Mobile App Privacy Policy for Users Outside the EU and UK

 

Revised Date: October 22, 2018

 

Introduction

 

Appy Go Lucky Inc. (”Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

•             The types of information we may collect or that you may provide when you download, purchase, install, access, or use a mobile application published by the Company (the “App”).

•             Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App, in email, text, and other electronic communications sent through or in connection with this App.

 

This policy DOES NOT apply to information that:

•             We collect offline or on any other Company apps or websites, including websites you may access through this App.

•             You provide to or is collected by any third party.

Our websites and apps, and these third parties have their own privacy policies, which we encourage you to read before providing information on or through them.

 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download or use this App. By downloading or using this App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

Children Under the Age of 16

 

The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email address provided at the end of this Privacy Policy.

 

Information You Provide to Us, Information We Collect and How We Collect It

 

We collect information from and about users of our App:

•             Directly from you when you provide it to us.

•             Automatically when you use the App.

 

Automatic Information Collection and Tracking 

•             We may collect personally identifiable information under applicable law (”personal information”).

•             We may also collect details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.

•             You may also provide information to be published or displayed (”Posted”) on public areas of websites you access through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

•             Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.

•             Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

•             Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device.

 

We do not track users of our App over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked.

The technologies we use for automatic information collection may include:

•             Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.

•             Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

 

•             Advertisers, ad networks, and ad servers.

•             Analytics companies.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

 

How We Use Your Information

 

We use information that we collect about you or that you provide to us, including any personal information, to:

•             Provide you with the App and its contents, and any other information, products or services that you request from us.

•             Fulfill any other purpose for which you provide it.

•             Give you notices about your account, including expiration, renewal notices, and updates.

•             Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

•             Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

•             Create game accounts and allow users to play our games.

•             Operate and improve our App.

•             Understand you and your preferences to enhance your experience and enjoyment using our App.

•             Respond to your comments and questions and provide customer service.

•             Provide and deliver products and services you request.

•             Deliver advertising and marketing and promotional information to you.

•             Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

•             Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by Company and our selected partners.

•             Conduct and administer contests promoted by the Company.

•             Enable you to communicate with other users.

•             Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.

We may use location information we collect to offer you products and services of our own and third parties that may be of interest to you. If you do not want us to use your information in this way, adjust your user preferences in your account profile.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

Disclosure of Your Information

 

We may disclose aggregated information about our users without restriction.

 

In addition, we may disclose personal information that we collect or you provide:

•             To our subsidiaries and affiliates.

•             To contractors, service providers, and other third parties we use to support our business.

•             To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our App users is among the assets transferred.

•             To third parties to market their products or services to you if you have not opted out of these disclosures.

•             To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or App, we will transmit the contents of that email and your email address to the recipients.

•             For any other purpose disclosed by us when you provide the information.

•             With your consent.

•             To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

•             To enforce our rights arising from any contracts entered into between you and us, including the App Terms of Use, and for billing and collection.

•             If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Your Choices About Our Collection, Use, and Disclosure of Your Information

 

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

•             Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the App to collect information through other tracking technologies by opting out.

•             Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings.

•             Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request. Please see our email contact at the end of this Privacy Policy.

•             Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending us an email stating your request. Please see our email contact at the end of this Privacy Policy.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

 

Your California Privacy Rights

 

California Civil Code Section 1798.83 permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email with your request or send us an email to provide you with out mailing address for mailing requests. Please see our email contact at the end of this Privacy Policy.

 

Data Security

 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

 

Changes to Our Privacy Policy

 

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and an in-App alert the first time you use the App after we make the change. The date the privacy policy was last revised is identified at the top of the page.

 

Contact Information

 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

[email protected]

 

 

 

 

Privacy Policy for EU and UK Users

 

Revise: October 22, 2018

 

Appy Go Lucky Inc. (we or Company) are committed to protecting your personal data and respecting your privacy.

 

INTRODUCTION 

This Privacy Policy (together with our end-user licence agreement (EULA) attached hereto and any additional terms of use incorporated by reference into the EULA, together applies to your use of:

•             Our mobile application software (App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device) and any of the services accessible through the App (Services).

