Privacy Policy

Privacy Policy 
 

This Application collects some Personal Data from its Users. 
 

Owner and Data Controller 
 

Faruk KAYADUMAN 
 

SOĞUKPINAR MAH., SOĞUKPINAR 5 SK. Kale/Malatya ED1- 4 NO: 10, İÇ KAPI NO: 13 44370 Doğu Anadolu/Malatya Türkiye 
 

Owner contact email: sanalkaptanyt@gmail.com 
 

Types of Data collected 
 

This Application gathers various types of Personal Data either directly or through third-party services. These may include but are not limited to: Trackers, Usage Data, unique advertising device identifiers (such as Google Advertiser ID or IDFA), device specifications, geographical region, user count, session count, session length, in-app purchases, app openings, updates, launches, operating systems, Universally Unique Identifier (UUID), crash reports, country, device logs, app-related information, multiple forms of data, approximate location permissions (non-continuous), and payment details. 
 

Detailed information regarding the types of Personal Data collected can be found in the relevant sections of this privacy policy or through specific explanation texts shown before Data collection occurs. Personal Data may be voluntarily provided by the User or, in the case of Usage Data, automatically collected during the use of this Application. Unless stated otherwise, all Data requested by this Application is essential, and failure to supply this Data may prevent the Application from delivering its services. Where the Application specifies that certain Data is optional, Users may choose not to provide it without affecting the availability or functionality of the Service. Users who are unsure about which Data is mandatory can reach out to the Owner for clarification. The use of Cookies or other tracking mechanisms by this Application or third-party service providers associated with it is intended to deliver the Service requested by the User, as well as for other purposes outlined in this document and in the Cookie Policy, if applicable. 
 

Users are accountable for any third-party Personal Data they acquire, publish, or share via this Application and must ensure that they have obtained the necessary consent from the third party to provide such Data to the Owner. 
 

Mode and place of processing the Data 
 

Methods of processing 
 

The Owner implements appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the Data. Data processing is conducted through computers and/or IT systems, adhering to organizational protocols that are strictly aligned with the stated purposes. In some instances, the Data may also be accessible to specific individuals responsible for managing the Application's operations (e.g., administration, sales, marketing, legal, system administration) or external entities (such as third-party technical service providers, mail carriers, hosting services, IT companies, communication agencies) who may be appointed as Data Processors by the Owner when necessary. An updated list of these parties can be requested from the Owner at any time. 
 

Legal basis of processing 
 

The Owner may process Personal Data relating to Users if one of the following applies: 
 

Users have given their consent for one or more specific purposes. Note: In certain jurisdictions, the Owner may be permitted to process Personal Data until the User objects to such processing (“opt-out”) without needing to rely on consent or any other legal bases. However, this does not apply where the processing of Personal Data is governed by European data protection law. Other legal bases include: 

• The provision of Data is necessary for the performance of a contract with the User and/or for any pre-contractual obligations. 

• Processing is required to comply with a legal obligation to which the Owner is subject. 

• Processing is connected to a task carried out in the public interest or in the exercise of official authority vested in the Owner. 

• Processing is necessary to fulfill the legitimate interests of the Owner or a third party. 

In any case, the Owner is available to assist in clarifying the applicable legal basis for the Data processing, particularly whether providing Personal Data is a legal or contractual requirement, or a necessity for entering into a contract. 
 

Place 
 

The Data is processed at the Owner’s operational offices and any other locations where the parties involved in the processing are based. Depending on the User’s geographical location, this may involve transferring their Data to a country different from their own. For more details about where such Data transfers occur, Users can refer to the relevant section outlining the processing of Personal Data. 
 

Users also have the right to understand the legal basis for transferring Data outside the European Union or to any international organization governed by public international law, such as the UN, and the security measures put in place by the Owner to protect their Data. If such transfers occur, Users can learn more by reviewing the applicable sections of this document or by reaching out to the Owner via the contact information provided. 
 

Retention time 
 

Personal Data will be processed and retained for the duration necessary to fulfill the purposes for which it was collected. 

