Privacy Policy of Chrooma Keyboard

Full policy

Owner and Data Controller

Loopsie SRL, Via Teodosio 85, Milano, Italia

Owner contact email: info@loopsie.it

Types of Data collected

Among the types of Personal Data that Chrooma Keyboard collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Chrooma Keyboard.
Unless specified otherwise, all Data requested by Chrooma Keyboard is mandatory and failure to provide this Data may make it impossible for Chrooma Keyboard to provide its services. In cases where Chrooma Keyboard 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.
Any use of Cookies – or of other tracking tools – by Chrooma Keyboard or by the owners of third-party services used by Chrooma Keyboard 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 Chrooma Keyboard and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

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 Chrooma Keyboard (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

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 concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Hosting and backend infrastructure, Analytics, Managing contacts and sending messages, Infrastructure monitoring, Social features, Content performance and features testing (A/B testing) and Advertising.

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.

Detailed 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 Chrooma Keyboard, 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.
  Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Chrooma Keyboard. For more information, please check the privacy policies of the relevant services.
  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.

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

  Chrooma Keyboard may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

  Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

  Personal Data collected: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

• Analytics

  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.

  Amplitude (Sonalight, Inc.)

  Amplitude is an analytics service provided by Sonalight, Inc.
  This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Amplitude privacy policy.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Facebook Analytics for Apps (Facebook, Inc.)

  Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

  Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google Analytics for Firebase (Google LLC)

  Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
  In order to understand Google's use of Data, consult Google's partner policy.

  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

  Chrooma Keyboard uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

  Personal Data collected: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Chrooma Keyboard.

  Firebase Remote Config (Google LLC)

  Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Hosting and backend infrastructure

  This type of services has the purpose of hosting data and files that enable Chrooma Keyboard to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Chrooma Keyboard. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Heroku (Heroku, Inc.)

  Heroku is a hosting service provided by Heroku, Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Firebase Cloud Storage (Google LLC)

  Firebase Cloud Storage is a hosting service provided by Google LLC.

  Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Firebase Realtime Database (Google LLC)

  Firebase Realtime Database is a hosting and backend service provided by Google LLC.

  Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Infrastructure monitoring

  This type of service allows Chrooma Keyboard to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Chrooma Keyboard.

  Firebase Crash Reporting (Google LLC)

  Firebase Crash Reporting is a monitoring service provided by Google LLC.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Firebase Performance Monitoring (Google LLC)

  Firebase Performance Monitoring is a monitoring service provided by Google LLC.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Firebase Cloud Messaging (Google LLC)

  Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Firebase Notifications (Google LLC)

  Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Social features

  Firebase Dynamic Links (Google LLC)

  Firebase Dynamic Links is a social feature provided by Google LLC. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within Chrooma Keyboard.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

• Mocha - Search Emoji Privacy Policy

  You can access the privacy policy at this link
  
  https://s3.amazonaws.com/chrooma-us/SearchEmoji_Privacy_Policy_2018v2_Sept_2018.pdf

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

Legal action

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 Chrooma Keyboard 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.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Chrooma Keyboard may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Chrooma Keyboard and any third-party services may collect files that record interaction with Chrooma Keyboard (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

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.

How “Do Not Track” requests are handled

Chrooma Keyboard 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 Chrooma Keyboard 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.

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.