Policy summary
Personal Data processed for the following purposes and using the
following services:
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Content performance and features testing (A/B testing)
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Device permissions for Personal Data access
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Infrastructure monitoring
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Managing contacts and sending messages
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Platform services and hosting
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the
services listed in this document, Users may follow the
instructions provided by
YourOnlineChoices
(EU), the
Network Advertising Initiative
(US) and the
Digital Advertising Alliance
(US),
DAAC
(Canada),
DDAI
(Japan) or other similar initiatives. Such initiatives allow
Users to select their tracking preferences for most of the
advertising tools. The Owner thus recommends that Users make use
of these resources in addition to the information provided in
this document.
The Digital Advertising Alliance offers an application called
AppChoices
that helps Users to control interest-based advertising on mobile
apps.
Users may also opt out of certain advertising features through
applicable device settings, such as the device advertising
settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
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Push notifications
This Application may send push notifications to the
User to achieve the purposes outlined in this privacy
policy.
Users may in most cases opt-out of receiving push
notifications by visiting their device settings, such
as the notification settings for mobile phones, and
then change those settings for this Application, some
or all of the apps on the particular device.
Users must be aware that disabling push notifications
may negatively affect the utility of this Application.
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Owner and Data Controller
DF Dev IE - Ireland
Owner contact email:
df.dev.ie@gmail.com
Full policy
Owner and Data Controller
DF Dev IE - Ireland
Owner contact email: df.dev.ie@gmail.com
Types of Data collected
Among the types of Personal Data that this Application collects,
by itself or through third parties, there are: Tracker; Usage
Data; unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example); geography/region; number of
sessions; session duration; In-app purchases; Application opens;
Application updates; first launches; operating systems; payment
data; Universally unique identifier (UUID); Crash information;
device information; Storage permission.
Complete details on each type of Personal Data collected are
provided in the dedicated sections of this privacy policy or by
specific explanation texts displayed prior to the Data
collection.
Personal Data may be freely provided by the
User, or, in case of Usage Data, collected automatically when
using this Application.
Unless specified otherwise, all
Data requested by this Application is mandatory and failure to
provide this Data may make it impossible for this Application to
provide its services. In cases where this Application
specifically states that some Data is not mandatory, Users are
free not to communicate this Data without consequences to the
availability or the functioning of the Service.
Users who
are uncertain about which Personal Data is mandatory are welcome
to contact the Owner.
Any use of Cookies – or of other
tracking tools — by this Application or by the owners of
third-party services used by this Application serves the purpose
of providing the Service required by the User, in addition to
any other purposes described in the present document.
Users are responsible for any third-party Personal Data
obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent
unauthorized access, disclosure, modification, or unauthorized
destruction of the Data.
The Data processing is carried out
using computers and/or IT enabled tools, following
organizational procedures and modes strictly related to the
purposes indicated. In addition to the Owner, in some cases, the
Data may be accessible to certain types of persons in charge,
involved with the operation of this Application (administration,
sales, marketing, legal, system administration) or external
parties (such as third-party technical service providers, mail
carriers, hosting providers, IT companies, communications
agencies) appointed, if necessary, as Data Processors by the
Owner. The updated list of these parties may be requested from
the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in
any other places where the parties involved in the processing
are located.
Depending on the User's location, data transfers may involve
transferring the User's Data to a country other than their own.
To find out more about the place of processing of such
transferred Data, Users can check the section containing details
about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall
be processed and stored for as long as required by the purpose
they have been collected for and may be retained for longer due
to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to
provide its Service, comply with its legal obligations, respond
to enforcement requests, protect its rights and interests (or
those of its Users or third parties), detect any malicious or
fraudulent activity, as well as the following: Advertising,
Infrastructure monitoring, Analytics, Platform services and
hosting, Handling payments, Content performance and features
testing (A/B testing), Device permissions for Personal Data
access and Managing contacts and sending messages.
For specific information about the Personal Data used for each
purpose, the User may refer to the section “Detailed information
on the processing of Personal Data”.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may
request certain permissions that allow it to access the User's
device Data as described below.
By default, these permissions must be granted by the User before
the respective information can be accessed. Once the permission
has been given, it can be revoked by the User at any time. In
order to revoke these permissions, Users may refer to the device
settings or contact the Owner for support at the contact details
provided in the present document.