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Therefore: 

Personal Data collected for purposes related to the performance of a contract between the Owner and the User will be retained until the contract has been fully executed. Personal Data collected for the Owner’s legitimate interests will be retained for as long as necessary to achieve those purposes. Users can find specific details regarding the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting the Owner directly. 
 

The Owner may retain Personal Data for extended periods if the User has consented to such processing, provided that the consent is not revoked. Additionally, the Owner may be legally required to retain Personal Data for longer periods to comply with legal obligations or upon authority orders. Once the retention period ends, Personal Data will be deleted. As a result, after the expiration of the retention period, rights such as access, erasure, rectification, and data portability can no longer be exercised. 
 

The purposes of processing 
 

The Data related to the User is collected to enable the Owner to provide its Service, meet legal obligations, respond to enforcement requests, safeguard its rights and interests (or those of its Users or third parties), and detect any malicious or fraudulent activities. Additionally, the Data may be used for the following purposes: advertising, social features, content performance and feature testing (A/B testing), infrastructure monitoring, analytics, managing contacts and communications, handling payments, platform services and hosting, beta testing, data transfers outside the EU, device permissions for accessing Personal Data, and hosting and backend infrastructure. 
 

For detailed information regarding the specific Personal Data used for each purpose, the User can refer to the section titled “Detailed information on the processing of Personal Data.” 
 

Device permissions for Personal Data access 
 

Based on the User’s specific device, this Application may request certain permissions that enable it to access the User’s device Data, as outlined below. 

By default, these permissions must be granted by the User before the Application can access the respective information. Once granted, the User can revoke these permissions at any time. To revoke permissions, Users can adjust their device settings or contact the Owner for assistance using the contact information provided in this document. The specific process for managing app permissions may vary depending on the User’s device and software. 

Please be aware that revoking these permissions may affect the proper functioning of this Application. 

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If the User grants any of the permissions listed below, the corresponding Personal Data may be processed by this Application, meaning it could be accessed, modified, or removed. 

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Approximate location permission (non-continuous) 

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Used for accessing the User’s approximate device location, this Application may collect, use, and share location Data to provide location-based services. The geographic location of the User is determined intermittently, meaning that the Application cannot continuously track or derive the User’s approximate location at all times. 

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Detailed information on the processing of Personal Data 

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

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Advertising 

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This type of service enables the use of User Data for advertising purposes. Ads, such as banners or other formats, may be displayed within this Application, potentially based on User interests. However, not all Personal Data is used for this purpose. Detailed information and conditions of use are provided below. 

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Some services may use Trackers to identify Users or implement behavioral retargeting, which involves displaying ads tailored to the User's interests and behavior, including those observed outside this Application. For more details, please review the privacy policies of the relevant services. In addition to any opt-out options offered by the services below, Users can also opt out by visiting the Network Advertising Initiative opt-out page. 

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Users may also opt out of certain advertising features through relevant device settings, such as the device's advertising preferences for mobile phones or general ad settings. 

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Admob (Google Ireland Limited) 

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AdMob is an advertising service provided by Google Ireland Limited. In order to understand Google’s use of Data, consult Google’s partner policy. 

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

Place of processing: Ireland – Privacy Policy – Opt Out. 

Facebook Audience Network (Facebook Ireland Ltd) 

Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd In order to understand Facebook’s use of Data, consult Facebook’s data policy. 

This Application may utilize mobile device identifiers (such as the Android Advertising ID or the Advertising Identifier for iOS) and technologies similar to cookies to operate the Facebook Audience Network service. One of the methods Audience Network uses to display ads is by leveraging the User’s ad preferences, which can be managed through the User’s Facebook ad settings. 

Users can opt out of certain Audience Network targeting through their device's advertising settings, such as the mobile phone's advertising preferences, or by following the instructions provided in other relevant sections of this privacy policy, if available. 

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

Place of processing: Ireland – Privacy Policy – Opt Out. 

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Adjust (Adjust GmbH) 

Adjust is an advertising service provided by Adjust GmbH. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Germany – Privacy Policy | Opt Out 

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AdColony (AdColony, Inc.) 

AdColony is an advertising service provided by AdColony, Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Tapjoy (Tapjoy, Inc.) 

Tapjoy is an advertising service provided by Tapjoy, Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Liftoff (Liftoff Mobile, Inc.) 

