Spelling Bee: Privacy Policy

Spelling Bee: English Words

IMPORTANT PRIVACY INFORMATION

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).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions will remain unanswered, please contact us at support@basenjiapps.com.

PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use the Spelling Bee: English Words mobile application (the “App”), the services and products provided through it (together with the App, the “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time; and (c) delete the App from your devices.

Any translation from English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version of this Privacy Policy available at https://basenjiapps.com/docs/spelling_bee_privacy_policy and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

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.

TABLE OF CONTENTS

1. PERSONAL DATA CONTROLLER

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

7. AGE LIMITATION

8. INTERNATIONAL DATA TRANSFERS

9. CHANGES TO THIS PRIVACY POLICY

10. CALIFORNIA PRIVACY RIGHTS

11. DATA RETENTION

12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

13. CONTACT US

1. PERSONAL DATA CONTROLLER

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.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

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).

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3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

  1. 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.

    See More
  2. To provide you with customer support

    We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

  3. 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.

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  4. 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.

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  5. 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.

  6. 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:

    See More
  7. 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.

  8. 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).

  9. 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.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA

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:

  1. your consent

    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.

  2. to perform our contract with you;

    Under this legal basis we:

    • Provide our Service (in accordance with our Terms and Conditions of Use)
    • Customize your experience
    • Provide you with customer support
    • Communicate with you regarding your use of our Service
    • Process your payments
  3. 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.

  4. to comply with legal obligations.

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

  1. Service providers

    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:

    • cloud storage providers (Amazon, Google, Digital Ocean)
    • data analytics providers (Facebook, Firebase, Appsflyer)
    • measurement partners
    • communication service providers (Firebase)
    • marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat, TikTok, Twitter)
  2. 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.

  3. 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.

6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

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 support@basenjiapps.com.

7. AGE LIMITATION

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.

8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

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).

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. CALIFORNIA PRIVACY RIGHTS

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 support@basenjiapps.com 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.

11. DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Except as otherwise stipulated in this Privacy Policy, this App 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.

13. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@basenjiapps.com.

Effective as of: 24 November 2020