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Privacy Policy

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

1. General

Regarding the Services: Mobsoft Technology SRL. ("Mobsoft", "we", "us" or "our") is the Data Controller within the meaning of the General Data Protection Regulation ("GDPR").

This privacy policy shall inform you on how we collect, process and use ("Use") personal data in connection with the Services.

2. Data we collect, process and use

2.1 In general, you can use the Services without providing any personal information such as e.g. your name, email address, postal address, telephone number, financial information (all such information concerning the personal or material circumstances of an identified or identifiable individual data subject together "Personal Data"). Therefore, if you do not provide us directly with Personal Data in another way or actively consent to the Use by us of certain Personal Data, we, in general, do not Use your data with the exception of the following:

2.1.1 Regarding the Website: your browser transfers certain data so that it can access the Website, namely:

2.1.2 Regarding the App: certain data is transmitted by your mobile device: namely your IP address, the periods of time in which you use the App and the type of device you use (e.g. iPhone, iPad), as well as events within the application recorded with Answers (The analytics engine of Fabric by Google) in order to give us the possibility to continuously improve the App.

2.1.3 Regarding the App: in certain cases, such as downloading and installing a free trial of a paid App, we ask you to enter a valid email address to recover your passcode and unlock your albums.

2.1.4 Regarding the email: we save a record of communication including attachments and information you voluntary decide to share with us for troubleshooting purposes whenever you communicate with our support team.

The legal basis for the processing of the data described above in section 2.1.1 through 2.1.6 (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; regarding section 2.1.1 the legitimate interests to Use such data arises from the fact that without such data the Website cannot be accessed by our customers and/or other users; regarding section 2.1.2 the legitimate interests to Use such data is that we have an interest to continuously improve the App; regarding section 2.1.3 the legitimate reason is that we need to inform you about the end of your free trial; regarding section 2.1.5 the legitimate reason is that we need the information to provide you with the support you requested).

2.2 Only in cases in which you have given us prior consent we also use your Personal Data for other purposes but only to the extent needed in each specific case. The legal basis for the processing of the data described in this section 2.2 is Art. 6 (1) sentence 1 lit. a GDPR (consent).

2.3 We may disclose Personal Data to third parties where such disclosure is required by law (for example, upon request of a court or of law enforcement authorities). The legal basis for the processing of the data described in this section 2.3 is Art. 6 (1) sentence 1 lit. c GDPR (legal obligation).

2.4 We may also Use certain data as set forth in section 3 below.

3. Mobsoft's cookies policy

3.1 Mobsoft's websites use cookies to personalize your experience on our sites. Cookies tell us which parts of our websites people have visited, help us measure the performance of ads, and give us insights into user behavior so we can improve our communications and products.

You can disable cookies anytime in your web browser. Here is how it works in Google Chrome and Safari browsers:

Chrome:

Safari:

For other browsers, please check the documentation your provider provides.

Mobsoft's cookies don't collect information that personally identify you. Also, other sites or companies won't be able to track you through our cookies.

When you disable cookies, our website can no longer provide you with the best user experience and you miss the opportunity to get more personalized information, such as displaying information in your language or displaying prices in your currency.

Cookies: use of (further analyzing) tools

Cookies are stored on your computer when using the Website. Cookies are small text files that are stored on your hard disk of the computer with which you visit a website and which are allocated to your browser and through which certain information is submitted to the cookies user that sets the cookie (in this case us). Cookies serve to make the website offering more user-friendly and effective overall.

The Website uses cookies to the following extent:

Transient cookies are automatically deleted when you close your browser. This includes in particular the session cookies. These store a so-called session ID, which identify user session in the browser. Session cookies are deleted when you log out or close your browser.

Persistent cookies help the Website remember your information and settings when you visit them in the future. They are automatically deleted after a specified period, which may differ depending on the cookie.

We also use cookies on our website which enable an analysis of the user's surfing behavior.

3.2 The Website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help analyze how you use the Website. The information generated by the cookie about your use of the Website will normally be transmitted to and stored by Google on servers in the United States.

Because IP-anonymization is activated on the Website, your IP address will be truncated within the area of member states of the European Union or within other contracting states to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. Google will use this information on behalf of Mobsoft for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services for Mobsoft relating to website activity and internet usage.

The IP address that your browser transfers within the scope of Google Analytics will not be associated with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings in your browser, however please note that if you do so you may not be able to use all functions of the Website. You can also opt-out from the storage by Google of the data that is created by the cookie and is related to the use of the Website (including your IP address) and the processing of such data by Google by downloading and installing the Google Analytics opt-out Browser add-on available under https://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser add-on or within browsers on mobile devices, you can click this link in order to opt-out from being tracked by Google Analytics within this Website in the future (this opt-out option applies only for the browser in which you set it and with regard to the Website). In this case an opt-out cookie is put on your device. In case you delete your cookies, you will have to use the aforementioned link again.

For further information on Google Analytics please refer to: http://www.google.com/analytics/terms/, https://support.google.com/analytics/answer/6004245?hl=en and https://policies.google.com/privacy?hl=en&gl=en

3.3 Our Apps use Facebook SDK of Facebook 1 Hacker Way, Menlo Park, to analyze sources of app installations and how you use the app. Facebook SDK and Analytics is a service which helps us to improve ours Service by better understanding general app usage patterns.

3.4 If you decide to deactivate (some of) the cookies and tools described above, please note that certain features and functionalities of the Services might not work or might not be accessible to you.

