This Privacy Statement was last updated on 24/05/2018.
BY DOWNLOADING, InSTALLING AND/OR USING the app and making IN-APP purchases YOU AGREE TO THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT STOP USING THE APP AND UNINSTALL IT, AS WELL AS DO NOT proceed to MAKE IN-APP PURCHASES.
Veraxen Ltd. is a private company limited by shares incorporated under the laws of the Republic of Cyprus, duly registered in the relevant Companies Register kept at the Department of Registrar of Companies and Official Receiver of the Republic of Cyprus with registration number HE 361858, whose registered office is at Archiepiskopou Kyprianou, 2, and Zakinthou, Office 101, 6016, Larnaca, Cyprus (hereinafter “the Company” or “We” or “Us”, unless otherwise provided herein), that shall be the controller and the entity responsible for your personal data. We take your privacy very seriously and we ask that you read the present Privacy Statement carefully before proceeding with the submission of your personal data either on the Company’s website (hereinafter “Website”) and/or via mobile application software developed or owned by the Company (hereinafter “App”).
The provision of your data is voluntary, however, please note that if you do not provide us with the required personal data, We may not be able to provide the information, products or services you need or process your request. You are strongly urged to read the present Privacy Statement and make sure that you agree with the contents thereof.
This Privacy Statement applies to information We collect about:
visitors to Our Website; and
persons who use Our Apps.
Purpose of Collection of Personal Data and Intended Use
In accordance with the applicable regulatory framework We may use your personal data solely for the purpose for which these have been provided by you and for no other purpose.
We and our Partners may collect, use and otherwise process your personal data for the purposes of performance of our obligations towards you, information storage and access, content and ad personalization, ad selection, delivery, reporting, and measurement.
We define the purposes above as follows:
Storage and access of information
The storage of information, or access to information that is already stored, on your device and subsequently on Our servers such as accessing advertising identifiers and/or other device identifiers, and/or using cookies or similar technologies. This is necessary to ensure the better experience for you in the course of using App.
Our App hosts third-party content or material such as advertisements. We provide an opportunity to personalize your advertising experience. By consenting to this enhanced ad experience, you’ll see ads that we and Our Partners believe are more relevant to you. Depending on your privacy settings, We and Our Partners may process personal data such as device identifiers, location data and other data, including information about your use of the App to personalize your advertising experience.
Ads selection, reporting and delivery
We also advertise Our App via different ad networks and measure their delivery via third party providers of analytical systems. And you may probably find Us via such advertising. If so, We may process your personal data such as online identifiers, IP addresses, location data, and information about your behavior in relation to the ads, in order to measure the delivery and effectiveness of such advertisement, improve Our ads, select and deliver the better ads for you. Such processing includes collection of information, its combination with previously collected information and sharing with ad networks and third party providers of analytical systems involved.
The collection of information about your use of content and your behavior in the App, and combination with previously collected information, used to measure, understand, and report on your usage of the App.
The processing of personal data that you are asked to submit on Our Website and/or via an App shall only be carried out after We have obtained your consent or because such processing is necessary for the performance of a contract to which you, in your capacity as the data subject, are a party (or are about to become a party), or in order to take measures at your request prior to entering into a contract, or in the course of pursuing a legitimate business purpose or interest on the part of the Company (or of a third party), provided always that such legitimate business interest does not override your fundamental rights and interests, or where We need to comply with a legal or regulatory obligation. We seek only to obtain such information as may be necessary for facilitating and procuring an optimal level of service for users of the Website and/or Our App.
The information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Each time you visit our Website We will automatically collect the following information:
Internet Protocol Address (IP-address) which is not the IP-address of your Device, but rather the IP-address allocated by your Internet-service provider;
Accepted languages. That means that We automatically obtain approximate information, based on IP-address, regarding the most preferable language for you;
Other information which is of technical nature and does not enable Us to identify you personally.