The exact procedure for
controlling app permissions may be dependent on the User's
device and software.
Please note that the revoking of such permissions might impact
the proper functioning of this Application.
If User grants any of the permissions listed below, the
respective Personal Data may be processed (i.e accessed to,
modified or removed) by this Application.
Storage permission
Used for accessing shared external storage, including the
reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using
the following services:
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Advertising
This type of service allows User Data to be utilized for
advertising communication purposes. These communications
are displayed in the form of banners and other
advertisements on this Application, possibly based on
User interests.
This does not mean that all Personal Data are used for
this purpose. Information and conditions of use are
shown below.
Some of the services listed below may use Trackers to
identify Users or they may use the behavioral
retargeting technique, i.e. displaying ads tailored to
the User’s interests and behavior, including those
detected outside this Application. For more information,
please check the privacy policies of the relevant
services.
Services of this kind usually offer the possibility to
opt out of such tracking. In addition to any opt-out
feature offered by any of the services below, Users may
learn more on how to generally opt out of interest-based
advertising within the dedicated section "How to opt-out
of interest-based advertising" in this document.
AdMob
AdMob is an advertising service provided by Google LLC
or by Google Ireland Limited, depending on how the
Owner manages the Data processing.
In order to understand Google's use of Data,
consult
Google's partner policy.
Personal Data processed: Tracker; unique device
identifiers for advertising (Google Advertiser ID or
IDFA, for example); Usage Data.
Place of processing: United States –
Privacy Policy
–
Opt Out; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: identifiers; internet or other electronic
network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Analytics
The services contained in this section enable the Owner
to monitor and analyze web traffic and can be used to
keep track of User behavior.
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is
an analytics service provided by Google LLC or by
Google Ireland Limited, depending on how the Owner
manages the Data processing.
In order to understand Google's use of Data,
consult
Google's partner policy.
Firebase Analytics may share Data with other tools
provided by Firebase, such as Crash Reporting,
Authentication, Remote Config or Notifications. The
User may check this privacy policy to find a detailed
explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices
and technologies similar to cookies to run the
Firebase Analytics service.
Users may opt-out of certain Firebase features through
applicable device settings, such as the device
advertising settings for mobile phones or by following
the instructions in other Firebase related sections of
this privacy policy, if available.
Personal Data processed: Application opens; Application
updates; first launches; geography/region; In-app
purchases; number of sessions; operating systems;
session duration; Usage Data.
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: commercial information; internet or other
electronic network activity information; geolocation
data.
This processing constitutes:
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner
to track and analyze the User response concerning web
traffic or behavior regarding changes to the structure,
text or any other component of this Application.
Firebase Remote Config
Firebase Remote Config is an A/B testing and
configuration service provided by Google LLC or by
Google Ireland Limited, depending on how the Owner
manages the Data processing.
Personal Data processed: various types of Data as
specified in the privacy policy of the service.
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: internet or other electronic network activity
information.
This processing constitutes:
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Device permissions for Personal Data access
This Application requests certain permissions from Users
that allow it to access the User's device Data as
described below.
Device permissions for Personal Data access (this
Application)
This Application requests certain permissions from
Users that allow it to access the User's device Data
as summarized here and described within this document.
Personal Data processed: Storage permission.
Category of Personal Information collected according to
the CCPA: internet or other electronic network activity
information.
This processing constitutes:
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Handling payments
Unless otherwise specified, this Application processes
any payments by credit card, bank transfer or other
means via external payment service providers. In general
and unless where otherwise stated, Users are requested
to provide their payment details and personal
information directly to such payment service providers.
This Application isn't involved in the collection and
processing of such information: instead, it will only
receive a notification by the relevant payment service
provider as to whether payment has been successfully
completed.
Payments processed via the Google Play Store
This Application uses a payment service provided by
Google LLC or by Google Ireland Limited, depending on
how the Owner manages the Data processing, that allows
the Owner to offer the purchase of the app itself or
in-app purchases.
Personal Data processed to complete the purchases are
processed by Google, as described in the
privacy policy for the Google Play store.
Personal Data processed: payment data.
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: commercial information.
