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Privacy Policy

This Application collects some Personal Data from its Users. Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.

 

 

This page constitutes the Privacy Policy for this Application.

We have developed this Privacy Policy to help you understand how we use the information you share with us. We encourage you to read this Privacy Policy carefully in order to be able to make informed decisions about your use of this Application.

 

Types of Data collected

 

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, unique device identifiers for advertising, geographic position.

 

The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

 

We use Android Advertiser ID only for advertising.

The advertising identifier is not connected to personally identifiable information or associated with any persistent device identifier.

 

All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.

 

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

 

Users are responsible for any third party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

 

 

Methods of processing the Data

 

The Owner processes the Data of Users in a proper manner and takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

 

 

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

 

 

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

 

Place of processing the Data

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

 

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

 

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

 

 

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

 

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 

 

The purposes of processing the Data

 

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Advertising, Analytics, Handling payments, Location-based interactions, Remarketing and behavioral targeting, Device permissions for Personal Data access, Access to third-party accounts, Backup saving and management, Contacting the User, Interaction with external social networks and platforms and Platform services and hosting.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

 

 

Device permissions for Personal Data access

 

This Application may request certain permissions that allow it to access the User's device Data as described below.

These permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed by this Application.

 

Camera permission

Used for accessing the camera or capturing images and video from the device.

 

Storage permission

Used for accessing shared external storage.

 

 

 

The way this App uses photographs you provide when you use the App, via your Camera and/or Photos (if you have granted us permission to access your Camera and/or Photos):

We access only the specific images you chose to modify using the App at the moment of modification; we do not collect your photo albums even if you grant us your access to them. Any photo you take with the camera or modify while using the app is stored locally on your device. This means that the only device that can view the photo is the device with which the photo was taken or on which the modified photo was saved – the user’s device. We do not collect nor require you to upload photos to our or a third party server. Therefore, we do not share your photos with any third party.

 

 

Information on the processing of Personal Data

 

Personal Data is collected for the following purposes and using the following services:

 

 

Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

 

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out

 

Unity Ads (Unity Technologies ApS)

Unity Ads is an advertising service provided by Unity Technologies ApS.

Personal Data collected: Cookies and Usage Data.

Place of processing: Denmark – Privacy Policy

 

Android Advertiser ID

We use Android Advertiser identifier only for advertising. The advertising identifier is not connected to personally identifiable information or associated with any persistent device identifier.

 

The rights of Users

 

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

 

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

 

 

Applicability of broader protection standards

 

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

is performed by an Owner based within the EU;

concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;

concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

 

 

Additional information about Data collection and processing

 

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

 

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.

 

Acceptance of the Terms

By using this Application, you agree to the terms of this policy. If you do not accept the terms stated in this policy, you should not use this Application. The continued use of this Application after any amendment to this privacy policy will be deemed your acceptance of the changes and/or new terms.

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