[Last Updated: July 1, 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 user’s use of the Mobile App (“Non-Personal Information”). We are not aware of the identity of and cannot determine the user from whom the Non-Personal Information was collected.
Non-Personal Information which we collect may include your aggregated usage information and technical information transmitted by your device, including: (i) certain software and hardware information, such as: type of device and operating system; (ii) Mobile App session ID, the time and date you access the Mobile App; (iii) information about browsing activity (the type of browser, a list of web pages visited and time stamps of such visits); (iv) information about installed apps, such as name, installation and update date, and version of the Mobile App; (v) the Internet Protocol (IP) address associated with the communication between your device and our network server, which we store in hashed (encrypted) form, with the last class permanently deleted before storing it, in order to retain only general (e.g., country and city) location; and (vi) GUID, which is a random number generated on your device and used to distinguish between different users, and which cannot be used to identify you. We consider GUID and IP address as non-personal information, however, in some countries and jurisdictions, such as the European Union, this data might be considered as “Personal Information”.
The second type of information we may collect when you install or otherwise use the Mobile App is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). The Personal Information we collect on or through the Mobile App includes contact information, such as your name, telephone number, address, email, etc., which you might provide us if you voluntarily contact us. We will use this information solely to respond to your requests and support your needs.
HOW DO WE COLLECT AND USE YOUR INFORMATION?
HOW DO WE SHARE THE INFORMATION, AND FOR WHAT PURPOSE?
We do not share any Personal Information collected from you with third parties or any of our partners except in the following circumstances: (i) we will 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; (ii) we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
The Non-Personal Information we collect may be shared in any of the above circumstances, as well as
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 steps necessary 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 (including but not limited to the interaction with our US-based servers), 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.
You may opt out of the automatic collection and sharing of Non-Personal Information related to our Mobile App and service, by uninstalling the Mobile App from your device. You may also contact our Data Protection Officer at: firstname.lastname@example.org and we will be happy to assist you.
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. If you object to such collection, use and sharing of data, please cease using the Mobile App immediately and remove the Mobile App from your device. The data we receive in the event you access the Mobile App 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 Mobile App.
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 law (as is the case in the European Union).
CALIFORNIA CONSUMER PRIVACY ACT
Consumers in the State of California, United States are granted certain rights related to Personal Information under the California Consumer Privacy Act (the “CCPA”).
The CCPA grants California consumers the following rights:
Requests under the CCPA described above can be made at no cost to the consumer. Requests can only relate to Personal Information collected in the prior 12 months. Up to two (2) requests can be made in any 12-month period.
Only you or a representative authorized and registered with the California Secretary of State to act on your behalf may make a CCPA request. Requests must be sent by e-mail to firstname.lastname@example.org.
We must verify your identity and that you have the authority to make the request before we can respond, beginning with matching the information in the request with information in our files. As a result, while we will attempt to limit the additional information required in a CCPA request, we need sufficient personal details to verify your request. At a minimum, we must confirm to a reasonable degree of certainty you are the person about whom the request relates (or are that person’s duly-authorized representative), and we must have sufficient details about what you are requesting to allow us to understand and respond. Without sufficient information, we may need to decline your request.
If we can verify a request, we will make efforts to respond within 45 days. If we need more than 45 days (up to 90 days), we will inform you in writing, including the reason(s) we need more time.
The exercise of your CCPA rights will not result in any discrimination against you. We will not charge you more or give you lower-quality goods and services and we will not deny you goods or services as a result of you exercising your CCPA rights.
CALIFORNIA SHINE THE LIGHT LAW
California consumers who do business with us have additional rights under California's "Shine the Light" law (Civil Code Section §1798.83). These include the right to inquire about your Personal Information we provide to third parties for their direct marketing purposes. Such requests apply only to disclosures made in the prior calendar year and may not be made more than once in any 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 (made under either the CCPA or Shine the Light law) not submitted by email to firstname.lastname@example.org.
HOW DO WE SAFEGUARD YOUR INFORMATION?
We take great care in implementing and maintaining the security of the Mobile App and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Mobile App, and we make no warranty, express, implied or otherwise, that we will prevent such access. We may adopt what we believe is appropriate data collection, storage and processing practices and security measures to protect against unauthorized access to such data.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Mobile App or acted in an inappropriate manner, please contact our Data Protection Officer directly at email@example.com.
If you have any general questions about the Mobile App or the information that we collect about you and how we use it, please contact us at: firstname.lastname@example.org.