Privacy Policy English • Whatwapp

Information relating to the Privacy Policy and processing purposes
1. Our Application collects the Personal Data of its Users to allow them greater security in the usability of the services offered by Whatwapp Entertainment S.r.l. which has always based its work on observance and compliance with current legislation and the confidentiality of its Users.
2. The Data of the Data Subject is collected for the following purposes:
  1. manage, improve and optimize our services and the experiences of our Users;
  2. create game accounts and allow the User to use our services and digital content;
  3. allow the purchase of services made available by the Data Controller through third parties authorized to do so (banks or financial intermediaries);
  4. identify and suggest connections with other Users in our games based on the User’s needs;
  5. allow Users to communicate with each other;
  6. provide technical assistance and respond to Users’ requests;
  7. protect the security and confidentiality of all Users;
  8. protect the rights of Whatwapp Entertainment S.r.l. concerning the services offered;
  9. prevent cases of fraud and potentially illegal activities;
  10. provide advertising to our Users;
  11. notify Users of game updates, new products or promotional offers;
  12. administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or operated by us or our business partners
  13. fulfil our legal obligations, resolve any disputes that may arise with the User or between players and enforce our agreements with third parties;
  14. research activities.
3. The processing of Personal Data will be based on principles of lawfulness, correctness, transparency, limitation of processing purposes, minimization of collected Data, the accuracy of Data, limitation of Data retention, integrity and confidentiality of the same.
4. In this section, you will find information relating to the methods of collection and management of Users’ Data.
5. This Policy is to be considered valid also for Article 13 of EU Regulation no. 679/2016 (GDPR), which refers to the information collected directly by the Data Subject.
6. It should be noted that the EU Regulation no. 679/2016 (GDPR) concerns the protection of individuals concerning the processing of their Personal Data and lists the specific rules relating to the free circulation of such Data.
7. This Policy is considered valid as information for all Users who interact with the applications of Whatwapp Entertainment S.r.l.
8. The privacy policy refers only to the use of the Application, and not for other applications and websites that may be consulted by the User through advertising links contained therein, to whose privacy policies, in case of interaction with them, please refer.
9. The privacy policy may be Subject to changes as a result of changes in the relevant legislation; it is the User’s responsibility to periodically consult this section to learn about the methods of processing their Data, which are always available for viewing.
10. In any case, the Data Controller undertakes to inform the Data Subject of any changes to this document through specific notices that will be displayed directly on the Application.
11. If the User is under 16 (sixteen) years old, according to article 8, paragraph 1 of the GDPR, and article 2-quinquies of Legislative Decree 193/2003 and subsequent amendments he will have to legitimize his consent through his parents or whoever takes their place. In any case, Whatwapp Entertainment S.r.l. will endeavour to verify that consent is given or authorized by the holder of parental responsibility for the minor, taking into consideration the technologies and methods available.
12. Our Applications do not intentionally collect personal information from individuals under the age of 16 (sixteen) years, but if this happens we will take appropriate measures aimed at deleting such information from our archives, following a specific reporting. In any case, it is forbidden to use the Application under 13 (thirteen) years of age.
13. This information is to be considered in any case known and accepted by the Users, if they have expressly declared that they consent to the processing of Data through the appropriate “I agree” button, after viewing it. The use of the application will not be allowed if there is no explicit consent to the processing of the Data in question.
Definitions
1. For this Privacy Policy, the following definitions apply:
  1. Personal Data: any information concerning an identified or identifiable natural person (so-called “Data Subject”); the natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location Data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social;
  2. Data Processing: any operation or set of operations carried out with or without the aid of automated processes and applied to Personal Data or sets of Personal Data, such as the collection, registration, organization, structuring, storage, adaptation o modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction;
  3. Limitation to Data Processing: the marking of Personal Data stored to limit their processing in the future;
