Privacy Policy
Last Updated: April 01, 2025This Privacy Policy applies to your use of “Freewave” romance audiobooks application, both the mobile and web version (“App”), our websites https://wromance.com/ and https://temptromance.com/ (“Websites”), our official social networks pages ( “Social Networks Pages”), all together referred as the “Services”. This Privacy Policy explains how we collect, store, use and share your personal data and how you can exercise your privacy rights. This Privacy Policy is an integral part of our Terms & Conditions (“Terms”).
Womanly Corp, with registered address at: 8 The Green, Suite A, City of Dover, Delaware 19901, United States (“we” or “us”), is a data controller with respect to your data processed in accordance with this Privacy Policy.
We may update our Privacy Policy from time to time. When we do, we will revise the date at the top of the Policy. If we make changes that are material, we will use reasonable efforts to notify you (such as via an in-app notice or a push-notification). We encourage you to check this Privacy Policy regularly for updates, so that you know our current practices.
By downloading, accessing and/or using the Services, you acknowledge the collection and use of your information in accordance with this Privacy Policy, including our and our partners’ use of your data for the purposes as described below.
PLEASE, READ THE FOLLOWING CAREFULLY AND MAKE SURE YOU FULLY UNDERSTAND THIS PRIVACY POLICY. IF YOU HAVE ANY CONCERNS ABOUT PROVIDING INFORMATION TO US OR IT BEING USED AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE, DISCONTINUE AND AVOID USING THE SERVICES.
- 1. DATA COLLECTED
- 1.1 Within the use of the App:
We collect the following types of personal data about you:
- 1.1.1 Data provided by you
- Data you voluntarily provide to us at your sole discretion.
We do not require you to provide us with any personal data, in addition to those we get from your Apple, Facebook, Google or other third-party account when you sign-in to the App using these tools (see Clause 1.1.3 for more details). However, if you voluntarily choose to provide us with any data when you contact us via the App, we will process such data in accordance with this Privacy Policy. For example, if you decide to contact us with a request, we will process the content of your message, the date and time of your message, our response and any other personal data you provide in that context. If you decide to have a chat in the App, we will process the details of your conversation.
- 1.1.2. Data collected by us automatically
- Usage data, i.e. data about your use of the App (e.g. the date and time you used the App, session length, liked and saved books, App version, App install date, your interaction with advertisements (including clicks, views, impressions) and your interaction with other users, crash logs (errors, bugs), privacy preferences);
- IP address;
- Approximate location data, such as country or city-level location inferred from your IP address (we do not collect precise geolocation);
- Device identifiers (such as your device ID, MAC address, IMEI);
- First-party user identifiers (our own identifiers we assign to distinguish users);
- Third-party user identifiers (such as Firebase ID, Adjust ID, and other identifiers generated by a third party);
- Advertising identifiers (such as IDFA, AAID);
- Device data, such as device manufacturer, device type, device model, RAM, operating system name and its version, device performance information, browser type, time zone, language, locale, timestamp, HTTP header, push notification token, platform, and other technical data like screen resolution or processor, or combination of this data (for checking the device compatibility with the App), if ad tracking is limited.
We will automatically collect the following data of yours:
- 1.1.3. Data provided by third parties
- Analytics Providers. Our analytics providers may provide us with:
- Data about your use of the App (such as in-app events, your interaction with the App, software bugs and errors, etc.) so that we could improve the App and detect and prevent fraud in our Services;
- Data about the performance of our advertising campaigns (e.g. we may be provided with information from which ad network and advertising campaign the install of the App originated from, or data on fraud traffic such as refund abuse in games or click fraud in advertising);
- Other data mentioned in clause 1.1.2 above.
- Marketing Partners. From time to time, we may receive non-personal information from our marketing partners concerning the performance of our advertising campaigns displayed outside our Services (e.g. we may be provided with data about interaction with our advertisement (such as clicks, views, impressions, installs or other advertising campaign performance indicators).
