Privacy Policy of Alictus Yazilim A.S., owner of Clown Games, with games: Landix.io, Twix.io, Blobie.io, Jellies.io, Shooters.io, Pikes.io, Zlax.io, Dotz.io, Goons.io, Fisp.io, Facepunch.io, Snix.io, Smashers.io, Mobg.io, SkyRoyale.io, Biters.io, Slimes.io, 4096 Merge Matc

This Application collects some Personal Data from its Users.


This document can be printed for reference by using the print command in the settings of any browser.

Policy summary

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

    • Advertising

      • AppLovin, AdColony, Chartboost, Fyber, Unity Ads, Vungle, MoPub, Appnext, AppNexus, Applifier, Google AdSense, MobFox, PubMatic, Rubicon Project, SupersonicAds, TubeMogul Advertising Platform, Yahoo App Publishing Advertising, Microsoft Advertising, Apple iAd and RevMob

        Personal Data: Cookies; Usage Data

      • AdMob and Facebook Audience Network

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

    • Analytics

      • GameAnalytics, Analytics collected directly, Google Analytics, Google Analytics with anonymized IP, Appsflyer, Facebook Ads conversion tracking (Facebook pixel), Google Ads conversion tracking, Twitter Ads conversion tracking and Yahoo Advertising conversion tracking

        Personal Data: Cookies; Usage Data

      • Unity Analytics and Facebook Analytics for Apps

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

      • TestFlight

        Personal Data: Cookies; email address; Usage Data

      • Google Analytics for Firebase

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

    • Contacting the User

      • Mailing list or newsletter and Contact form

        Personal Data: email address

    • Data transfer outside the EU

      • Data transfer abroad based on consent, Data transfer abroad based on standard contractual clauses, Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield, Data transfer to countries that guarantee European standards and Other legal basis for Data transfer abroad

        Personal Data: various types of Data

    • Device permissions for Personal Data access

      • Device permissions for Personal Data access

        Personal Data: Storage permission

    • Hosting and backend infrastructure

      • Amazon Web Services (AWS) and DigitalOcean

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

    • Infrastructure monitoring

      • Crashlytics

        Personal Data: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service

    • Interaction with external social networks and platforms

      • Twitter Tweet button and social widgets and Facebook Like button and social widgets

        Personal Data: Cookies; Usage Data

    • Managing contacts and sending messages

      • Firebase Cloud Messaging and Firebase Notifications

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

    • Tag Management

      • Google Tag Manager

        Personal Data: Usage Data

    • Traffic optimization and distribution

      • Cloudflare

        Personal Data: Cookies; various types of Data as specified in the privacy policy of the service

Further information about Personal Data

    • Unique device identification

      This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

    • User identification via a universally unique identifier (UUID)

      This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

    • The Service is not directed to children under the age of 13

      Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.

    • Push notifications

      This Application may send push notifications to the User.

    • Personal Data collected through sources other than the User

      The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
      Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

    • Analysis and predictions based on the User’s Data (“profiling”)

      The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
      User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
      The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

    • Automated decision-making

      Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
      Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
      The rationale behind the automated decision making is:

      • to enable or otherwise improve the decision-making process;
      • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
      • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
      • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

      Consequences of automated decision-making processes for Users and rights of Users subjected to it

      As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
      In particular, Users have the right to:

      • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
      • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
      • request and obtain from the Owner human intervention on such processing.

      To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Contact information

    • Owner and Data Controller

      Alictus Yazilim A.S. - Universiteler Mah. Ihsan Dogramaci Bulv. No:19 Cankaya, Ankara, Turkey

      Owner contact email: privacy@alictus.com

Full policy

Owner and Data Controller

Alictus Yazilim A.S. - Universiteler Mah. Ihsan Dogramaci Bulv. No:19 Cankaya, Ankara, Turkey

Owner contact email: privacy@alictus.com

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 (Google Advertiser ID or IDFA, for example); geographic position; email address; various types of Data; Storage permission.

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 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.
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.

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 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.

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.

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 Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Advertising, Interaction with external social networks and platforms, Infrastructure monitoring, Managing contacts and sending messages, Contacting the User, Data transfer outside the EU, Device permissions for Personal Data access, Hosting and backend infrastructure, Traffic optimization and distribution and Tag Management.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

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.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

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 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.
    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 this Application. For more information, please check the privacy policies of the relevant services.

