PRIVACY POLICY

Last modified: November 01, 2018.

1. Introduction

Koliuzhnov Viacheslav develops mobile applications. We may also refer to Koliuzhnov Viacheslav as "We" or "Us".

This document, the "Privacy Policy", explains how your personal data is collected and processed by Koliuzhnov Viacheslav when you use one of the mobile applications published in Koliuzhnov Viacheslav Google Play, Amazon and Appstore accounts (the "App").

We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent. We encourage you to review the Privacy Policy whenever you access the App to stay informed about how we process your personal data and how you can protect your privacy.

2. Information collection

When you use the App, we automatically collect general information about you, including:

- Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times.

- Device Information: We collect information about the device you use to access the App, including information about the device software and hardware, unique device advertising ID, mobile network information and time zone. Advertising ID are non-permanent, non-personal, device identifiers such as the Android advertising ID and/or Apple ID for advertising, or IDFA.

3. Information usage

We use information about you for the following purposes in accordance with the legalbases as described below.

Log information and device information are being processed:

a) to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;

b) to provide and maintain the App and the usage experience;

c) to send you technical notices, updates, security alerts, and support;

Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.

d) to provide users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Information Sharing) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).

Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule"). The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Information Sharing).

e) to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with the App; preventing cheating, crime or fraud.

4. Information storage

Koliuzhnov Viacheslav will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules. Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with Koliuzhnov Viacheslav has ceased.

5. Information sharing

We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):

a) Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

b) Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and advertising ID). Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:

- AdMob https://policies.google.com/privacy

- Flurry https://policies.oath.com/us/en/oath/privacy/index.html

The recipients' use of the disclosed information will not be covered by this Privacy Policy.If you have questions concerning the processing carried out by such third parties, please review their privacy policy.

6. Information Protection.

The security of your Information is important to us. We maintain appropriate technical and physical safeguards to protect your Information against accidental or unlawful destruction or loss, alteration, unauthorised disclosure or access, use and all other unlawful forms of processing of the data in our possession. We use the same level of skill in protecting your Personal Information as other similar applications developers. However, since the internet is not a completely secure environment we cannot guarantee that information you transmit via our applications will not be accessed, disclosed, altered or destroyed by breach of any of our safeguards.

7. Links from our Applications

Our mobile applications may have links to other sites. We are not responsible for their content, activities, or the way they use the information they collect and/or you may provide to them. Please review their privacy policies.

8. Your rights

If you wish to use any of the rights described below, you may contact us at: [email protected].

We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Right to request access.

You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:

- the purposes of the processing

- the categories of personal data concerned

- the recipients or categories of recipient to whom the personal data have been or will be disclosed

- the envisaged period for which the personal data will be stored

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

The right to object.

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-ofinterest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.

Right to rectification and erasure.

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR. Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:

- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed

- if you have withdrawn your consent and there are no other legal grounds for the processing

- if you have objected to the processing and there are no overriding legitimate grounds for the processing

- the personal data have to be erased for compliance with a legal obligation in Union or Member State law

- the personal data have been unlawfully processed or

- the personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

The right to restriction.

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest

The right to withdraw consent.

If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your user license to use the App will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability.

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

9. Contact us

If for any reason you are concerned with the way that we may be using your information, you have questions about the privacy aspects of our applications, or you wish to file a complaint, please contact us at:geniussoftbot@gmail.com