Each time you use our App We may automatically collect the following information:
Internet Protocol Address (IP-address) which is also not the IP-address of your Device, but rather the IP-address allocated by your Internet-service provider;
Advertiser identifier such as Apple’s Identifier For Advertisers (IDFA) and Google’s Advertising ID, which is a random device identifier assigned by Apple or Google respectively to a user’s device. Advertisers use this identifier to track data so they can deliver customized advertising. The advertiser identifier reveals no personal information. Instead, it’s used for tracking and identifying a user, which then allows advertisers to access aggregated data which can be used to discover information – such as which in-app events they trigger. The advertiser identifier can also identify users when they interact with a mobile advertising campaign, provided the channel offers advertiser identifier tracking and that the advertiser tracks users who interact with adverts successfully. If this occurs the advertiser identifier can pick up whether specific users click an advert for payment and attribution purposes;
Apple’s identifier For Vendor which is an alphanumeric string that uniquely identifies a device to the app’s vendor;
Your data from Facebook, in particular profile link, name, birthday, email, gender, list of your friends, Facebook ID and etc. We receive these data only if you log-in via Facebook in our App;
Technical information from your Device (for example, type of internet connection, current date, platform or operational system, device type and model, device screen resolution, App version, language settings used in the App, etc.);
Online identifiers such as User Identifier or Game Identifier. These identifiers do not allow Us to identify your personality and are created and used by us for the purpose of performing Our contract towards you.
When you address an inquiry or issue to Our customer service team via Our Website or App, You will be asked to provide us with your full name and email. We assume that the personal information provided is accurate. However, We are not in a position, nor do We intend to verify whether the personal information you have provided is accurate or to confirm your identity.
If you object to the collection and use of such personal information by Us in this way, you should refrain from downloading, installing and/or using the App and/or visiting Our Website. In the event that you have already installed, downloaded and/or using the App, you can always stop Us from collecting such information by uninstalling or removing the App from your Device or, in the case of Our Website, by leaving the Website.
We also collect, use and share certain data with Our analytical systems such as statistical data for any purpose. Such data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, We may use such data to calculate the percentage of users accessing a specific App feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.
We may also use GPS technology and/or other relevant technologies to determine your current location. We do not use it now. However, we automatically collect the information that can be defined as information of location nature from your Device or from any third party in the course of calculating your estimated location. In some cases you may be asked to consent to your rough location data being used for legitimate purpose(s). By consenting to this you authorize Us and Our affiliates, contractors (and their subcontractors, if it is in line with the purpose(s) for which the consent is asked) and licensees for transmission, collection, retention, maintenance, processing and use of your location data. You can withdraw your consent at any time by visiting App settings and/or turning off the location services settings on your Device.
How We will use the information about you
We gather this information in order to improve Our Website and/or the App as well as to enhance your experience in the course of using the App. Provided you expressly authorize Us to do so, we may share your personal information with Our analytical systems for the purposes of monitoring our Website and/or our Apps and we may also provide such information to third parties such as advertisement networks. The information shared with such analytical systems and third parties will not include information sufficient to identify you personally. You may withdraw your consent authorizing Us to share your information in this way, at any time by visiting App settings or uninstalling the App.Use of User Comments or Reviews
For the purposes of promoting the App, We may also wish to use any comments or reviews that you may make on the App’s official page on any App Store or on any social networking sites (“the Social Networks”) or sent to our customer service team via email. We will always ask for your express, unambiguous consent before using any of your comments or material uploaded, posted or otherwise shared by you on the App’s official page on App Store or on such Social Networks or sent to our customer service team via email. In the event that you authorize Us to do so, We may use your comments or reviews in full or in part and We may also use your name, user or profile name on the Social Network in question. You may revoke your consent authorizing Us to use your personal information in this manner at any time by contacting us.
Data Protection Officer (DPO)
The General Data Protection Regulation which shall enter into force on 25/05/2018, requires that We appoint a Data Protection Officer entrusted with the responsibility of ensuring compliance with our obligations under GDPR in respect of matters pertaining to privacy and data protection. You may contact our DPO here.