This processing constitutes:
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Infrastructure monitoring
This type of service allows this Application to monitor
the use and behavior of its components so its
performance, operation, maintenance and troubleshooting
can be improved.
Which Personal Data are processed depends on the
characteristics and mode of implementation of these
services, whose function is to filter the activities of
this Application.
Firebase Performance Monitoring
Firebase Performance Monitoring is a monitoring
service provided by Google LLC or by Google Ireland
Limited, depending on how the Owner manages the Data
processing.
Personal Data processed: various types of Data as
specified in the privacy policy of the service.
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: internet or other electronic network activity
information.
This processing constitutes:
Crashlytics
Crashlytics is a monitoring service provided by Google
LLC or by Google Ireland Limited, depending on how the
Owner manages the Data processing.
Personal Data processed: Crash information; device
information; Universally unique identifier (UUID).
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: identifiers; internet or other electronic
network activity information.
This processing constitutes:
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Managing contacts and sending messages
This type of service makes it possible to manage a
database of email contacts, phone contacts or any other
contact information to communicate with the User.
These services may also collect data concerning the date
and time when the message was viewed by the User, as
well as when the User interacted with it, such as by
clicking on links included in the message.
Firebase Notifications
Firebase Notifications is a message sending service
provided by Google LLC or by Google Ireland Limited,
depending on how the Owner manages the Data
processing. Firebase Notifications can be integrated
with Firebase Analytics to target analytics-based
audiences and track opening and conversion events.
Personal Data processed: various types of Data as
specified in the privacy policy of the service.
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: internet or other electronic network activity
information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Platform services and hosting
These services have the purpose of hosting and running
key components of this Application, therefore allowing
the provision of this Application from within a unified
platform. Such platforms provide a wide range of tools
to the Owner – e.g. analytics, user registration,
commenting, database management, e-commerce, payment
processing – that imply the collection and handling of
Personal Data.
Some of these services work through geographically
distributed servers, making it difficult to determine
the actual location where the Personal Data are stored.
Google Play Store
This Application is distributed on the Google Play
Store, a platform for the distribution of mobile apps,
provided by Google LLC or by Google Ireland Limited,
depending on how the Owner manages the Data
processing.
By virtue of being distributed via this app store,
Google collects usage and diagnostics data and share
aggregate information with the Owner. Much of this
information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly
through their device settings. More information on how
to manage analysis settings can be found on
this page.
Personal Data processed: Usage Data.
Place of processing: United States –
Privacy Policy; Ireland –
Privacy Policy.
Category of Personal Information collected according to
the CCPA: internet or other electronic network activity
information.
This processing constitutes:
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the
services listed in this document, Users may follow the
instructions provided by
YourOnlineChoices
(EU), the
Network Advertising Initiative
(US) and the
Digital Advertising Alliance
(US),
DAAC
(Canada),
DDAI
(Japan) or other similar initiatives. Such initiatives allow
Users to select their tracking preferences for most of the
advertising tools. The Owner thus recommends that Users make use
of these resources in addition to the information provided in
this document.
The Digital Advertising Alliance offers an application called
AppChoices
that helps Users to control interest-based advertising on mobile
apps.
Users may also opt out of certain advertising features through
applicable device settings, such as the device advertising
settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
-
Push notifications
This Application may send push notifications to the
User to achieve the purposes outlined in this privacy
policy.
Users may in most cases opt-out of receiving push
notifications by visiting their device settings, such
as the notification settings for mobile phones, and
then change those settings for this Application, some
or all of the apps on the particular device.
Users must be aware that disabling push notifications
may negatively affect the utility of this Application.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of
the following applies:
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Users have given their consent for one or more specific
purposes.
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provision of Data is necessary for the performance of an
agreement with the User and/or for any pre-contractual
obligations thereof;
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processing is necessary for compliance with a legal obligation
to which the Owner is subject;
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processing is related to a task that is carried out in the
public interest or in the exercise of official authority vested
in the Owner;
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processing is necessary for the purposes of the legitimate
interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific
legal basis that applies to the processing, and in particular
whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into
a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall
be processed and stored for as long as required by the purpose
they have been collected for and may be retained for longer due to
applicable legal obligation or based on the Users’ consent.
Therefore:
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Personal Data collected for purposes related to the performance
of a contract between the Owner and the User shall be retained
until such contract has been fully performed.
