Effective from: May 25th, 2018
Information we collect
Information provided by the user
Customer service through the web form or sending email, we collect the messages with the information provided by the user to track the problem and improve future assistance as well as the email address and the name that appear in the email.
Subscription to the newsletter, we collect the name and email address.
Information we collect automatically
When the user uses our applications with an Internet connection, we collect aggregated user data, which does not allow us to personally identify you. We also use other technologies and external analytical providers that help us collect this information, as specified in the Cookies Policy.
When the user accesses our website we can collect and analyze the following information on your device: browser, IP address, mobile device ID, browser language, operating system or usage and error records.
When the user uses the mobile applications, we automatically receive certain information about the mobile device and the use of the application, including the identifier of the mobile device (such as the IDFA on Apple devices), the operating system, the version, the IP address and other similar data, such as the time spent in the different sections of the application and the error log to solve them in future updates.
When installing the mobile applications, the user is requested to consent to granting access to the geolocation data of the mobile device. By accepting such permission, we collect information about your geo-location and use that information to personalize ads and other location-based features. The user can withdraw their consent at any time, deactivate the GPS or other localization mechanisms as long as the device allows it.
Use of the Information
Our applications use the personal data it collects as described in the previous article for the purposes and with the legal basis described below:
- Share usage data. With the explicit consent of the user, both on our website and applications. We use this data to analyze the use of our app and to better understand the user’s interaction in the different areas of the web and the apps, and certain user information, such as the connection speed depending on the type of network and geographical location.
- Personalized Ads. If the user gives us their consent, we share certain information with the suppliers with whom we work to show personalized advertising that may be of interest to the user.
- Customer Service. According to the data provided by the user at the time of contact to answer their questions, provide assistance and manage Premium accounts. We will communicate with the user through the email used at the time of contact.
- Newsletter and updates notifications. Only with the prior consent of the user, we may occasionally send them information about products, services, special promotions, contests, events and customer satisfaction surveys. The user can subscribe to receive these emails and social media campaigns on our newsletter registration page. The user has the option to withdraw their consent for these types of communications at any time.
The legal basis for such processing of personal data is, therefore, the user’s consent (Article 6  [a] of the GDPR). The user must take into account that they are not legally obliged to provide us with their personal data. However, without their personal data, we will not be able to send them our newsletters or show customized advertising content as described above.
Exchange and divulgation of the information
We do not share, sell, pass or disclose in any other way the user’s personal data to third parties, unless required by law in accordance with the art. 6 (1) (c) of the GDPR, unless it is necessary for the purpose of the contract in accordance with the art. 6 (1) (b) of the GDPR, and unless the user has given us their express consent to do so according to the art. 6 (1) (a) of the GDPR.
The exchange of the user’s personal data with external service providers will be carried out in accordance with applicable data protection laws and will be limited to the extent necessary. These third parties are expressly prohibited from using the user’s personal data for any purpose other than those described here.
The companies with which we share the aforementioned data are:
OpenSignal, Inc (94 Durharm Road, London, N2 9DS, UK, email@example.com)
MoPub (Twitter Inc, 1355 Market St. 94103, San Francisco, CA, USA, firstname.lastname@example.org)
We show ads in our applications through MoPub. If you give consent to personalize the ads we will share the following information.
The MoPub Services are designed to avoid collecting information such as your name, address, or email address, but the personal data we collect does enable us to recognize your device over time and across apps. Depending on where you live and your privacy choices, the personal data we collect includes:
- Device identifiers such as your IP address, iOS Identifier for Advertising (IDFA), Android Advertising ID, or a MoPub-specific identifier.
- Your precise geo-location, when location services have been enabled for an app on your device that has integrated the MoPub Services. Note that when location services have not been enabled in any of your apps that have integrated the MoPub Services, we will still infer data about your location based on your IP address.
- Information that a Publisher Partner has collected about you and shared with MoPub, such as demographic information (e.g., your age or gender) or information about your interests, to help make the ads served to you more relevant.
- Information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g. Chrome, Safari), and screen size.
- Information about your app usage, including the apps on your device that use the MoPub Services and the version of such apps, the app on your device that is requesting an ad, the start/stop time of your app session, your current time zone, and your network connection type (e.g., WiFi, cellular).
- Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s app.
For more information please visit https://www.mopub.com/legal/privacy/
Google Ireland Limited (Gordon House Barrow Street, Dublin, Dublin 4, Ireland)
We use Google services to show ads and obtain analytical data to better understand the general behavior of our users.
To show ads we use AdMob. If the Personalization of Ads feature is enabled, Google will use your information to make the ads more useful to you. For example, if you access a website that sells mountain bikes and that uses Google’s advertising services, a mountain bike ad may appear on another website that includes advertisements published by Google.