  4. Profiling: any form of automated processing of Personal Data consisting in the use of such Personal Data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning professional performance, economic situation, health, preferences personal interests, reliability, behaviour, location or travel of said natural person;
  5. Pseudonymisation: the processing of Personal Data in such a way that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and Subject to technical and organizational measures designed to ensure that such Personal Data is not attributed to an identified or identifiable natural person;
  6. Data File: any structured set of Personal Data accessible according to specified criteria, regardless of whether this set is centralized, decentralized or divided functionally or geographically;
  7. Data Controller: the natural or legal person, public authority, service or other which, individually or together, determines the purposes and means of the processing of Personal Data; when the purposes and means of such processing are determined by the law of the Union or of the Member States, the Data controller or the specific criteria applicable to its designation may be established by the law of the Union or of the Member States;
  8. Data Processing Manager: the natural or legal person, public authority, service or other Authority that processes Personal Data on behalf of the Data controller;
  9. The Recipient of the Personal Data: the natural or legal person, public authority, service or other Authority that receives communication of Personal Data, whether it is a third party or not. However, public authorities that may receive disclosure of Personal Data in the context of a specific investigation under the law of the Union or the Member States are not considered recipients; the processing of such Data by said public authorities comply with the applicable Data protection rules according to the purposes of the processing;
  10. Third Party: the natural or legal person, public authority, service or other Authority other than the Data Subject, the Data controller and the persons authorized to process Personal Data under the direct authority of the Data controller or responsible;
  11. The Consent of the Data Subject: any manifestation of the free, specific, informed and unequivocal will of the interested party, with which the same expresses his/her consent, through an unequivocal positive declaration or action, that the Personal Data concerning him/her are being processed;
  12. Data Breach: the security breach that accidentally or unlawfully involves the destruction, loss, modification, unauthorized disclosure or access to Personal Data transmitted, stored or otherwise processed;
  13. Data Protection Authority: independent public authority responsible for monitoring the application of EU Regulation no. 679/2016 (GDPR), to protect the fundamental rights and freedoms of individuals concerning processing and to facilitate the free circulation of Personal Data within the Union;
  14. EU Regulation no. 679/2016 (GDPR): Regulation that establishes rules relating to the protection of individuals concerning the processing of Personal Data, as well as rules relating to the free circulation of such Data, protects the fundamental rights and freedoms of individuals, in particular the right to the protection of Personal Data. The free circulation of Personal Data in the Union cannot be limited or prohibited for reasons relating to the protection of individuals concerning the processing of Personal Data;
  15. Hosting provider: network service that allows the publication on a designated server of pages belonging to a website;
  16. Device: an electronic device used to access the services provided;
  17. Cookies: storage of specific information regarding the interactions between the device and the website/service used, which can be managed through the device or program used;
  18. Identify for Advertisers (IDFA): an identifier that allows Users to control their habits and developers to monetize their applications, guaranteeing Users to have constantly updated advertising corresponding to their interests;
  19. Aggregated Data: Collective Data relating to a group of Users, not suitable for directly identifying the individual natural person (by way of example, but not limited to, use of the services by a group of Users aged between 20 and 25 years).
Data Processing
1. Data Controller
  1. The Data Controller is Whatwapp Entertainment S.r.l., having its registered office in, 20123, Milan (MI), Italy, at Via Venti Settembre n. 27. Whatwapp Entertainment S.r.l. is a company operating in the IT sector and which determines the purposes and means of the processing of Personal Data necessary for the correct and safe use of the services and digital content it provides.
  2. The Data Controller implements all the technical and organizational measures necessary and adequate to ensure a Treatment that complies with the legislative dictates, as expressly sanctioned by art. 24 GDPR.