Liftoff is an advertising service provided by Liftoff Mobile, Inc. 

Personal Data processed: Tracker; Usage Data. 

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

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PubMatic (PubMatic, Inc.) 

PubMatic is an advertising service provided by PubMatic, Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States –Privacy Policy | Opt Out 

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Smaato (Smaato, Inc.) 

Smaato is an advertising service provided by Smaato, Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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TripleLift (TripleLift, Inc.) 

TripleLift is an advertising service provided by TripleLift, Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Unruly (Unruly Group Ltd.) 

Unruly is an advertising service provided by Unruly Group Ltd. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United Kingdom – Privacy Policy | Opt Out 

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InMobi 

InMobi is an advertising service. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: India – Privacy Policy | Opt Out 

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Mintegral (Mintegral International Ltd.) 

Mintegral is an advertising service provided by Mintegral International Ltd. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: China – Privacy Policy | Opt Out 

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AppLovin (AppLovin Corporation) 

AppLovin is an advertising service provided by AppLovin Corporation. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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myTarget (MGL MY.COM (CYPRUS) LIMITED) 

myTarget is an advertising service provided by MGL MY.COM (CYPRUS) LIMITED. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Russia – Privacy Policy | Opt Out 

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DT Exchange (Digital Turbine Inc.) 

DT Exchange is an advertising service provided by Digital Turbine Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Pangle (Bytedance Pte. Ltd.) 

Pangle is an advertising service provided by Bytedance Pte. Ltd. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Singapore – Privacy Policy | Opt Out 

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Google Ad Manager (Google Ireland Limited) 

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Google Ad Manager is an advertising service provided by Google Ireland Limited, enabling the Owner to run ad campaigns in collaboration with external advertising networks, with which the Owner may have no direct relationship unless stated otherwise in this document. To opt out of tracking by various advertising networks, Users can visit Youronlinechoices. For more information on how Google uses data, Users can refer to Google's partner policy. This service uses the "DoubleClick" Cookie to track User interactions with this Application and User behavior related to ads, products, and services offered. 

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Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Ireland – Privacy Policy |   

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Google AdSense (Google Ireland Limited) 

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Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered. Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings – Opt Out. 

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Personal Data processed: Tracker; Usage Data. 

Place of processing: Ireland – Privacy Policy | Opt Out 

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Unity Ads (Unity Technologies ApS) 

Unity Ads is an advertising service provided by Unity Technologies ApS. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Denmark – Privacy Policy | Opt Out 

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Aarki (Aarki Inc.) 

Aarki is an advertising service provided by Aarki Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Fluct (Fluct Inc.) 

Fluct is an advertising service provided by Fluct Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Japan – Privacy Policy | Opt Out 

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Vungle 

Vungle is an advertising service. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Chartboost (Chartboost Inc.) 

Chartboost is an advertising service provided by Chartboost Inc. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: United States – Privacy Policy | Opt Out 

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Ironsource (Ironsource Mobile Ltd.) 

Ironsource is an advertising service provided by Ironsource Mobile Ltd. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Israel – Privacy Policy | Opt Out 

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Analytics 

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The services described in this section allow the Owner to monitor and analyze web traffic and can be used to track User behavior. 

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Google Analytics for Firebase (Google Ireland Limited) 

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Google Analytics for Firebase, or Firebase Analytics, is an analytics service provided by Google Ireland Limited. To better understand how Google handles Data, Users can refer to Google's partner policy. 

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Firebase Analytics may share Data with other Firebase tools, such as Crash Reporting, Authentication, Remote Config, or Notifications. Users can refer to this privacy policy for detailed explanations about these additional tools used by the Owner. 

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This Application utilizes mobile device identifiers and technologies similar to cookies to operate the Firebase Analytics service. 

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Users can opt out of certain Firebase features through their device's advertising settings or by following the instructions provided in other Firebase-related sections of this privacy policy, if available. 

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Personal Data processed includes: Application opens, Application updates, device information, geography/region, in-app purchases, launches, number of sessions, number of Users, operating systems, session duration, Trackers, unique device identifiers for advertising (such as Google Advertiser ID or IDFA), and Usage Data. 

