PRIVACY POLICY
Updated and Effective as of May 5, 2023
1. General.
Thank you for choosing to be part of our community!
This privacy policy describes how our organization Appmaking LTD is the legal entity incorporated in accordance with the laws of the Republic of Cyprus (collectively, “we”, “us”, or “our”) collects, uses, stores, transfers and discloses personal information from our Users in connection with our Services. One way to protect your privacy is to learn how will be used personal information before you give it out. We attach great importance to your privacy right and truthfully explaining why and how we use your information.
We hope you take some time to read through it carefully, as it is important.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Appmaking LTD will be the data controller responsible for any personal data we process.
In this privacy policy, the following definitions are used:
«Services» refers to our Apps, Websites, and any related services or properties we control;
«Apps» refers to games, applications, and other products produced by us on any and all platforms;
«Websites» refers to websites and other online properties we control;
«Personal Data» is used when referring to personal data that relates to you as an identified or identifiable individual;
«Anonymous data» does not include data where the identity has been removed;
«User, consumer» is any third party that use our Services.
We have the right to update this Privacy Policy from time to time so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.
Please read this Policy carefully and do not hesitate to contact us if you have any questions at support@appmaking.app. Where applicable, if you do not provide us the relevant Personal Data, you may not be able to use our Services completely. You should not use the Services if you do not agree with this Policy, our Terms of Use.
How to contact us:
Name: Appmaking LTD
Address: PROMACHON ELEFTHERIAS 1, 2ND FLOOR, FLAT/OFFICE 32, AGIOS ATHANASIOS, 4103, Limassol, Cyprus
E-mail: support@appmaking.app
2.1. When you use our Services, we can collect, use, receive, process, transfer and share some of your Personal Data for different legitimate purposes. You will find below explanations regarding what Personal Data we may collect, the reasons why we may collect this data and the legal bases relied on in each case. Please, be notice that the types of information that we may collect depend on how you use the
Type | Personal Data |
User-provided information (In some instances, we may require certain Registration Information, in other cases, we may ask you to provide such data voluntarily.) | |
Contact Data – when the User registers for the Service and enters the contract | email; Name/Surname/Nickname; password or passcode; last 4 digits of the card number; comment. |
Location Data - we do not collect the User’s precise location | country; state; coarse location such as Approximate Location Services (general - non-precise location). |
Quiz Data - during the onboarding questionnaire, the User may provide different quiz personal data. We do not collect, store, share, or transfer this quiz data or use this data for identification, marketing, or advertising purposes. | date and place of birth, birth time, gender, weight, age, photo (arm, face, Etc.), relationship status, future goals, source of stress, answers to the questions, data on physical characteristics (including height, weight, areas for improvement), Etc. |
Automatically collected information. When you use the Service, some information about your device and user behavior may be processed automatically. This information is generally non-personal, and we may access it only in aggregated form. We process this information based on our legitimate interest in improving our Service and giving our users the best experience. Otherwise, we may need help to provide you with all the requested services and features of the Service. Examples of such information: | |
Device Info – technical data | device type and model, two-character country code, a subdivision of country (e.g., state), city, two-character language code, operating system, and version number (ex.: ios 7.1.3, android), hardware type, connection type (for example, WiFi, 3G, 4G), network service provider, device motion parameters and carrier. |
Identity Data - identify a computer, device, browser, or product | IP Address; ID for advertisers (IDFA) (iOS only); Google Advertising ID, or GPS ADID (ID Device) if Google Advertising ID is empty; API level (Android only); Firebase ID and other similar unique identifiers. |
Usage Data (Events) - indicates if the activity happened on mobile or web | length of the User's last session in seconds; Length of the User's current session in seconds; Number of sessions recorded; Push notification token, i.e., registration token (Android), device token (iOS); clicks on User's ads; the type of ads and the webpage or Application from which such ads were displayed; downloads and installations of applications. |
Diagnostic information | logs, error reports, events, and the type, number, date, and page relating to this information. |
Cookies and Other Tracking Technologies | cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or information received from third parties. |
2.2. Our Services allow in-app purchases. In-app purchases are not mandatory and it is up to you whether to pay for accessing such functionality or not. You should know that we don’t process payments directly, payments processed via Apple App Store (Apple, https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store (Google, https://policies.google.com/privacy). Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform. We may receive the billing and payment information that you provide when your purchase is processed by someone else (like, Apple or Google, or PayPal, Solidgate, Stripe) such as when you purchase subscription. If you purchase the subscriptions in our apps, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information. We don’t collect or store payment data, details or payments-related personal data. However, our’s payment processors may share information with us related to your purchases. We may use this information for purposes as described in this Privacy Policy.