  3. The Data Controller undertakes to process only the Data necessary for the nature of the activity carried out, ensuring their accessibility by the interested party at all times.
  4. The Data Controller will manage independently and through its employees, the processing of the Personal Data collected, thus exempting it from the need to designate a specific Data Processing Manager.
  5. For any clarification or request aimed at exercising the rights guaranteed to the User referred to in point 9., the User may contact us at the certified e-mail address [email protected] at the e-mail address [email protected], or by sending a special registered letter to the office referred to in point 1.1.
2. Data Processing Place
  1. The Personal Data collected will be processed at the operational headquarters of the Data Controller and in any other place where the parties involved and the Subjects authorized to the processing (for example the employees of the Company) are located, always guaranteeing confidentiality and lawfulness in the execution of the operations implemented for this purpose.
  2. The Personal Data of the interested party may be processed or transferred to a country other than the one in which the same is located. However, these Data will be processed mainly in the EU, in which it is possible to apply the European Regulation 679/2016 according to which this Policy is drawn up.
  3. Personal Data may be processed or transferred to a country outside the European Union; in this case, Whatwapp Entertainment S.r.l. ensures that the countries in which these Data will be processed guarantee a level of privacy protection equal to or higher than that expressly provided for by European Regulation 679/2016, to ensure adequate protection of the rights of the Data Subject.
3. The Juridical Foundation for the Data Processing
  1. The Data Controller is authorized to process the Data based on what is defined in the following points:
    1. the consent, which must be expressly given by the Data Subject at the time of acceptance of this Information Policy, or even only through conclusive facts, such as the use of the Application in question if the User manages to circumvent the reading of this document through bugs or other means for this purpose;
    2. the execution of a contract to which the Data Subject is a party, taking into account the contents and activities possible during the execution of the Application;
    3. the fulfilment of a legal obligation to which the Data Controller is Subject;
    4. the safeguarding the vital interests of the Data Subject or another natural person;
    5. the execution of a task of public interest;
    6. pursuit of a legitimate interest of the Data Controller.
  2. It is always possible for the Data Subject to request the Data Controller for the concrete legal basis on which the Processing of each Data is based. To this end, the same can contact us at the certified e-mail address [email protected], at the e-mail address [email protected], or by sending a special registered letter to the registered office located in 20123, Milan ( MI), Italy, at Via Venti Settembre n. 27.
4. Types of Data collected
  1. To provide our services and guarantee our Users a unique gaming experience, Whatwapp Entertainment S.r.l. collects and processes, independently or through third parties, the following information:
    1. information on how to use our services and digital content; we use this type of information to implement the development of our applications and games, to ensure a constantly renewed gaming experience;
    2. information relating to the device that our Users use to access our services, the language set, the version of the operating system, the time and the IP address, the type of device used, the time spent using our services and digital content, the date and time of use of the same;
    3. information relating to the geographical location, based on the IP address;
    4. information relating to your Facebook account if access to our services and digital content is made by this provider; in this case, we only process necessary and limited information, such as name, age, profile photo, gender, language, e-mail address and lists of Friends;
    5. information relating to the Advertising ID; this function can be modified at any time from the settings of the device used;
    6. information relating to the User’s contacts, if provided by the User to increase their gaming experience and also share it with friends and acquaintances; in this case, the User assumes full responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties;
    7. information relating to Payment Data when the User purchases a license for the use of the virtual game currency or virtual objects provided by Whatwapp Entertainment S.r.l., in this regard our third financial partner will collect the Billing Data necessary to process the charges borne by the User. These Data may include Personal Data, postal address, e-mail address and the User’s financial Data. Whatwapp Entertainment S.r.l. does not collect or store such User Data (by way of example, but not limited to, credit card numbers). However, the payment managers of Whatwapp Entertainment S.r.l., such as Apple Inc. and Google LLC, may share with us the User’s non-financial Data relating to purchases, such as his Data, billing address and items purchased at purposes of order fulfilment.
