Privacy Notice
This privacy notice will inform you how we look after, collect, process, and use your personal data when you use our App and tell you about your legal rights.
About us
Vitalii Kuprenko is the controller and responsible for your data ("we", "us", or "our").
Name | Vitalii Kuprenko | ||
Legal Address | Ukraine, Dnipro city, Krushelnytska Lane 6/119, N/A 49125 | ||
[email protected] – for general questions | |||
[email protected] – for privacy questions | |||
Please note! We do not knowingly process the personal data of users under the age of 16. If you are such a user or the legal representative of such a user, please contact us.
By accessing or registering the App, the user agrees to the privacy notice and consents to collecting, processing, transferring, and using your personal data.
Before using the App, you must read and accept this privacy notice. If you don’t accept and agree to this privacy notice, you must immediately stop using our App.
Sources of data
Depending on your actions, we receive your data when you use and interact with the App.
You can change your personal data by exercising your right to rectification and contact us about it. Please note that the same lawful basis and storage terms apply to the changed data.
We may also receive data from third parties. It depends on your settings and the features you use.
Lawful bases
For processing your personal data, we rely on the following lawful bases:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect (automatically or with your consent), use, store, and transfer different kinds of personal data about you, which we have grouped as follows:
Reasons for Processing | Types of data | Lawful bases |
For marketing and analytical purposes. To provide, improve, and develop the application. | Device Data. Includes model, OS version, and language. Unique device identifiers (including IDFA). | Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app)/ |
For marketing and analytical purposes. To provide, improve, and develop the application. To use functions of the app. | Location and Demographic data. Includes internet protocol (IP), address, and location, country, state, city, zip code, time zone. | Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app). |
For marketing and analytical purposes. To provide, improve, and develop the app. | Log and Usage Data. Information about how you use our app and user activity within the application. | Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app). |
To provide access to the application, identify the user, and track the subscription period. | Data on subscription fees. | Performance of a contract with you. Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app). Necessary to comply with a legal obligation. |
To use App functions. To be able to scan a QR code to set up two-factor authentication | Device functions. Includes your camera. Processing is carried out only on your device and is not transferred to third parties. | Performance of a contract with you. Your consent. |
To use Apple Face ID functionality. | Face recognition data | Your consent. |
To participate in reviewing user refund requests to the Apple App Store or our suppliers to prevent fraudulent and deceptive actions by users. | Consumption Information. Account Tenure, App Account Token (UUID), Consumption Status, Customer Consented, Delivery Status, lifetime Dollars Purchased, lifetime Dollars Refunded, Platform, play Time, Refund Preference, Sample Content Provided, and User Status. | Your consent. It is necessary for our legitimate interests (to keep our records updated and to study how customers use our App). |
We don’t collect personal data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). We don't collect any information about criminal convictions and offenses.
We also undertake to collect only such amounts and types of personal data strictly required for the purposes mentioned in this privacy notice section (data minimization principle).
We will ask for your separate explicit consent for any new processing purpose. To the extent necessary for those purposes, we take all reasonable steps to ensure that personal data is reliable, accurate, complete, and current for its intended use.
Face ID use disclaimer. We may use Apple Face ID to authenticate the user to the App. You can enable Face ID for authentication. We are notified only as to whether the authentication is successful. We can’t access Face ID data associated with the enrolled face. In case of using Face ID, all data is collected and processed exclusively by Apple Inc. as a processor of personal data to the extent and for the purposes specified in this policy. Such data, in particular face recognition data, is not collected, stored or processed by us as a controller.
We share your Personal Data with our service providers, strictly limited to cases and purposes stipulated in this privacy notice.
We’ll not use the information gained through your use of our App and other frameworks for advertising or similar services or sell it to advertising platforms, data brokers, or information resellers.
We require all third parties to respect the security of your personal data and treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes.
We will not process personal data in a way incompatible with the purposes for which it has been collected or subsequently authorized by you by Section "Types of data we collect" of this privacy notice or collect any personal data that is not required for the mentioned purposes.
We disclose potentially personally-identifying information (i.e., personal data) among our employees, contractors, and affiliated or other third-party organizations that (i) need to know that information in order to process it on our behalf or to provide services available at the Company, and (ii) that have agreed not to disclose it to others.
We share your data with the parties below for purposes described in Section "Types of data we collect."
External Third Parties!: Google LLC, Meta Platforms, Inc., Apple Inc., Amplitude Inc., Velia.net Internetdienste GmbH, Firebase, Inc., Appsflyer, Inc.