- Sign-In Tools. When your account in the App is linked to your Apple, Facebook, Google or other third-party account (“Sign-In Tools”), such Sign-In Tools will share with us certain bulk of your personal data. What data they will share will depend on your privacy setting within those Sign-In Tools, but it would typically include your basic profile information such as your name, user ID, user token, email address, language preference and profile picture. If you want to limit the sharing of data with us, you need to regulate this in the privacy settings of the relevant Sign-In Tool. We do not get access to or store your logins or passwords for any of these Sign-In Tools. We encourage you to review privacy policies and terms of service of Sign-In Tools for further information before linking your account in Sign-In Tools with the App.
- Online Stores. As all the purchases within the mobile version of the App run via Apple Store or Google Play Store (“Online Stores”), we will get limited data on your purchases from the Online Stores, which would typically include a list of purchased items, id of operation, date, time, id, amount and currency of purchase. We will not get your sensitive financial data, such as your credit card number or bank account data. We encourage you to review privacy policies and terms of service of the platforms for further information before making a purchase in the Online Stores.
- Payment Processors. The purchases within the website version of the App run with assistance of payment processors. Please note that payment processors will not share any sensitive financial data with us, like bank card or bank account details, we will get a very limited scope of data, like id of operation, time, id, amount and currency of purchase. We encourage you to review privacy policies and terms of service of payment processors for further information before making a purchase with their assistance.
We may receive information relating to you and your use of the App from the following third-party providers:
- 1.1.1 Data provided by you
- 1.2. Within the use of the Websites:
We collect the following types of personal data about you:
- 1.2.1. Cookies
Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyze use, target advertisements and prevent fraud. You can disable cookies, but some parts of the Services may then not function properly. For further information, please, read our Cookie Policy
- 1.2.2. Data provided by you via the Websites
If you decide to contact us via the Website (e.g. leaving your e-mail to get the personalized list of recommended romance books) we will process all the data related to such messages in accordance with this Privacy Policy. In particular, we will process your name, e-mail, content of your message, the date and time of your message, our response and any other personal data you provide in that context.
- 1.2.3 Device data
We shall also collect the data about your device, like browser type, language settings, IP address, platform, model and operating system of the device.
- 1.3. Within the use of the Social Networks:
When you somehow interact with our Social Networks Pages (e.g. visit pages, like the pages / posts, forward them, write messages to the posts or to us directly, reference us), we shall collect the following types of personal data about you:
- 1.3.1 Data provided by you
If you decide to contact us via our Social Networks Pages, we will process all the data related to such messages, like your profile name, the content of your message, the date and time of your message and our response.
- 1.3.2. Data collected by us
When you somehow interact with our Social Networks Pages we may process all the details of such interaction (e.g. visiting pages, liking the pages / posts, forwarding them, writing messages to the posts or to us directly, referencing us).
- 1.3.3. Data provided by third parties
- Social Networks Providers. Social Networks providers may share with us certain statistics and analytics data about you. For instance, we operate a page on Facebook, a service of Meta. Meta collects and uses your data to provide analytics services, known as "Page Insights" for the page admins to gain insight into how people interact with their page and the content associated with them. This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices users use, such as IP addresses, operating system, browser type, language settings, cookie data. For more information on which data Meta may share with us see Information about Page Insights. We and Meta are jointly responsible for the collection and processing of such data. You can view the terms and conditions of the contract concluded with Meta here. You can find Meta's privacy policy here.
- Analytics Providers. Our analytics providers may provide us with some aggregated data on our Social Networks visitors and subscribers, like approximate age and gender (however these data are always aggregated, i.e. we cannot know your particular age and gender using them).
We may receive information relating to you from the following third parties:
- 1.4. Within other sources
You may contact us via email or other communication channels, regarding any issues (related to the App or not). In this case we will process all the data provided by you within such communication in accordance with this Privacy Policy (we will process the content of your message, the date and time of your message, our response and any other personal data you provide in that context).
- 1.5 We do not request or intend to collect any sensitive data (“special categories of information”), such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please, be cautious when sharing this information about yourself (or others) via the Services.