Marketing and Third-Party Content
Our App is made available free of charge. The App hosts third-party content or material such as advertisements of generic nature not specifically tailored to match your individual preferences. Such third-party content is hosted by default and We do not share your personal information with such third parties. However, provided that We receive your express, prior consent, We may share your information with carefully selected third parties whose products or services We believe may be of interest to you, in which case the advertisements appearing on the App may be related to your particular preferences. If, after having provided such express authorization for the sharing of your personal information by us in this way, you have changed your mind, you can always revoke such authorization to prevent Us from disclosing your information in this manner by visiting App settings and/ or changing the advertising preferences on your Device, as well as turn off the Advertising Tracking feature on it.
Alternatively, if you wish to use the App without having to view such third-party content at all, you may block it by making an in-app purchase.
We may share your personal information with third parties based on your consent; and/or or because such processing is necessary for the performance of a contract to which you is a party; and/or in the context of pursuing a legitimate business interest, provided that such legitimate business interest does not override your fundamental rights and interests; and/or where We need to comply with a legal or regulatory obligation.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In order to safeguard your rights emanating from this Agreement, We have entered into Non-Disclosure Agreements (NDAs) and/ or Data Protection Agreements (DPAs) with Our subcontractors in order to ensure that your personal information remains confidential and obtains an adequate level of protection.
We may also share your personal information with third parties to whom We may choose to sell, transfer, or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in our Privacy Statement.
How We protect your information
We have put in place the following security procedures and technical and organisational measures to safeguard your personal information: encryption, pseudonymization, firewalls, limited access, use of passwords and other relevant measures as appropriate.
In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will use all reasonable efforts to safeguard your personal information and for this purpose We undertake to review our security procedures and technical and organizational measures regularly in order to account for the latest technological developments. However, you should be aware that use of the Internet is not entirely secure and for this reason We cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
Pursuant to the requirements of the GDPR in the event that We become aware of any suspected data breach in our system We are under an obligation to notify you of the nature of the data breach in question without undue delay. We are also obliged to report this to the Office of the Commissioner for Personal Data Protection (OCPDP) in its capacity as the competent supervisory authority concerning personal data protection, within 72 hours of any such suspected breach coming to Our attention.
For How Long Do We Keep your Data Stored in our System?
Any requests, inquiries, comments, feedback or complaints communicated to Us via Our user support feature, including your name and email address, shall be kept until such time as the relevant request, inquiry or complaint has been conclusively dealt with or resolved and for the request history purpose.
Your history of visits to our Website is only maintained for a period of two (2) weeks after which time all such history is erased or deleted.
Personal information that you submit in the course of using the App shall be kept by Us only as long as you use the App, or as long as it is absolutely necessary in order to attain the purpose for which such personal data was submitted by you in the first place, or as otherwise required by law or and/or applicable regulations.
The information you provide to Us may be transferred to countries (hereinafter ‘third countries’) or organisations (hereinafter ‘international organisations’) outside the European Economic Area (EEA) that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy.
Protection is afforded to your personal information by ensuring at least one of the following safeguards is implemented:
Where We use certain service providers, we may use standard data protection clauses adopted by the Office of the Commissioner for Personal Data Protection and approved by the Commission or such contractual clauses that have been approved and authorized by the Office of the Commissioner for Personal Data Protection as ensuring an adequate and effective level of protection of your personal information.
Where We use providers based in the US, We may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection of personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information you consent to these transfers for the purposes specified above.
You have the right to request a copy of the information that We hold about you (including whether or not personal data concerning you is being processed, where and for what purpose). If you would like a copy of some or all of your personal information, please contact us and an electronic copy (unless otherwise requested by you) will be provided to you free of charge, within a month of receipt of such request.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to the Company changes please let Us know the correct details by contacting us.
You may ask Us, or We may ask you, to correct information you or We think is inaccurate, and you may also ask Us to remove information which is inaccurate.
