Privacy Policy
The foreword.
This Privacy Policy (hereinafter the “Policy”) is intended to help you to ascertain how do we collect your information (or "data"), why do we collect that information, with whom do we share your information and how long do we store it. Additionally, here you can find the information on how can you manage the processing of your information and what rights do you have in the course of the processing of your information by us.
What information about you do we collect?
When you use our Application, we collect the following information about you:
Device data. We collect the following information about your device:
- The version of Android and its firmware (build);
- The information about the model of your device, its manufacturer;
- The information about your Device ID and other related identifiers;
- The language and time-zone, chosen on your device;
- The information about your device display (screen size and resolution);
- The information from the accelerometer, pedometer, vibration accelerometer of your device (if applicable);
- The information on Google accounts, installed on your device;
- Information from your device camera (if applicable).
Location and telecommunication data:
- The information about your mobile network operator and/or your internet provider;
- The information about your location.
Performance data:
- We monitor how do you use our Application: the buttons you clicked, the pages you visited, your performance within the Application, the information on whether or not have you read a notification or message.
Marketing and contact data:
- The referral code you used;
- Your e-mail address (if you contact us via the Application interface or by e-mail).
How do we use your information and in what legal grounds?
The Purposes of processing Legal Ground of the processing
A) To provide you with all the functionality of our Application.
B) To provide you with Application, adapted for your device, display and firmware.
A) Your Consent.
B) The processing is necessary for the purposes of the legitimate interests pursued by Us.
A) To provide you with the Application, tailored for your interests, preferences, needs and geography.
B) To provide you with the Application in your language.
C) To deliver you personalized advertising materials. A) Your Consent.
B) The processing is necessary for the purposes of the legitimate interests pursued by Us.
To administer our Application in order to protect our business. We use your information in order to prevent any fraud, cheating, collusion and other illegal activity. We can also track your information in order to prevent any attempts to attack, hack or otherwise intervene in the performance of our application and digital infrastructure of the our Company. The processing is necessary for the purposes of the legitimate interests pursued by Us.
A) To respond to your message or your request.
B) To contact you. For example, if we discovered a suspicious activity of your profile, we may use the e-mail of your Google account in order to communicate with you on this issue. A) Your Consent.
B) The processing is necessary for the purposes of the legitimate interests pursued by Us.
To comply with the request of the Public Authorities, such as Police, Court, Financial Regulators or their Investigation Units. The processing is necessary for compliance with a legal obligation to which We are subject.
To maintain the record of processing activities. The processing is necessary for compliance with a legal obligation to which We are subject.
To undertake research and analysis. We remove all personally identifiable information from your profile sets - only statistical information shall be retained (for example, the age, gender, geography, device manufacturer and other). Then, this statistical information will be used to undertake research on how our Application is used by the different groups of people. Please note that after the anonymization this information shall no longer be classified as "personal data", because it will contain no personally identifiable information and, as the result, you couldn’t be identified through this information. A) Your Consent.
B) The processing is necessary for the purposes of the legitimate interests pursued by Us.
With whom do we share your information?
The members of our business group.
We may share your information with our employees, contractors, affiliates. Our Application is developed and maintained by the large staff. Thus, your information may be shared with those people. We want to assure you, that all the members of our team, who has access to information of our users signed proper agreements on the confidentiality of our user`s information.
Providers of Analytics services.
We use Analytics services to understand the needs of our users and optimize their experience with our Application.
Facebook.
We use Facebook Software Development Kit (SDK). We share with Facebook your Device Data to display advertising in our Application or to manage and improve our advertising.
In order to find out how Facebook processes your personal information, please follow Facebook Data Policy
Firebase.
Firebase is an analytics provider, owned by Google. We share with Firebase your Device data and Performance data for A) To track events in our Application. B) To monitor the behaviour of our users. For example, we track on how our user reacts to the new functionality and features of our Application. C) To conduct A/B test via Firebase Remote Config. A/B tests mean that we will provide some categories of our users with new screens or the functionality, tailored for the needs of the particular audience. Then, Firebase shall track on how users react to these changes. D) To track how some particular incidents and events happened. For example, Firebase tracks how crashes of our Application took place. F) To prevent fraudulent, illegal use of our Application.
In order to find out how Firebase processes your personal information, please, follow Privacy and Security Policy of Firebase
Host providers, Software providers and other providers of IT Services.
Please note, that when providing you with the Application, we may involve third parties, and, thus, your data may be shared with these parties. You should note, that all those transfers are based on proper data transfer agreements. It means that all these third-parties shall be obliged to process your data in accordance with this Policy.