•             This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

IMPORTANT INFORMATION AND WHO WE ARE 

 

Appy Go Lucky  Inc. is the controller and is responsible for your personal data (collectively referred to as ”Company”, “we”, “us” or “our” in this policy).

 

We have appointed a data privacy manager. If you have any questions about this privacy policy, please email us to request this information. The email contact information is available at the end of this policy.

 

Changes to the privacy policy and your duty to inform us of changes

 

We keep our privacy policy under regular review and the last revised date is provided above. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS or email or when you next start the App or log onto one of the Services. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

 

Third party links

 

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

 

THE DATA WE COLLECT ABOUT YOU 

 

We may collect, use, store and transfer different kinds of personal data about you as follows:

 

•             Identity Data.

•             Contact Data.

•             Financial Data.

•             Transaction Data.

•             Device Data.

•             Content Data.

•             Profile Data.

•             Usage Data.

•             Marketing and Communications Data.

•             Location Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

HOW IS YOUR PERSONAL DATA COLLECTED? 

 

We will collect and process the following data about you:

 

•             Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

•             Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.

•             Location Data. We also use GPS and wifi technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

•             Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:

•             advertising networks based outside the EU];

•             Contact, Financial and Transaction Data from providers of technical, payment and delivery services outside the EU;

•             Identity and Contact Data from data brokers or aggregators outside the EU].

COOKIES 

 

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies.

 

HOW WE USE YOUR PERSONAL DATA 

 

We will use your personal data in the following circumstances:

 

•             Where you have consented before the processing.

•             Where we need to perform a contract we are about to enter or have entered with you.

•             Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

•             Where we need to comply with a legal or regulatory obligation.

•             Create game accounts and allow users to play our games

•             Operate and improve our App and Services.

•             Understand you and your preferences to enhance your experience and enjoyment using our App and Services.

•             Respond to your comments and questions and provide customer service.

•             Provide and deliver products and services you request.

•             Deliver advertising and marketing and promotional information to you.

•             Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

•             Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by Company and our selected partners.

•             Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

 

Purpose/activity

 

Type of data

 

Lawful basis for processing

 

To install the App and register you as a new App user

 

Identity

Contact

Financial

Device

 

Your consent

 

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

 

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Location

 

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you including notifying you of changes to the App or any Services

 

Identity

Contact

Financial

Profile

Marketing and Communications

 

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

 

To enable you to participate in a prize draw, competition or complete a survey

 

Identity

Contact

Device

Profile

Marketing and Communications

 

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

 

To administer and protect our business and this App including troubleshooting, data analysis and system testing

 

Identity

Contact

Device

 

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

 

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

 

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

 

Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

 

 

 

 

DISCLOSURES OF YOUR PERSONAL DATA 

 

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties for the purposes set out in the table.

 

DATA SECURITY 

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. 

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

 

DATA RETENTION 

 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data. 

 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted.

 

GLOSSARY 

 

LAWFUL BASIS  Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    

 YOUR LEGAL RIGHTS  You have the right to:

 

•             Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

•             Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

•             Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

•             Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

•             Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a)  if you want us to establish the data’s accuracy;

 

(b)  where our use of the data is unlawful but you do not want us to erase it;

 

(c)  where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

 

(d)  you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

•             Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

•             Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

DESCRIPTION OF CATEGORIES OF PERSONAL DATA 

 

•             Identity Data: first name, last name, maiden name, username or similar identifier, date of birth.

•             Contact Data: billing address, delivery address, email address and telephone numbers.

•             Financial Data: payment card details.

•             Transaction Data: includes details about payments to and from you and details of in-App purchases.

•             Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

•             Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.

•             Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise.

•             Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

•             Location Data: includes your current location disclosed by GPS or wifi technology.

 

Contact details

 

Appy Go Lucky Inc.

Data Privacy Manager

[email protected]

157 Orr Ave, Vaughan, ON, Canada, L4L 9K2