PRIVACY POLICY
Last updated December 28, 2020
Thank you for choosing to be part of our community at
ApkSparrow (“Company“,
“we“, “us“, “our“). We are committed to protecting
your personal information and your right to privacy. If you have any questions or concerns about this
privacy notice or our practices with regards to your personal information, please contact us at
thefactsparrow@gmail.com.
When you use our mobile application, as the case may be (the
“App“) and more generally, use any of our services (the “Services“,
which include the
App
), we appreciate that you are trusting us with your personal information. We
take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible
what information we collect, how we use it, and what rights you have in relation to it. We hope you take some
time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do
not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all
information collected through our Services (which, as described above, includes
our App), as well as, any related services, sales, marketing, or
events.
Please read this privacy notice
carefully as it will help you understand what we do with the information that we
collect.
TABLE OF
CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Information automatically collected
In
Short: Some information — such as
your Internet Protocol (IP) address and/or browser and device characteristics — is
collected automatically when you visit our App.
We automatically collect
certain information when you visit, use, or navigate the App. This information does not reveal your specific
identity (like your name or contact information) but may include device and usage information, such as
your IP address, browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use our App and other technical
information. This information is primarily needed to maintain the security and operation of our App, and for our internal
analytics and reporting purposes.
The information we collect
includes:
- Device Data. We collect device data such as information about your computer, phone, tablet, or another device you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system, and system configuration information.
Information collected through our App
In
Short: We collect
information regarding your push notifications when you use our
App.
If you use our App, we
also collect the following information:
- Push Notifications. We may request to send you to push notifications regarding your account or certain features of the App. If you wish to opt-out of receiving these types of communications, you may turn them off in your device’s settings.
This
information is primarily needed to maintain the security and operation of our
App, for troubleshooting, and for our internal analytics and reporting
purposes.
2.
HOW DO WE USE YOUR
INFORMATION?
In Short:
We process your information for
purposes based on legitimate business interests, the
fulfillment of our contract with you, compliance with our
legal obligations, and/or your
consent.
We use personal information collected via our
App
for a variety of business purposes described below. We process your
personal information for these purposes in reliance on our legitimate business
interests, in order to enter into or perform a contract with you, with your
consent, and/or for compliance with our legal obligations. We indicate the
specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or
receive:
-
To
send administrative information to
you. We may use your
personal information to send you the
product, service, and new feature
information and/or information about
changes to our terms, conditions, and
policies.
-
To
protect our Services. We
may use your information as part of our
efforts to keep our
App
safe and secure (for example,
for fraud monitoring and
prevention).
-
To
enforce our terms, conditions, and policies
for business purposes, to comply with legal
and regulatory requirements, or in
connection with our contract.
-
To
respond to legal requests and
prevent harm. If we receive
a subpoena or other legal request, we
may need to inspect the data we hold to
determine how to respond.
- To
send you marketing and promotional
communications. We and/or
our third-party marketing partners may
use the personal information you send to
us for our marketing purposes if this is
in accordance with your marketing
preferences. For example, when
expressing an interest in obtaining
information about us or our App,
subscribing to marketing, or otherwise
contacting us, we will collect personal
information from you. You can opt-out of
our marketing emails at any time (see
the “WHAT
ARE YOUR PRIVACY
RIGHTS”
below).
- Deliver
targeted advertising to
you. We may
use your information to develop and
display personalized content and
advertising (and work with third parties
who do so) tailored to your interests
and/or location and to measure its
effectiveness.
- For other business
purposes. We may use your
information for other business purposes, such as data
analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns, and to
evaluate and improve our App,
products, marketing, and your experience. We may use and
store this information in aggregated and anonymized form
so that it is not associated with individual end-users
and does not include personal information. We will not
use identifiable personal information without your
consent.
3. WILL YOUR
INFORMATION BE SHARED WITH
ANYONE?
In
Short: We only share information
with your consent, to comply with laws, to provide you
with services, to protect your rights, or to fulfill
business obligations.
We may process or share
your data that we hold based on the following legal
basis:
- Consent:
We may process your data if you have
given us specific consent to use your
personal information for a specific
purpose.
- Legitimate
Interests: We may process
your data when it is reasonably
necessary to achieve our legitimate
business
interests.
- Performance
of a Contract: Where we
have entered into a contract with you,
we may process your personal information
to fulfill the terms of our
contract.
- Legal
Obligations: We may
disclose your information where we are
legally required to do so in order to
comply with applicable law, governmental
requests, a judicial proceeding, court
order, or legal processes, such as in
response to a court order or a subpoena
(including in response to public
authorities to meet national security or
law enforcement
requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically,
we may need to process your data or share your
personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4.
IS YOUR INFORMATION
TRANSFERRED
INTERNATIONALLY?