    AppLovin (AppLovin Corporation)

    AppLovin is an advertising service provided by AppLovin Corporation.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy – Opt out.

    AdMob (AdMob Google Inc.)

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

    Place of processing: US – Privacy Policy – Opt Out.

    AdColony (Jirbo, Inc.)

    AdColony is an advertising service provided by AdColony, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy – Opt out.

    Chartboost (Chartboost, Inc.)

    Chartboost is an advertising service provided by Chartboost Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Fyber (SponsorPay GmbH)

    Fyber is an advertising service provided by Fyber GmbH.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Germany – Privacy Policy.

    Unity Ads (Unity Technologies ApS)

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

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Denmark – Privacy Policy.

    Vungle (Vungle, Inc.)

    Vungle is an advertising service provided by Vungle, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    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.

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

    Place of processing: USA – Privacy Policy – Opt Out.

    MoPub (MoPub Inc.)

    MoPub is an advertising service provided by MoPub Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Appnext (Appnext Ltd.)

    Appnext is an advertising service provided by Appnext Ltd.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Virgin Islands, British – Privacy Policy.

    AppNexus (AppNexus Inc.)

    AppNexus is an advertising service provided by AppNexus Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy – Opt out.

    Applifier (Applifier Ltd.)

    Applifier is an advertising service provided by Applifier Ltd.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Finland – Privacy Policy – Opt out.

    Google AdSense (Google Inc.)

    Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
    Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.

    Personal Data processed: Cookies; Usage Data.

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

    MobFox (MobFox Mobile Advertising GmbH)

    MobFox is an advertising service provided by MobFox Mobile Advertising GmbH.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Austria – Privacy Policy.

    PubMatic (PubMatic, Inc.)

    PubMatic is an advertising service provided by PubMatic, Inc.

    Personal Data processed: Cookies; Usage Data.

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

    Rubicon Project (The Rubicon Project, Inc.)

    Rubicon Project is an advertising service provided by The Rubicon Project, Inc.

    Personal Data processed: Cookies; Usage Data.

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

    SupersonicAds (SupersonicAds Ltd.)

    SupersonicAds is an advertising service provided by SupersonicAds Ltd.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United Kingdom – Privacy Policy.

    TubeMogul Advertising Platform (TubeMogul, Inc.)

    TubeMogul Advertising Platform is an advertising service provided by TubeMogul, Inc.

    Personal Data processed: Cookies; Usage Data.

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

    Yahoo App Publishing Advertising ( Oath Inc.)

    Yahoo App Publishing is an advertising service provided by Yahoo! Inc.
    If the User chooses to opt-out, Yahoo App Publishing will stop tracking data for the device identified by the provided MAC address and/or device identifier going forward.
    Yahoo App Publishing will stop providing ads and/or recommendations to that MAC address and/or device identifier across all publishers.

    Personal Data processed: Cookies; Usage Data.

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

    Microsoft Advertising (Microsoft Corporation)

    Microsoft Advertising is an advertising service provided by Microsoft Corporation.

    Personal Data processed: Cookies; Usage Data.

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

    Apple iAd (Apple Inc.)

    Apple iAd is an advertising service provided by Apple Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy – Opt out.

    RevMob (RevMob Mobile Ad Network)

    RevMob is an advertising service provided by RevMob Mobile Ad Network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Brazil – Privacy Policy.

  • 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.

    GameAnalytics (GameAnalytics ApS)

    GameAnalytics is an analytics service provided by GameAnalytics ApS.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy – Opt Out .

    Unity Analytics (Unity Technologies ApS)

    Unity Analytics is an analytics service provided by Unity Technologies ApS.

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

    Place of processing: Denmark – Privacy Policy.

    Facebook Analytics for Apps (Facebook, Inc.)

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

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

    Place of processing: US – Privacy Policy.

    TestFlight (Apple Inc.)

    TestFlight is an analytics service provided by Apple Inc.

    Personal Data processed: Cookies; email address; Usage Data.

    Place of processing: US – Privacy Policy.

    Analytics collected directly (This Application)

    This Application uses an internal analytics system that does not involve third parties.

    Personal Data processed: Cookies; Usage Data.

    Google Analytics (Google Inc.)

    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 processed: Cookies; Usage Data.

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

    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.