Place of processing: Ireland – Privacy Policy 

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Facebook Analytics for Apps (Facebook Ireland Ltd) 

Facebook Analytics for Apps is an analytics service provided by Facebook Ireland Ltd 

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

Place of processing: Ireland – Privacy Policy 

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Unity Analytics (Unity Technologies ApS) 

Unity Analytics is an analytics service provided by Unity Technologies ApS. 

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

Place of processing: Denmark – Privacy Policy 

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Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd) 

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd. It connects data from the Facebook advertising network with actions performed within this Application. The Facebook pixel tracks conversions that are attributable to ads displayed on Facebook, Instagram, and Audience Network. 

Personal Data processed: Tracker; Usage Data. 

Place of processing: Ireland – Privacy Policy 

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Beta Testing 

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This type of service allows the management of User access to this Application, or specific parts of it, for testing purposes, whether it’s a particular feature or the entire Application. The service provider may automatically collect data related to crashes and usage statistics in a personally identifiable form. 

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Google Play Beta Testing (Google Ireland Limited) 

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Google Play Beta Testing is a beta testing service provided by Google Ireland Limited. 

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

Place of processing: Ireland – Privacy Policy 

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TestFlight (Apple Inc.) 

TestFlight is a beta testing service provided by Apple Inc. 

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

Place of processing: United States – Privacy Policy 

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Content performance and features testing (A/B testing) 

The services described in this section enable the Owner to track and analyze User responses related to web traffic or behavior in reaction to changes in the structure, text, or any other component of this Application. 

Firebase Remote Config (Google Ireland Limited) 

Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited. 

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

Place of processing: Ireland –Privacy Policy 

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Data transfer outside the EU 

The Owner is permitted to transfer Personal Data collected within the EU to third countries (i.e., countries outside the EU) only under a specific legal basis. Such transfers are conducted in accordance with one of the legal bases outlined below. Users can contact the Owner to find out which legal basis applies to each specific service. 

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Data transfer abroad based on standard contractual clauses (this Application) 

If this is the legal basis, the transfer of Personal Data from the EU to third countries is conducted by the Owner under the “standard contractual clauses” issued by the European Commission. This ensures that Data recipients have committed to processing Personal Data in accordance with the data protection standards established by EU data protection laws. For further information, Users can contact the Owner using the contact details provided in this document. 

Personal Data processed: various types of Data. 

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Device permissions for Personal Data access 

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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 includes Approximate location permission (non-continuous), and Storage permission. 

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Handling payments 

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Unless otherwise specified, this Application processes payments via credit card, bank transfer, or other methods through external payment service providers. Generally, and unless otherwise noted, Users are required to provide their payment details and personal information directly to these payment service providers. This Application does not collect or process such information; it only receives a notification from the relevant payment service provider indicating whether the payment was successfully completed. 

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RevenueCat (RevenueCat, Inc.) 

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RevenueCat is a payment service provided by RevenueCat, Inc. This service enables the Owner to monitor and analyze User purchase history and can be used to track User behavior related to in-app purchases. 

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

Place of processing: United States – Privacy Policy | Opt Out 

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Payments processed via the Apple App Store (Apple Inc.) 

This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases. 

Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store. 

Personal Data processed: payment info. 

Place of processing: United States – Privacy Policy 

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Payments processed via the Google Play Store (Google Ireland Limited) 

This Application uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases. 

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store. 

Personal Data processed: payment info. 

Place of processing: Ireland – Privacy Policy 

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Hosting and backend infrastructure 

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This type of service is designed to host Data and files that allow this Application to operate and be distributed, while also providing the necessary infrastructure to support specific features or components of the Application. 

Some of the services listed below, if any, may operate through geographically distributed servers, which can make it challenging to determine the exact location where the Personal Data is 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 

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Infrastructure monitoring 

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This type of service enables this Application to monitor the usage and behavior of its components, allowing for improvements in performance, operation, maintenance, and troubleshooting. The specific Personal Data processed depends on the features and implementation of these services, which function to filter and analyze the activities within this Application. 

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Firebase Performance Monitoring (Google Ireland Limited) 

Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited. 

