PRIVACY POLICY
At
SHLAV
HABA LTD ("Company,"
"we," "us," or "our"), we
deeply value your privacy and are committed to protecting it. This privacy
policy ("Policy") outlines our practices regarding data
collection, processing, and transfer as they relate to your use of our mobile
applications ("App(s)"). It serves to inform you about how we
handle your Personal Data and your rights concerning that data.
This
Policy applies within the jurisdictions where our Company operates, adhering to
the relevant data protection laws. It details the types of Personal Data we may
collect, our methods of processing and retaining this data, how you can
exercise your rights regarding your Personal Data, and other pertinent
information about our data handling practices. This Policy forms an essential
part of our Terms
of Use ("Terms"), and any
terms used herein without definition shall be interpreted as defined in our
Terms.
BONNY WELL LIMITED.,
with its registered address at 90 Hasharon EVEN YEHUDA, 4051275 Israel,
an Israeli company, acts as the "Data Controller" (as defined under
the EU General Data Protection Regulation (“GDPR”) or equivalent privacy
legislation) for the Personal Data processed as described in this Policy. We
encourage you to read this Policy carefully to understand our practices
regarding your Personal Data and how we will treat it. Should you have any
questions or concerns about this Policy or our privacy practices, please reach
out to our privacy team at: [email protected]
Definitions.
For
the purpose of this Policy, the term “Personal Data” refers to
information that identifies, relates to, or could reasonably be linked with an
individual by reasonable means. For example, it could include your name,
email address other contact information, and any information associated with
such. Personal Data shall Include “Personal
Information” as such term is defined under applicable data protection laws.
We do not
knowingly collect or process any Personal Data constituting or revealing racial
or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic
data, biometric data, data concerning a person's health, or data concerning a
person’s sex life or sexual orientation (“Special Categories of Personal
Data” or “Sensitive Data”).
We may collect aggregated, non-personal
non-identifiable information which may be collected directly or indirectly
through your use of our App (“Non-Personal Data“). Non-Personal Data
includes technical information transmitted from your device, such as browser
version, type of operating system, mobile network information, internet service
provider, mobile carrier, device settings, language preference, etc. For the avoidance of doubt, any
Non-Personal Data connected or linked to any Personal Data shall be deemed as
Personal Data if such connection or linkage exists.
Data
Sets Processed, Purposes of Processing, and Lawful Basis for Processing.
The
following describes the Personal Data we may collect, process, or use while you
are installing, and using the App:
DATA SET #1:
Online Identifiers- When you install, access, and use our
Apps, we collect certain identifiers such
as your Internet Protocol (“IP”) address, device ID, Google advertising
ID (GAID), etc. (all shall be defined as “Online Identifiers”).
Purpose of
Processing-
We process such Online Identifiers for the following
purposes:
(1)
Operational- providing our services, enabling the operation of the App;
(2)
Security- Security and fraud prevention purposes (i.e., to prevent
or to be able to address any errors or technical issues in the App); and
(3)
Analytics- Telemetry data, as
detailed below, as well as for analytics, marketing, and measurements and
providing you with personalized ads.
Lawful
Basis for Processing [GDPR]-
When we process such Online Identifiers for operational, functional, and
security purposes, we process your data based on our legitimate interest.
Consent- Where we use the Online Identifiers for marketing,
personalized ads, and tracking it will be based on your consent provided
through the Apps' organic permissions. You may withdraw consent at any time
through the App settings or the device settings (please see the section on
Opt-Out options).
DATA SET #2:
Contact Details- If you voluntarily contact us for support or other inquiries, you
may be required to provide us with certain contact information such as your
full name, email address, and any additional information you choose to provide
us.
Purpose
of Processing- We process such
data to provide you with the support you requested or to respond to your
inquiry. The correspondence with you may be processed and stored by us to
improve our customer service. We store such correspondence in the event we
reasonably believe it is required to protect our legitimate interests, for
example, in the event of any possible future disputes or legal claims, or to
provide you with any further assistance (if applicable).
Lawful
Basis for Processing [GDPR]-
We process such data based on our
legitimate interests. In the event you contact us for customer support, we will
process such data to provide you with the support as part of our contractual
obligations to you.
