Effective Date: 24th of May 2018Digital Upground ("we") are committed to protecting and respecting your privacy.
SCOPE OF THIS POLICY
Our mobile application software ("Apps") available online from the app stores where we publish the Apps ("App Site"), once you have downloaded a copy of an App onto your mobile telephone or handheld device ("Device"); and Any of the services accessible through the Apps ("Services") that are available on the App Site or other sites of ours ("Services Sites").
This Policy sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we will treat it. For the purpose of the Data Protection Directive 95/46/EC, the data controller is Bucuresti, Romania.
2. DATA PROCESSING AND YOUR CONSENT2.1 In order for us to process your personal data and/or your sensitive personal data in the way described in this Policy, we will usually need your permission to do so. There are, however, statutory exceptions to this requirement in certain circumstances.
2.4 If you do not accept the terms of this Policy and/or our TOS, you must not use any of the Apps or the Services.
3. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
3.1 "Information you give us ("Submitted information")": You may give us information about you by filling in forms on the App Site and the Services Sites (together the "Sites"), or by corresponding with us (for example, by e-mail). This includes information you provide when you register to use the App Site, download or register an App, subscribe to or use any of our Services, search for an App or Service, make an in-App purchase, share data via an Apps' social media functions, and when you report a problem with any App, our Services, or any of our Sites. The information you give us may include your name, address, e-mail address and phone number, contact book data, the Device's phone number, age, username, password and other registration information. If you use your Facebook account or other third party social network accounts to register for the Services, we will collect your Facebook account or other third party social network account information.
3.2 Information we collect about you and your Device ("Collected Information"): Each time you visit one of our Sites, use one of our Apps or use any of our Services we may automatically collect information about you. This may include the following information:3.2.1 technical information including the type or model of mobile Device you use, a unique Device identifier (for example but not limited to, your Device's IMEI number, the MAC address of the Device's wireless network interface, the mobile phone number used by the Device, or your Device’s android identification number), mobile network information, your mobile operating system, the type of mobile browser you use, resolution, screen size, system version, Bluetooth settings, internet connection, RAM, history of app usage, the apps you have installed, the apps you have running in the background, the apps you launch, the apps you have running in the foreground, your mobile Device’s Android advertising identification number, your account activation time or timezone settings, the content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, notifications that have appeared on your mobile Device, your IP address, your mobile country code, your identity, and Device event information such as crashes, system activity, hardware settings and the date and time of your request; if you access the Apps or Services through a mobile device, we may be able to identify the general location of your mobile device.
3.2.2 details of your use of any of our Apps or any of our Services or your visits to any of our Sites and any other resources that you access or download; and3.2.3 we might also request access to your photos, media and files, your Device’s camera, your Wi-Fi connection information and your Device identification, missed calls, SMS and call information.
3.3 Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, search information providers, credit reference agencies) and may receive information about you from them. We may work with third party analytics services, including for example Google Analytics and Facebook Analytics, to help us understand how our Services are being used, such as tracking the frequency and duration of use of our Services. These services may collect information about the content you view, the websites you visit immediately prior to and after visiting an App Site or using the Services, and your system information and geographic information. The information generated about your use of the Services will be transmitted to and stored by the applicable analytics services.
If you contact us, we may keep a record of that correspondence.
5. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
5.1 Submitted Information may be used for the following purposes:
5.1.1 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
5.1.2 to provide you with information about other goods and services we offer that are similar to those that you have already downloaded, used, purchased or enquired about;
5.1.3 to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing user, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those you have previously used. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
5.1.4 to respond to inquiries, where in such circumstances, we may keep a record of your communication to help solve any issues you might be facing;
5.1.5 to notify you about changes to our service;
5.1.6 to ensure that content from our Services and Services Sites is presented in the most effective manner for you and for your Device.
5.2 Collected Information may be used for the following purposes:
5.2.1 to administer our Services and Services Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
5.2.2 to help us better understand how our products and services are being used;
5.2.3 to improve our Services and Services Sites to ensure that content is presented in the most effective manner for you and for your computer. This could include automatic decision making, for example showing different content inside the app in different countries, based on what kind of content other users from each country engaged more with;
5.2.4 to improve the design of our products and services and improve user experience;
5.2.5 to allow you to participate in interactive features of the Services, when you choose to do so;
5.2.6 as part of our efforts to keep our Services and Services Sites safe and secure;
5.2.7 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
5.2.8 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
5.3 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.