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Personal Data collected for the purposes of the Owner’s
legitimate interests shall be retained as long as needed to
fulfill such purposes. Users may find specific information
regarding the legitimate interests pursued by the Owner within
the relevant sections of this document or by contacting the
Owner.
The Owner may be allowed to retain Personal Data for a longer
period whenever the User has given consent to such processing, as
long as such consent is not withdrawn. Furthermore, the Owner may
be obliged to retain Personal Data for a longer period whenever
required to fulfil a legal obligation or upon order of an
authority.
Once the retention period expires, Personal Data shall be deleted.
Therefore, the right of access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced
after expiration of the retention period.
The rights of Users based on the General Data Protection
Regulation (GDPR)
Users may exercise certain rights regarding their Data processed
by the Owner.
In particular, Users have the right to do the following, to the
extent permitted by law:
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Withdraw their consent at any time. Users have
the right to withdraw consent where they have previously given
their consent to the processing of their Personal Data.
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Object to processing of their Data. Users have
the right to object to the processing of their Data if the
processing is carried out on a legal basis other than consent.
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Access their Data. Users have the right to
learn if Data is being processed by the Owner, obtain disclosure
regarding certain aspects of the processing and obtain a copy of
the Data undergoing processing.
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Verify and seek rectification. Users have the
right to verify the accuracy of their Data and ask for it to be
updated or corrected.
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Restrict the processing of their Data. Users
have the right to restrict the processing of their Data. In this
case, the Owner will not process their Data for any purpose
other than storing it.
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Have their Personal Data deleted or otherwise
removed.
Users have the right to obtain the erasure of their Data from
the Owner.
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Receive their Data and have it transferred to another
controller.
Users have the right to receive their Data in a structured,
commonly used and machine readable format and, if technically
feasible, to have it transmitted to another controller without
any hindrance.
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Lodge a complaint. Users have the right to
bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data
transfers abroad including to any international organization
governed by public international law or set up by two or more
countries, such as the UN, and about the security measures taken
by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the
exercise of an official authority vested in the Owner or for the
purposes of the legitimate interests pursued by the Owner, Users
may object to such processing by providing a ground related to
their particular situation to justify the objection.
Users must know that, however, should their Personal Data be
processed for direct marketing purposes, they can object to that
processing at any time, free of charge and without providing any
justification. Where the User objects to processing for direct
marketing purposes, the Personal Data will no longer be
processed for such purposes. To learn whether the Owner is
processing Personal Data for direct marketing purposes, Users
may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner
through the contact details provided in this document. Such
requests are free of charge and will be answered by the Owner as
early as possible and always within one month, providing Users
with the information required by law. Any rectification or erasure
of Personal Data or restriction of processing will be communicated
by the Owner to each recipient, if any, to whom the Personal Data
has been disclosed unless this proves impossible or involves
disproportionate effort. At the Users’ request, the Owner will
inform them about those recipients.
Further information for Users in Brazil
This section of the document integrates with and supplements the
information contained in the rest of the privacy policy and is
provided by the entity running this Application and, if the case
may be, its parent, subsidiaries and affiliates (for the
purposes of this section referred to collectively as “we”, “us”,
“our”).
This section applies to all Users in Brazil (Users are referred
to below, simply as “you”, “your”, “yours”), according to the
"Lei Geral de Proteção de Dados" (the "LGPD"), and for such
Users, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.
This part of the document uses the term “personal information“
as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a
legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
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compliance with a legal or regulatory obligation that lies
with us;
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the carrying out of public policies provided in laws or
regulations or based on contracts, agreements and similar
legal instruments;
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studies conducted by research entities, preferably carried out
on anonymized personal information;
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the carrying out of a contract and its preliminary procedures,
in cases where you are a party to said contract;
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the exercising of our rights in judicial, administrative or
arbitration procedures;
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protection or physical safety of yourself or a third party;
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the protection of health – in procedures carried out by health
entities or professionals;
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our legitimate interests, provided that your fundamental
rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at
any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are
processed, you can read the section titled “Detailed information
on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can
read the sections titled “Detailed information on the processing
of Personal Data” and “The purposes of processing” within this
document.