DATA SET #3:
Usage Data & Telemetry- We further collect information related to your use and
interaction with the App, such as access time, date logs, activity logs, the
features and content you interact with, conversions and your interaction with
ads, social media-related information, your purchase, and transaction history
(if applicable), etc.
Purpose of Processing- We process such data for the purpose of:
(1)
Operating
and improving the Services, as well as securing and correcting any error in our
Apps.
(2)
Internal
analytics for future improvement of the App, and to provide you with
personalized interface.
(3)
We
may also use data related to the ads you interact with to help advertisers
understand the performance of their ad campaigns and provide them with
applicable reports.
Lawful Basis for Processing [GDPR]- We process your data subject to our contractual
obligations with you, to enable the installation, operation, and function of
our Apps, and to improve our App and your UX. When we process such data for
analytic and advertising purposes, it is based on your consent provided through
the onboarding permissions.
Other purposes, such as operational
and security, are based on our legitimate interests.
DATA SET #4:
Profiling Data- Our App may include certain advertisements ("Ads")
placed by our partners' SDK (as detailed hereunder), and collect certain
information on you, such as your IP, online activities, and demographic data,
to display targeted Ads ("Targeted Ads").
If you wish to prevent the display
of Targeted Ads or other identifiers for interest-based advertising on the App,
you may change your settings to reset such Targeted Ads or opt-out of the
targeted advertising in your device settings. Please note that if you opt-out
of Targeted Ads, you may still see Ads in our App, however, those Ads will be
contextual ads.
Purpose of Processing- Our partners will process this Profiling Data to manage and
deliver Ads more effectively and personally, including contextual, behavioral,
and interests-based advertising based on your activity, preferences, or other
data available to us or our partners, including for re-targeting purposes.
Lawful Basis for Processing [GDPR]- We process this Profiling Data based on your consent as
required under applicable jurisdictions. You may withdraw consent at any time
through the App settings or the device setting (i.e., opt-out from
advertising ID or tracking as further detailed under the Opt-Out options).
DATA SET #5:
Installed
Application Information - We will collect,
process and transit Installed Application information that will include the
list of application installed on your device. We will collect the
Installed Application Information through the Inventory Permission (as detailed
below)
Purpose
of Processing- We will process the Installed Application Information to allow the
performance of our launcher including the redesign of your home screens. We
will further user the Installed Application Information to improve our App performances according to
your device's special features, functions; in addition, we will use the
Installed Application Information for internal
business purposes such as improving the App, learning users’ preferences, and
providing personalized and customized services.
Lawful Basis for Processing [GDPR]- We process this data based on your consent to the Inventory
Permission as further detailed below.
DATA SET #6:
App's Permissions- Your use of our App
or the features you wish to enjoy may vary, and depending on such desired
activities, you will be asked to grant us access permissions such as:
(1)
Precise location permission (“Location Permission”);
(2)
Inventory Permission – list of installed apps on your device (“Inventory Permission”);
(3)
Phone – access to your call log and contacts;
(4)
Storage – we may collect through your storage permission data on your USB
storage;
(5)
Network – we may collect through your network permissions list of devices and
networks your device can connect to and the connection history of your device;
and
(6)
Photo Library – we will need access to your camera roll and photo
library to allow you the use of certain Apps features. You may choose to grant
us full access to your camera roll and photo library or limited access to
selected photos and videos (“Gallery
Permissions“);
(all collectively “Permissions“, and each “Permission“).
Before activating each Permission, we will provide
you information regarding the data sets that are processed through such
Permission and the purpose of use of such Permission.
Purpose of Processing- We will process the
Permissions for the purposes of providing the services; enabling the
installation of the Apps and the use of certain features; improving the App;
learning users’ preferences; and providing personalized and customized
services.