  2. Unless otherwise specified, all Data requested by this application are mandatory. If the User refuses to communicate with them, it may be impossible to provide the Service.
  3. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating them, without this having any consequence on the usability of the Service or its operation.
  4. Users who have doubts about which Data are mandatory and which are not are invited to contact the Data Controller at the certified e-mail address [email protected], at the e-mail address [email protected], or send a registered letter to the registered office located in 20123, Milan (MI), Italy, at Via Venti Settembre n. 27.
  5. Some of the information reported above is acquired by Whatwapp Entertainment S.r.l. also through third parties. This information is acquired automatically when you use our services through the aforementioned third parties and the providers made available by them (such as Play Store, Apple Store, etc.). For more clarifications regarding the collection and processing of Sensitive Data by these third parties, we invite you to consult the relevant privacy policies.
5. Data Processing Methods
  1. The Data provided will be kept by the Data Controller, who will implement diligence and professionalism not inferior to those used in carrying out his business activity for the correct conservation of the same.
  2. The Data Controller implements adequate technical and organizational measures to ensure that only the Personal Data necessary for each specific processing purpose are processed.
  3. The Data Processing will be carried out through the use of IT means, through operations and logical organizations of the Data, which must be strictly indispensable for the purposes indicated and to guarantee its security and confidentiality.
  4. The processing of Personal Data will be entrusted to the staff in charge of Whatwapp Entertainment S.r.l., within the limits and for the sole purpose of allowing the interested party to use the services and digital content offered by the same.
  5. We use the collected Data to guarantee our Users the best possible gaming experience. To achieve this purpose the Data in question must be used for the following purposes:
    1. manage, improve and optimize our services, digital content and the experiences of our Users;
    2. create game accounts and allow the User to use our services and digital content;
    3. allow the purchase of services made available by the Data Controller through third parties authorized to do so (banks or financial intermediaries);
    4. identify and suggest connections with other Users in our games;
    5. allow Users to communicate with each other;
    6. provide technical assistance and respond to Users’ requests;
    7. protect the security and confidentiality of all Users;
    8. protect the rights and property of Whatwapp Entertainment S.r.l. concerning our services;
    9. prevent cases of fraud and potentially illegal activities;
    10. manage and deliver advertising to our Users;
    11. notify Users of game updates, new products or promotional offers;
    12. administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or operated by us or our business partners;
    13. fulfil our legal obligations, resolve any disputes that may arise with the User or between players and enforce our agreements with third parties;
    14. conduct research.
  6. In addition to the Data Controller and the personnel it uses, access to the Data in question could also be granted to third parties (by way of example, but not limited to, suppliers of technical and telematic services, hosting providers, IT companies, etc.), who will be appointed, should this prove necessary, as Data Processing Manager by the Owner. It is the right of the Data Subject to request and obtains from the Data Controller an updated list of the Data Processing Manager identified by the same.
  7. The Data Controller reserves the right to share different types of aggregated Data with third parties for analysis, demographic profiling, marketing and other commercial purposes, subject to the explicit consent of the Data Subject.
  8. The Data Controller reserves the right to share the types of Data referred to in point 4. of this document also to:
    1. fulfil legal obligations;
    2. at the express request of a competent Authority;
    3. report a criminal activity by one or more Users;
    4. protect the rights and interests of Whatwapp Entertainment S.r.l. in court or out of court.
  9. The Application may contain advertising and services offered by third parties, companies other than Whatwapp Entertainment S.r.l.. Therefore, it should be noted that, as regards the methods of collection and processing of Data, as well as any profiling activities through cookies by these Subjects, Whatwapp Entertainment S.r.l. cannot be held responsible in any way. For more information, Users are invited to read the relative privacy policies of the same, as well as the information contained at the bottom of this document.