Public Authorities.
We may disclose your data to the Public Authorities, such as Police, Court, Financial Regulators or their Investigation Units upon their lawful requests.
Protection of children.
Please note, that this Application is not intended for the users under the legal age (in most of the countries this age is 18 years old). If you are under the legal age of your jurisdiction, you should stop the use of our application. If you used our application before discovering a fact, that this Application is not intended for children, please, send us a notification to remove all your data.
Information for parents and legal guardians - if you discovered, that your child or ward used or uses our application - please, contact our Support Team - we will remove all the information from your child or ward what we have.
We assume no responsibility for any use of our Application by the children.
How long do we store and how do we protect your information?
Time limit for the storage of information:
We store your personal information as long as you use our Application. We may store your personal information for an additional period of time if:
- We need this information for fraud investigation;
- We have a legal obligation to store your information for an additional period of time.
As specified before, we may anonymize your data for the purpose of further researches of our audience. Please note that after the anonymization this information shall no longer be classified as "personal data", because such information will contain no personally identifiable information and, as the result, you couldn’t be identified through this information.
Protection of information.
We protect your information by application of modern encryption standards. It means that your information can be decrypted only by use of the decryption key. The decryption keys are in exclusive access of authorized members of our team. It means, that even in case of any hypothetical leakage of the information, unauthorized entities would not get any of your information.
How can you manage the processing of your information?
You can manage the processing of your information either a) by the interface of our application; or b) by contacting our Support Team via e-mail [email protected]:
The right to access. You can ask us whether or not do we process your personal information, and, if we indeed process your information, to request us for a copy of the information we have about you.
The right to correction. You can send us a request to correct inaccurate or no longer relevant personal information concerning you.
The right to delete your information. You can send us a request to remove all personal information we have about you.
The right to portability of your information. You can request us to provide you with your personal information in a structured, commonly used and machine-readable format and/or transmit this information to another Company.
The right to withdraw consent. You can always withdraw previously given consent to the processing of your personal information. It means that we shall stop the processing, for which your consent is required. Please note, that any withdrawal is without prejudice to the lawfulness of processing, consent to which was previously given.
If you reside in the European Economic Area, you request us to exercise your data subject`s rights under the Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR"):
The right to object to the processing. You can object, on grounds relating to your particular situation, to the processing of your personal information, if the processing was necessary for the purposes of the legitimate interests pursued by us or by the third-party, which processed your personal information on our behalf. You can also object to the processing of your information for direct marketing purposes.
The right to restriction of the processing of your personal information. You can obtain from us the restriction of your personal data processing in case of one of the following conditions applies: A) you contested the accuracy of your personal information - the restriction shall be applied for a period enabling to verify the accuracy of your personal data; B) the processing was unlawful and you oppose the deletion of your personal data and request the restriction instead of the deletion; C) We no longer need your personal information, but you need this information for the establishment, exercise or defence of legal claims; D) You exercised the right to object the processing and want to restrict the processing of your personal information pending to verification whether our legitimate grounds override those of you.
Restrictions to the rights:
A) We will exercise your request only if we are able to determine your personality. We shall do this to avoid your data to be obtained by the wrong hands.
В) The exercise of your request may be restricted by the legislation, to which we are subject. We will notify you the legal ground of the restriction in the letter response to your request.
The right to lodge a complaint.
In case of any problems, or disputes, or complaints, please, do not hesitate to contact our Support Team via e-mail [email protected] will do our best to solve your problem or find a mutually beneficial outcome. If you are not satisfied with the outcome, you can realize your right to lodge a complaint with the supervisory authority.
If you reside in the European Union, you can find the relevant supervisory authority by the link
https://edpb.europa.eu/about-edpb/board/members_en
For EU residents - transfer of the information within the European Union.
Please note, that due to the global nature of our business, your information may be transferred outside the European Union. The legislation on the personal data protection in these countries may differ to legislation in force within the European Union. By accepting this Policy, you hereby accept your information to be transferred outside the European Union. However, all the transfers of the information of our EU customers outside the European Union are based on the Standard contractual clauses for data transfers between EU and non-EU countries.
Links to third-party services.
This Application may contain links to other sites. If you click on a third-party link, you will be directed to that site or service. Note that these external sites/services are not operated by us. Therefore, we strongly advise you to review the Privacy Policy or another privacy document of these websites/services. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Changes to this Policy.
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.