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Privacy Policy of GemIQ

Policy summary

Personal Data processed for the following purposes and using the following services:

    • Analytics

      • Amplitude Analytics

        Personal Data: coarse location; device information; Universally unique identifier (UUID); Usage Data

    • Contacting the User

      • Contact form

        Personal Data: email address; User ID

    • Data transfer outside of the UK

      • Data transfer abroad based on consent (UK), Data transfer abroad based on standard contractual clauses (UK), Data transfers according to a UK adequacy regulation and Other legal basis for Data transfer abroad (UK)

        Personal Data: various types of Data

    • Data transfer outside the EU

      • Data transfer abroad based on consent, Other legal basis for Data transfer abroad, Data transfer to countries that guarantee European standards and Data transfer abroad based on standard contractual clauses

        Personal Data: various types of Data

    • Hosting and backend infrastructure

      • Amazon Web Services (AWS)

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

    • Infrastructure monitoring

      • Bugsnag

        Personal Data: app information; country; device information; device logs; various types of Data as specified in the privacy policy of the service

    • Location-based interactions

      • Non-continuous geolocation

        Personal Data: coarse location

    • Managing contacts and sending messages

      • Firebase Cloud Messaging

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

    • Platform services and hosting

      • App Store Connect

        Personal Data: advertising data; diagnostics; product interaction; purchase history

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

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.

Further information about the processing of Personal Data

    • Analysis and predictions based on the User's Data ("profiling")

      The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
      User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
      The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

    • Automated decision-making

      Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User's explicit consent, where such consent is required by the law.
      Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
      The rationale behind the automated decision making is:

      • to enable or otherwise improve the decision-making process;
      • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
      • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
      • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

      Consequences of automated decision-making processes for Users and rights of Users subjected to it

      As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
      In particular, Users have the right to:

      • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
      • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
      • request and obtain from the Owner human intervention on such processing.

      To learn more about the User's rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

    • Collection of personal information about California consumers aged 13 to 16

      We collect personal information of consumers between the age of 13 and 16 and won't sell or share their data personal information unless those consumers have opted in.

    • Equal protection of User Data

      This Application shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.

    • Personal Data collected through sources other than the User

      The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
      Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

    • Push notifications

      This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.

      Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
      Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    • Transfer of personal information outside of Brazil based on your consent

      We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
      When we ask for your consent, we'll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
      Such information will be given in clear and plain language and in such a way that you'll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
      You may withdraw your consent at any time.

    • Transfer of personal information outside of Brazil based on contracts and other legal means

      We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.

      To do so, we may use one of the following legal means:

      • specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD's prior verification;
      • standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
      • global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD's prior verification;
      • seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.

    • Unique device identification

      This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

    • User identification via a universally unique identifier (UUID)

      This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Contact information

    • Owner and Data Controller

      LSA Management (Services) Australia Pty Ltd
      24B Andrew Street,
      Mount Waverley,
      3149, Vic
      Australia

      Owner contact email: info@mobisec.lk

Full policy

Jewelry Data Usage

GemIQ uses jewelry data to provide you with personalized jewelry analysis and recommendations. Here's how we collect, use, and protect your jewelry data:

Collection:

  • When you use the jewelry analysis feature, the app captures an image of your jewelry through your device's camera.
  • We may also collect jewelry data from images you choose to upload from your device's photo library.

Use:

  • Jewelry Analysis: Your jewelry data is securely transmitted to our AI algorithms where it is analyzed to assess your jewelry's condition, including factors like authenticity, quality, and value.
  • Personalized Recommendations: The analysis results are used to provide you with customized care routines and product recommendations tailored to your jewelry's needs.
  • Condition Tracking: If you choose to track your jewelry's condition, your data may be used to compare its state over time.

Sharing and Disclosure:

  • AI Analysis: We use AI algorithms for the purpose of jewelry analysis. Our privacy policy governs the use of this data.
  • No Other Third-Party Sharing: We do not share your jewelry data with any other third parties, including advertisers, data brokers, or other companies.
  • Secure Storage: Your jewelry data is stored securely on your device. We do not store jewelry data on our servers.

Retention:

  • Local Storage: Your jewelry data is stored locally on your device and is only retained for as long as you choose to keep it. You can delete your jewelry data at any time through the app's settings.

Your Privacy Controls:

  • Access and Deletion: You can access and delete your jewelry data within the app's settings at any time.
  • Opt-Out: You can choose not to use the jewelry analysis feature, which will prevent the app from collecting your jewelry data.

Important Note:

  • We take your privacy seriously and are committed to protecting your jewelry data. Our AI analysis is performed securely, and we do not collect or store any personally identifiable information in connection with your jewelry data.