In certain Apps, we may
provide you with various types of home screen widgets including weather
widgets, theme wallpaper changer features, and launchers to provide you with
the best user experience we can. These special features may require certain
permissions for the following purposes:
(1) We will process the
Inventory Permission for the purpose of:
(i) Enable the activation of our launchers on your device, including providing you
with the launcher's functions such as reorganizing and customizing your
applications, your home screens, and widgets. Without providing us access to
the list of installed apps, our App cannot be activated or function;
(ii) Optimization of the App and device's performances, especially,
improving our App performances according to your device's special features,
functions; and
(iii)
For internal business purposes such as improving the App, learning
users’ preferences, and providing personalized and customized services.
(2) We will process the Location
Permission for enabling the activation of our Apps, as it supports certain core
features within our Apps, including:
(i)
the weather application activation and
weather suggestions based on local weather data;
(ii) offering the live events
feature we provided within certain Apps;
(iii)
the local leaderboard within our games
which is location-based, and
(iv)
the local challenges feature which is
location-based.
Lawful
Basis for Processing [GDPR]- To allow
Permissions, you will need to actively and explicitly enable them through
in-app permission or your device settings, depending on the Permission. Each Permission is provided separately, and you can
decide to either accept them all, accept partly or none of them.
Note that
you can disable the App Permissions at any time, however, depending on
the App Permission you disable a feature, or all features might not properly
operate.
DATA SET #7:
Transaction Data- When you decide to make
a purchase on our App, the payments are in-app payments and shall be subject to
the app store terms and privacy Google Terms of Service & Google Privacy Policy. We do not keep any payment data; however,
we process commercial transaction data such as records of purchases and prices,
shipping details (if applicable), address, phone number, and email address.
Purpose of Processing- We will use third-party in-app payment processors, any
transactions that are processed by this third-party will be governed by their
policies.
Lawful
Basis for Processing [GDPR]- We process
such data to perform our contract with you, and to enable you to use certain
features of our Apps.
We use
different technologies to process the information listed above. Therefore, the
actual processing operation per each purpose of use and lawful basis detailed
in the table above may differ. Such processing operation usually includes a set
of operations, made by automated means, such as collection, storage, use,
disclosure by transmission, erasure, or destruction. Transfer of Personal Data
to third-party countries as further detailed in the International Data
Transfer section is based on the same lawful basis as stipulated in the
table above.
In
addition, we may use certain Personal Data to prevent potentially prohibited or
illegal activities, fraud, misappropriation, infringements, identity thefts,
and any other misuse of the Services and to enforce our policies and
agreements, as well as to protect the security or integrity of our databases
and the Apps, and to take precautions against legal liability. Such processing
is based on our legitimate interests.
Collecting the Personal Data.
Depending
on the nature of your interaction with us, we may collect information as
follows:
1) Automatically – we may directly or
indirectly gather information (e.g., Non-Personal Data or Online
Identifiers) automatically (i.e., by getting access permissions to
certain processing activities and the information stored in your mobile device).
2) Provided
by you voluntarily – we will collect and process Personal Data if you choose to
contact us for support, make a purchase, or any information you uploaded to our Apps.
Categories of Recipients to Whom We
Share the Personal Data.
To enhance the relevance of ads
and content for our users, we will disclose advertising IDs to our advertising
partners. Additionally, we will share various categories of Personal Data with
our diverse service providers. These collaborations are essential for a range
of operational functions, including but not limited to communication dispatch,
payment processing, credit and compliance risk assessments, data analysis, and
marketing and sales support. Sharing user Personal Data is necessary to
facilitate these services. We ensure that our service providers and agents access
only the information essential for delivering our Services, adhering to strict
data protection standards. These entities are obligated to protect the data
they receive and are limited to using the information solely for agreed-upon
purposes, in line with all relevant data protection laws (though they may
utilize non-personal data for their own benefit).
Should legal or regulatory
compliance necessitate, we may disclose Personal Data in response to lawful
requests from authorities, including investigations or as part of our legal
defense strategies against claims.
In the case of a significant
corporate event, such as a sale, merger, consolidation, or asset transfer, the
rights and obligations outlined in this Policy will be assumed by the relevant
affiliated or acquiring entities. Furthermore, information may be shared within
our corporate group for internal collaboration purposes, including with related
entities (such as applications, extensions, and websites).
