PRIVACY POLICY

 

Last update 22/02/22

This Privacy Policy (“Policy”) applies to the processing of your personal data when you access and use the Application (“App”). The Policy is designed to explain to you how do we collect and process your personal data, purposes, and legal bases for personal data processing, information about the transfer of your personal data, and the rights you have as a data subject.

We encourage You to take some time to read it through attentively because it applies to all personal data collected within the use of the App and our communication with you.

If You have any questions concerning this Policy, our privacy practices, or want to exercise your rights please do not hesitate to contact our Support Team via e-mail corissarahme@gmail.com

We adhere to the data minimization principle and do not collect personal data that may be used for your direct identification. We do not intentionally process your data about you, except for some technical data about your device (if applicable) and information you may voluntarily provide to us by email communication.

Сhildren’s Privacy  

Please note, that our App is not intended for users under the legal age (in most of the countries this age is 18 years old). If you are under the legal age of your jurisdiction, you should stop the use of our App. If you used our App before discovering a fact, that this App is not intended for children, please, send us a notification to remove all your data.

Information for parents and legal guardians: if you discovered, that your child or ward used or uses our App, please, contact our Support Team via e-mail corissarahme@gmail.com and we will remove all the information about your child or ward that we have.

We assume no responsibility for any use of our App by the children.

What types of personal data do we collect?

We are trying to minimize personal data collected about you. Personal data we process are limited to:

Device data. We collect the following information about your device:

• IP address;

• type of operating system, its version;

• devise identifiers.

 

Performance data. To analyse how you interact with the App we may collect the following information:

• date and time of your activities in the App;

• duration of your session within the App;

• how long you interact with the App and spend on each page.

 

Contact data. When you contact us via an available e-mail address, we collect:

• your e-mail address;

• other information you additionally give us.

 

What are the purposes and legal bases for personal data processing?

Purpose of processing

Lawful basis for processing

Providing you with full and correct functionality of the App

Our legitimate interest is to enable you to access the App and use its functionality completely (Article 6 (1)(f) of the GDPR).

 

Maintaining the correct operation and ensuring the security of the App

 

Our legitimate interest is in ensuring the proper functioning of the App, protection against cyberattacks and any other illegal activity (Article 6 (1)(f) of the GDPR).

Improving, monitoring the effectiveness of the App

 

Our legitimate interest is to analyze the effectiveness of Your interaction with the App and provide it to You in the best possible way (Article 6 (1)(f) of the GDPR).

Communication with you in course of your use of the App

 

Our legitimate interest is to maintain communication with the users (Article 6 (1)(f) of the GDPR).

Providing you with personalized advertising materials, information on updates (if applicable)

Your consent (Article 6 (1)(a) of the GDPR).

 

With whom do we share your personal data?

We engage different natural and legal persons to ensure the correct and effective operation of the App, namely:

Members of our team

Our App is developed and maintained by a large staff. We may share your personal data with our employees, contractors, subcontractors, external consultants. We guarantee that these persons have a contractual obligation with us to process your personal data in accordance with this Policy and the applicable law.

 

Providers of Analytics services

We use Analytics services to understand the needs of our users and optimize their experience with our App.

Firebase

Firebase is an analytics provider, owned by Google LLC, USA. Firebase collects from its SDK your Device data and Performance data to help us: A) track events in our App; B) monitor the behaviour of our users. For example, we track how our user reacts to the new functionality and features of our App; C) conduct A/B test via Firebase Remote Config. A/B tests mean that we will provide some categories of our users with new screens or functionality, tailored for the needs of the particular audience. Then, Firebase shall track on how users react to these changes; D) track how some particular incidents and events happened. For example, Firebase tracks how crashes of our App took place; F) prevent fraudulent, illegal use of our App.

In order to find out how Firebase processes your personal data, please, follow Privacy and Security Policy of Firebase.

OneSignal

OneSignal is a service provided by OneSignal, Inc., USA. OneSignal collects from its SDK your Device data and Performance data to help us: A) send, optimise and manage in-app messengers and push notifications; B) conduct A/B test. A/B testing is a way to compare up to 10 message variants on the same notifications to determine which one performs better.

In order to find out how OneSignal processes your personal data, please, follow OneSignal Privacy Policy.

