right to opt in, and if you are the parent or guardian of users who are aged 13~16, you can also contact us.
8.1. Any information that is collected is a subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our App following the change of the Policy will mean you accept those changes.
9.1. If you have any questions or concerns about the Policy, you may contact us at email: firstname.lastname@example.org.