(Last Updated: May 13, 2022)
The data controller is Oxagile LLC 165 Broadway, 23rd Floor, New York, NY 10006, USA
INFORMATION WE COLLECT FROM YOU
The information we collect include:
- Device Information. When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, and the mobile device identifiers (such as your device ID, advertising ID), language and time zone and IP address.
- Usage Information. We collect information automatically about your activity through our Services, for example date and time you used a service, features you have used, in-app purchases history, subscriptions, and advertising that you click on and data generated when you use our Services.
- Other information. We may collect upon your permission other information such as precise geolocation (latitude and longitude) using information including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, we may ask for access to your camera in case you want to use certain features of our Services.
- Information we obtain from third parties. We may receive information about you from our analytic service providers with data they collect through our Services in accordance with their own privacy policies. A list of the third parties that operate in our Services can be found in the APPENDIX B
- Customer enquiries. We collect some information from you when you provide it to us directly, such as via an online form such as name and email or when you contact us through our in-app support feature or when you send us an email directly.
HOW WE USE YOUR INFORMATION
- To provide and maintain our Services, recognize you when you return to our apps, and to perform essential business operation, our legal basis for processing is performance of a contract with you which you entered into with us when you download our Services and accept our End User License Agreement.
- To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data), our legal basis for processing is legitimate interests for running our business, provision of administration and services.
- To communicate with you about apps support and to understand how you use our Services so that we can continuously improve our offerings, our legal basis is performance of a contract, legitimate interests or consent depending on the particular case to keep our users updated about our Services and our new features in accordance with your preference, and to continue to improve the Services we offer.
- To cross-advertise our Services and products and to send push notifications for changes to our Services, to allow you to participate in new features of our Services when you choose to do so, our legal basis is legitimate interests to be able to advertise our Services and products to our users and keep our users updated about our Services and our new features in accordance with your preference.
- To serve personalized advertisements in our Services using third-party advertising networks, our legal basis is legitimate interests to run our business. You can opt-out from personalized advertisement experience, at any time by checking the privacy settings of your Android or iOS device.
For Apple Devices:
- Open Settings
- Select Privacy
- Select Tracking and disable tracking per individual app
For Android Devices:
- Open Settings
- Select Google
- Select Ads and enable “Opt out of Ads Personalization”
HOW LONG WE RETAIN YOR INFORMATION
HOW WE SHARE YOUR INFORMATION
We share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
We may share such information to:
- Our analytics providers.We use third-party analytics such Firebase for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking feature.
- Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as iCloud, Google Cloud Platform;
- Third-party advertising partners.We have contracted with certain third-party advertising networks that assist us in delivering advertising to you.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps and Services. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.
The list of our current service providers and partners is available in Appendix A and Appendix B.
We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.
For any additional questions about third-party information collection, please refer to firstname.lastname@example.org
Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.
LOCATION DATA AND SERVICES
Our mobile applications require access to precise location data on your device ins order to function even when the app is closed or not in use. However, precise location data is stored locally on your device and is not transmitted to our servers and is not shared with any third parties.
YOUR RIGHTS AND OPTIONS
With respect to Your personal data We process (if any) You have the right:
- to obtain from Us the information regarding Our processing of Your personal data;
- to obtain from Us without undue delay the rectification of inaccurate personal data concerning You;
- to obtain from Us the erasure of Your personal data (Your ‘right to be forgotten’);
- to restrict Our processing of Your personal data, when it is permitted under applicable law;
- to obtain from Us Your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any obstacle on Our side;
- to withdraw Your consent to Our processing of Your personal data (where We are relying on consent to process Your personal data).
- to lodge a complaint against Us with a supervisory authority for GDPR purposes.
Any requests to exercise your rights should be made through our contact support feature located in our apps. You can also send us an email at email@example.com.
LINKS TO OTHER SITES
APPENDIX A – Advertising networks and their partners
Below, you can find a list with third-party advertising networks and their partners, with whom we work to provide you with a personalized advertisement experience within our apps. The advertising networks listed below, are independent data controllers in respect of your personal data and you can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.
In order to provide personalized advertisements to our users, those listed below use device information that include personal and non-personal information, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize this advertising procedure. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple’s ID for advertising (IDFA).
AdMob by Google and their partners
AdMob by Google is provided by Google Inc. (US)
For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903
You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
APPENDIX B – Analytics and other service providers
We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.
Firebase is analytics service provided by Google Inc. (US)