I may refer to Service as "I" or "my". I may refer to you as "reader", "you", or "your". The purpose of this policy is to inform you about the information I collect, how I use and share that information, and the ways in which you can control how I use and share that information. By submitting your information through my Service, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your information in accordance with this policy. I am a controller of your personal data. You can contact me at any time convenient for you. Contacts are at the end.
The personal information I am collecting or can collect automatically:
- IP address
The personal information I am collecting or can collect:
- Device ID (UIID for iOS devices, AndroidID for Android devices) This identifier is hashed with SHA256)
- Operating system (iOS, Android or Amazon)
- Location based on your IP-address
- User ID
- Language
- Gender
- Age
- Nickname
- Email (Email is hashed with SHA256 or/and encrypt using AES algorithm)
- Storage, photos and/or media
- Camera
- Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.
What I collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
I do NOT require your nickname and/or gender and/or email and/or age to be your real.
Legal bases for processing:
I will process your personal information lawfully, fairly and in a transparent manner. I collect and process information about you only where I have legal bases for doing so.
These legal bases depend on the services you use and how you use them, meaning I collect and use your information only where:
- it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when I provide a service you request from us);
- it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
- you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or I need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
I don’t keep personal information for longer than is necessary. While I retain this information, I will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, I advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, I may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
Why I collect personal information:
I may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
- for technical assessment, including to operate and improve our app, associated applications and associated social media platforms;
- to provide you with our app and platform’s core features;
- to process any transactional or ongoing payments;
- to contact and communicate with you;
- for internal record keeping and administrative purposes;
- for analytics, market research and business development, including to operate and improve our app, associated applications and associated social media platforms;
- to run competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that I consider may be of interest to you; and
- to comply with our legal obligations and resolve any disputes that I may have.
Disclosure of personal information to third parties:
I may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services I have provided to you; and
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.
International transfers of personal information:
The personal information I collect is stored and processed in EU, or where I or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.
I will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Where I transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
Your rights and controlling your personal information:
Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. Our services are provided only to users aged 18 years and older. I do not allow persons under the age of 18 to use our platform, and I do not knowingly collect personal information from persons under the age of 18. If you suspect that the user is under 18 years old, use the reporting mechanism available on the service. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it. Information from third parties: If I receive personal information about you from a third party, I will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how I process your personal information, I will let you know how the restriction affects your use of our app or products and services. Access and data portability: You may request details of the personal information that I hold about you. You may request a copy of the personal information I hold about you. Where possible, I will provide this information in CSV format or other easily readable machine format. You may request that I erase the personal information I hold about you at any time. You may also request that I transfer this personal information to another third party.
Correction: If you believe that any information I hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. I will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: I will comply laws applicable to us in respect of any data breach.
Complaints: If you believe that I have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. I will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps I will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Cookies:
Our privacy policy covers the use of cookies between your device and our servers.
A cookie is a small piece of data that an app may store on your device, typically containing a unique identifier that allows the app servers to recognise your device when you use the app; information about your account, session and/or device; additional data that serves the purpose of the cookie, and any self-maintenance information about the cookie itself.
I use cookies to give your device access to core features of our app, to track app usage and performance on your device, to tailor your experience of our app based on your preferences, and to serve advertising to your device. Any communication of cookie data between your device and our servers occurs within a secure environment.
Limits of our policy:
Our app may link to external sites that are not operated by us. Please be aware that I have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to this policy:
At our discretion, I may change our privacy policy to reflect current acceptable practices. I will take reasonable steps to let users know about changes via our app or app delivery service. Your continued use of our app after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information. If I make a significant change to this privacy policy, for example changing a lawful basis on which I process your personal information, I will ask you to re-consent to the amended privacy policy.
How long the information is stored:
- Personal data is kept for 12 months since the last usage of the service.
- If you don't use the service for 12 months your personal data will be automatically deleted, the content will be moved to a special user "DELETED", this way the authorship of the content will be impossible to determine
- Until you do not remove it yourself
Manage your personal information:
- You can delete your personal data (or all information including the content) with the appropriate button in the settings menu
The usage of the side services for analytics and advertising:
- Facebook, analytics, read their terms: https://developers.facebook.com/terms/ and business tools https://www.facebook.com/legal/terms/businesstools
- AdCel, advertisings, read their privacy policy https://adcel.co/privacy
- Firebase, analytics, read their privacy policy https://firebase.google.com/support/privacy
You have the right to a number of rights to protect your personal data. These rights:
- The right to access information about you;
- The right to correct inaccurate information about you;
- The right to transfer all or part of the information collected about you to you or another data controller where technically possible (the right to data portability);
- The right to delete any data relating to you. Users may require removal of data without undue delay;
- The right to restrict data processing.
- The right to object in the processing of personal data;
The user has the right to file a complaint with the National Data Protection Agency in his / her country of residence if his rights can be violated.
However, I recommend trying to reach a peaceful resolution of a possible dispute by contacting me.
doption of this policy
I assume that all users have read this document carefully and agreed to its contents.
If someone disagrees with this policy, they should refrain from using the mobile app.
I reserve the right to change the policy at any time
By accepting this policy, you agree that you are 18 or over
How to contact me
Email: support.uapp@protonmail.com
Effective date
14 January 2021