- 1.1 Within the use of the App:
- 2. PURPOSES AND BASIS FOR PROCESSING
- 2.1 We will process your personal data for the following purposes and on the following basis:
Purpose shortly
Purpose in detail
Legal Basis (Data Needed for)
2.1.1.
Data collected within the use of the App
(a)
Making the App work
- Enabling you to use the App (facilitating, operating, providing and maintaining the App availability, operability and proper functioning, fixing bugs and errors)
- Recognizing you when you return to the App or when you change the devices, allowing you to synchronise progress in the App across multiple devices
- Verifying and confirming payments of in-app purchases
- Sending you the app-related communications (security alerts, updates, other notifications)
- Responding to your comments and questions and providing customer support
- Protecting the security and integrity of the App
- Localising the App and App content for you
Performance of a contract which you enter into when you download or access the App and accept our Terms
(b)
Improving the App and your in-app experience
- Monitoring and analyzing the use of the App to improve the App operation and functionality, to identify bugs and errors in the App, to understand and analyze the usage trends and preferences of our users, the App user audience, and to otherwise improve and customize (personalize) the App content for you and your in-app experience
- Testing the new features of the App
- Running surveys to get your feedback about the App from time to time
Our legitimate interest to improve and optimize the App and enhance user experience
(c)
Ensuring compliance with the Terms
- Detecting, preventing and combating potential or actual breaches of the Terms, which includes monitoring the use of the App, investigating suspicious activity within the App, taking actions against the users violating the Terms
- Defending ourselves against any third-party claims or allegations
- Detecting, preventing and combating unlawful actions of users
Our legitimate interest to keep the App safe, to fight fraud, ensure security of the App and protect our interests
(d)
Ensuring compliance with applicable law
- Complying with legal obligations, including complying with orders from a court or regulatory authority, responding to request from regulatory authorities
- Detecting your jurisdiction, to consider which specific laws do apply to you and whether we need to disable or change some features to stay compliant with those specific laws
- Detecting, preventing and combating unlawful actions of users
Compliance with legal obligations
(e)
Promoting the App / Measuring performance of marketing campaigns
- Reaching the audience that may be interested in the App
- Tracking and attributing App installations, analysing where a user comes from
- Detecting fraudulent traffic
Our legitimate interest to advertise and promote the App
(f)
Serving you third-party ads within the App
Serving you (using third party advertising networks):
- generic, contextual (non-personalized) advertisements
- targeted (personalized) advertisements (for which purposes tracking the content you access within the App and your online behaviour)
NOTE*: you may opt out of personalized advertising via your device settings (see Section 6 below) and withdraw your consent to showing you personalized ads by contacting us (as described in section 10)
NOTE**: for showing personalized we use Google CMP (Consent Management Platform) to receive your consent
Our legitimate interest in monetizing the App (for non-personalized ads)
Consent (for personalized ads)
2.1.2.
Data collected within the use of the Websites
(a)
Making the Websites work
- Enabling availability, operability and proper functioning of the Websites (essential cookies)
Performance of a contract which you enter into when you access the Website
(b)
Improving the Websites and their visitor experience
- Monitoring and analyzing the use of the Websites to improve its operation and functionality, to identify bugs and errors in the Websites, to improve the visitors experience (performance / functional cookies)
Depending on the jurisdiction:
Our legitimate interest to improve and optimize the Websites and visitor experience
Consent
(c)
Responding to your requests
- Responding to your questions, applications, requests, other messages submitted via the Websites
Depends solely on the subject of the request (e.g. if the request relates to the App, that would be contract performance)
(d)
Protecting the Websites operability / content
- Protecting security and integrity of the Websites (against DDoS and other cyber attacks)
- Detecting, preventing and combating unlawful actions of Websites visitors
Our legitimate interest to ensure security of the Websites and protect our interests against unlawful actions
2.1.3.