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

Place of processing: Ireland – Privacy Policy 

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Crashlytics (Google Ireland Limited) 

Crashlytics is a monitoring service provided by Google Ireland Limited. 

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

Place of processing: Ireland –Privacy Policy. 

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Managing contacts and sending messages 

This type of service allows for the management of a database containing email contacts, phone contacts, or other contact information to communicate with the User. These services may also collect data on when the message was viewed by the User and any interactions with it, such as clicking on links within the message. 

Firebase Notifications (Google Ireland Limited) 

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Firebase Notifications is a messaging service provided by Google Ireland Limited. It can be integrated with Firebase Analytics to target audiences based on analytics data and track events such as message openings and conversions. 

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

Place of processing: Ireland – Privacy Policy 

Platform services and hosting 

These services are designed to host and run key components of this Application, enabling it to be provided from within a unified platform. Such platforms offer the Owner a variety of tools, such as analytics, user registration, commenting, database management, e-commerce, and payment processing, all of which involve the collection and handling of Personal Data. Some of these services operate through geographically distributed servers, making it difficult to pinpoint the exact location where Personal Data is stored. 

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Apple App Store (Apple Inc.) 

This Application is distributed via Apple’s App Store, a mobile app distribution platform provided by Apple Inc. 

As a result of being available on this platform, Apple collects basic analytics and offers reporting features that allow the Owner to access usage analytics data and assess the performance of this Application. A significant portion of this information is processed on an opt-in basis. 

Users can opt out of this analytics feature directly through their device settings. For more information on how to manage these analytics settings, Users can refer to the instructions provided on this page. 

Personal Data processed: Usage Data. 

Place of processing: United States – Privacy Policy 

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Google Play Store (Google Ireland Limited) 

This Application is distributed via the Google Play Store, a mobile app distribution platform provided by Google Ireland Limited. 

As a result of being distributed through this platform, Google collects usage and diagnostics data and shares aggregated information with the Owner. A large portion of this data is processed on an opt-in basis. 

Users can opt out of this analytics feature through their device settings. More information on managing these settings can be found on this page. 

Personal Data processed: Usage Data. 

Place of processing: Ireland –Privacy Policy 

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Social features 

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Firebase Dynamic Links (Google Ireland Limited) 

Firebase Dynamic Links is a social feature provided by Google Ireland Limited. These Dynamic Links are tracked through Firebase or Google Analytics for Firebase, providing the Owner with insights into the User's journey both to and within this Application. 

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

Place of processing: Ireland –Privacy Policy 

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Firebase Invites (Google Ireland Limited) 

Firebase Invites is a social feature provided by Google Ireland Limited that allows Users to share this Application. Users may share referral codes or content from the Application via email or SMS. Sharing activities are tracked using Google Analytics for Firebase, which informs the Owner when a User has opened or installed the Application through an invite. 

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

Place of processing: Ireland –Privacy Policy 

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Further information about Personal Data 

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Push notifications 

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This Application may send push notifications to the User to fulfill the purposes described in this privacy policy. 

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In most cases, Users can opt out of receiving push notifications by visiting their device settings, such as notification settings for mobile phones, and adjusting those settings for this Application or for some or all of the apps on the device. Users should note that disabling push notifications may impact the usefulness of this Application. 

The rights of Users 

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Users may exercise certain rights regarding their Data processed by the Owner. 

In particular, Users have the following rights: 

• Withdraw consent at any time: Users can withdraw their consent if they have previously given consent for the processing of their Personal Data. 

• Object to processing of their Data: Users can object to the processing of their Data if it is based on a legal basis other than consent. More information can be found in the relevant section below. 

• Access their Data: Users can learn if their Data is being processed by the Owner, receive details about the processing, and obtain a copy of the Data. 

• Verify and seek rectification: Users can verify the accuracy of their Data and request updates or corrections. 

• Restrict processing of their Data: Under certain circumstances, Users can restrict the processing of their Data. In this case, the Owner will only store the Data and not process it for any other purpose. 

• Have their Data deleted: Under certain circumstances, Users can request the erasure of their Data from the Owner. 

