This Application collects some Personal Data from its Users.
Sharklab SNC di Lorenzo Lazzeri e Simone Cammilli - Via Casentino, 25 - 50127 Florence (Italy)
Owner contact email: firstname.lastname@example.org
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 (Google Advertiser ID or IDFA, for example); Storage permission.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, 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 consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
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.
The Owner 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (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.
The Owner may process Personal Data relating to Users if one of the following applies:
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.
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.
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.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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 Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Advertising, Analytics and Device permissions for Personal Data access.
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.
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, 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. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
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 (i.e accessed to, modified or removed) by this Application.
Used for accessing shared external storage, including the reading and adding of any items.
Personal Data is collected for the following purposes and using the following services:
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.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
AdMob is an advertising service provided by AdMob Google Inc.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data collected: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
MoPub is an advertising service provided by MoPub Inc.
Personal Data collected: Cookies; Usage Data.
Millennial Media is an advertising service provided by Millennial Media Inc.
Personal Data collected: Cookies; Usage Data.
Vungle is an advertising service provided by Vungle, Inc.
Personal Data collected: Cookies; Usage Data.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data collected: Storage permission.
We only use Google Analytics to track the way the app is used, in terms of sections visited and interactions. FVD does not track any information about the download activity performed through the Application.
Ogury’s privacy practices concerning User Data
What is the Ogury Product and how does it work?
Ogury has developed and maintains software code that it integrates into Partner Apps operated by publishers and app developers (“Publishers”) – in these Principles this technology is called the “Ogury Product”. Once the Ogury Product has been integrated into a Partner App, with Users’ consent, Ogury may collect User Data from the tablet, mobile or handheld device (“Device”) on which a Partner App is installed in the manner described in these Principles.
For the purposes of these Principles, we refer to those individuals, on whose Device a Partner App integrating the Ogury Product has been installed, as “Users”.
How is User Data used?
In simple terms – User Data is used by Ogury, advertisers and advertising agencies and Publishers (together “Partners”), so Users can see adverts for products and services they actually want to see based on how they use their Device.
Adverts of this nature are commonly referred to as “interest-based advertisements” or “behavioural advertising”. For more information on interest-based advertising, how it works, and information on choices about how Users can interact with it, Users can go to http://www.youronlinechoices.com/uk/. This is a helpful guide made available by the European Interactive Digital Advertising Alliance a cross-industry coalition of European-level associations with an interest in delivering a responsible European Self-Regulatory Programme for Online Behavioural Advertising, which benefits internet users with greater transparency, choice and control.
Collecting User Data also allows us to effectively cap the number of times that Users see an Ogury Ad, so they do not see the same one too many times or too frequently.
We may also use User Data to create aggregated compilations of Users which is “deidentified” in a manner which prevents that User Data from being associated with, or capable of being associated with, any particular Device, Partner or Partner App (“Aggregated Data”).
In addition to the processes described above, Ogury also uses User Data for its internal purposes which may include:
performing analysis and research aimed at improving the Ogury Product and the services and products Ogury provides to its Partners; and security and fraud detection.
What is User Data?
The Ogury Product allows Ogury to collect real-time information about Users, including the following categories of information which we collectively refer to as “User Data”:
Information and data about how Users use their Devices, together with the applications and systems on those Devices – this information includes:
What Users have bookmarked.What applications Users have downloaded (including the nature and category of those applications).Users’ usage levels of the applications they have downloaded.The nature of any products or services viewed by Users on their Device, whether in‑app or via their browser.
The Usage Data collected by the Ogury Product is not limited to Usage Data that directly relates to the Partner App in which the Ogury Product is integrated. Rather, the Ogury Product collects Usage Data from all applications and systems on the Device on which a Partner App is installed.
Technical Information that is collected by the Ogury Product may include:
The type of Device being used (including manufacturer and model).The version number of the Ogury Product used by the Partner App.A User’s network status.Other analytics and information about Users’ use of their Devices together with the applications and systems on that Device.
To allow Ogury to collect the Usage Data and Technical Information listed above and link it to individual Users, the Ogury Product also collects certain device and user identifiers, which may include a User’s:
Email address.Google Advertising ID. Android ID.Users’ Device ID.
These are used by Ogury and its Partners to link individual Users with their Devices.
All User Data we collect is associated with these Identifiers, rather than their name or other personal information.
AD ENGAGEMENT INFORMATION
To enable Ogury and its Partners to provide personalised Ogury Ads to Users and to report back to our Partners on Users’ engagement and interaction with Ogury Ads, we collect information on how Users engage with Ogury Ads that are displayed to them, including:
What each Ogury Ad is about. The format of each Ogury Ad (e.g., text, image, or video). Where the Ogury Ad is displayed within the Partner App.
In addition, we combine the Ad Engagement Information with Usage Data collected about Users to determine what Users do when interacting with or after viewing each Ogury Ad – for example, did a User go on to buy the product or services that were displayed to them in an Ogury Ad?
OUR POLICY TOWARDS CHILDREN
In accordance with applicable European Union guidance on the practice, we do not use any User Data to target adverts to children. Accordingly, we do not use the User Data we collect to specifically target Ogury Ads to children under 13 years old.
User Data includes any other information (including Personal Data) that may be submitted to us directly.
Users’ acceptance of our Principles
Ogury adheres to its obligations under the Privacy and Electronic Communications Regulations (as amended to implement the EU Cookie Directive). Accordingly, Users are required to give their consent before Ogury starts to collect any User Data from them. In addition, Users may opt-out of such collection at any time by following the instructions outlined at the section titled “Opting Out of Ogury Interestbased Advertising”.