You may withdraw your consent allowing Us to collect and use your personal information at any time. If you elect to withdraw your consent you are entitled to have the personal information we hold about deleted or erased without undue delay, following a relevant request to this effect. You may also be entitled to require Us to stop sharing this information and prevent any third parties from continuing to use this information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You may also exercise your right to have such information erased or deleted from Our system in so far as the information in question is no longer relevant for the purpose for which it was originally provided by you for processing. If you would like to exercise these rights, please contact us.
You are also entitled to request an electronic copy of the personal data that you have provided and request that these be transmitted directly, where this is possible, to another entity without hindrance. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where we used the information to perform a contract with you.
Furthermore, you have a right to object, at any time, to the processing of the personal information that you have submitted provided such an objection can be justified on legitimate grounds.
Our Website and/ or App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and/ or apps and are not responsible for their privacy statements. When you leave Our Website or App, we encourage you to read the privacy notice of every website or app you visit.
Your consent, persons below the age of 16 and COPPA
Where required by applicable data protection laws, We will always seek to obtain your express permission before We ask you to submit your personal information on our Website and/or via Apps. In respect of persons below the age of 16 or below such age limit as determined by applicable local laws, who reside within the territory of the EU, please note that we do not knowingly collect information about the age of Our users. Furthermore, We undertake to immediately erase and/or delete from Our records, archives and/or databases any personal information in respect of any child below the age of 16 or below such age limit as determined by applicable local laws, who reside within the territory of the EU, that was inadvertently collected, kept or stored by Us and ask Our partners to do so.
We take the privacy rights of users of Our Website and/or Our Apps very seriously, including, without limitation, all and any rights bestowed upon children under the age of 13 pursuant to the US Children’s Online Privacy Protection Act (hereinafter “COPPA”).
In so far as COPPA is applicable in your country of residence and in the course of safeguarding the rights of children under the age of 13 and ensuring compliance with the stipulations of COPPA, We do not knowingly collect or store any personal information pertaining to children under the age of 13 residing in the United States of America. Furthermore, We undertake to immediately erase and/or delete from Our records, archives and/or databases any personal information in respect of any child below the age of 13 that was inadvertently collected, kept or stored by Us and ask Our partners to do so.
Changes to Our Privacy Statement
We keep Our Privacy Statement under regular review. If We change Our Privacy Statement We will post the changes on this page. Also, We may place notices on other pages of Our Website or inform you via the App, so that you may be aware of the information We collect and how We use it at all times.
Please note that the data protection law in Cyprus will change with effect from 25 May 2018. Although this Privacy Statement sets out most of your rights under the new laws, We may not yet be able to respond to some of your requests (for example a request for the transfer of your personal data) until May 2018 as We are still working towards getting Our systems ready for some of these changes.
It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.
How to contact Us
We welcome your views about Our Website and/or any of Our Apps, and Our Privacy Statement. You can contact us here.
Our Website and Our Apps may contain links to other websites or applications. This Privacy Statement only applies to Our Website(s) and Our Apps so when you link to other websites or applications you should read their own privacy policies.
If you have reason to believe that there has been an unauthorised use of your personal data or that your personal data may have been used in a manner inconsistent with the purpose for which you have agreed to provide or supply such personal data in the first place, or that your personal data may have been compromised by reason of improper use, you are encouraged to contact Us in order communicate your complaint.
Alternatively, you are entitled to submit a complaint to the Office of the Commissioner for Personal Data Protection (hereinafter the OCPDP) in its capacity as the competent supervisory authority in respect of the applicable regulatory framework pertaining to personal data protection. The contact details of the OCPDP are provided hereinbelow:-
Office of the Commissioner for Personal Data Protection
1, Iasonos str.,
P.O.Box 23378, 1682 Nicosia
Telephone no.: +00357 22 818456
Fax no.: +00357 22 304565
E-mail Address: email@example.com
For more information concerning your rights emanating from the Data Protection Law and the applicable regulatory framework including the relevant EU Regulations including the General Data Protection Regulation (GDPR) set to take effect on 25/05/2018, you are encouraged to visit the OCPDP website at the following address: http://www.dataprotection.gov.cy