Data collected within the use of Social Networks
(a)
Responding to your messages and actions
- Responding to your questions, applications, requests, other messages submitted via our Social Networks Pages
- Reacting to your actions with regard to our Social Networks Pages (e.g. likes, follows, recommendations, sharing, etc.)
Performance of a contract (as our Social Networks Pages relate solely to the App)
(b)
Improving our Social Networks Pages and their visitor experience
- Understanding the target audience of our Social Networks Pages
- Understanding which content and promotional activities are of the most interest for our Social Networks audience
- Measuring, adjusting and improving effectiveness of such content / activities
Our legitimate interest to enhance the content of Social Networks Pages and user experience
(c)
Combating unlawful actions of Social Networks users
- Detecting, preventing and combating unlawful actions of users
Our legitimate interest to protect our interests against unlawful actions
2.1.4.
Data collected within other sources
(a)
Responding to your requests
- Responding to your questions, applications, requests, other messages submitted via email or other communication channels
Depends solely on the subject of the request (e.g. if the request relates to the App, that would be contract performance)
2.2 We may also ask for your consent in certain cases when we are required to ask for it under the applicable terms of the Online Stores (e.g. to send you push notifications, to track your activity across other companies’ apps and websites, etc.).- 2.3. We do not carry out any decision-making having legal effects for you based solely on automated processing, including profiling.
- 2.1 We will process your personal data for the following purposes and on the following basis:
- 3. SHARING OF DATA
- 3.1 We may share your personal data with:
- 3.1.1. Our service providers and other partners, who perform the following functions / services:
Cloud storage providers
we engage them for storage of Services data
Payment processors
we engage them to process payments for our Services
Analytics services
we engage them for analytics, attribution and mobile measurement services which allows us to improve our Services through data analysis and know our audience
Customer support
we collaborate with them to facilitate customers requests and questions
Marketing partners
we collaborate with several marketing partners who help us advertise our Services, they assist us in measuring and optimizing our advertising campaigns so we can reach audiences interested in our Services and expand our user base
Advertising networks
we may also share information with advertising partners who distribute advertising in our Services or allow them to collect data directly from you through their mobile SDKs or similar technologies embedded in our Services. We share a very limited scope of data with our advertising partners (networks): for non-personalized ads that’s usually the IP address, some device IDs, with respect to personalized ads that could be also some data on your behavior within the App, e.g. the content that you access. Our advertising partners may combine this information with data they have collected about you when you use their services or third-party websites and services. This helps them show you more relevant advertising in our Services and improve their ad targeting and measurement systems. We advise you to сheck their privacy policy for further details
Other service providers
we may engage other service providers, e.g. assisting us with software maintenance, technical support, security issues, external auditors, etc.
3.1.2. State authorities and institutions (upon their requests, when otherwise required under applicable law or on our initiative in order to combat the violations of the Terms);- 3.1.3. Our affiliated companies;
- 3.1.4 Acquiring party or assignee in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our company or its assets;
- 3.1.5 Other third parties, providing such sharing is needed for the purposes of processing listed above or upon your consent for this.
- 3.1.1. Our service providers and other partners, who perform the following functions / services:
- 3.2. You may find the current List of our service providers and other partners here.
- 3.3. We share your personal data with these third parties only for the purposes listed in Section 2 above, where we have a legal basis for this and to the extent such sharing is needed to achieve the purpose. Such third parties will provide the same or equal protection of your data as stated in this Privacy Policy and required by applicable laws and Online Stores guidelines.
- 3.4. Information about you may be also disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction.
- 3.1 We may share your personal data with:
- 4. INTERNATIONAL DATA TRANSFERS
4.1. Our Services are global by nature and your data can therefore be transferred and processed in countries other than the country in which you are resident, which sometimes may offer a lower level of protection compared to the one provided in your home jurisdiction. We will always take steps to ensure adequate safeguards are in place to protect your data within such transfers. Adequate safeguards that we and our partners may use include transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection, or entering into standard contractual clauses approved by the EU Commission with the respective recipients.