  10. Within the application, it is possible to receive different types of rewards simply by looking at some advertisements made available by third parties. These advertisements are specially hosted on the provider of the third party, and not that of Whatwapp Entertainment S.r.l., which makes the advertisement available. In this context, the advertiser’s provider may collect a series of Data and information, for the processing and collection of which please refer to the privacy and cookies policy of the same.
  11. Some of the Personal Data processed referred to in point 4. will also be made visible to other Users, to allow the interactions that characterize our online games. In detail, the Data made visible to other Users are name or pseudonym, the game profile photo uploaded by the User, or the photo of the social profile to which the game account is connected and the game statistics of each User.
  12. The Data Subject could be Subjected to profiling based on automated systems, always respecting the privacy and confidentiality of their Data, as this is necessary to fulfil contractual obligations arising from the use of the Application and with explicit consent by the Data Subject.
6. Automated Decision-Making Processes
  1. By automated decision-making processes, we mean a set of activities for the collection and processing of Data relating to the Data Subject that are used to provide personalized services to the same, and which take place through processes that do not require human intervention.
  2. This type of profiling activity takes place exclusively within the scope of the purposes described in this document and only for what concerns the Data referred to in point 4.
  3. This Application uses automated decision-making processes to the extent that it is necessary to conclude or execute a contract between the Data Subject and the Data Controller, but also with the explicit consent of the Data Subject depending on the Data processed.
  4. Automated decision-making processes allow the Data Controller to improve the decision-making process regarding the provision of particular services, thus ensuring fair and impartial treatment to Users.
  5. In this way, it is also possible to reduce the potential damage resulting from human error, or other similar circumstances that could lead to discrimination or imbalances in the treatment of individuals.
  6. To obtain further information on the purposes, any third-party services and on the specific logic of the automated decision-making processes adopted by this Application, the interested party may exercise the rights referred to in point 9. of this document.
7. Transfer of Data outside of the EEA
  1. The Data Controller may transfer the Data collected to a third country (not part of the European Union) only if that country guarantees an adequate level of protection and on the condition that the Data Subjects have enforceable rights and effective remedies. In this case, the transfer does not require specific authorizations from the Data Subject.
  2. In the absence of adequate guarantees referred to in the previous point, the transfer of Data to a third country is allowed only if the following conditions are met:
    1. the Data Subject has explicitly consented to the transfer in question, after having been duly informed of the possible risks;
    2. the transfer is necessary for the conclusion or execution of a contract between the Data Controller and another natural or legal person in favour of the Data Subject;
    3. the transfer is necessary for important reasons of public interest;
    4. the transfer is necessary to ascertain, exercise or defend a right in court;
    5. the transfer is necessary to protect the vital interests of the interested party or other persons if the interested party is physically or legally incapable of giving his consent.
8. Data Retention Period
  1. The Data will be processed and stored for the time required by the purposes for which they were collected. Therefore:
    1. the Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed;
    2. the Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner;
    3. when the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer, or until such consent is revoked;
    4. a longer period of Data retention may be imposed by requests made by the Public Administration or by a Judicial, Government or Regulatory Authority;
  2. At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification, portability and any other right connected to them can no longer be exercised.
9. Rights of the Data Subject
  1. At any time, the Data Subject can exercise the rights referred to in Articles 15 and following the 2016/679 European Regulation. In detail, he may exercise, towards Whatwapp Entertainment S.r.l. the right to:
    1. ask for confirmation of the existence or otherwise of their Sensitive Data;