Tracking Technologies.
we use “cookies” and similar tracking technologies such as software developer kits (”SDKs”) when you
access or use our services. Such tracking technologies are small text files
that a website (cookie) or an application (SDK) places and stores on your device while you are
viewing or using such interfaces.
Such tracking technologies are very helpful and can be used for various
purposes. These purposes include: (i) allowing you to navigate between pages efficiently; (ii)
enabling automatic activation
of certain features; (iii) remembering your preferences; and (iv) making the interaction between you and our
Services quicker and easier.
|
Cookie
& SDK |
Purpose |
Privacy Policy |
|
Google Analytics |
Analytical & Measurement |
www.google.com/policies/privacy/partners https://policies.google.com/technologies/managing?hl=en https://tools.google.com/dlpage/gaoptout For
additional information regarding our use of Google products, click HERE. |
|
Wix.com |
Operational
& Functional |
|
|
AppsFlyer |
Attribution
- Analytical &
Measurement |
https://www.appsflyer.com/legal/privacy-policy/ To
opt-out: https://www.appsflyer.com/legal/opt-out/ |
|
Adjust GmbH. |
Attribution
– Analytical &
Measurement |
|
|
Game Analytics |
Analytical &
Measurement |
|
|
FireBase |
Analytical &
Measurement |
|
|
SmartLook |
User
behavior – Analytical &
Measurement |
|
|
Unity |
Game
engine |
|
|
OneSignal |
Push
notifications |
We may disclose certain information collected through
third-party tracking tools for the purposes of:
(1)
Providing you with our Services, including enabling the operation
of the Services and Apps (such as language preferences);
(2)
Security and fraud prevention purposes (i.e., to prevent or to be
able to address any errors or technical issues in our Services);
(3)
For analytics, marketing, and measurements for tracking and
providing you with personalized ads.
When the processing is for marketing
or tracking, we will process the Personal Data solely based on the consent you
provide us as part of the onboarding permissions. Otherwise, we will process
these SDKs subject to our legitimate interests.
Security Measures.
We are
committed to safeguarding the Personal Data we handle, striving to prevent
unauthorized access, alteration, disclosure, or destruction. To this end, we've
put in place robust physical, technical, and administrative security measures
tailored to the Refine Services, ensuring compliance with both legal standards
and industry best practices. However, it's important to acknowledge that no
security system is impervious. We cannot guarantee absolute protection against
all unauthorized or unforeseen breaches and do not offer warranties, express or
implied, of infallible security.
Should you have concerns about how your privacy is managed, suspect a breach of our Policy, or become aware of any unauthorized attempts to access your Personal Data, please reach out to us at: [email protected]. In the event of a security incident involving your Personal Data, we are committed to making a diligent effort to notify both you and, when legally required, the relevant authorities, thereby upholding our responsibility to protect your information to the best of our ability.
International Data Transfers.
Our data servers in which we host and store
the information are located in the US. The Company’s HQ is based in Israel in
which we may access the information stored on such servers or other systems. If
we need to transfer your Personal Data out of your jurisdiction, we will take
appropriate measures to ensure that your Personal Data receives
an adequate level of protection as required under applicable law. When Personal
Data that is collected within the European Economic Area ("EEA")
is transferred outside of the EEA to a country that has not received an
adequacy decision from the European Commission, we will take necessary steps to
ensure that sufficient safeguards are provided during the transferring of such
Personal Data, following the provision of the Standard Contractual Clauses
approved by the European Union, or rely on adequacy decisions issued by the
European Commission. Some of these assurances are well-recognized certification
schemes.
User Privacy
Rights.
We aim for transparency in our data collection
practices to empower you with the knowledge to make informed decisions about
the use of your information. Your rights regarding your Personal Data can vary
based on our relationship, your location, and the data protection laws
applicable to you. These rights may include, but are not limited to:
ý The Right to Be Informed: You have the right to receive clear information
about how your Personal Data is processed.
ý The Right of Access: You can request access to your Personal Data.
ý The Right to Rectification and Amendment: If your Personal Data is inaccurate or incomplete,
you have the right to have it corrected.
ý The Right to Deletion/Erasure: You can request the deletion of your Personal Data.
ý The Right to Restrict Processing: You have the right to request that the processing
of your Personal Data be limited.