Owner and Data Controller

LSA Management (Services) Australia Pty Ltd
24B Andrew Street,
Mount Waverley,
3149, Vic
Australia

Owner contact email: info@mobisec.lk

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Trackers; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users; number of sessions; session duration; Application opens; Application updates; launches; operating systems; Data communicated while using the service; email address; User ID; various types of Data; Storage permission; Social media accounts permission; Photo Library permission; country; device logs; app information; Universally unique identifier (UUID); crash data; coarse location; diagnostics; advertising data; product interaction; purchase history; username.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Advertising, Collection of privacy-related preferences, Contacting the User, Data transfer outside of the UK, Data transfer outside the EU, Device permissions for Personal Data access, Hosting and backend infrastructure, Infrastructure monitoring, Location-based interactions, Managing contacts and sending messages, Platform services and hosting, Registration and authentication and Social features.

For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".

Facebook permissions asked by this Application

This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User's Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me

Provides access to the 'About Me' section of the profile.

Device permissions for Personal Data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Photo Library permission

Allows access to the User's Photo Library.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • 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

    This service allows this Application to connect with the User's account on the Facebook social network, provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.

    Permissions asked: About Me.

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA, CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • 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.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    AdMob

    AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
    In order to understand Google's use of Data, consult Google's partner policy.

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

    Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  • 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

    Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("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: Trackers; Usage Data.

    Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

    Google Analytics 4

    Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("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.
    In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google's official documentation.

    Personal Data processed: device information; Usage Data.

    Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

    Google Analytics for Firebase

    Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
    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; launches; number of sessions; number of Users; operating systems; session duration; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information; geolocation data.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

    Amplitude Analytics (Amplitude Inc.)

    Amplitude Analytics is an analytics service provided by Amplitude Inc.

    Personal Data processed: coarse location; device information; Universally unique identifier (UUID); Usage Data.

    Place of processing: United States – Privacy Policy; Netherlands – Privacy Policy; Singapore – Privacy Policy; United Kingdom – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information; geolocation data.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • a sharing according to the CCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • Collection of privacy-related preferences

    This type of service allows this Application to collect and store Users' preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

    iubenda Consent Database (iubenda srl)

    The iubenda Consent Database allows to store and retrieve records of Users' consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
    In order to do so, it makes use of a Tracker that temporarily stores pending information on the User's device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.

    Personal Data processed: Data communicated while using the service; Trackers.

    Place of processing: Italy – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • Contacting the User

    Contact form (this Application)

    By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form's header.

    Personal Data processed: email address; User ID.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA and VCDPA

  • Device permissions for Personal Data access

    This Application requests certain permissions from Users that allow it to access the User's device Data as described below.

    Device permissions for Personal Data access (this Application)

    This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

    Personal Data processed: Photo Library permission; Social media accounts permission; Storage permission.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • 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.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • 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.

    Bugsnag (Bugsnag Inc.)

    Bugsnag is a monitoring service provided by Bugsnag Inc.

    Personal Data processed: app information; country; device information; device logs; various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

    Crashlytics

    Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • Location-based interactions

    Non-continuous geolocation (this Application)

    This Application may collect, use, and share User location Data in order to provide location-based services.
    Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User's location data may be tracked by this Application.
    The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

    Personal Data processed: coarse location.

    Category of personal information collected according to the CCPA: geolocation data.

    This processing constitutes:

    • a sale according to the VCDPA, CPA, CTDPA and UCPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  • 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: Australia – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  • 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.

    App Store Connect (Apple Inc.)

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

    App Store Connect enables the Owner to manage this Application on Apple's App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of this Application. App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here.

    Personal Data processed: advertising data; diagnostics; product interaction; purchase history.

    Place of processing: United States – Privacy Policy.

    Category of personal information collected according to the CCPA: commercial information; internet information.

    This processing constitutes:

    • a sale according to the CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

  • 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.

    Facebook Authentication

    Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

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

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CCPA and VCDPA

    Google OAuth

    Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.

    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.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

  • Social features

    Firebase Dynamic Links

    Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. 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: United States – Privacy Policy; Ireland – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

    Public profile (this Application)

    Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.

    Personal Data processed: username.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • targeted advertising according to the CPA, CTDPA and UCPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

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.

Further information about the processing of Personal Data

  • Analysis and predictions based on the User's Data ("profiling")

    The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
    User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
    The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

  • Automated decision-making

    Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User's explicit consent, where such consent is required by the law.
    Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
    The rationale behind the automated decision making is:

    • to enable or otherwise improve the decision-making process;
    • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
    • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
    • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

    Consequences of automated decision-making processes for Users and rights of Users subjected to it

    As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
    In particular, Users have the right to:

    • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
    • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
    • request and obtain from the Owner human intervention on such processing.

    To learn more about the User's rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.