Your Brazilian privacy rights, how to file a request and our
response to your requests
Your Brazilian privacy rights
You have the right to:
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obtain confirmation of the existence of processing activities
on your personal information;
- access to your personal information;
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have incomplete, inaccurate or outdated personal information
rectified;
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obtain the anonymization, blocking or elimination of your
unnecessary or excessive personal information, or of
information that is not being processed in compliance with the
LGPD;
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obtain information on the possibility to provide or deny your
consent and the consequences thereof;
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obtain information about the third parties with whom we share
your personal information;
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obtain, upon your express request, the portability of your
personal information (except for anonymized information) to
another service or product provider, provided that our
commercial and industrial secrets are safeguarded;
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obtain the deletion of your personal information being
processed if the processing was based upon your consent,
unless one or more exceptions provided for in art. 16 of the
LGPD apply;
- revoke your consent at any time;
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lodge a complaint related to your personal information with
the ANPD (the National Data Protection Authority) or with
consumer protection bodies;
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oppose a processing activity in cases where the processing is
not carried out in compliance with the provisions of the law;
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request clear and adequate information regarding the criteria
and procedures used for an automated decision; and
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request the review of decisions made solely on the basis of
the automated processing of your personal information, which
affect your interests. These include decisions to define your
personal, professional, consumer and credit profile, or
aspects of your personality.
You will never be discriminated against, or otherwise suffer any
sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free
from any charge, at any time, by using the contact details
provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make
sure to communicate to you the factual or legal reasons that
prevent us from immediately, or otherwise ever, complying with
your requests. In cases where we are not processing your
personal information, we will indicate to you the physical or
legal person to whom you should address your requests, if we are
in the position to do so.
In the event that you file an access or
personal information
processing confirmation request, please make
sure that you specify whether you’d like your personal
information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer
your request immediately, in which case we will answer in a
simplified fashion, or if you need a complete disclosure
instead.
In the latter case, we’ll respond within 15 days from the time
of your request, providing you with all the information on the
origin of your personal information, confirmation on whether or
not records exist, any criteria used for the processing and the
purposes of the processing, while safeguarding our commercial
and industrial secrets.
In the event that you file a
rectification, deletion, anonymization or personal
information blocking
request, we will make sure to immediately communicate your
request to other parties with whom we have shared your personal
information in order to enable such third parties to also comply
with your request — except in cases where such communication is
proven impossible or involves disproportionate effort on our
side.
Transfer of personal information outside of Brazil permitted by
the law
We are allowed to transfer your personal information outside of
the Brazilian territory in the following cases:
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when the transfer is necessary for international legal
cooperation between public intelligence, investigation and
prosecution bodies, according to the legal means provided by
the international law;
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when the transfer is necessary to protect your life or
physical security or those of a third party;
- when the transfer is authorized by the ANPD;
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when the transfer results from a commitment undertaken in an
international cooperation agreement;
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when the transfer is necessary for the execution of a public
policy or legal attribution of public service;
-
when the transfer is necessary for compliance with a legal or
regulatory obligation, the carrying out of a contract or
preliminary procedures related to a contract, or the regular
exercise of rights in judicial, administrative or arbitration
procedures.
Further information for Users in the United States
This part of the document integrates with and supplements the
information contained in the rest of the privacy policy and is
provided by the business running this Application and, if the
case may be, its parent, subsidiaries and affiliates (for the
purposes of this section referred to collectively as “we”, “us”,
“our”).
The information contained in this section applies to all Users
(Users are referred to below, simply as “you”, “your”, “yours”),
who are residents in the following states:
California, Virginia, Colorado, Connecticut, Utah, Texas,
Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey,
Nebraska and Montana.
For such Users, this information supersedes any other possibly
divergent or conflicting provisions contained in the privacy
policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely
notice about the
categories of Personal Information collected or disclosed in
the past 12 months
so that you can exercise meaningful control over our use of that
Information.
While such categorization of Personal Information is mainly
based on California privacy laws, it can also be helpful for
anyone who is not a California resident to get a general idea
of what types of Personal Information are collected.
