This Privacy Policy explains how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. This Privacy Policy applies to personal information that we collect through our apps, mobile applications and other products (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

 

1. INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes directly from you when you use our Apps or interact with third-party ads in our Apps or with our ads in other publisher’s Apps. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you use our Apps and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests.

The information that we may collect about you through the Services broadly falls into the following categories:

 (a) Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to submit inquiries to us, such as:

  • your name, email address or other details, necessary to process your inquiries;
  • any information you submit to our support team via email.

The personal information that you are asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information.

 (b) Information that we collect automatically
When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:

  • Data and analytics about your use of our Services
  • Your IP address and device identifiers such as your Advertising ID, Device ID numbers.
  • Your device type and the operating system that you use
  • Broad geographic location (e.g. country or city-level location) based on your IP address

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for the mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt-out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt-out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Device identifier/information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this information may be collected through cookies as explained further under the heading Cookies below.

 (c) Location Information
Our weather applications can deliver weather data for your current location if you choose to enable this feature in the apps. When you start the app for the first time you will be prompted to grant the app access to the location service of your device. If you agree and enable access to your location, your current location will be stored locally on your device, and will then be used by the app to query weather data for that location from our weather providers. Your location will also be shared with our advertising partners. You can disable access for the app to your device location in your device settings at any time. If you do not enable the location, we will not collect or store location information.

 (d) Information we obtain from third-party sources:
Tutela Technologies Ltd. (Telecom analytics)
Works with telecoms companies globally to help them understand and improve network speeds and network coverage for consumers like you. They help them build better networks in the areas that need it most.

Tutela may collect data relating to the wireless network performance your device experiences, in a pseudonymized manner, that may include the following types of personal information and/or personal data:

  1. Geolocation data. Precise location information (GPS and network-based) may be collected to develop geo-based analysis and plot network performance on a map to convey coverage.
  2.  Daily Session Tag. A random number representing a measurement session, that is reset every 24 hours. A Daily Session Tag is assigned each day to each mobile application install contributing to Tutela so that they can assess the statistical reliability of network insights.
  3. Network Element IDs. Network names, cell tower identifiers, BSSID, and other access point information is collected so that Tutela may know what network operator or network equipment they’re testing for issues.
  4. State of Test Application. The state of this application during a network test (e.g. “in use”) may be collected for data validation purposes. Tutela never sees or records any content viewed by users.

Using our servicesand permitting Tutela to collect pseudonymous data may help improve the performance of your wireless network and your apps. This pseudonymous data may be shared with mobile network operators, network equipment manufacturers, and other third parties within the telecom ecosystem. They use it to understand, communicate, and optimize network performance.
We do not collect data unless the app is in foreground. This means that the user always have control on when the app collect data (i.e. when the app is opened). If you do not enable the location, we will not collect or store location information.

Tutela never collects your sensitive personal information, name, phone number, a persistent device identifier, or e-mail, and takes technical and administrative measures to ensure data is not attributed to particular consumers. For further information about Tutela’s data practices please see the Tutela Privacy Charter.

CellRebel (Telecom analytics)
By using our services you understand and agree that CellRebel may sample data from your device, including location data, for the purposes of analyzing the following areas: network performance, network user experience and user equipment performance. This information can be shared with third parties in an aggregated format without personal identifiable information with the purpose to improve the network performance or to be used in designing marketing campaigns (No personal data that can identify a person or a person’s movements patterns is shared. We prohibit any form of tracking). This can help to improve your mobile network and your network connectivity. Further information can be obtained in the Privacy Policy found at www.cellrebel.com/privacy_policy

Type of data collected
We collect data that provides CellRebel with relevant information on network quality and how the networks are used. This includes data such as network metrics, device manufacturer, device model, device operating system, network operator, client IP address, GPS coordinates, Cell ID/LAC ID, signal strength, access network technology from our Data Partner. When we collect data to our Data Partners, we require data has been collected in accordance with applicable privacy laws, policies.
We do not collect data unless the app is in foreground. This means that the user always have control on when the app collect data (i.e. when the app is opened). If you do not enable the location, we will not collect or store location information.

 

2. HOW WE USE YOUR INFORMATION

2.1. In General
We use the information we collect about you/your device to deliver services in our Apps to you and to operate our business. We use it also for improving our services and Apps, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Apps. We use your information also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations.