- 5. YOUR RIGHTS
- 5.1. You will generally have the following rights with regard to our processing of your personal data (the full set of rights you have will always depend on your home jurisdiction and the particular circumstances of processing; some of the rights have their particular execution conditions, i.e. can be exercised providing certain conditions are met):
- 5.1.1. Right to access: You have the right to access the personal data we hold about you and certain information about processing of such data (e.g. categories of data collected, purposes of processing, data recipients, retention period, the sources of collected data, etc.);
- 5.1.2. Right to rectification: You have the right to request us to rectify your personal data (if they are inaccurate or incomplete);
- 5.1.3 Right to erasure: You have the right to request the erasure of your personal data (where we do not have a legal basis to continue to process such personal data or in other particular circumstances);
- 5.1.4. Right to data portability: You have the right to receive the personal data you have provided us with, in a structured, commonly used and machine-readable format, as well as to request us to transfer your personal data to another controller, where this is technically feasible (in certain circumstances and under certain conditions);
- 5.1.5. Right to withdraw consent: You have the right to withdraw your consent (when we rely on consent as the legal basis for processing). Note that withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent;
- 5.1.6. Right to opt-out: to opt out of personalized advertising via your device settings or privacy settings of the App (see Section 6 below);
- 5.1.7. Right not to be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects or could significantly affect you;
- 5.1.8. Right to object: You have the right to object to or restrict how we process your data (in certain circumstances). Please note in case of such a request we may not be always able to provide you with all the Services functionalities and / or the Services performance may suffer;
- 5.1.9. Right to lodge a complaint: You have the right to lodge a complaint with a data protection supervisory authority (if you think that any of your rights have been violated by us).
- 5.2. Please note that residents of certain US states have specific rights, which are sometimes different from those mentioned above (see “US Privacy Addendum” attached hereto for more details).
- 5.3. If you wish to exercise any of the above rights, please contact us via (i) the in-app support feature (Option 1) or (ii) the contact details in Section 10 of Privacy Policy (Option 2). If using Option 2, please note that we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond. Please, note that your request for exercising any of your rights must:
- 5.3.1. provide sufficient information necessary to verify you as an individual about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
- 5.3.2. contain sufficient details describing your request to allow us to properly understand, review and respond to it.
- 5.4. We reserve the right to ask for reasonable information to verify your identity before we process your request, and not to respond to your request or provide you with personal data, in case we are unable to verify your identity or authority to make such a request.
- 5.5. Permissible number of requests, whether they are free of charge or not, and other conditions of requests shall fully depend on your home jurisdiction requirements.
- 5.1. You will generally have the following rights with regard to our processing of your personal data (the full set of rights you have will always depend on your home jurisdiction and the particular circumstances of processing; some of the rights have their particular execution conditions, i.e. can be exercised providing certain conditions are met):
- 6. PERSONALIZED ADVERTISING
- 6.1. You can opt-out of personalized advertising within the App via your device settings or the App privacy settings:
- 6.1.1.Option 1 – CMP Start Page – If Google CMP (Consent Management Platform) is implemented for your region, after the launch of the App you will see the screen asking for your consent for various purposes of processing, including for personalized advertising. If you want to opt out from personalized advertising make your choices accordingly.
- 6.1.2.Option 2 – App Settings (where Google CMP (Consent Management Platform) is implemented for your region):
- Open App settings menu
- Select “Consent Preferences”
- Tap “Manage preferences” and adjust your choices
- 6.1.3.Option 3 – App Settings (where US Privacy Laws apply - see “US Privacy Addendum” attached hereto for more details)
- 6.1.4.Option 4 – Device Settings
On iOS:
- Open “Settings”
- Select “Privacy” / “Privacy & Security”
- Select “Tracking” and disable “Allow Apps to Request to Track”, or select “Advertising” and enable "Limit Ad Tracking"
On Android:
- Open “Settings”
- Tap “Privacy” > (“Advanced”) > “Ads”
- Tap “Delete advertising ID” and confirm your changes, or Select “Ads” and enable "Opt out of Ads Personalization".