ý The Right to Data Portability: You can ask to receive your Personal Data in a
structured, commonly used, and machine-readable format or have it transferred
directly to another organization.
ý The Right to Object: You have the right to object to the processing of
your Personal Data.
ý The Right to Opt-Out of 'Sale': Where applicable, you can opt-out of the sale of
your Personal Data.
ý Rights Related to Automated
Decision-Making and Profiling: You
have rights concerning decisions made about you based solely on automated
processing.
To exercise any of these rights, you may submit a
Data Subject Request (DSR) by contacting us at: [email protected]. Please include in your request: (i) the specific
right you wish to exercise; (ii) your full name; (iii) your contact information
(email address and phone number); (iv) the nature of your relationship with us;
and (v) any other relevant details about your request.
Upon receiving your request, we will process it in
accordance with the required timelines set forth by applicable data protection
laws. Should we need further information from you, we will reach out using the
contact details you provided. Please note, the information you provide for this
request will be used solely to process and respond to your inquiry and will be
deleted promptly afterward.
NOTE
THAT DELETING THE APP FROM YOUR DEVICE WILL NOT RESOLVE IN DELETING YOUR
PERSONAL DATA.
If you
are a California resident, please see ANNEX A hereunder for
California Residents, which discloses the categories of 'Personal Information' collected, the
purpose of processing, categories of recipients with whom we share the Personal
Information, the retention period, and how to exercise your rights as a
California resident.
Certain rights can be
easily executed independently by you without the need to send us a request:
· You can opt-out from
receiving our marketing emails by clicking the “unsubscribe” link.
· You can withdraw consent for
processing Personal Data for analytics or marketing purposes, by using the settings on your Android device
as follows: (1) go to Settings > Privacy > Ads and enable opt-out of Ads
personalization; or (2) In addition, you can reset your advertising
identifier in the same section (this also may help you to see less personalized
ads).
To learn even more about
how to affect advertising choices on various devices and different versions,
please look at the information available HERE.
In case you opt-out of interest-based advertising, some
information will still be collected for other purposes, such as research,
analytics, and internal operations. You will also continue to receive
contextual advertisements, but they may be less relevant to your interests.
Ad choice settings and options will vary depending on your
browser and device settings, and this is not an exhaustive list. Please note
that your opt-out choices will only apply to the specific browser or device
from which you opt-out. We encourage you to explore your device and browser
settings to better understand your choices.
Data Retention.
We
hold onto the Personal Data we collect for the duration necessary to fulfill
the purposes outlined previously, in compliance with relevant laws, or until
you decide to opt-out where such an option is available. The criteria guiding
our data retention periods are as follows:
· Purpose of Data Collection:
We keep your Personal Data for as long as needed to accomplish the specific
purposes for which it was collected. For instance, if you reach out to us with
an inquiry, we will retain your contact details at least until your question
has been fully addressed.
· Regulatory Compliance: Certain types
of data, such as transaction records, may be retained for up to seven years—or
longer in specific situations—to meet our bookkeeping and regulatory
obligations.
· Dispute Resolution: In cases of legal disputes or claims
involving you, we will retain the relevant Personal Data until the matter is
resolved, including the duration of any legal proceedings. Additionally, we may
keep this data for longer if necessary, according to applicable statutory
limitation periods.
There
are instances where we might keep your Personal Data for extended periods, such
as when required by legal, regulatory, tax, or accounting needs, to maintain an
accurate record of your interactions with us in case of complaints or disputes,
or if we believe there is a potential for litigation regarding your Personal
Data. It's important to note that, barring specific legal requirements, we are
not obligated to retain your data for any fixed period. We reserve the right to
delete it at any time for any reason, without prior notice.
Children Privacy.
The Refine Services are not intended for use by children
(the phrase "child" shall mean an individual that is under the age
defined by applicable law which concerning the EEA is under the age of 16 and concerning
the US, under the age of 13) and we do not knowingly process children’s
information. We will discard any information that we receive from a user who is
considered a "child" immediately upon our discovery that such a user
shared information with us. Please contact us at: [email protected] if you have
reason to believe that a child has shared any information with us.