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Identifiers
Personal Information collected or disclosed:
Tracker, Usage Data, unique device identifiers for
advertising (Google Advertiser ID or IDFA, for
example), Universally unique identifier (UUID), Crash
information, device information
Purposes:
- Advertising
- Infrastructure monitoring
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
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Internet or other electronic network activity
information
Personal Information collected or disclosed:
Tracker, Usage Data, unique device identifiers for
advertising (Google Advertiser ID or IDFA, for
example), various types of Data as specified in the
privacy policy of the service, geography/region,
number of sessions, session duration, In-app
purchases, Application opens, Application updates,
first launches, operating systems, Universally unique
identifier (UUID), Crash information, device
information, Storage permission
Purposes:
- Advertising
- Infrastructure monitoring
- Analytics
- Further information about Personal Data
- Platform services and hosting
-
Content performance and features testing (A/B
testing)
- Device permissions for Personal Data access
- Managing contacts and sending messages
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
Service providers or contractors: this
Application
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Commercial information
Personal Information collected or disclosed:
Usage Data, geography/region, number of sessions,
session duration, In-app purchases, Application opens,
Application updates, first launches, operating systems
Sensitive Personal Information collected or
disclosed ℹ️:
payment data
Purposes:
- Analytics
- Handling payments
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
-
Geolocation data
Personal Information collected or disclosed:
Usage Data, geography/region, number of sessions,
session duration, In-app purchases, Application opens,
Application updates, first launches, operating systems
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of
certain processing activities and to limit the use of your
sensitive personal information (“Limit the Use of My Sensitive
Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information,
please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or
for purposes that are not reasonably necessary to and compatible
with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal
Information, either directly or indirectly, from you when you
use this Application.
For example, you directly provide your Personal Information when
you submit requests via any forms on this Application. You also
provide Personal Information indirectly when you navigate this
Application, as Personal Information about you is automatically
observed and collected.
Finally, we may collect your Personal Information from third
parties that work with us in connection with the Service or with
the functioning of this Application and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal
Information. In particular, to the extent permitted by
applicable law, you have:
-
the right to access Personal Information: the right to
know.
You have the right to request that we confirm whether or not
we are processing your Personal Information. You also have the
right to access such Personal Information;
-
the right to correct inaccurate Personal Information.
You have the right to request that we correct any inaccurate
Personal Information we maintain about you;
-
the right to request the deletion of your Personal
Information.
You have the right to request that we delete any of your
Personal Information;
-
the right to obtain a copy of your Personal Information.
We will provide your Personal Information in a portable and
usable format that allows you to transfer data easily to
another entity – provided that this is technically feasible;
-
the right to opt out from the Sale of your Personal
Information;
We will not discriminate against you for exercising your
privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in
the United States, as a User residing in California, you have
-
The right to opt out of the Sharing of your Personal
Information
for cross-context behavioral advertising;
-
The right to request to limit our use or disclosure of your
Sensitive Personal Information
to only that which is necessary to perform the services or
provide the goods, as is reasonably expected by an average
consumer. Please note that certain exceptions outlined in the
law may apply, such as, when the collection and processing of
Sensitive Personal Information is necessary to verify or
maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado,
Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New
Hampshire, New Jersey, Nebraska and Montana
In addition to the rights listed above common to all Users in
the United States, as a User residing in Virginia, Colorado,
Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New
Hampshire, New Jersey, Nebraska and Montana you have
-
The right to opt out of the processing of your personal
information for Targeted Advertising or profiling in
furtherance of decisions that produce legal or similarly
significant effects concerning you;
-
The right to freely give, deny or withdraw your consent for
the processing of your Sensitive Personal Information.
Please note that certain exceptions outlined in the law may
apply, such as, but not limited to, when the collection and
processing of Sensitive Personal Information is necessary for
the provision of a product or service specifically requested
by the consumer.
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in
the United States, as a User residing in Utah and Iowa, you have
-
The right to opt out of the processing of your
Personal Information for Targeted Advertising;
-
The right to opt out of the processing of your Sensitive
Personal Information.
Please note that certain exceptions outlined in the law may
apply, such as, but not limited to, when the collection and
processing of Sensitive Personal Information is necessary for
the provision of a product or service specifically requested
by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your
request to us by contacting us via the contact details provided
in this document.
