[Last Updated: October 14, 2021]
WHAT TYPE OF INFORMATION DO WE COLLECT?
The first type of information we collect is non-identifiable information pertaining to a user, which may be made available or gathered via the users’ installation or use of the App, and for which we are not aware of and cannot determine the identity of the user from whom such non-personal information was collected (“Non-Personal Information”). Non-Personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information, all as detailed below:
The second type of information we may collect when you install and use the App is individually identifiable information, namely information that identifies an individual or may with reasonable effort allow the identification of an individual (“Personal Information”), which may include the following:
HOW DO WE COLLECT AND USE YOUR INFORMATION?
We collect your information once you download, access or use the App or Services, and where applicable via the Android accessibility services feature. We will use the information to provide you with the Services, and deliver, manage and improve our App and Services. We may also use your Non-Personal Information for the purpose of aggregating it with other anonymized information to perform statistical analysis and to provide related marketing and analytical services, which do not describe or identify any individual user.
HOW IS THE DATA SHARED OR TRANSFERRED?
We do not share any Personal Information collected from you with third parties or any of our partners. However, we may disclose information you submitted if we have a good faith belief that disclosure of such information is reasonably necessary for any of the following reasons:
Compliance with the Law: We may share your information, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request or to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
If we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
The Non-Personal Information we collect may be used or shared in the above circumstances, as well as:
for the purpose of providing and improving our Services; or
internally within the Company, to conduct business and marketing analysis, and enhance your experience; or
with our partners as part of Company’s aggregated data analysis services. If we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
Notwithstanding the above, it is clarified that any data obtained through the Permissions will not be shared for any other purpose other than (i) as required by law or regulation; (ii) if needed for security and fraud detection; (iii) to provide the services and user facing feature; and (vi) in the event of merger and acquisition.
Note that we may also appoint third-party service providers, operating under our instructions, who may need access to your information in connection with their services on our behalf. Transfers of your Personal Information will be made in accordance with applicable data protection laws and regulations.
We will take the necessary steps to ensure that international transfers of personal data (including Personal Information) meet all requirements under applicable data protection laws. When personal data collected within the European Economic Area (“EEA“) is transferred outside the EEA, we will take the steps necessary to ensure that the transfer of such data provides sufficient safeguards, and you may exercise your rights, where applicable, to receive information on such transfer mechanism.
FOR HOW LONG WILL WE RETAIN THE INFORMATION WE COLLECT?
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. We value your privacy and control over your Personal Information, and therefore you may, at any time, request the removal of your Personal Information by contacting our Data Protection Officer at: firstname.lastname@example.org. Please note that unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
Unless you instruct us otherwise, we retain the information we collect for as long as necessary to provide the services described herein and to comply with our legal obligations, resolve disputes and enforce our agreements. The data we receive in the event you access our Website, App or Service via a third-party social or other network depends on your privacy settings with such network (i.e., Gmail, Yahoo). You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.
Where provided under applicable law (e.g., within the European Union), you may have the right to ask us to delete Personal Information which you have provided to us, subject to applicable exceptions, such as in order to preserve that information for anticipated litigation or demands from a regulator, or some or all of the following rights: the right to obtain information on our use of your Personal Information, the right to obtain a copy thereof, the right to data portability, the right of data rectification, the right to object to processing based on our legitimate interests, the right to restriction of the processing, and the right to withdraw your consent.
In order to assert any of these rights, please contact our Data Protection Officer at: email@example.com. Note that we may request proof of your identity, and we reserve the right to charge a fee where allowed by law, such as in circumstances where your request is deemed to be excessive.
In addition, you may have the right to lodge a complaint with a supervisory authority, subject to applicable laws (as is the case in the European Union).
FURTHER RIGHTS GRANTED TO CALIFORNIA CONSUMERS
Consumers in the state of California are given additional rights related to Personal Information pursuant to the California Consumer Privacy Act (the “CCPA”).
California consumers have the following rights under the CCPA:
to request what types of Personal Information we collect and how we use, sell or disclose it
Subject to some exceptions, California consumers may make a request for the following:
Deletion of Personal Information we have collected in the past 12 months;
A copy of Personal Information we have collected in the past 12 months; and/or
A description of the sources and categories of Personal Information collected, the purpose for its collection, the method of handling the information, and the parties it was shared with and why.
The requests described above are at no cost to the consumer. Requests can only include Personal Information collected in the prior 12 months and only 2 requests can be made in any 12-month period.
Only you, or someone authorized and registered with the California Secretary of State to act on your behalf is allowed to make a request under the CCPA. Requests must be sent by e-mail to firstname.lastname@example.org.
All requests must be verified by confirming the requestor’s identity and authority to make the request. To do so, we compare the information in the request with the information in our files. We try to limit the amount of additional information required to verify a CCPA request, but we do require sufficient details to confirm the request, including confirming that the requestor is the person about whom the request relates (or is their authorized representative). We also require a request detailed enough for us to understand it and properly respond. If we are unable to confirm your identity or understand the request, we may decline to respond to it.
If we can verify and confirm a request, we try to respond within 45 days. If we need more than 45 days (it may be up to 90 days), we will inform you in writing, including the reason(s) we need more time.
Exercising your CCPA rights will not result in any discrimination against you. We will not deny you goods or services, or charge you more or give you lower-quality goods and services, as a result of you exercising these rights.
California consumers doing business with us also have rights under California’s “Shine the Light” law (Civil Code Section §1798.83) to inquire about Personal Information disclosed to third parties for the purpose of direct marketing. These requests can only apply the preceding calendar year, and only one is allowed per calendar year. Requests under the California Shines the Light law must be sent to email@example.com.
We reserve the right to not respond to requests not submitted by email to firstname.lastname@example.org.
DATA STORAGE AND SECURITY
You represent and warrant that you are at least 13 years of age and of legal competence to enter into the Terms. If you have any reason to believe that a child under the age of 13 has shared any information with us, please contact our Data Protection Officer at email@example.com. If you are under 18, please be sure to read the Terms with your parents or legal guardians, and ask questions about things you do not understand.
If you have any questions about the App or the information that we collect about you and how we use it, please contact us at: firstname.lastname@example.org.