- 6.2. Please note that opting out via any option described above does not mean that you will stop seeing advertisements in our Services. Instead, third-party advertising networks will consider your choice as withdrawal of consent for personalised advertising experience and will show you contextual (non-personalized) advertisements not tailored to your interests in the same volume. Please be aware that such actions may result in decrease of advertising quality and less enjoyable user experience.
- 6.3. If you are interested in more information about personalized advertising and your choices in this regard, you may visit the following websites:
- 6.3.1.Network Advertising Initiative Consumer Opt-Out Page (NAI's opt-out platform)
- 6.3.2.Digital Advertising Alliance Opt-Out Page (DAA's opt-out platform)
- 6.3.3.Your Online Choices Page (EDAA's opt-out platform)
- 6.1. You can opt-out of personalized advertising within the App via your device settings or the App privacy settings:
- 7. AGE RESTRICTIONS
- 7.1. Our Services are intended for use only by adults (i.e. individuals who are over 18 years of age or of the age of majority in their country, whichever is older). All the individuals of the younger age we treat as children and do not allow them to use our Services.
- 7.2. If we learn that personal data has been collected via the Services from children, then we will take the appropriate steps to delete this personal data.
- 7.3. If you are a parent or guardian and discover that your child is using the Services and that we may have collected information from that child through the Services, then you may alert us at help@wromance.com and we will delete that child’s personal data from our systems as soon as possible.
- 8. SECURITY SAFEGUARDS
- 8.1. We are continuously developing and implementing administrative, technical and physical security measures to protect the confidentiality, security and integrity of the collected data and to prevent from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to the data under our control. In addition, we limit access to personal data by our personnel and partners on a need-to-know basis only.
- 8.2. Although we use commercially reasonable efforts to assure that your data remain secure when maintained by us, please, be aware that no security measures are perfect or impenetrable. Unfortunately, the transmission of data via the internet is not completely secure and we cannot guarantee the security of your data transmitted via the Services; any transmission is at your own risk. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
- 9. DATA RETENTION
- 9.1. We store the collected personal data of yours for as long as necessary to fulfil the purposes we collected it for, including for complying with our legal obligations. We may retain your personal data for a longer period in the event of any existing, upcoming or possible complaint, dispute or litigation.
- 9.2. To determine appropriate retention period with respect to your personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as applicable legal requirements.
- 9.3. In some circumstances we can anonymise your personal data (so that it can no longer be associated with you, even if combined with other data) for analytical or statistical purposes, in which case we may use this data indefinitely (i.e. also after deletion of your account) without further notice to you.
- 10. CONTACT US
- 10.1. If you have questions about this Privacy Policy, or if you have any requests for exercising any of your privacy rights, you can contact us through the in-app support feature (if available) or via e-mail at help@wromance.com. However, please note that we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond.
US PRIVACY ADDENDUM
- 1. SCOPE OF APPLICATION
- 1.1. This Addendum provides additional information for residents of the following US States: California, Virginia (“US States”), who have certain privacy rights as specified under their state privacy acts (together “US Privacy Laws”).
- 2. YOUR RIGHTS
- 2.1. Below you will find information what rights you may have and how to exercise those rights and our process of handling those requests:
- 2.1.1 Right to know: You have the right to know before accessing the Services certain information about processing of your personal data (e.g. categories of data collected, purposes of processing, data recipients, sources of collected data, etc.) (We ensure this right by posting this Privacy Policy both on the Website and on the onboarding screen when you launch the App for the first time).
- 2.1.2. Right to access: You may request us to disclose certain information about processing of your personal data (e.g. categories of data collected, purposes of processing, data recipients, sources of collected data, etc.) (NOTE: the scope of data we have to disclose to you, the period for which the data should be disclosed and the frequency of free-of charge requests depend on your state of residency; for instance, for California residents - the disclosed personal information shall be provided for the period of 12 (twelve) months preceding the date of receiving your verifiable request; Virginia residents may request the information free of charge up to twice annually).