Policy Updates.
We
reserve the right to amend this Policy from time to time, at our sole
discretion. The most recent version of the Policy will always be available on
the App. The updated date of the Policy will be reflected in the “Last Updated”
footer hereunder. We will provide notice if these changes are material and, if
required under applicable laws, we will obtain your consent prior to enforcing
such revisions and modifications. Otherwise, any amendments to the Policy will
become effective within 30 days. We recommend you review this Policy from time
to time.
[Last Updated: February 12,
2024]
ANNEX
A
NOTICE
FOR CALIFORNIA RESIDENTS
The California
Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act
of 2020 effective January 1, 2023 (“CPRA”), any other California privacy
laws, and this privacy notice (“CCPA Notice”) apply to users who
are California residents (“consumers” or “you”). Any terms
defined in the CCPA and CPRA have the same meaning when used in this CCPA
Notice. This CCPA Notice applies to California residents’ Personal Information,
which we collect directly or indirectly while using our Apps.
Categories
Of Personal Information We Collect
We collect "Personal Information" which is defined under the CCPA as any
information that identifies, relates to, describes, references,
is capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer, household, or device, all as detailed
in the table below.
Personal Information further includes Sensitive
Personal Information (“SPI”) as detailed in the table below.
Personal Information does not include publicly
available information that is lawfully made available from government records,
that a consumer has otherwise made available to the public; De-identified or
aggregated consumer information; information excluded from the CCPA’s or CPRA’s
scope, such as health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPPA) and the California
Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal information covered by certain sector-specific privacy laws, including
the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or
California Financial Information Privacy Act (FIPA) and the Driver’s Privacy
Protection Act of 1994.
We have collected the following categories of
Personal Information within the last twelve (12) months:
|
CATEGORY |
EXAMPLE |
COLLECTED |
|
|
A.
Identifiers. |
A real name, alias, postal address,
unique personal identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number, driver's license number,
passport number, or other similar identifiers. |
Yes: Real name and email address (if applicable - when
conducting a transaction). Online identifiers, IP addresses,
unique identifiers, or other similar identifiers. |
|
|
B.
Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical
characteristics or description, address, telephone number, passport number,
driver's license or state identification card number, insurance policy
number, education, employment, employment history, bank account number,
credit card number, debit card number, or any other financial information,
medical information, or health insurance information. Some personal information included in this category
may overlap with other categories. |
Yes:
Photos, videos, and images as part of using the App features. |
|
|
C. Protected classification characteristics under
California or federal law. |
Age (40
years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including familial genetic
information). |
No. |
|
|
D.
Commercial information. |
Records of personal property, products or services
purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies. |
Yes:
Transactions conducted, purchase history and habits, however, not the payment
information which is processed by third-party Google Pay. |
|
|
E.
Biometric information. |
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a template or other
identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data. |
No. |
|
|
F.
Internet or other similar network activity. |
Browsing history, search history, information on a
consumer's interaction with a website, application, or advertisement. |
Yes:
All mentioned in the category. |
|
|
G.
Geolocation data. |
Physical location, approximate location derived
from IP address or movements. |
Yes:
Approximate location. |
|
|
H.
Sensory data. |
Audio, electronic, visual, thermal, olfactory, or
similar information. |
Yes: audio
records, and call logs and records. |
|
|
I. Professional or employment-related information. |
Current or past job history or performance
evaluations. |
No. |
|
|
J.
Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student
maintained by an educational institution or party acting on its behalf, such
as grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student disciplinary
records. |
No. |
|
|
Profile reflecting a person's preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes. |
|
|
|
|
L.
Sensitive personal information. |
Government-issued identifying numbers, financial
account details, genetic data, precise geolocation, race or ethnicity,
religious or philosophical beliefs, union membership, mail, email, text
messages, biometric data, health data, and sexual orientation or sex life. |
Yes:
precise geolocation. |
|
Categories
of Sources of Personal Information
·
Directly and indirectly from activity on
our Services:
For example, from App usage details or your interaction with our Services
collected automatically from measurement tools.
·
Directly from you: For example, from forms you complete,
contact us, etc.