    2. obtain information about the purposes of the processing, the categories of sensitive Data processing, the recipients or categories of recipients to whom such Data have been or will be communicated and, when possible, the retention period;
    3. obtain the correction of inaccurate Sensitive Data concerning him without undue delay;
    4. obtain the integration of incomplete Sensitive Data concerning him, also by providing a supplementary declaration;
    5. obtain the cancellation of Sensitive Data concerning him without undue delay;
    6. obtain the limitation of processing, if possible, or the cancellation of Sensitive Data;
    7. oppose, against the Data Controller, the processing itself;
    8. obtain the portability of their Sensitive Data;
    9. obtain all available information regarding the origin of the Sensitive Data that do not come directly from the Data Subject;
    10. withdraw at any time the consent to the processing of their Sensitive Data, without prejudice to the lawfulness of the processing based on the consent given before the revocation;
    11. propose a complaint to a supervisory Authority or take legal action.
  2. For any clarification, data deletion request or any other request aimed at exercising the rights guaranteed to the User, the User can contact us at the certified e-mail address [email protected], at the e-mail address [email protected], or by sending a registered letter to the Registered Office located in 20123, Milan (MI), Italy, at Via Venti Settembre n. 27.
    1. To exercise his/her rights referred to in point 9.1., The User may send a request to the Data Controller, in which he must provide the necessary and sufficient information to allow us to verify that he/she is the person concerned by the Treatment, or of a subject authorized to do so (by way of example only and not exhaustive if the Treatment involves minors).
    2. In the case of a request for deletion of data (according to Article 17, paragraph 1, of EU Regulation no. 2016/679), the User must specify the reasons underlying the same.
    3. It should be noted that requests for which it is not possible to verify the identity of the applicant will not be considered.
    4. Requests will be handled by the Data Controller within 30 (thirty) days of their receipt. If we need more time to process the request, we will inform the User.
    5. In case of refusal of the request, we will care to explain the reasons.
10. Information not contained in this Policy
  1. Further information concerning the processing of Personal Data may be requested at any time from the Data Controller at the certified e-mail address [email protected], at the e-mail address [email protected], or by sending a registered letter to the Registered Office located in 20123, Milan (MI), Italy, at Via Venti Settembre n. 27.
11. Data Protection
  1. Every day we strive to take the most appropriate security measures to protect the security of the Data of our precious Users, both online and offline. Our organization is entirely based on the creation and adoption of reasonable measures to ensure that all Users’ Data are treated securely, in compliance with this Privacy Policy and the regulations in force.
  2. If the User has an account registered directly with Whatwapp Entertainment S.r.l., his profile Data will be protected by the password used to access the account in question.
  3. We remind you of the importance of constantly protecting the security of your Whatwapp Entertainment Srl account, therefore, we invite you to immediately report any unauthorized use of your account by sending a duly report to the certified e-mail address [email protected], at e-mail address [email protected], or by sending a registered letter with to the registered office located in 20123, Milan (MI), Italy, at Via Venti Settembre n. 27.
  4. In case of access to our services or digital content through a social network, we invite you to preserve the security of this account and, if the social network account is violated in any way, we invite you to report duly through the channels made available from the same.
  5. If the User decides to use our paid services, we inform you that payments will be made exclusively through the so-called technology SSL (Secure Socket Layer) specially made available by our payment managers, which allows you to encrypt the transmission of such Data to prevent any illegal use by third parties.
12. Amendments to this document
  1. The Data Controller reserves the right to make changes to this Privacy Policy at any time by informing Users through this Application. Therefore, please consult this document regularly and carefully, referring to the date of the last modification indicated in the footer.
  2. In any case, the Data Controller undertakes to inform the Data Subject of any changes to this document through notices that will be displayed directly on the Application.
  3. If the changes concern treatments whose legal basis is the explicit consent of the Data Subject, the Data Controller will collect it again.
  4. Unless otherwise specified, this privacy statement only concerns this Application.

