We automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the app and to measure ads.
For improving the app and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amazon, Appsflyer, Google, Grafana Labs, Firebase, Yandex, Twitter, TikTok, Pinterest, Snapchat. Therefore, some of the data is stored and processed on the servers of such third parties. This enables us to (1) analyze different interactions (how often users make purchases); (2) serve and measure ads (and show them only to a particular group of users, for example, only to subscribers).
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
8. INTERNATIONAL DATA TRANSFERS
12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Basenji App Limited, a company registered under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.
We collect data you give us voluntarily (for example, email address). We also may receive data about you from third parties (for example, when you sign in via Facebook). We also collect data automatically (for example, your IP address).
Data provided by third parties
When you use sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with Apple screen. Find more about sign with Apple here.
When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID. Unless you opt out on the Facebook Login screen, we will also collect other data, such as email address.
For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the App on their Apps and Websites page.
When you initiate a payment, we may receive from third-party payment service provider information about the transaction amount, date and time.
Data we collect automatically:
Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
Device and Location data
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. We also record the ads in our App with which you interact (and the Internet links to which those ads lead).
We record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, how often you use the App, how long you are in the App, your subscription orders.
We collect your Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
We process your personal data:
To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.
To provide you with customer support
To communicate with you regarding your use of our Service
We communicate with you, for example, by push notifications if you opt-in. As a result, you may, for example, receive a push notification every day at a particular time reminding you to use the service. To opt out of receiving push notifications, you need to change the settings on your device.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping on links included in the message.
To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
To send you marketing communications
We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features available on the App. We may show you advertisements on our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications from us, you need to change the settings on your device.
To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook’s feed.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.
Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, installed the App). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.
Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, installing our App. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
To process your payments
We may provide paid products and/or services within the App. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.
We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
Under this legal basis we may communicate with you regarding your use of our Service, for example, by sending you push notification reminding you to use the App.
to perform our contract with you;
Under this legal basis we:
for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).
to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
to comply with legal obligations.
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the App.
Deleting your personal data. You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
Additional information for EEA-based users:
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below.
To exercise any of your privacy rights, please send a request to email@example.com.
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to firstname.lastname@example.org which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
Effective as of: 24 November 2020