Privacy Policy

Last Updated: April 01, 2025

This 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. 1.1 Within the use of the App:
  We collect the following types of personal data about you:
  1. 1.1.1 Data provided by you
    - Data you voluntarily provide to us at your sole discretion.
  1. 1.1.2. Data collected by us automatically
  1. 1.1.3. Data provided by third parties
2. 1.2. Within the use of the Websites:
  We collect the following types of personal data about you:
  1. 1.2.1. Cookies
  1. 1.2.2. Data provided by you via the Websites
  1. 1.2.3 Device data
3. 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. 1.3.1 Data provided by you
  1. 1.3.2. Data collected by us
  1. 1.3.3. Data provided by third parties
4. 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).
5. 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.

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.

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.

3.2. 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.

4. INTERNATIONAL DATA TRANSFERS
1. 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
1. 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):
  1. 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.);
  2. 5.1.2. Right to rectification: You have the right to request us to rectify your personal data (if they are inaccurate or incomplete);
  3. 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);
  4. 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. 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;
  6. 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);
  7. 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;
  8. 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;
  9. 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).
2. 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).
3. 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:
  1. 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;
  2. 5.3.2. contain sufficient details describing your request to allow us to properly understand, review and respond to it.
4. 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. 5.5. 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.
6. PERSONALIZED ADVERTISING
1. 6.1. You can opt-out of personalized advertising within the App via your device settings or the App privacy settings:
  1. 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.
  2. 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
  3. 6.1.3.Option 3 – App Settings (where US Privacy Laws apply - see “US Privacy Addendum” attached hereto for more details)
  4. 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".
2. 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.
3. 6.3. If you are interested in more information about personalized advertising and your choices in this regard, you may visit the following websites:
  1. 6.3.1.Network Advertising Initiative Consumer Opt-Out Page (NAI's opt-out platform)
  2. 6.3.2.Digital Advertising Alliance Opt-Out Page (DAA's opt-out platform)
  3. 6.3.3.Your Online Choices Page (EDAA's opt-out platform)
7. AGE RESTRICTIONS
1. 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.
2. 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.
3. 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
1. 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.
2. 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
1. 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.
2. 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.
3. 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
1. 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. 1.1. 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
1. 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:
  1. 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. 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).
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. 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.
  9. 2.1.9. Right to appeal (for Virginia residents only): You have the right to appeal our decision to deny your privacy rights request.
3. SUMBITTING A REQUEST
1. 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.
2. 3.2. Please note that your request must:
  1. 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;
  2. 3.2.2. contain sufficient details describing your request to allow us to properly understand, review and respond to it.
3. 3.3. We reserve the right to ask for reasonable information to verify your identity before we process your request.
4. 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.
5. 3.5. If you are a Virginia resident, you have the right to appeal our decision to deny your rights request.
4. AUTHORIZED AGENTS
1. 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
1. 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.
2. 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

6.2. 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

6.3. We obtained personal information from various sources, including but not limited to:
1. 6.3.1. Directly from you.
2. 6.3.2. Directly and indirectly from activity within the Services.
3. 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).

7. DATA RETENTION
1. 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.