If this feature is disabled, Google will not collect or use your information to create an advertising profile or customize the ads it shows you. Ads will continue to appear, but may not be as useful. Ads can continue to be based on the theme of the website or application you use, your current search terms or your general location, but will not take into account your interests or your search or browsing history. However, we may continue to use your information for the purposes mentioned above, such as measuring the effectiveness of advertising and protecting you from fraud and abuse.
When you interact with a website or an application that uses Google services, you may be asked if you want to see personalized ads from ad providers, including Google. Regardless of which option you choose, Google does not personalize the ads that are shown if this option is turned off or if your account does not meet the requirements to see personalized ads.
You can view and control the information we use to show you ads in the [Ad Settings]((https://adssettings.google.com/).
To capture analytical and statistical data about the use of the application, we use Firebase. To share personal data for analysis you have to give your explicit consent at the start of the applications or modify it whenever you want from the menu of the app itself.
Amazon Europe Core SARL (5 RUE PLAETIS, Luxembourg City, L-2338, Luxembourg)
We use an Amazon SDK to show ads in the applications. If you want these ads to be personalized you have to give us your explicit consent. We will share with this company the data detailed above.
Facebook Ireland Limited (4 Grand Canal Square Grand Canal Harbour, Dublin, Dublin 2, Ireland)
If you give us your consent to share personal information, Facebook will display personalized ads through the Facebook Audience Network program. For more information and to make adjustments about the behavior of this ads you can visit the site [https://www.facebook.com/ads/about/(https://www.facebook.com/ads/about/)
AppLovin Corporation (849 High St., 94301, Palo Alto, CA, USA, email@example.com)
We use the AppLovin SDK to show ads in our applications, with your consent, AppLovin collects some data from your device such as:
- Brand of device, model and operating system.
- Device properties related to screen size, orientation, audio volume and battery.
- Telephone company.
- Operating system.
- Country, time zone and language options.
- Type of network connection and speed.
- IP address.
- The browser user-agent used to access the services.
- Advertising identifier (IDFA).
This device information can be captured through other applications and websites over time. This information can be combined with other information using analysis techniques.
For more information visit https://www.applovin.com/privacy/
Fyber N.V. (Johannisstrasse 20, Berlin, 10117, Alemania, firstname.lastname@example.org)
Our applications integrate the Fyber SDK to show ads, if you give your consent to have personalize ads, Fyber can collect the following information:
- Information about your device, such as type, brand and model, network provider, browser type and language.
- Information about your operating system, such as Android or iOS.
- Information about your mobile advertising identifiers such as the Advertising ID (Apple IDFA or Google AAID).
- Information provided by your device, such as your IP, type of network connection and GPS location (only if you have accepted that permission).
For more information visit https://www.fyber.com/legal/privacy-policy/
Ogury Limited (24 Highbury Grove, London, N5 2EA, UK, email@example.com)
We show personalized ads under your consent through Ogury. For more information about what data is captured and for what purpose please visit https://www.ogury.com/privacy/
Glispa (Sonnenburger Strasse 73, 10437 Berlin, Alemania, firstname.lastname@example.org)
We use Glispa Connect services to show ads in our applications. With your explicit consent we may share the following information to make use of the ad personalization.
Information about your device, such as type or model, manufacturer, operating system (such as iOS or Android), telephone company, IP address, web browser, installed applications that use Glispa Connect and the version of those applications, and the identifiers assigned to your device as the Identifier for Advertising (IDFA), Android Advertising ID, or the unique device identifier (a unique number located on your device by the manufacturer)
Registration information, including apps or websites visited, the start and end time of session, time zone, language and type of internet connection. The geolocation of your device (using GPS or other information), provided you have accepted the permission to share location.
Information about displayed, viewed or clicked ads as well as the type of ad and when you have visited the advertiser’s website or installed their app. Glispa anonymizes certain information after collecting it. Like IP addresses or GPS tracking.
For more information please visit [https://www.glispa.com/privacy-policy/(https://www.glispa.com/privacy-policy/)
Tutela Technologies Ltd. (1124 Vancouver St, Victoria, BC V8V 3W2, Canada, email@example.com)
Tutela Technologies Ltd. collects data relating to your use of our apps, other apps and your device, in a pseudonymized manner, that may include (a combination of) Personal Data elements, such as:
- Wireless network performance, usage, and identifiers, and
- other permission-based user information.
Pseudonymous data is shared with wireless service providers and other third parties who use it to analyze aggregate consumer mobile trends and improve your wireless networks. Outside of GDPR participating countries, mobile advertiser ID may be shared for network marketing and advertising purposes in accordance with the Digital Advertising Alliance principles. No data is stored by Tutela for longer than 12 months.