2.3. The app requires your permission to access your microphone recordings and your photo and video library when you use the app to activate voice command and to enable you to share your achievements on your social media accounts. However, we do not collect or have access to such data.
2.4. We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.
Purpose of this Privacy Policy is fulfillment of the provisions of the Terms of Service (“Contract”) concluded between the User and APPMAKING LTD. We collect user’s personal data when user starts using our Services. For example, we may use the Personal Data in the following ways:
Purposes | Personal Data Category | Legal Basis |
To provide the Services according to our policies with you. For example, we use your Personal Data to: help you with the onboarding process and personalize your results; provide the app when you download it onto your device. | Contact Data; Quiz Data; Location Data; Usage Data | Contract |
Research and development: We use Personal Data for internal research and development purposes and to improve and test the features and functions of our Services. We use information processed automatically to understand better user behavior and trends, detect potential outages and technical issues, and operate, protect, improve, and optimize our Service. | Automatically collected information | Legitimate interest |
To diagnose and fix issues with the Service. | Usage Data | Contract |
To help the User to choose a subscription plan, provide entertainment services, to send analysis reports, and go through the quiz to customize the User experience. | Quiz Data | Contract |
To communicate with you. When you contact us (for example, to inquire about our Services), we want to communicate with the User to provide support. | Contact Data | Contract |
To allow us to track the performance of our marketing campaign to help us optimize our Service features and events for each user. | User ID, in-Apps activity data, advertising ID, IP address, location | Legitimate interest |
An alternative way to register (only for voluntary users’ desires). | If you sign into the Services with Facebook Connect (Instagram) or Google Connect, or Apple, we will collect information that is visible via your Facebook or Google account, such as (1) your first and last name, (2) Facebook ID/Google ID/Apple ID (3) Profile Picture/URL, city-level location. | Contract |
If applicable, billing (invoicing), account management, and other administrative purposes. If you pay for Services directly through our website, you authorize us to have our payment processor collect this information. | Contact Data. In the event, the User purchases products or Services directly from us, we, or a third party on our behalf, may collect the billing information the User provides us, as well as the payment card and other payment information, solely as required to process payments or send User invoices for such purchase. | Contract |
To send you marketing communications. | Contact Data | Consent |
To personalize ads, monitor the effectiveness of third-party marketing campaigns, monitor aggregate site usage metrics such as total number of visitors and pages accessed, provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future | Automatically collected information | Legitimate interest |
To deliver content and advertising that’s relevant to you. | Location data | Legitimate interest |
To prevent fraud or harm to us or any third party and ensure the security of our network and services. | Automatically collected information | Legitimate interest |
Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. For example, when we use your date of birth when required for age verification purposes. | Contact Data | The legal basis |
To fulfill contractual obligations with third parties. For example, when we provide pseudonymized data to our partners in analytics matters or process your payment. | Automatic collected information. Contact Data | Legitimate interest |
Remember your information so that you will not have to re-enter it during your visit or the next time you access our Services | Automatic collected information. Cookies. | Consent |
Send you push notifications, related information, including confirmations and reminders (if you choose to allow that function)— user can choose to stop disable these at any time, by opting out or changing your browser or device settings. | Automatic collected information. | Consent |
Noted: Providing you with interest-based (behavioural) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the Digital Advertising Alliance or Network Advertising Initiative consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website https://www.youronlinechoices.eu/.