3.5 The legal basis for the processing of the data described in this section 3 (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests to Use such data is that we use and analyze the respective data to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services and to help personalize your user experience).

4. Technical implementation of the services by subcontractors

We partly use service providers who process Personal Data on behalf of us to operate the technical platform for the Services. These service providers process the data exclusively according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).

5. Duration of storage of personal data

Unless no shorter storage period is indicated in this privacy policy, we, in general, store Personal Data as long (i) as required for the provision of the Services to you, and/or (ii) as it is necessary with regard to the contractual relationship with you, thereafter only if and to the extent that we are obliged to do so by mandatory statutory retention obligations. If we no longer require the respective Personal Data for the purposes described above, such Personal Data will only be stored during the respective legal retention period and not processed for other purposes.

6. Your rights

You have the right to request information from us at any time about your Personal Data stored by us. If the legal requirements are met, you also have rights vis-à-vis us to request from us access to and rectification or erasure or restriction of processing concerning your Personal Data or to object the processing of your Personal Data as well as the right to receive your Personal Data provided to us in a structured, established and machine-readable format from us (you can transfer this data to other parties or have it transferred; data portability).

If you have given your consent to the use of personal data, you can revoke such consent at any time (for the future).

If you believe that the processing of your Personal Data by us is in breach of the applicable data protection laws, you can issue a complaint with the competent supervisory authority for data protection.

7. Keeping your personal data secure

We have taken extensive technical and operational precautions to protect the Personal Data retained by us against unauthorized access and misuse. Our security procedures are revised regularly and adapted to reflect technological progress.

 

8. Access to third-party accounts

 

This type of service allows Mobsoft to access Data from your account on a third-party service and perform actions with it.

These services are not activated automatically, but require explicit authorization by the User.

 

Facebook account access

 

This service allows App to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

 

Permissions asked: E-mail address, Public profile, User photos and videos.

 

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Instagram account access

 

This service allows App to connect with the User's account on the Instagram social network, provided by Facebook, Inc.

 

Permissions asked: Access to Basic profile and Public content

 

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Google Drive account access

 

This service allows App to connect with the User's account on the Google Drive, provided by Google, Inc.

 

Permissions asked: Basic profile, View and manage the files in your Google Drive..

 

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Dropbox account access

 

This service allows App to connect with the User's account on the Dropbox, provided by Dropbox, Inc.

 

Permissions asked: Access to the files and folders in your Dropbox.

 

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

OneDrive account access

 

This service allows App to connect with the User's account on the OneDrive, provided by Microsoft Corporation.

 

Permissions asked: Access to the app folder, offline access, read and write.

 

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Box account access

 

This service allows App to connect with the User's account on the Box, provided by Box, Inc.

 

Permissions asked: Read and write all files and folders stored in Box.

 

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

 

 

 

9. Advertising

 

 

 

 

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on App, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside App. For more information, please check the privacy policies of the relevant services.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

In order to understand Google's use of Data, consult Google's partner policy.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

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

AdColony (Jirbo, Inc.)

AdColony is an advertising service provided by Jirbo, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy Opt out.

Chartboost (Chartboost, Inc.)

Chartboost is an advertising service provided by Chartboost Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Flurry RTB (Yahoo! Inc.)

Flurry RTB (Flurry Real-Time Bidding) is an advertising service provided by Yahoo! Inc. that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.

App is collecting and transmitting Data from the User through the Flurry RTB service to media buyers bidding to purchase its inventory. These buyers may collect and store such Data and use such Data for retargeting or other advertising purposes.

If the User chooses to opt-out, Flurry will stop tracking Data for the device identified by the provided MAC address and/or device identifier going forward. Flurry will also stop providing ads and/or recommendations to that MAC address and/or device identifier across all publishers.

In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices.

Personal Data collected: Cookies and Usage Data.

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

MoPub (MoPub Inc.)

MoPub is an advertising service provided by MoPub Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

MobFox (MobFox Mobile Advertising GmbH)

MobFox is an advertising service provided by MobFox Mobile Advertising GmbH.

Personal Data collected: Cookies and Usage Data.

Place of processing: Austria – Privacy Policy.

SupersonicAds (SupersonicAds Ltd.)

SupersonicAds is an advertising service provided by SupersonicAds Ltd.

Personal Data collected: Cookies and Usage Data.

Place of processing: United Kingdom – Privacy Policy.

Unity Ads (Unity Technologies ApS)

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

Personal Data collected: Cookies and Usage Data.

Place of processing: Denmark – Privacy Policy.

Vungle (Vungle, Inc.)

Vungle is an advertising service provided by Vungle, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Appnext (Appnext Ltd.)

Appnext is an advertising service provided by Appnext Ltd.

Personal Data collected: Cookies and Usage Data.

Place of processing: Virgin Islands, British – Privacy Policy.

Facebook Audience Network (Facebook, Inc.)

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

App may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

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

 

 

 

11. Changes to this privacy policy

 

 

 

Mobsoft reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within App and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

 

Should the changes affect processing activities performed on the basis of the User’s consent, the Mobsoft shall collect new consent from the User, where required.

 

 

12. Contact

 

You can contact us (e.g. if you have any questions about data protection regarding Mobsoft (including regarding the assertion of your rights further explained in section 6 above)), for example, via the address indicated above in section 1 or via the following emails: mc@mob-soft.eu

 

15 General Nicolae C. Dona Street

 

Bucharest, Romania

 

Updated at: 30/10/2018