IMPORTANT PRIVACY INFORMATION
In order to use the app, we will ask you to sign up with email, Facebook or Snapchat and to enter at least your name, date of birth, gender and email. We also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the App, to serve ads.
For improving the App and serving ads, we may share this data with third parties. Such parties include Facebook, Google, Snapchat, Amplitude, Appsflyer, Firebase, TikTok. As a result of sharing this data with third parties we (1) analyze different interactions (how many users buy subscriptions, how often users visit our app); (2) serve and measure ads (and are able to show them only to a particular group of users, for example, to subscribers).
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
TABLE OF CONTENTS
1. PERSONAL DATA CONTROLLER
ACESOFT LIMITED, a company registered in Cyprus (with registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus) will be the controller of your personal data.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, email address, name, date of birth, gender, interests and photos). We also collect data automatically (for example, your IP address, device type, etc.).
3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To customize your experience
We process your personal data to adjust the content of the Service and make offers tailored to your personal preferences. As a result of such processing, we may show you users of the gender you are interested in and users that live in the same city as you do.
To manage your account and provide you with customer support
To communicate with you regarding your use of our Service
We may communicate with you, for example, by push notifications. These may include reminders, updates, information on upcoming events or other information about the App. As a result, you may, for example, receive a push notification that a new feature has been deployed in the App. To opt out of receiving push notifications, you need to change the settings on your device.
To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the App and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the App our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing.
To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook’s feed.
We may target advertising to you through a variety of ad networks and exchanges, using data from advertising technologies on and off of our Services like, unique cookie, or similar tracking technology, pixel, device identifiers, geolocation, operation system information, email.
How to opt-out or influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).
To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt-out of some interest-based advertising, by visiting the following links:
- Network Advertising Initiative – http://optout.networkadvertising.org/
- Digital Advertising Alliance – http://optout.aboutads.info/
- Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
- Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
- DAA AppChoices page – http://www.aboutads.info/appchoices
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (applies only to EEA-based users)
In this Section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This Section applies only to EEA-based users.
We process your personal data under the following legal bases:
- your consent;
to perform our contract with you;
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Customize your experience
- Provide you with customer support
- Communicate with you regarding your use of our Service
for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
to communicate with you regarding your use of our Service
This includes, for example, sending you push notifications. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you.
to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).
to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.
to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
- to communicate with you regarding your use of our Service
to comply with legal obligations.
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers (Amazon Web Services)
- data analytics providers (Facebook, Google, Appsflyer, Firebase, Crashlytics, Amplitude, Tableau)
- marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat, TikTok, ironSource)
- API providers (SendGrid, Twilio)
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
6. HOW YOU CAN EXERCISE YOUR RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may request a copy of, as well as updating and correcting your personal data collected during your use of the Service at firstname.lastname@example.org.
Deleting your personal data. You can request erasure of your personal data by sending us an email at email@example.com.
When you request deletion of your personal data by email, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at firstname.lastname@example.org.
7. AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at email@example.com.
8. INTERNATIONAL DATA TRANSFERS
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
10. CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to firstname.lastname@example.org, which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
11. DATA RETENTION
12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
13. CONTACT US
Effective as of: 23 October 2020