Privacy policy.
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This Privacy Policy (“Policy”) describes how we collect, process, use and share your personal information when you use the Aveola mobile application (the “App”), the services and Service provided through it (together with the App, the “Service”).
1. CONTROLLER’S NAME AND CONTACT DETAILS
The data controller in respect of our Service (as defined below) is:
Pepitama Limited ("Aveola", "We", "Us" or "Our")
Registered number HE 432934
loanni Mina, 8, Agios loannis, 4871,
Limassol, Cyprus
Email: [email protected]
2. GENERAL INFORMATION IN BRIEF
We process Personal Data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms for which require the protection of your Personal Data.
3. INFORMATION WE COLLECT
In relation to your use of our Service, we collect information either directly from you or indirectly.
3.1. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you provide to us. You provide us information about yourself when you register for and/or use the Service. For example: email, name (nickname), gender, date of birth, access to camera/microphone. You may also decide to answer quiz questions and upload a photo.
3.2. INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our Service.
a) Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
b) Device and Location data
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. We also record the ads in our App with which you interact (and the Internet links to which those ads lead).
c) Usage data
We record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, how often you use the App, how long you are in the App, your subscription orders.
d) Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
How opt out of targeted advertising and analytics
If you wish to limit behaviourally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out choice will take effect.
For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).
3.3. INFORMATION FROM OTHER SOURCES
When you use sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with Apple screen. Find more about sign with Apple here.
4. HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to perform the contract with you as a user. We will use your Personal Data, unless otherwise prohibited by law, for the following purposes:
· to provide you with the Service you request;
· to research and analyze your use of the Service;
· to communicate with you about your Account or transactions with us and send you information about features on our Sites or changes to our policies;
· to provide support including, but not limited to, Service updates and other similar communications;
· to send you marketing communications;
· to personalize your advertising;
· to enforce our Terms of Use;
· to combat fraud;
· to comply with our legal obligations;
5. HOW WE SHARE YOUR INFORMATION
For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data with the following categories of third parties:
(1) Advertising and advertising measurement partners
a) We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s Service (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, installed the App). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s Service (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.
b) Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.
c) We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website.
d) We also use Snapchat Advertising Platform together with Snapchat Audience Based Match, which is an ad delivery service provided by Snapchat that can link the activity of some users of our App with the Snapchat advertising network and show some of our ads to them. As a result, you may see more of ads on Snapchat in case you use our App. Snapchat allows you to Opt Out of their audience based ads. Privacy Policy.
e) TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). TikTok’s Privacy Policy.
f) Unity Ads is a comprehensive monetization platform for Unity, iOS, and Android developers. For more information, please refer to Unity Privacy Policy.
(2) Data storage partners: we store some of your information using third-party data storage services owned or operated by other entities.
a) To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.
b) We use Firebase Performance Monitoring, which is monitoring service provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.
c) To monitor infrastructure and the App’s performance, we use Crashlytics, which is a monitoring service provided by Google. Here’s its Data Collection Policy.
(3) Communication service providers. The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping on links included in the message.
a) To communicate with you we also use Firebase Cloud Messaging, which is message sending service provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our Website across platforms such as Android and iOS when you access our Website from a mobile device or across your internet browser when you access our Website from a laptop. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send reminders only to users who used the Website more frequently. Google's privacy policy.
b) We use Apple Push Notification service (“APNs”), that is a notifications service provided by Apple. APNs allows us to send information to iOS devices. Apple’s privacy policy.
(4) Research ana analytics partners: we may provide access to some of your data to provide marketing-related and other research.
a) To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy. Appsflyer allows you to Opt Out of having data from my device sent to Appsflyer's servers for apps usage collection.
b) We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our Website, how often users make purchases, and other interactions. Lean more about Facebook’s approach to data from its Privacy Policy.
c) To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase.
d) Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy.
e) We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information. Google’s Privacy Policy.
f) We also use RevenueCat, a mobile subscription toolkit. If you want to learn more about how RevenueCat handle your data, please read its Privacy Policy.
(5) Public authorities and auditors: some personal data shall be disclosed to public authorities, e.g., tax and customs authorities, auditors, and other competent parties, in accordance with the laws of each local jurisdiction where we operate;
(6) Change of control: we may share your information as part of, or during the negotiation/preparation of, our company’s sale, merger, change in control, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
6. YOUR RIGHTS
To the extent provided by applicable law, you can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also have the right to request that we delete personal information that we hold about you. You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.
To the extent provided by applicable laws, you can also ask us to restrict or limit the processing of your personal information, as well as to provide you with personal information that we have collected from you so that you may use it for your own purposes, and to ask us to share (port) this data to another controller.
In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
You also may have the right under applicable law to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.
We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in the EU Member State where you reside, work or where the alleged infringement has taken place.
To exercise any of your privacy rights, please send a request to [email protected].
7. OPT-OUT OF DIRECT MARKETING AND RIGHT TO OBJECT
You can unsubscribe from marketing email in the footer of any marketing email. Please note that even if you unsubscribe from all our personalized marketing emails and messages, we will still send you some notifications (we often refer to them as “transactional”), e.g. to confirm purchases or changes in your Account, give warranty or security information, information about changes to the Terms of Use and Privacy Policy. We will be able to stop all communications only after your Account is deleted.
Where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data are necessary for the establishment, exercise or defense of legal claims. To exercise your right to object please send a request to [email protected].
8. AGE LIMITATION
We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us.
9. INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
10. CHANGES
We may change this Policy from time to time for various reasons, such as legal and regulatory changes, changes in industry practices and technological developments that need to be reflected. If the changes are material, we may provide you additional notice to your email address.
11. SHINE THE LIGHT
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
12. CONTACT
You can contact us via [email protected].
Effective as of: 28 April 2022