·
From third-parties: For example, from vendors who assist us
in performing services for consumers, advertising networks, internet service
providers, data analytics providers, social networks, and data brokers.
·
Publicly accessible sources.
Use of
Personal Information
We commit to not collecting additional categories of Personal
Information or using the Personal Information already gathered for purposes
that are significantly different, unrelated, or incompatible with those
mentioned, without first notifying you
Children Under the Age 16
We
do not knowingly collect information from children under the age of 16.
Disclosures
of Personal Information for a Business Purpose
|
Business
Purpose (as defined under CCPA) |
Category
of Recipient |
Category
(following the table above) |
|
Helping to ensure security and integrity of
our properties to the extent the use of your Personal Information is
reasonably necessary and proportionate for these purposes. |
Affiliates, operational partners, security
and fraud prevention providers, and operating systems. |
Category B Category D Category F Category G Category H |
|
Debugging to identify and repair errors that
impair existing intended functionality. |
Analytic providers, operational partners,
security and fraud prevention providers, and operating systems. |
Category A Category B Category F |
|
Performing services on our behalf or service
provider, including maintaining or servicing accounts, providing customer
service, processing or fulfilling orders and transactions, verifying customer
information, processing payments, providing financing, providing advertising
or marketing services, providing analytic services, or providing similar
services on our behalf or service provider |
subsidiaries, affiliated companies,
operating systems, CRM, ERP, customer support, cloud computing and storage
vendors, etc. |
Category B Category D Category F Category G Category H |
|
Undertaking internal research for
technological development and demonstration. |
Developers, operating systems, cloud and
hosting providers, SaaS platforms for task management and development,
customer support and optimization tools. |
Category B Category D Category F |
|
Undertaking activities to verify or maintain
the quality or safety of a service or device that is owned, or controlled by
us, and to improve, upgrade, or enhance the service or device that is owned
or controlled by us. |
Developers, operating systems, cloud and
hosting providers, SaaS platforms for task management and development,
customer support and optimization tools. |
Category A Category B Category D Category F Category G Category H |
Sale or
Share of Personal Information
The
CCPA defines “sharing” as “communicating orally, in writing, or by electronic
or other means, a consumer’s personal information” to “a third party for
cross-context behavioral advertising, whether or not for money or other
valuable consideration”. In other words, we may share your Personal Information
with a third party to help serve personalized content or ads that may be more
relevant to your interests and to perform other advertising-related services
such as enabling our partners to serve such personalized content.
In the preceding twelve (12) months, we “sell” or
“share” the following categories of Personal Information for a business
purpose:
|
CATEGORY (CORRESPONDING WITH THE TABLE
ABOVE) |
CATEGORY RECIPIENT |
PURPOSE OF SALE OR SHARE |
|
Category
F Category
G |
marketing
and analytic tools. |
Share
for targeted advertising, cross-contextual behavioral ads, promoting the
Apps, analytics and security services. |
Updates
This notice was last updated on February 12,
2024. As required under the CCPA, we will update our CCPA Notice every
12 months. The last revision date will be reflected in the “Last
Modified” heading at the top of this CCPA Notice.
Data Retention
All as detailed in our Privacy Policy above.
User Privacy Rights Under the CCPA
If
you are a California resident, you may exercise certain privacy rights related
to your Personal Information. You may exercise these rights free of charge
except as otherwise permitted under applicable law. We may limit our response
to your exercise of these privacy rights as permitted under applicable law, all
as detailed under our Privacy Policy above.