We use your information for the following purposes:

  1. Delivering and improving our services. We use your information for developing, delivering and improving our Apps and other products, services, and content, tailoring our products and services, providing App updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Apps, and administering the Apps.
  2. Displaying advertisements. We use your information for showing advertisements for our Apps in other publisher’s apps and for displaying third-party advertisements in our Apps. Please see more in Advertising Section of this Privacy Policy.
  3. Cross-promotion. We use your information for cross-promoting our Apps and services, meaning to promote one of our Apps while you are using a different App of ours.
  4. Tracking and fraud prevention for advertising purposes. We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.
  5. Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the app was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new app features and content.
  6. We use your information for enhancing the safety and security of our Apps, products and services.
  7. Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
  8. Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.

2.2. In-App Purchases
Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are completed through the app store via your App Store account or Google Play account. Any post-purchase processes are controlled by the Apple and Google stores and are subject to specific terms of such Apple and Google stores. Please review privacy policy and terms of service of your Apple and Google stores.

 

3. HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Apps by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

  • Our analytics providers. We use third-party analytics such as Google Analytics, Firebase for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking feature.
  • Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as Google Cloud Platform;
  • Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Apps for free or at low cost.
  • Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers.
  • Telecom analytics partner’s. We have contracted with certain third-party Telecom analytics that collect data relating to the wireless network performance your device experiences, in a pseudonymized manner

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.

The list of our current service providers and partners is available here.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

 

4. ADVERTISING

 4.1. In General
We use advertising to fund our Services and to make our apps available for free. We offer our Apps for free or at low cost and in order to do that we need to share information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites, and Apps and – at the same time – keep our Apps free for a wide base.

If you are an European Economic Area (EEA) – based user be aware that:

(a) When you use our Apps, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads to EEA-based users is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR . We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements.

(b) Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at relevant button at loading of the App. We allow our advertising partners to show personalized ads to you only if you have pressed ACCEPT in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you ACCEPT to show you personalized ads at loading of the App. The list of our current advertising partners with links to their privacy policies is available here. The legal basis to show personalized ads to EEA-based users is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. The purpose is to improve our Apps and provide the user with more relevant ads. You have an option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Phone settings and clicking “Settings –> Google –> Ads. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.

4.2. app advertising (i.e. when you view ads in Our Apps)

To enable us to show app ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our app (it is controlled by ad networks), but we do blacklist certain categories of ads.

Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

  • limit the number of times you see the same ad;
  • ensure they are dealing with humans with real devices and not ‘automated’ bots;
  • serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Apps. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;

4.3. View of Our ads on third-party services
We also advertise Apps in other apps by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs).

The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

  • measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ apps);
  • informing users, that have not been using the app for a while, about new content in the App. We give a list of these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about the new content;
  • not showing ads on a app which a user is already using.

 

4.4. WHO CAN SHOW PERSONALIZED ADS TO YOU?
Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here.

 

4.5. HOW CAN YOU TURN OFF PERSONALIZED ADS?
Besides specific instruments available to EEA-based users via the App you can use your device settings.

iOS
Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.

Android
Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data.

 

5. COOKIES
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options of our Service.

 

6. YOUR RIGHTS
If you are EEA-based user you have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests

Your rights include:

  • Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you may withdraw your consent to show personalized ads to you, by go to the Phone settings and clicking “Settings –> Google –> Ads and following the instructions.
  • Right to access your data in accordance with Art. 15 GDPR (e.g. you may check what data we store about you, for this purpose please contact us.
  • Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your email address has been changed and we should replace your old email address)
  • Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data that we have stored about you
  • Right to restrict processing of your personal information in accordance with Art. 18 GDPR (e.g. you can contact us if you want to restrict processing)
  • Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data if you want to upload it to another service)
  • Right to object how your data is handled in accordance with Art. 21 GDPR (e.g. you can contact us if you do not agree with any user analytics procedures as described within this privacy policy)

Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly).

 

7. GENERAL
Your information privacy and security is important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under EEA data protection laws that apply to EEA users. We have appointed data protection officer to help us ensure compliance with EEA data protection laws. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners (see the List of our current Partners here) as for the purposes described above in “How We Share Your Information” Section, which may include a transfer of your personal information outside of the European Economic Area (the “EEA”). Please check regularly for changes to our Privacy Policy.

 

8. LEGAL BASES
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.

The legal bases that we rely upon are the following:

  • Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver features in our Apps.
  • Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when using our apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
  • Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.

 

9. INTERNATIONAL TRANSFER
Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third party service providers and partners, which require us to protect personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.

 

10. RETENTION
We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in “Your Rights” Section.

 

11. CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

 

12. Your acceptance of these terms
By using our Services, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Services. Your continued use of our Services following the posting of changes to this policy will be deemed your acceptance of those changes.

 

13. CONTACT US
If you have questions or concerns about this Privacy Policy, please contact us via our privacy email: info @ appcode.dk

This document was last updated on January 24, 2018