These parties help us store Personal Data, analyze or keep your data, and display relevant information about the app when you use it to help us understand how you use the App, engage with particular features, and what you like or dislike the most. This information is then used to generate statistical reports.
User’s consumption Information and refund. By requesting a refund in the Apple App Store for an in-app purchase or automatically renewing a subscription, you acknowledge and consent to the transfer by us of Consumption Information described in the "Types of data we collect" section to Apple. Our legitimate interest must prevent fraudulent and deceptive actions by users. Apple uses and protects the data you share through the Send Consumption Information API in accordance with Apple’s Privacy Policy.
Cross-border transfer of personal data.
Some employees, contractors, and affiliated or third-party organizations may be located within or outside the USA, EU, or the European Economic Area (EEA). By using our App, you consent to transfer such information to them.
Changes to the privacy notice
We reserve the right to and may change this privacy notice occasionally. If we make any material changes, we will notify you through our App or email or by presenting you with a new version of this privacy notice for you to accept if we, for example, add new processing activities or collect additional personal data from you.
Your continued use of the App after the effective date of an updated version of the privacy notice will indicate your acceptance of the modified privacy notice.
Opt-out options
You can withdraw your consent or opt-out, whatever applies in your case, from sharing your Personal Data under this subsection anytime by using one of the following options:
Obtaining data from third parties
When a user buys a subscription, we receive transaction data, ID subscriptions, subscription terms, and App statistics from the Apple App Store.
The Apple App Store data processing policy further regulates the collection, processing, and transmission of data on purchase via the Apple App Store.
Banking information
When you pay for a subscription to our App, you share your banking information with the Apple App Store. The privacy notices in the Apple App Store further regulate this relationship.
We do not collect or process your bank information when buying a subscription.
Data security
We have implemented appropriate security measures to prevent your data from being accidentally lost, used, or accessed unauthorizedly, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data based on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We also use technical data encryption tools like SSL protocols to secure your data.
Data retention
How long will you use my personal data?
We will only retain your data for as long as necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
We store your data while you use our App.
In some circumstances, you can ask us to delete your data. To send an email to our address: [email protected].
In some circumstances, we may anonymize your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We require all third parties to respect the security of your personal data and treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process it for specified purposes and under our instructions.
We do not sell (or engage in any other commercial activity) user data to other companies. User data is used solely to ensure the app's functionality.
Your legal rights
Please note! Depending on the state and legislative requirements, we have from 30 to 60 days to exercise your request, with the right to postpone it for 30 days more. |
If your complaint is not satisfied, you can file a complaint with the Federal Trade Commission.
Your rights vary depending on the laws that apply to you but may include:
Right | Description | Area | |
Right to access | You can request an explanation of how your personal data is processed. |
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Right to correct | You can change the data if it needs to be more accurate or complete. |
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Right to delete | You can request to delete your personal data from our systems. |
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Right to portability | You can request all the data you provided to us and request to transfer data to another controller. |
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Right to opt out of sales | The right to opt out of the sale of personal data to third parties. |
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Right to opt out of certain purposes | The right to opt-out of processing for profiling/targeted advertising purposes. |
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Right to opt out of the processing of sensitive data | The right to opt-out of processing of sensitive data. |
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Right to opt in for sensitive data processing | The right to opt in before processing sensitive data. |
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Right against automated decision-making | A prohibition against a business making decisions about a consumer based solely on an automated process without human input |
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Private right of action | The right to seek civil damages from a controller for statute violations. |
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Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is missing from the list, please contact us. | |||
California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by the CCPA.
We do not sell your personal information to anyone nor use your data as a business model.
However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. Please contact us if you would like to record your preference that we will not sell your data in the future.
As data subjects, you have privacy rights prescribed by Canada’s federal and provincial privacy laws.
If you want additional information, please contact us by filling a request.
If your complaint is not satisfied, you can file a complaint to the Office of the Privacy Commissioner of Canada.
Glossary
Legitimate Interest: This refers to our business interests in conducting and managing our operations to provide you with the best service/product and the most secure experience. We carefully consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data based on our legitimate interests. We do not use your personal data for activities where our interests are outweighed by the impact on you (unless we have your consent or are legally required or permitted to do so).
For more information on how we assess our legitimate interests against potential impacts on you for specific activities, please contact us at [email protected].
Performance of Contract: This means processing your data as 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.
Compliance with Legal or Regulatory Obligations: This means processing your personal data where necessary to comply with legal or regulatory obligations that apply to us.