|
CALIFORNIA PRIVACY RIGHT |
DETAILS |
|
The right to know what Personal Information the business has
collected. |
The right to know what Personal Information the business has
collected about the consumer, including the categories of personal
information, the categories of sources from which the Personal Information is
collected, the business or commercial purpose for collecting, selling, or
sharing Personal Information, the categories of third parties to whom the
business discloses Personal Information and the specific pieces of Personal
Information the business has collected about the consumer. |
|
Deletion
Rights. |
The
right to delete Personal Information that the business has collected from the
consumer, subject to certain exceptions. |
|
Correct
Inaccurate Information |
The right to correct inaccurate Personal Information that a
business maintains about a consumer. |
|
Opt-Out
of Sharing for Cross-Contextual Behavioral Advertising |
You have the right to opt-out of the “sharing” of your Personal
Information for “cross-contextual behavioral advertising”, often referred to
as “interest-based advertising” or “targeted advertising.” |
|
Opt-out
from Selling or Sharing |
The
right to opt-out of the sale or sharing of Personal Information by the
business. |
|
Limit
the Use or Disclosure of SPI |
Under
certain circumstances, If the business uses or discloses SPI, the right to
limit the use or disclosure of SPI by the business. |
|
Opt-Out
of the Use of Automated Decision Making |
In certain circumstances, you have the right to opt-out of the
use of automated decision-making in relation to your Personal Information. |
|
Non-Discrimination |
The right not to receive discriminatory treatment by the
business for the exercise of privacy rights conferred by the CCPA, including
an employee’s, applicant's, or independent contractor’s right not to be
retaliated against for the exercise of their CCPA rights, denying a consumer
goods or services, charging different prices or rates for goods or services,
providing you a different level or quality of goods or services, etc. We may,
however, charge different prices or rates, or provide a different level or
quality of goods or services, if that difference is reasonably related to the
value provided to us by your Personal Information. |
|
Data
Portability |
You may request to receive a copy of your Personal Information,
including specific pieces of Personal Information, including, where
applicable, to obtain a copy of the Personal Information you provided to us
in a portable format. |
To learn more about your California
privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
Exercising
the User Privacy Rights
We provide
the option to opt out of Sharing for Cross-Contextual Behavioral Advertising or
Selling Personal Information by using the following opt-out options:
-
If you are
a California resident and you wish to opt out of having your data used for
interest-based advertising, you may exercise your right here: https://optout.privacyrights.info/.
-
Use the Global Privacy Control
(“GPC”) signals.
Otherwise please submit a request to
exercise your rights to [email protected]
Your
right to opt-out can be executed without filling out the form by:
- Android
Interface. To opt-out of ads on an Android
device: go to Settings > Privacy > Ads and enable opt-out of Ads
personalization. In addition, you can reset your advertising identifier in
the same section (this also may help you to see less personalized ads).
· You can also opt out of interest-based advertising
with some of the service providers we use, such as Google HERE, and Google Analytics HERE.
- To
learn even more about how to affect advertising choices on various devices
and different versions, please look at the information available HERE.
Notice of
Financial Incentive
We do not
offer financial incentives to consumers for providing Personal Information.
Authorized
Agents
“Authorized
agents” may submit opt-out requests on a consumer’s behalf. If you have elected
to use an authorized agent, or if you were an authorized agent who would like
to submit requests on behalf of a consumer, the following procedures will be
required prior to acceptance of any requests by an authorized agent on behalf
of a California consumer. Usually, we will accept requests from qualified third
parties on behalf of other consumers, regardless of either the consumer or the
authorized agent’s state of residence, provided that the third party successfully
completes the following qualification procedures:
a.
When a
consumer uses an authorized agent to submit a request to know or a request to
delete, a business may require that the consumer do the following:
1.
Provide
the authorized agent signed permission to do so or power of attorney.
2.
Verify
their own identity directly with the business.
3.
Directly
confirm with the business that they provided the authorized agent permission to
submit the request.
b.
A
business may deny a request from an authorized agent that does not submit proof
that they have been authorized by the consumer to act on their behalf.
Direct Marketing Requests: California Civil Code Section 1798.83
permits you, if you are a California resident, to request certain information
regarding the disclosure of Personal Information to third parties for their
direct marketing purposes. To make such a request, please send us an email with
your request and applicable details to: [email protected].
Do Not Track Settings: Cal. Bus. and Prof. Code Section 22575
also requires us to notify you how we deal with the “Do Not Track”
settings in your browser. As of the effective date listed above, there is no
commonly accepted response for Do Not Track signals initiated by browsers.
Therefore, we do not respond to the Do Not Track settings. Do Not Track is a
privacy preference you can set in your web browser to indicate that you do not
want certain information about your web page visits tracked and collected across
websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us.