Accordingly, when Users first open a version of a Partner App which contains the Ogury Product, a page is displayed which notifies them that, with their consent, certain User Data will be collected by the Ogury Product unless and until they opt-out from such collection. So that Users are fully and properly informed about our data usage practices and how their User Data is collected, stored, used and shared, they are also provided with a link to these Principles.
If Users do not provide accept the terms of these Principles, Ogury will not collect their User Data and will not deliver them targeted Ogury Ad’s. However, Users will still see advertisements in their Partner App, but the advertisements they see will not be tailored to them based on their User Data.
Opting Out of Ogury Interest-based Ogury Ads
Users can opt out of receiving targeted Ogury Ads and having their User Data collected by Ogury by:
Sending an email to email@example.com with their Google Advertising ID and opt-out from receiving interest-based Ogury Ads
When Users notify us of their desire to opt-out of receiving interest-based Ogury Ads, we will as soon as reasonably practicable stop collecting their User Data. If they opt-out, Users will still see advertisements in their Partner App, but the advertisements they see will not be tailored to them based on their User Data.
In addition, we will, as soon as reasonably possible, delete from our systems any Personal Data comprised in the User Data that we have already collected.
In addition to the opt-out process described above, if their Device permits, Users can opt out of interest-based advertising by changing the settings of their Google Advertising ID by clicking the button titled “opt out of interest-based advertising” in Settings > Google in their Device’s app menu. For more information on this, Users can follow the instructions provided by Google here: Google Play Help. Users should be aware that clicking this opt-out button will disable interest-based ads from all advertising networks that use Google Advertising IDs, although Users will still see untargeted advertisements.
How Ogury shares User Data
We share the User Data (including any Personal Data comprised therein) that we collect in the following ways and with the following parties:
PUBLISHERS AND ADVERTISERS
We may share User Data with our Partners to aid in their understanding of how Users are using Partner Apps and engaging with Ogury Ads.
We may share or sell compilations of Aggregated Data with third parties (including Data Management Platforms).
We may share User Data with the service providers who perform services on our behalf, such as providers of analytics, payment processing, product fulfilment, technical infrastructure, data services, engineering and other technical support, and email and customer support.
We may share User Data in connection with any merger, reorganisation, a sale of some or all Ogury assets, or a financing or acquisition of all or a portion of our business by another company. In these circumstances, Ogury will endeavour to ensure that the parties with whom User Data is shared agree appropriate confidentiality terms to protect the User Data they receive.
We may share User Data for the following purposes:
To comply with laws or to allow us to enforce the terms of these Principles.To respond to lawful requests and legal processes.To protect the rights and property of Ogury, our agents, customers, and others. To protect the safety of our employees and agents, our Partners or any other person.
We may share User Data with other companies within the Ogury group. For these purposes, this means other entities that Ogury controls or are under common control with Ogury. We share information in this way to allow Ogury to provide certain services to such companies and to allow them to perform services for Ogury. This allows us to better help our Partners provide Ogury Ads that are relevant to Users.
INTERNATIONAL DATA TRANSFER
User Data, including any Personal Data therein, may be transferred to, stored at and processed by third parties in a country outside the EEA.
Users should be aware that the data protection and privacy regulations that apply in countries outside the EEA may not offer the same level of protection as provided for inside the EEA.
We require Users provide their consent to the storage, processing and transfer of their User Data in and to countries outside the EEA. We do this by requesting their consent to these practices in the notice that is displayed to them when they first use a Partner App containing the Ogury Product.
We will take all steps reasonably necessary to ensure that such Personal Data wherever it is held or processed is treated securely and in accordance with these Principles and the Act.
DATA MANAGEMENT PLATFORMS
We may share or sell User Data to data management platforms that are used by participants in the advertising industry as sources of data (“Data Management Platforms”). The User Data we may share or sell may include any or all of the User Data outlined above, including Users’ email addresses.
Data Management Platforms use the data Ogury. and many other participants in the advertising industry, sell to them to inform advertising targeting and the purchase of advertising space.
We seek to use reasonable organisational, technical and administrative measures to protect User Data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If a User has any reason to believe that their interaction with us is no longer secure, they should notify us of this problem immediately by contacting us at firstname.lastname@example.org
If, while using one of our Partner Apps, a User recognises a problem with an Ogury Ad, they can notify us of the problem by contacting us via email at email@example.com. We will ask for their email address and other contact information so that they can receive a response.
REQUEST YOUR INFORMATION
The Act gives any individual whose Personal Data we store, the right to access that data. If you wish to exercise this right in accordance with the Act, please contact us at firstname.lastname@example.org. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
We do not collect any sensitive Personal Data in the User Data. Examples of sensitive Personal Data include information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership.
THIRD PARTY OPERATIONS
If Users follow a link to any of third party websites via an Ogury Ad, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We ask that Users please check these policies before they submit any information to these websites. The links to third party websites or locations are for convenience only and do not signify our endorsement of such third parties or their products, content, or websites. If Users disclose information to others, or authorise us to do the same under these Principles, the use and disclosure restrictions contained in these Principles will not apply to any third party. Ogury does not control the privacy policies of third parties.
If you have any questions or concerns regarding our data usage principles, please send us a message at email@example.com.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
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.
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.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
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.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small piece of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).