Some particular types of Data processed and the methods of processing the same will be specifically indicated below. It should be noted that the following information also concerns the use of cookies by third parties. Therefore, Users are invited to read it and to deepen its processing methods through the Policies provided by these Subjects.

The processing will take place according to the principles established by the EU Regulation no. 679/2016, which are understood to be fully reported in this document.

You can access this page any time to review the updated list of all our partners.

Access to third-party accounts

This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.

Facebook account access (Facebook, Inc.)

This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.

Permissions asked: Age range; Email; Gender; List of Friends; Photos.

Place of processing: United States – Privacy Policy.

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are 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 Trackers 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.
In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Facebook Audience Network (Facebook Ireland Ltd)

Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd 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: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

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

AdMob (Google Ireland Limited)

AdMob is an advertising service provided by Google Ireland Limited.
In order to understand Google’s use of Data, consult Google’s partner policy.

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

Place of processing: Ireland – Privacy Policy.

Unity Ads (Unity Technologies ApS)

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

Personal Data processed: Tracker; Usage Data.

Place of processing: Denmark – Privacy Policy.

AdColony (AdColony, Inc.)

AdColony is an advertising service provided by AdColony, Inc.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Ogury (Ogury Ltd.)

Ogury is an advertising service provided by Ogury Ltd.

Personal Data processed: Tracker; Usage Data.

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

Google Ads Similar audiences (Google Ireland Limited)

Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Application.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.

Users who don’t want to be included in Similar audiences can opt out and disable the use of advertising cookies by going to: Google Ad Settings.

Personal Data processed: Tracker; Usage Data.

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

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.

Google Analytics for Firebase (Google Ireland Limited)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited.
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: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: Ireland – Privacy Policy.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited (“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: Tracker; Usage Data.

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

Google Ads conversion tracking (Google Ireland Limited)

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

Personal Data processed: Tracker; Usage Data.

Place of processing: Ireland – Privacy Policy.

Google Analytics Advertising Reporting Features (Google Ireland Limited)

Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users’ ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

Users can opt out of Google’s use of cookies by visiting Google’s Ads Settings.

Personal Data processed: Tracker; 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: Ireland – Privacy Policy – Opt Out.

Google Analytics Demographics and Interests reports (Google Ireland Limited)

Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).

Users can opt out of Google’s use of cookies by visiting Google’s Ads Settings.

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

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

Analytics collected directly (this Application)

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

Personal Data processed: Tracker; Usage Data.

Appsflyer (AppsFlyer Ltd)

Appsflyer is an analytics service provided by AppsFlyer Ltd.

Personal Data processed: Tracker; Usage Data.

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

Facebook Analytics for Apps (Facebook Ireland Ltd)

Facebook Analytics for Apps is an analytics service provided by Facebook Ireland Ltd

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

Place of processing: Ireland – Privacy Policy.

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.

Handling payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Payments processed via the Google Play Store (Google Ireland Limited)

This Application uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data processed: device information; email address; payment info; Usage Data.

Place of processing: Ireland – Privacy Policy.

Payments processed via the Apple App Store (Apple Inc.)

This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

Personal Data processed: device information; Usage Data.

Place of processing: United States – Privacy Policy.

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 services among those listed below, if any, may 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; Ireland – Privacy Policy; Germany – Privacy Policy.

Google BigQuery

Google BigQuery is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

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

Place of processing: United States – Privacy Policy; Ireland – 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 Ireland Limited)

Crashlytics is a monitoring service provided by Google Ireland Limited.

Personal Data processed: crash data; device information; Universally unique identifier (UUID).

Place of processing: Ireland – 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 Ireland Limited)

Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited. 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: Ireland – Privacy Policy.

Firebase Notifications (Google Ireland Limited)

Firebase Notifications is a message sending service provided by Google Ireland Limited. 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: Ireland – Privacy Policy.

Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Google Play Store (Google Ireland Limited)

This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Apple App Store (Apple Inc.)

This Application is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of this Application. Much of this information is processed on an opt-in basis.

Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Sign in with Apple (Apple Inc.)

Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account – therefore shielding their actual email address from the Owner.

Personal Data processed: email address; first name; last name; User ID.

Place of processing: United States – Privacy Policy.

Facebook Oauth (Facebook Ireland Ltd)

Facebook Oauth is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

Personal Data processed: Tracker; various types of Data.

Place of processing: Ireland – Privacy Policy.

Facebook Authentication (Facebook Ireland Ltd)

Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

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

Place of processing: Ireland – Privacy Policy.

Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Remarketing with Google Analytics (Google Ireland Limited)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data processed: Tracker; Usage Data.

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

Google Ads Remarketing (Google Ireland Limited)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings.

Personal Data processed: Tracker; Usage Data.

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

Facebook Custom Audience (Facebook Ireland Ltd)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Application with the Facebook advertising network.

Users can opt out of Facebook’s use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: email address; Tracker.

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

Social features

Firebase Dynamic Links (Google Ireland Limited)

Firebase Dynamic Links is a social feature provided by Google Ireland Limited. 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 this Application.

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

Place of processing: Ireland – 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 Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Last update: April 2021