For us to respond to your request, we must know who you are. We
will not respond to any request if we are unable to verify your
identity and therefore confirm the Personal Information in our
possession relates to you. You are not required to create an
account with us to submit your request. We will use any Personal
Information collected from you in connection with the
verification of your request solely for verification and shall
not further disclose the Personal Information, retain it longer
than necessary for purposes of verification, or use it for
unrelated purposes.
If you are an adult, you can make a request on behalf of a child
under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to
opt-out of Sale or Sharing and Targeted Advertising you can also
use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and
Targeted Advertising activities via a user-enabled
global privacy control, such as for example the Global
Privacy Control (“GPC”), you are free to do so and we will abide by such request in
a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all
cases within the timeframe required by applicable law. Should we
need more time, we will explain to you the reasons why, and how
much more time we need.
Should we deny your request, we will explain to you the reasons
behind our denial (where envisaged by applicable law you may
then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request
unless such request is manifestly unfounded or excessive and in
all other cases where it is permitted by the applicable law. In
such cases, we may charge a reasonable fee or refuse to act on
the request. In either case, we will communicate our choices and
explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the
Owner in Court or in the stages leading to possible legal action
arising from improper use of this Application or the related
Services.
The User declares to be aware that the Owner may
be required to reveal personal data upon request of public
authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy,
this Application may provide the User with additional and
contextual information concerning particular Services or the
collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any
third-party services may collect files that record interaction
with this Application (System logs) or use other Personal Data
(such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal
Data may be requested from the Owner at any time. Please see the
contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy
policy at any time by notifying its Users on this page and
possibly within this Application and/or - as far as technically
and legally feasible - sending a notice to Users via any contact
information available to the Owner. It is strongly recommended
to check this page often, referring to the date of the last
modification listed at the bottom.
Should the changes affect processing activities performed on the
basis of the User’s consent, the Owner shall collect new consent
from the User, where required.
Definitions and legal references
Personal Data (or Data) / Personal Information (or
Information)
Any information that directly, indirectly, or in connection
with other information — including a personal identification
number — allows for the identification or identifiability of
a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal
Information that is not publicly available and reveals
information considered sensitive according to the applicable
privacy law.
Usage Data
Information collected automatically through this Application
(or third-party services employed in this Application),
which can include: the IP addresses or domain names of the
computers utilized by the Users who use this Application,
the URI addresses (Uniform Resource Identifier), the time of
the request, the method utilized to submit the request to
the server, the size of the file received in response, the
numerical code indicating the status of the server's answer
(successful outcome, error, etc.), the country of origin,
the features of the browser and the operating system
utilized by the User, the various time details per visit
(e.g., the time spent on each page within the Application)
and the details about the path followed within the
Application with special reference to the sequence of pages
visited, and other parameters about the device operating
system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise
specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or
other body which processes Personal Data on behalf of the
Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or
other body which, alone or jointly with others, determines
the purposes and means of the processing of Personal Data,
including the security measures concerning the operation and
use of this Application. The Data Controller, unless
otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is
collected and processed.
Service
The service provided by this Application as described in the
relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner
to
a third party, for monetary or other valuable
consideration, as defined by the applicable privacy US state law. Please
note that the exchange of Personal Information with a
service provider pursuant to a written contract that meets
the requirements set by the applicable law, does not
constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other
means, a consumer's Personal Information by the business to
a
third party for cross-context behavioral advertising,
whether for monetary or other valuable consideration,
including transactions between a business and a third party
for cross-context behavioral advertising for the benefit of
a business in which no money is exchanged, as defined by the
California privacy laws. Please note that the exchange of
Personal Information with a service provider pursuant to a
written contract that meets the requirements set by the
California privacy laws, does not constitute sharing of your
Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a
consumer where the advertisement is selected based on
Personal Information obtained from that consumer’s
activities over time and across nonaffiliated websites or
online applications to predict such consumer’s preferences
or interests, as defined by the applicable privacy US state
law.
European Union (or EU)
Unless otherwise specified, all references made within this
document to the European Union include all current member
states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored
in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique
identifiers, web beacons, embedded scripts, e-tags and
fingerprinting - that enables the tracking of Users, for
example by accessing or storing information on the User’s
device.
Legal information
This privacy statement has been prepared based on provisions
of multiple legislations.
This privacy policy relates solely to this Application, if
not stated otherwise within this document.