Privacy Policy

INTRODUCTION

This Privacy Policy shall apply to the applications published in the Apple App Store by Grotem Limited and that are accessible from mobile devices and personal computers (the "App"), and the use of the websites controlled by Grotem Limited in general (the "Website"; App, and Website together the "Services").

OUR PRIVACY PROMICE

Our Privacy and Cookie Notice below sets out in detail how we process your personal data, and we encourage you to read it in full. However, we also understand that people have busy lives and won't always find the time to read everything online immediately, and so wanted to help you by providing a brief overview of how and why we process your personal data.

We mainly only collect and process your personal data for two reasons: to provide you with services and to comply with legal and regulatory obligations.

I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)

Grotem Limited (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy ("Privacy policy") explains our data protection policy and describes the types of information we may process when you use Servises developed by Grotem Limited.

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social status.

Our Privacy policy applies to all users and others who access the Service (“Users”).

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:

• the categories of personal information that is processed;
• the categories of sources from which personal information is obtained;
• the purpose for processing of user personal data;
• the categories of third parties with whom we may share your personal information;
• the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows us to identify the user.

Please use the navigation links through this Privacy Policy:

PERSONAL INFORMATION

All about the categories of information, its sources, and purposes of the processing.

Please mind that according to CCPA personal information does not include de-identified or aggregated consumer information.

SHARING

How your information can be shared.

Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and according to business purpose.

OPT-OUT OPTIONS

If you don’t want us to process your personal information any more please contact us through the Support email [email protected]. In most cases, there is no way to maintain the App’s further operating without functional data therefore you will be advised to remove the App from your device.

If you don’t want us to share device identifiers and geolocation data with service providers please check your device settings to opt-out asopt-outbed below

REQUESTS

To submit a verifiable consumer request for access, portability, or deletion of personal data please contact us through the Support email [email protected] Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California”.

When submitting a verifiable request, you should be ready to:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code, and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request, or (ii) confirm the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third-party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete it after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

EQUAL RIGHTS

Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or a different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

SALE OF DATA

We do not sell any of your personal data to third parties.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Information that you submit

We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services.

Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email [email protected]. We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request.

Information That Is Processed Automatically

When you use the Service, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all the features of the Service.

We use third-party automatic data processing technologies to analyze certain information sent by your device via our Service (analytics tools). Some of them launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time launch the Service.

Device Details. When you use a mobile device (tablet / phone / smartwatch) to access our App, some of details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.What data can be processed:

• Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
• Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.
• Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”).
• Device identifiers: Identity For Advertisers for iOs devices/ Advertising ID, user identifiers (if they are set up by the Service’s developer).

Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analyzes. Some services also record the list of applications and/or processes which are installed or run on your device.

Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access a specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you.

Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.

In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Information provided automatically to analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).

Payment Information

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.

We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

To make our service available. We use the information that you submit and information that is processed automatically to provide you with all requested services.

To improve, test and monitor the effectiveness of our Service. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our Service.

To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy.

Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your personal data, we cannot guarantee the security of any information transmitted from the App directly to such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

• as required by law;
• when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

VI. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct change, update or rectify your data.
• Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through Support email [email protected] Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes.

VIII. Cookies and Pixels Notice

A: Cookies

A 'cookie' is a small text file containing small amounts of information which is downloaded to your device when you visit a website or use applications. The cookie enables the server to collect information from the browser. We may use the following types of cookies:

• ESSENTIAL COOKIES: Cookies that are essential to the running of a Website. Without the use of cookies, parts of the Website would not function correctly. For example, when logging in to your account a session is created to allow you to browse the site and play games;
• ANALYTICAL COOKIES: We use analytical cookies to monitor our Website performance and to determine how visitors use the site. These cookies provide us with information that helps us create better products for our users and to identify areas that may need maintenance. We currently use Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us to analyse how players use our Website. We also use analytical cookies from additional third-party providers;
• PERSISTENT COOKIES: These are saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, so the correct language is presented and to improve our users’ experience of the Website as well as present different marketing messages and advertisements for existing users;
• FUNCTIONAL COOKIES: Functional cookies are used to remember your preferences on our Website, enhancing the user experience. This can have a range of functions such as remembering your username or recording that you have read a site message so you don’t need to view it again;
• SESSION COOKIES: Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server's pages.

We use a number of different cookies on this Website to help us to recognise you, track your activity and improve your use and experience of the Website. In addition, we use a number of third party service providers, who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your use and experience of the Website by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.

We and/or third parties may use cookies to collect or receive information from the Website and use that information to advertise to you on other websites. You can view the cookies used for such purposes on this Website and opt out of the collection and use of your information for such targeted advertising here: www.aboutads.info/choices

Some people find the idea of a website storing information on their computer or mobile (or other) device intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set but you need to be aware that you might lose some functions of that website. Most online browsers automatically accept cookies. However, if you wish to restrict or block cookies you can modify your browser settings.

B: Pixels

We also use pixel-based tracking to track a visit or event on the platform and to track advertisements' impressions. This information is also used by us for remarketing purposes and for tracking conversions that are used to optimize our marketing activities. We may share such information (which is non-personal information) with our advertising and marketing partners. Please see specific information about our marketing practices in section 8. By accessing and using the Website and services, you consent to the placement of cookies and pixels on your device in accordance with this Notice.

IX. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through Support email [email protected]

XI. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

XII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us at Support email [email protected]