For further information about Tutela’s data practices, including technical and organisational measures to ensure that personal data are not attributed to an identifiable natural person, please see the Privacy Charter. To opt out of data sharing with Tutela, please utilize the opt-out measures provided in the privacy statement, contact firstname.lastname@example.org, or contact us at email@example.com
Huq Industries Limited (Monmouth House, 58 City Road, London, firstname.lastname@example.org)
To help us improve our service we collect the following information on an anonymous basis: Operating System, Date & time, Latitude, Longitude, Accuracy (GPS), SSID (network), BSSID (network), Internal MAC address (network), Bundle ID, Device Model, Device Manufacturer, Carrier Code (Android only), Carrier Name, Sim Code, Country, and Locale.
In addition to helping us to measure the usage of our app this anonymous information is shared with third parties for their business purposes, including the creation of reports, market research and trend analysis. One of these third parties is Huq, data shared does not contain information from which users can be identified and we will not provide additional information to such third parties that enables such third parties to identify you.
You can find a full description of Huq and what it does with the information collected via our app here.
Other cases in which we can share data
We may be required to disclose user information to government officials and members of the security forces in response to a lawful request by a public authority or to comply with a legal obligation, including the requirements of law and order and law enforcement according to the art. 6 (1) (c) of the GDPR. We may also disclose user information in order to achieve our legitimate interests when applying or enforcing our terms and conditions or in response to claims, to protect our rights or the rights of third parties, to protect the safety of any person or prevent any illegal activity (including the purposes of protection against fraud and reduction of credit risk) in accordance with the art. 6 (1) (f) of the GDPR.
If the user has any questions about the judicial weighing in relation to art. 6 (1) (f) of the GDPR, they must contact us through the contact information listed below.
The user is offered a series of options regarding the information we collect and use as indicated in this policy. Some of the options are:
- Marketing communications. If the user has given his consent through the web form to receive news, social network campaigns and promotional emails, they may opt to stop receiving them by following the instructions included in each message received or by writing an email to email@example.com
- Renunciation of personalized online advertising. Through our applications for Android or iOS we include a system of voluntary acceptance to provide us with data to personalize the advertising of our apps. Not activating this permission does not mean that advertising will not be shown, but that the ads shown will not be personalized for you based on the information you provide.
- Renunciation to share data for analytics. Through the acceptance system integrated in our applications you can share or not share the data of use of the application for analytical purposes that help us to have information to develop our app more efficiently.
Information about user rights
The user has the following rights:
- Right of access (Article 15 of the GDPR): the user has the right to request a confirmation of whether or not their personal data are being processed and, as appropriate, to request access to personal data and information, such as the purpose of processing or the corresponding personal data categories.
- Right of rectification (Article 16 of the GDPR): the user has the right to request the correction of incorrect personal data.
- Right of suppression (Article 17 of the GDPR): the user has the right to request the deletion of personal data without undue delay under certain circumstances. For example, if their personal data is no longer necessary for the purposes for which it was collected or if they withdraw the consent on which the processing is based in accordance with art. 6 (1) (a) of the GDPR and if there is no other legal basis for its processing.
- Right to limitation of processing (Article 18 of the GDPR): the user has the right to ask us to limit the processing of their personal data in certain circumstances, for example, if they believe that the personal data we process about them is incorrect or illegal.
- Right to data portability (Article 20 of the GDPR): under certain circumstances, the user has the right to receive the personal data that they have given to us in a structured, commonly used and mechanical reading format, and to transmit them to another controller without obstacles or ask us to do it.
- Right of opposition (Article 21 of the GDPR):
The user has the right to object to the processing of their personal data in certain circumstances, in particular if we process their personal data based on the existence of a legitimate interest (Article 6 (1) (b) of the GDPR) or if we use their personal data for marketing purposes.
The user can enforce these rights at any time by sending an email to correct or modify any information, or request what personal data (for example, name or email) we have stored, or enforce any of their rights as mentioned above by sending us an email to firstname.lastname@example.org
Right to file claims to the Data Protection Authority
The user has the right to submit a claim to a supervisory authority, in particular in the Member State of the European Union in which they habitually reside or work, or in the place of the alleged infringement, if they consider that the processing of his personal data infringes the current legislation on data protection. The user can contact us at email@example.com so that we can provide them with detailed information on the contact details of the respective competent supervisory authorities.
Links to external websites
In particular we offer links to our social network profiles of:
- Facebook (Facebook Ireland Limited, 4 Grand Canal Square Grand Canal Harbour, Dublin, Ireland)
- Twitter (Twitter Inc, 1355 Market St. 94103, San Francisco, CA, USA)
- Google+ (**Google Ireland Limited **,Gordon House Barrow Street, Dublin, Dublin 4, Ireland)
What we do to protect the user’s personal data.
The security of the personal data of the users is very important for us. We have implemented the newest administrative, technical and physical security measures to protect them against unauthorized access, destruction or alteration of information. However, despite all our efforts, no security measure is completely impenetrable. Data maintenance
Lowlevel Studios S.L. Calle Dimas Madariaga, 30, 4B Salamanca 37005 Spain Email address: firstname.lastname@example.org