 

 

Adjust

Adjust GmbH, Germany, provides us with analytics and marketing services. Adjust collects from its SDK your Device data and Performance data to help us: A) optimize our analytics and advertising campaigns; В) prevent fraudulent activity in the App.

In order to find out how Adjust processes your personal data, please, follow Adjust Privacy Policy.

IT services providers

To provide you with the App and conduct our business we may engage other IT services providers, including but not limited to hosting host providers, cloud services providers

Public Authorities

We may disclose your data to the Public Authorities, such as Police, Court, Financial Regulators or their Investigation Units upon their lawful requests.

How long do we store and how do we protect your information?

Time limit for the storage of information:

We store your personal information as long as you use our App. We may store your personal information for an additional period of time if:

- We need this information for fraud investigation;

- We have a legal obligation under applicable law to store your information for an additional period of time. 

As specified before, we may anonymize your data for the purpose of further researches of our audience. Please note that after the anonymization this information shall no longer be classified as "personal data", because such information will contain no personally identifiable information and, as the result, you couldn’t be identified through this information.

 

Protection of personal data

 

We protect data about you by the application of modern encryption standards. It means that your information can be decrypted only by use of the decryption key. The decryption keys are in exclusive access of authorized members of our team. It means, that even in case of any hypothetical leakage of the information, unauthorized entities would not get any of your information.

 

Data subject rights

 

You can exercise your data subject rights by contacting our Support Team via e-mail corissarahme@gmail.com
You can ask us whether or not do we process your personal data, and, if we indeed process your personal data, to request us for a copy of the data we have about you.

 

The right to correction. You can send us a request to correct inaccurate or no longer relevant personal data concerning you.

 

The right to delete your information. You can send us a request to remove all personal information we have about you.

 

The right to portability of your information. You can request us to provide you with your personal information in a structured, commonly used and machine-readable format and/or transmit this information to another Company.

 

The right to withdraw consent. You can always withdraw previously given consent to the processing of your personal data. It means that we shall stop the processing, for which your consent is required. Please note, that any withdrawal is without prejudice to the lawfulness of processing, consent to which was previously given.

 

If you reside in the European Economic Area, you request us to exercise your data subject`s rights under the Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR"):

The right to object to the processing.  You can object, on grounds relating to your particular situation, to the processing of your personal data, if the processing was necessary for the purposes of the legitimate interests pursued by us or by the third-party, which processed your personal data on our behalf. You can also object to the processing of your information for direct marketing purposes.

 

The right to restriction of the processing of your personal information. You can obtain from us the restriction of your personal data processing in case of one of the following conditions applies: A) you contested the accuracy of your personal data – the restriction shall be applied for a period enabling to verify the accuracy of your personal data; B) the processing was unlawful and you oppose the deletion of your personal data and request the restriction instead of the deletion; C) we no longer need your personal data, but you need this data for the establishment, exercise or defence of legal claims; D) you exercised the right to object the processing andwant to restrict the processing of your personal data pending to verification whether our legitimate grounds override those of you.

 

Restrictions to the rights:

 

1. We will exercise your request only if we are able to determine your personality. We shall do this to avoid your data to be obtained by the wrong hands.

 

В) The exercise of your request may be restricted by the legislation, to which we are subject. We will notify you the legal ground of the restriction in the letter response to your request.

 

The right to lodge a complaint.

 

In case of any problems, or disputes, or complaints, please, do not hesitate to contact our Support Team via e-mail corissarahme@gmail.com We will do our best to solve your problem or find a mutually beneficial outcome. If you are not satisfied with the outcome, you can realize your right to lodge a complaint with the supervisory authority.

 

If you reside in the European Union, you can find the relevant supervisory authority by the link https://edpb.europa.eu/about-edpb/board/members_en.

 

For EEA residents - transfer of the information outside the EEA

 

Please note, that due to the global nature of our business, your information may be transferred outside the EEA to the recipients in third countries within the meaning of the GDPR. Nevertheless, we guarantee a similar degree of protection afforded to Your personal data according to Art. 45 and Art. 46 of the GDPR. In most cases transfers of personal data outside the EEA are based on the Standard contractual clauses adopted by the European Commission.

 

Links to third-party services.

 

This App may contain links to other sites. If you click on a third-party link, you will be directed to that site or service. Note that these external sites/services are not operated by us. Therefore, we strongly advise you to review the Privacy Policy or another privacy document of these websites/services. Wehave no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Policy.

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.