- 2.1.3. Right to delete: You have the right to request that we delete any of your personal information we collected and retained, subject to certain exceptions. Once we receive and verify your consumer request, we will delete your personal information from our records, will notify any service providers and other third parties to whom we have sold or shared your personal information to delete it from their records, unless this proves impossible or involves disproportionate effort. However, we may deny your deletion request if retaining the information is necessary for us or our service providers under certain circumstances, which will be explained to you at the time of the denial, if any.
- 2.1.4. Right to correct: You have the right to request to correct the inaccurate personal information that we hold about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
- 2.1.5. Right to data portability (for Virginia residents only): You have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller without hindrance.
- 2.1.6. Right to opt-out: You have the right to opt-out of the processing of the personal data for purposes of (i) targeted advertising or cross-contextual behavioral advertising, (ii) the “sale” and/or sharing of personal data, or (iii) profiling (or solely automated decisions that produce legal or similarly significant effects concerning you), as defined by the applicable US Privacy Laws. If you would prefer that your personal information is not shared with third parties in this way, please visit Do Not Sell My Personal Information.
- 2.1.7. Right to be free from discrimination: We may not discriminate against you for exercising any of your rights under US Privacy Laws, including but not limited to (i) denying you our Services; (ii) charging you different prices or rates for our Services; (iii) providing you a different level or quality of Services; (iv) suggesting that you may receive a different price or rate for Services or a different level or quality of Services.
- 2.1.8. Right to limit use and disclosure of sensitive personal information (for California residents only): You have the right, however we do not collect any sensitive personal information.
- 2.1.9. Right to appeal (for Virginia residents only): You have the right to appeal our decision to deny your privacy rights request.
- 2.1. Below you will find information what rights you may have and how to exercise those rights and our process of handling those requests:
- 3. SUMBITTING A REQUEST
- 3.1. To submit your request, please use (i) the in-app support feature (Option 1) or (ii) the contact details in Section 10 of Privacy Policy (Option 2). If using Option 2, please note that we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond.
- 3.2. Please note that your request must:
- 3.2.1. provide sufficient information necessary to verify you as the individual about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
- 3.2.2. contain sufficient details describing your request to allow us to properly understand, review and respond to it.
- 3.3. We reserve the right to ask for reasonable information to verify your identity before we process your request.
- 3.4. We will respond to your request within 45 (forty five) days, and in more difficult cases we may extend our response time by another 45 (forty five) days. We reserve the right not to respond to your request or provide you with personal data, in case we were unable to verify your identity or authority to make such a request.
- 3.5. If you are a Virginia resident, you have the right to appeal our decision to deny your rights request.
- 4. AUTHORIZED AGENTS
- 4.1. In certain circumstances, you may exercise your rights by designating an authorized agent. If you would like to designate an authorized agent to make a request on your behalf, please be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. We reserve the right to require further reasonable information to verify the request. If the agent does not satisfy these requirements, we may deny the request.
- 5. SELLING OF DATA
- 5.1. We do not “sell” data of our users as most people would typically understand this term. The definition of “selling” shall be interpreted in accordance with the meaning attributed to this term under US Privacy Laws. We do, however, share certain data with third-party advertising partners for the purposes of serving advertisements tailored to your interests in our Services, measure advertising performance, fraud detection and prevention and advertising campaign management. Please see our List of Partners for additional details about them. Generally, the data collected is limited to the user’s advertising ID, device identifiers, your behavior within the Services and other technical information. Such data collection practices may fall under the definition of “selling” under US Privacy Laws.
- 5.2. If you would prefer that your personal information is not shared with third parties in this way, please visit “Do Not Sell My Personal Information.