We may share your information to third-party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, customer service and to assist us in our marketing efforts. We share your Personal Data with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service in the optimal way, such as serving you personalized, relevant advertisements within the Service. We hereby undertake not to conduct any disclosure or transfer of the User’s personal data to any third parties, except Processors, mentioned in this paragraph, without receipt of personal consent of the User. The following companies are the Processors of the Personal Data of the Services of APPMAKING LTD (In case you want to learn more about the services and privacy options please consult their websites and privacy policies):
Processor | Purpose | Policy and opt-out | ||
Customer support | ||||
Zendesk Inc. | Customer support (Email address Content of the emails) | https://www.zendesk.com/company/ agreements-and-terms/privacypolicy// | ||
Ad Partners: usually collect data via their own tools (Software Development Kits or “SDK”) | ||||
AppLovin Corp | Advertising service. Personal Data collected: Cookies and Usage Data. You may opt-out of certain features through your mobile device settings, such as your device advertising settings or by following the instructions provided in their Privacy Policy. You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interes tbased advertising and how to opt-out of this form of advertising on your web | https://www.applovin.com/privacy/ | ||
AdColony, Inc | https://www.adcolony.com/privacypolicy/ | |||
ArabyAds FZ LLC (AdFalcon) | http://adfalcon.com/en/ | |||
Сhartboost | https://answers.chartboost.com/en-us/ articles/200780269 | |||
IronSource Mobile Ltd. | https://ironsource.mobi/ privacypolicy.html | |||
Kadam | https://www.kadam.net/en/privacypolicy | |||
TapJoy | this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) selfregulatory program. | https://www.tapjoy.com/legal/general/ privacy-policy/ |
Unity Technologies | https://unity3d.com/legal/privacypolicy | |
Snap Inc. | https://www.snap.com/en-US/privacy/ privacy-policy/ | |
Analytic companies: provide us with tools and technologies that allow us to better understand how users interact with our services, usually collect data via their own SDKs | ||
Adjust, Ltd. | Mobile attribution and analytics. To perform research and analysis about how users interact with the Services. Personal Data collected: Cookies and Usage Data. Adjust, a mobile marketing platform, helps App-Developers, Brands, and Ad-Agencies attribute installs to campaigns and optimizes their users’ acquisition funnel. Personal Data collected: Device Info, Identity Data. | |
Amplitude, Inc. | Analytics service. Personal Data collected: Cookies and Usage Data. | https://amplitude.com/privacy |
Other partners | ||
Apple, Inc. | To collect and process payments for subscription to the App. Personal Data collected: Payment and banking information and Usage Data. | https://support.apple.com/en-us/ HT210584 |
Amazon Web Services, Inc. | Hosting and backend service Personal Data collected: various types of Data as specified in the privacy policy of the service. | https://aws.amazon.com/privacy/ |
BunnyWay d.o.o. | CDN Personal Data collected: various types of Data as specified in the privacy policy of the service. | https://bunnycdn.com/privacy |
Hetzner Online GmbH | Internet hosting. Personal Data collected: Cookies and Usage Data | https://www.hetzner.com/rechtliches/ datenschutz/ |
Facebook Ireland Ltd. | Our Services measures conversions using visitor action pixels from Facebook. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization. Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our Services. You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data. | https://www.facebook.com/policy.php |
Google Inc. | To collect and process payments for subscription to the App; AdMob Google Inc. is an advertising service. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data. | https://policies.google.com/terms? hl=ru , https://firebase.google.com/ terms/analytics/ |
PayPal | To collect and process payments for subscription to the App | https://www.paypal.com/by/webapps/ mpp/ua/privacy-full |
Solid | https://solidgate.com/privacypolicy | |
2checkout | https://www.2checkout.com/legal/ privacy/ | |
Stripe | https://stripe.com/en-gb-us/privacy | |
Competent Authorities | To comply with a legal obligation, process or requests. If we are bound to disclose your personal data by a judicial order or by a governmental or regulatory authority, we will comply and share the personal data with that body. | |
We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide. In all cases, APPMAKING LTD does not retain such data for more than 5 years. 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. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the processed personal data will be deleted or anonymized.
6.1. Personal data may be processed by both automated and non-automated means, and may be stored at our premises and on our service providers’ servers. We understand that unfortunately, the transmission of Information via the internet is not completely secure. We do all our best to maintain the privacy and integrity of your Information. We have implemented industry standard security measures, which include the encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk. We will also not use information received through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it.
6.2. We work in the international space and provide our Services to our Users around the world. We and thirdparty organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. You acknowledge and agree that The locations of servers for the services include:
(1) Cyprus and Germany (The European Union) - the servers located in European Union which automatically process your personal data and obtain the access to your personal data for the purposes of manual processing; Your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws. 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 a personal data as your country does. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We attach great importance to user’s privacy and would like to explain your data protection
(i) The withdrawal right. It's important to remember that if we process your data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of us via its Support service, i.e., by emailing support@appmaking.app with the topic «Consent withdrawal» or in the Settings menu of the application.