In
Short: We
may transfer, store, and process
your information in countries
other than your
own.
Our
servers are located in. If you are
accessing our App
from outside, please be aware that
your information may be transferred
to, stored, and processed by us in
our facilities and by those third
parties with whom we may share your
personal information (see “WILL
YOUR INFORMATION BE
SHARED WITH
ANYONE?”
above), in and other
countries.
If you
are a resident in the European
Economic Area, then these countries
may not necessarily have data
protection laws or other similar
laws as comprehensive as those in
your country. We will however take
all necessary measures to protect
your personal information in
accordance with this privacy notice
and applicable
law.
5.
HOW LONG DO WE KEEP
YOUR
INFORMATION?
In
Short: We
keep your information for as
long as necessary to fulfill the
purposes outlined in this
privacy notice unless otherwise
required by
law.
We
will only keep your personal
information for as long as it is
necessary for the purposes set out
in this privacy notice unless a
longer retention period is required
or permitted by law (such as tax,
accounting, or other legal
requirements). No purpose in this
notice will require us to keep your
personal information for longer than
90
days.
When
we have no ongoing legitimate
business need to process your
personal information, we will either
delete or anonymize such information
or, if this is not possible (for
example, because your personal
information has been stored in
backup archives), then we will
securely store your personal
information and isolate it from any
further processing until deletion is
possible.
6.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short: We
aim to protect your personal
information through a system of
organizational and technical
security
measures.
We
have implemented appropriate
technical and organizational
security measures designed to
protect the security of any personal
information we process. However,
despite our safeguards and efforts
to secure your information, no
electronic transmission over the
Internet or information storage
technology can be guaranteed to be
100% secure, so we cannot promise or
guarantee that hackers,
cybercriminals, or other
unauthorized third parties will not
be able to defeat our security, and
improperly collect, access, steal,
or modify your information. Although
we will do our best to protect your
personal information, the
transmission of personal information
to and from our App
is at your own risk. You should only
access the App
within a secure
environment.
7.
WHAT ARE YOUR
PRIVACY
RIGHTS?
In
Short:
You may review, change, or
terminate your account at any
time.
If you
are a resident in the European
Economic Area and you believe we are
unlawfully processing your personal
information, you also have the right
to complain to your local data
protection supervisory authority.
You can find their contact details
here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you
are a resident in Switzerland, the
contact details for the data
protection authorities are available
here: https://www.edoeb.admin.ch/edoeb/en/home.html.
8.
CONTROLS FOR
DO-NOT-TRACK
FEATURES
Most
web browsers and some mobile
operating systems and mobile
applications include a Do-Not-Track
(“DNT”) feature or setting you can
activate to signal your privacy
preference not to have data about
your online browsing activities
monitored and collected. At this
stage, no uniform technology
standard for recognizing and
implementing DNT signals has been
finalized. As such, we do not
currently respond to DNT browser
signals or any other mechanism that
automatically communicates your
choice not to be tracked online. If
a standard for online tracking is
adopted that we must follow in the
future, we will inform you about
that practice in a revised version
of this privacy
notice.
9.
DO CALIFORNIA
RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes,
if you are a resident of
California, you are granted
specific rights regarding access
to your personal
information.
California
Civil Code Section 1798.83, also
known as the “Shine The Light” law,
permits our users who are California
residents to request and obtain from
us, once a year and free of charge,
information about categories of
personal information (if any) we
disclosed to third parties for
direct marketing purposes and the
names and addresses of all third
parties with which we shared
personal information in the
immediately preceding calendar year.
If you are a California resident and
would like to make such a request,
please submit your request in
writing to us using the contact
information provided
below.
If you
are under 18 years of age, reside in
California, and have a registered
account with the
App,
you have the right to request the
removal of unwanted data that you
publicly post on the App.
To request removal of such data,
please contact us using the contact
information provided below, and
include the email address associated
with your account and a statement
that you reside in California. We
will make sure the data is not
publicly displayed on the App,
but please be aware that the data
may not be completely or
comprehensively removed from all our
systems (e.g. backups,
etc.).
10.
DO WE MAKE UPDATES
TO THIS
NOTICE?
In
Short: Yes, we
will update this notice as
necessary to stay compliant with
relevant
laws.
We may
update this privacy notice from time
to time. The updated version will be
indicated by an updated “Revised”
date and the updated version will be
effective as soon as it is
accessible. If we make material
changes to this privacy notice, we
may notify you either by prominently
posting a notice of such changes or
by directly sending you a
notification. We encourage you to
review this privacy notice
frequently to be informed of how we
are protecting your
information.
11.
HOW CAN YOU CONTACT
US ABOUT THIS
NOTICE?
If
you have questions or
comments about this
notice, you may email
us at
thefactsparrow@gmail.com