• Receive their Data and have it transferred: Users can receive their Data in a structured, commonly used, machine-readable format and have it transferred to another controller if technically feasible. This right applies when Data is processed by automated means and based on User consent, a contract the User is a part of, or pre-contractual obligations. 

• Lodge a complaint: Users can file a complaint with their local data protection authority.  

 

Details about the right to object to processing: 

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When Personal Data is processed in the public interest, in the exercise of official authority vested in the Owner, or for the legitimate interests pursued by the Owner, Users may object to such processing by providing reasons related to their specific situation. 

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However, if Personal Data is being processed for direct marketing purposes, Users can object at any time without needing to provide any justification. To determine whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

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How to exercise these rights: 

Users can direct any requests to exercise their rights to the Owner using the contact details provided in this document. These requests are free of charge and will be addressed by the Owner as soon as possible, and always within one month. 

Additional information about Data collection and processing: 

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Legal action: 

The User’s Personal Data may be used by the Owner for legal purposes, either in Court or during preparatory stages for potential legal actions arising from misuse of this Application or related Services. The User acknowledges that the Owner may be required to disclose personal data upon request by public authorities. 

Additional information about User’s Personal Data: 

Beyond the information provided in this privacy policy, this Application may provide the User with further contextual details regarding specific Services or the collection and processing of Personal Data upon request. 

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System logs and maintenance: 

For operational and maintenance purposes, this Application and any third-party services may collect files that record interactions with this Application (System logs), as well as other Personal Data (such as IP addresses). 

Information not contained in this policy: 

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More details regarding the collection or processing of Personal Data may be requested from the Owner at any time. Please refer to the contact information provided at the beginning of this document. 

How “Do Not Track” requests are handled: 

This Application does not support "Do Not Track" (DNT) requests. To determine whether any third-party services used by this Application honor DNT requests, please review their respective privacy policies. 

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Changes to this privacy policy: 

The Owner reserves the right to make changes to this privacy policy at any time by notifying Users on this page and possibly within this Application, and/or, as technically and legally feasible, by sending a notice to Users through any contact information available to the Owner. Users are strongly encouraged to check this page frequently, noting the date of the last update listed at the bottom. If changes affect the processing activities performed based on the User’s consent, the Owner will seek new consent from the User where required. 

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Definitions and legal references 

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Usage Data 

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Information collected automatically through this Application (or via third-party services used in this Application) may include: IP addresses or domain names of the computers used by Users of this Application, URI addresses (Uniform Resource Identifier), time of requests, the method used to submit requests to the server, size of the files received in response, numerical codes indicating the status of the server's response (e.g., successful, error), country of origin, browser and operating system details, various time-related details per visit (such as time spent on each page), details about the navigation path within the Application (including the sequence of pages visited), and other parameters related to the User's device, operating system, and IT environment. 

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App Usage Stats 

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Device usage history and statistics, including app usage history with package names. Usage data is aggregated into various time intervals: days, weeks, months, and years. 

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User 

The individual using this Application, who, unless otherwise specified, is the Data

 

Subject. 

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Data Subject 

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The natural person to whom the Personal Data refers. 

Data Processor (or Data Supervisor) 

The natural or legal person, public authority, agency, or other entity that processes Personal Data on behalf of the Controller, as described in this privacy policy. 

Data Controller (or Owner) 

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The natural or legal person, public authority, agency, or other entity that, alone or jointly with others, determines the purposes and means of processing Personal Data, including security measures for the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application. 

This Application 

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The methods used to collect and process the User's Personal Data. 

Service 

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The service offered by this Application, as described in the relevant terms (if available) and on this site/application. 

European Union (or EU) 

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Unless otherwise specified, all references in this document to the European Union include all current member states of the European Union as well as the European Economic Area. 

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Cookie 

Cookies are Trackers made up of small sets of data stored in the User’s browser. 

Tracker 

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A Tracker refers to any technology—such as Cookies, unique identifiers, web beacons, embedded scripts, e-tags, or fingerprinting—that allows for tracking Users, typically by accessing or storing information on the User's device. 

Legal information 

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This privacy statement has been prepared in accordance with multiple legislations, including Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation). 

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Unless otherwise stated, this privacy policy applies exclusively to this Application. 

Latest update: October 10, 2024