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

    Place of processing: United States – Privacy Policy.

    Google Analytics with anonymized IP (Google Inc.)

    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.
    This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

    Personal Data processed: Cookies; Usage Data.

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

    Appsflyer (AppsFlyer Ltd)

    Appsflyer is an analytics service provided by AppsFlyer Ltd.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Israel – Privacy Policy – Opt Out.

    Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

    Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

    Google Ads conversion tracking (Google Inc.)

    Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Application.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

    Twitter Ads conversion tracking (Twitter, Inc.)

    Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Application.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

    Yahoo Advertising conversion tracking (Yahoo! Inc.)

    Yahoo Advertising conversion tracking is an analytics service provided by Yahoo! Inc. that connects data from the Yahoo advertising network with actions performed on this Application.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: United States – Privacy Policy.

  • Contacting the User

    Mailing list or newsletter (this Application)

    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

    Personal Data processed: email address.

    Contact form (this Application)

    By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: email address.

  • Data transfer outside the EU

    The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
    Users can inquire with the Owner to learn which legal basis applies to which specific service.

    Data transfer abroad based on consent (this Application)

    If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
    In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.

    Personal Data processed: various types of Data.

    Data transfer abroad based on standard contractual clauses (this Application)

    If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
    This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

    Personal Data processed: various types of Data.

    Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (this Application)

    If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
    In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
    Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

    Personal Data processed: various types of Data.

    Data transfer to countries that guarantee European standards (this Application)

    If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
    The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

    Personal Data processed: various types of Data.

    Other legal basis for Data transfer abroad (this Application)

    If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:

    • the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
    • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
    • the transfer is necessary for important reasons of public interest;
    • the transfer is necessary for establishment, exercise or defence of legal claims;
    • the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.

    Personal Data processed: various types of Data.

  • Device permissions for Personal Data access

    This Application requests certain permissions from Users that allow it to access the User's device Data as described below.

    Device permissions for Personal Data access (this Application)

    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 processed: Storage permission.

  • Hosting and backend infrastructure

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

    Amazon Web Services (AWS) (Amazon Web Services, Inc.)

    Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

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

    Place of processing: United States – Privacy Policy; Germany – Privacy Policy; Korea, Republic of – Privacy Policy.

    DigitalOcean (DigitalOcean Inc.)

    DigitalOcean is a hosting service provided by DigitalOcean Inc.

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

    Place of processing: United States – Privacy Policy; Germany – Privacy Policy.

  • Infrastructure monitoring

    This type of service allows this Application 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 this Application.

    Crashlytics (Google Inc.)

    Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

    Personal Data processed: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
    The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

    Twitter Tweet button and social widgets (Twitter, Inc.)

    The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Facebook Like button and social widgets (Facebook, Inc.)

    The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

  • 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 Inc.)

    Firebase Cloud Messaging is a message sending service provided by Google, Inc. 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 processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: USA – Privacy Policy.

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

    Place of processing: United States – Privacy Policy.

  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
    This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

    Google Tag Manager (Google LLC)

    Google Tag Manager is a tag management service provided by Google LLC.

    Personal Data processed: Usage Data.

    Place of processing: United States – Privacy Policy.

  • Traffic optimization and distribution

    This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
    Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser.
    Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

    Cloudflare (Cloudflare)

    Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
    The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.

    Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

Further information about Personal Data

  • Unique device identification

    This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

  • User identification via a universally unique identifier (UUID)

    This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

  • The Service is not directed to children under the age of 13

    Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.

  • Push notifications

    This Application may send push notifications to the User.

  • Personal Data collected through sources other than the User

    The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
    Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

  • Analysis and predictions based on the User’s Data (“profiling”)

    The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
    User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
    The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

  • Automated decision-making

    Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
    Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
    The rationale behind the automated decision making is:

    • to enable or otherwise improve the decision-making process;
    • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
    • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
    • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

    Consequences of automated decision-making processes for Users and rights of Users subjected to it

    As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
    In particular, Users have the right to:

    • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
    • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
    • request and obtain from the Owner human intervention on such processing.

    To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

The rights of Users

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

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.

Cookie Policy

This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

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 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.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application 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, 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.

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

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 notifying 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.

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.

Definitions and legal references

Personal Data (or Data)

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.

Usage Data

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.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

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.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

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.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

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).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: October 11, 2018

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.