(ii) The right to be informed. The right to know what Personal Data we hold and how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access, please contact us as described below and let us know what information, in particular, you would like to receive.
(iii) The right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt out, you will still receive advertising but not direct or target interest. On Apple, you can opt out by going to Settings > Privacy > Advertising and turning on "Limit Ad Tracking." On Android, you can opt out by going to Settings > Google Services> Ads and turning on choosing "Opt out of Ads Personalization."
(iv) The right to request an update or correction (rectify) to any of your Personal Data that is out of date, incomplete or incorrect (according to Article 16 of the GDPR). In certain circumstances, you have the right to ask us to delete the Personal Data we hold about you.
(v) The right to delete your Personal data. (Right to be forgotten). You have the right to request that we delete certain of your Personal data. There are situations where we are unable to delete your data, for example, when: it's still necessary to process the data for the purpose we collected it for; our interest in using the data overrides your interest in having it deleted (for instance, we need the data to protect service from fraud); we have a legal obligation to keep the data or require the data to establish, exercise or defend legal claims. For example,
(vi) The right to object. You have the right to object to our processing of your personal data under certain conditions: we are processing your personal data on the legal basis of legitimate interest or processing your personal data for interest-based advertising. Object to us processing your personal data at any time on grounds relating to your particular situation Object to your personal data being processed for direct marketing purposes.
(vii) The right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence. You can do this if: your personal data is inaccurate; our processing is unlawful; we do not need your information for a specific purpose; you object to processing, and we are assessing your objection request.
(viii) The right to portability of your personal data. In some circumstances, you may have the right to request that the data you provided to us be provided so that you can transfer this to another data controller.
(ix) The right to complain to a data protection authority about our collection and use of your personal information. Don't hesitate to contact your local data protection authority for more information. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
(x) The right to Data portability. You have the right to Request a copy of your personal data in electronic format and transmit that personal data for use in another party's service.
(xi) The right to request access to the personal information we collect from you, change it or delete it in some circumstances. You have the right to ask for copies of your personal data. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional documents are provided on a reimbursement basis. In this case, please send an email to support@appmaking.app.
If you are based in the EEA, you have the following rights in addition to the above: The right to complain to the supervisory authority. We would love for you to contact us directly so that we can address your concerns. Nevertheless, you can complain to a competent data protection supervisory authority, particularly in the EU Member State where you reside, work, or where the alleged infringement has occurred.
The right to data portability. If you wish to receive personal data in a machine-readable format, you can send a respective request to support@appmaking.app.
You may send the request aimed at exercising your rights provided herein to our email or to our business address. If you make a request, we have one month to respond to you.
Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission. We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information. Moreover, some of the Apps are limited for users that are younger than 18.
This is additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA and any terms defined in the CCPA have the same meaning when used in this notice.
California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:
Category | Examples | Collected | We sell | Sources of Collection | Categories of Third Parties with Whom We Share Personal Information |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and Social Security number. | YES | NO | User, their Devices | Advertisers, Analytics Providers, and Third Parties as Legally required |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal data in this category may overlap with those from other categories. | NO | NO | N/A | N/A |
C. Protected classification characteristics under California or federal law. | Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), driver’s license number, passport number, or other similar identifiers. | NO | NO | N/A | N/A |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | NO | User | Payment Service Providers |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data (Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data). | NO | NO | N/A | N/A |
F. Internet or other similar network activity. | Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. | YES | NO | User, their Devices | Advertisers, Analytics Providers, and Third Parties as Legally required |
G. Geolocation data. | Physical location or movements. | NO | NO | N/A | N/A |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO | N/A | N/A |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO | NO | N/A | N/A |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | NO | N/A | N/A |
K. Inferences drawn from other personal information. | The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES | NO | User, their Devices, Partners | Advertisers, Analytics Providers, and Third Parties as Legally required |
We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission. We do share personal information with the Processors of the Personal Data of the Services of APPMAKING LTD mentioned in paragraph 4.
As a California resident, you have the rights listed below:
You may exercise your California privacy rights described above by emailing us. We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
If you have any questions or comments about this policy, you may contact us: via email at: support@appmaking.app.
via post to:
The Company name: APPMAKING LTD
Address: PROMACHON ELEFTHERIAS 1, 2ND FLOOR, FLAT/OFFICE 32, AGIOS ATHANASIOS, 4103, Limassol, Cyprus