- 6. PERSONAL DATA WE COLLECTED, DISCLOSED, SHARED OR “SOLD”
- 6.1. We have collected and disclosed the following categories of personal information from consumers of the US States within the preceding twelve (12) months:
- 6.1.1.Personal information collected and disclosed:
Category
Personal information
A. Identifiers
- Name, username;
- Email address;
- Profile picture (collected solely if you are linking your third-party account with the Services);
- IP address;
- Device identifiers (such as your device ID, MAC address, IMEI);
- First-party user identifiers (our own identifiers we assign to distinguish users);
- Third-party user identifiers (such as Firebase ID, Adjust ID, and other identifiers generated by a third party);
- Advertising identifiers (such as IDFA, AAID)
- Cookies (see our Cookie Policy for more details)
D. Commercial information
- Purchase history, transaction information: (e.g. list of purchased items, id of operation, date, time, id, amount and currency of purchase), NOTE: no sensitive financial data, like bank account and bank card details, is collected
F. Internet or other electronic network activity
- Usage data: data about your use of the App (e.g. the date and time you used the App, session length, liked and saved books, App version, App install date, your interaction with other users, crash logs (errors, bugs), privacy preferences)
- Advertising campaigns data: data on the performance of our advertising campaigns displayed outside our Services (data about interaction with our advertisement (such as clicks, views, impressions, installs or other advertising campaign performance indicators)
- Interactions with our Social Networks Pages: all the details of such interaction (e.g. your communication with us via the pages, visiting pages, liking the pages / posts, forwarding them, writing messages to the posts or to us directly, referencing us)
G. Geolocation data
- Approximate device location, such as country or city-level location inferred from your IP address (NOTE: we do not collect precise geolocation)
- 6.1.2. Categories of third parties to whom personal information was disclosed:
- Cloud storage providers
- Customer support providers
- Payment processors
- Marketing partners
- Analytics services providers
- Advertising networks
- External auditors
- Regulators and public authorities
- 6.1.3.Business or commercial purpose for collection / disclosure:
- See Clause 2.1 of the Privacy Policy
- 6.1.1.Personal information collected and disclosed:
- 6.2. We have shared or “sold” the following categories of personal information from consumers of the US States within the preceding twelve (12) months:
- 6.2.1. Personal information shared and “sold”:
Category
Personal information
A. Identifiers
- IP address;
- Device identifiers (such as your device ID, MAC address, IMEI);
- First-party user identifiers (our own identifiers we assign to distinguish users);
- Third-party user identifiers (such as Firebase ID, Adjust ID, and other identifiers generated by a third party);
- Advertising identifiers (such as IDFA, AAID)
- Cookies (see our Cookie Policy for more details)
D. Commercial information
- Purchase history, transaction information (e.g. list of purchased items, id of operation, date, time, id, amount and currency of purchase), NOTE: no sensitive financial data, like bank card details, is collected
F. Internet or other electronic network activity
- Advertising campaigns data: data on the performance of our advertising campaigns displayed outside our Services (data about interaction with our advertisement (such as clicks, views, impressions, installs or other advertising campaign performance indicators)
G. Geolocation data
- Approximate device location, such as country or city-level location inferred from your IP address (NOTE: we do not collect precise geolocation)
- 6.2.2. Categories of third parties to whom personal information was shared and “sold”:
- Advertising networks
- Analytics services providers
- 6.2.3. Business or commercial purpose for sharing and “selling”:
- Serving advertising to You within the Services, both personalized (targeted) and not
- Analysing your behaviour within the Services for personalized (targeted) advertising
- 6.2.1. Personal information shared and “sold”:
- 6.3. We obtained personal information from various sources, including but not limited to:
- 6.3.1. Directly from you.
- 6.3.2. Directly and indirectly from activity within the Services.
- 6.3.3. From third parties that interact with us or you in connection with the Services (e.g. payment processors, Online Stores, Sign-In Tools).
- 6.1. We have collected and disclosed the following categories of personal information from consumers of the US States within the preceding twelve (12) months:
- 7. DATA RETENTION
- 7.1. We retain your personal information for as long as necessary to provide our Services to you and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting, and preventing fraud and abuse, and enforcing our agreements. The criteria used to determine retention periods includes the legal limitation of liability period, agreed contractual provisions, applicable regulatory requirements, and industry standards.