We may disclose some or all of your personal data in the following circumstances:
6.1 With your consent. We will share personal information with companies, organisations or individuals when we have your consent to do so.
6.2 Affiliates, vendors, and agents. We provide personal information to affiliates or other trusted businesses or persons to process it for us or to act on our behalf. These parties are subject to contracts and confidentiality agreements and have no independent rights to use data outside of what this Policy allows.
6.3 Analytics Service Providers. We use analytics service providers, such as Google Analytics and Facebook Analytics, to better understand usage patterns of the Services or our Sites. These providers collect information on our behalf using cookies and similar technologies. We use these service providers to better understand how people use our services so that we can improve the design and usability of our products. We do not engage in "tracking" users outside of our Services and Services Sites.
6.4 Advertising Networks To show you relevant advertising, we work with advertising networks such as Google Admob and Facebook Audience Network. To find a full list of the advertising networks we work with, as well as their Privacy Policies, please access this link. These providers may collect information on our behalf using cookies, advertising identifiers and similar technologies. This information, as well as certain behaviours in our apps (for example, the ads you see and click on) may be used, in the future, to show you content that is more likely to be relevant, or that you're likely to engage with.
6.5 Group Companies. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
6.6 Other Disclosures. We may disclose your personal information to third parties:
6.6.1 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
6.6.2 If Digital Upground or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
6.6.3 If we are under a duty to disclose or share your personal data in order to comply with or respond to any legal, statutory or regulatory obligation, order or request.
6.6.4 In order to:
(a) enforce or apply the TOS and other agreements or to investigate potential breaches; or
(b) protect the rights, property or safety of Digital Upground , our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or service providers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By granting your consent to the processing of your personal data in accordance with this Policy and by submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
8.1 The data that we collect from you may be stored and processed for up to 180 days after you stop using our apps.
8.2 You have the right to request the deletion of your personal data, and you can do so from inside the app's menu. If you request the deletion of your personal data, we will retain your personal data for no longer than 30 days after you request deletion
8.3 You have the right to withdraw consent for the processing of your personal data, and you can do so from inside the app's menu. If you withdraw your consent, your data will no longer be collected, and we will retain your personal data for no longer than 30 days.
9.1 We take reasonable measures to protect your personal information in an effort to prevent loss, misuse and unauthorised access, disclosure, alteration, and destruction. We take the following steps to help keep personal information secure:
9.1.1 We encrypt data transmissions using SSL technology.
9.1.2 We have reasonable measures in place to protect the physical security of records we store on our premises.9.1.3 We restrict access to personal information to employees, contractors, agents and other trusted business partners who need to know that information in order to process it for us for the purposes described above, and who are subject to confidentiality or employment agreements.
9.1.4 We take steps to ensure that adequate levels of data protection are provided in any country outside of the EEA to or in which we may transfer or maintain your personal information.
9.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Access to any of your personal data is restricted to only those employees or partners of Digital Upground who are authorised to access such personal data and only on terms in compliance with this Policy. All employees are given proper instruction on the handling of any personal data.
10.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. In each communication you will have the option to opt-out of or unsubscribe from receiving any further marketing communications. You can also exercise this right to opt-out or unsubscribe at any time by contacting us at flashstudio.dev[at]gmail.com
10.2 The Services or our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Apps or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
10.3 You have the right to request the deletion of your personal data, and you can do so from inside the app's menu.
10.4 You have the right to withdraw consent for the collection and processing of your personal data, and you can do so from inside the app's menu.
10.5 You have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. You can find a list of Data Protection Authorities, and contact data for each of them, here.
11.1 The Data Protection Directive 95/46/EC gives you the right to access the personal data we hold about you. Your right of access can be exercised in accordance with that Directive. Any such access request may be subject to a nominal fee.
12.1 The Services may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services.
12.2 We accept no liability howsoever arising for the content, accuracy or reliability of any third party materials or websites or social media services, or any part of them, which may be referenced from time to time by link or other means at this site or otherwise via the Services or for the data collection and use practices or security measures exercised by third parties.
13.1 Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start an App or log onto the Services or one of the Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Apps or the Services.
14.1 Questions, comments and requests regarding this Policy are welcomed and should be addressed to flashstudio.dev[at]gmail.com