PRIVACY POLICY

Sunspot Studio LLC Privacy Policy
Last updated: 12 Dec, 2019

 

This Privacy Policy explains who we are, how personal information is collected, shared and used, and how you can exercise your privacy rights. We are Sunspot Studio LLC, (“Sunspot Studio” or “we”) - a developer and publisher of mobile applications that are made available via app stores including the Google Play Store. This Privacy Policy applies to personal information that is collected through our mobile applications and other products (“Apps”), and websites we control, including http://sunspotstudio.net/ (“Website”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

 

1. INFORMATION COLLECTED FROM YOU

Most of the information collected about you comes directly from you when you use our Apps or interact with third-party ads in our Apps. In general, the information collected about you relates to the type of device you are using, information that helps identify your device, how you use our Apps and may include information that you submit to us when you voluntarily contact us.

The information that we may be collected about you through the Services broadly falls into the following categories:

(a) Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, if you contact us via email, we may get access to your name and/or email address as well as any information you submit to our support team via email. This information will never be sent to third-party partners or used by us for advertising purposes.

 

(b) Information collected automatically

When you use our Services, certain information may be automatically collected from you and/or your device which may be considered personal information under applicable data protection laws, such as:

 

 

Advertising ID means Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

 

(c) No special categories of information

We do not request or intend to collect any “special categories of information” such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

 

2. HOW YOUR INFORMATION IS USED

2.1. In General

The collected information about you/your device is used to deliver Services and our Apps to you and to operate our business. It is also used for improving our services and Apps, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, your information is used to promote our services and Apps in our Apps and also in other publisher’s apps and to display third-party advertisements to you. Your information is used also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations.

We use your information for the following purposes:

1.    Delivering and improving our services. We use your information for developing, delivering and improving our Apps and other products, services, and content, tailoring our products and services, providing App updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Apps, and administering the Apps.

2.    Displaying advertisements. Your information is used for displaying third-party advertisements in our Apps. Please see more in Advertising Section of this Privacy Policy.

3.    Cross-promotion. We may use your information for cross-promoting our Apps and services, meaning to promote one of our Apps while you are using a different App of ours.

4.    Tracking and fraud prevention for advertising purposes. Your information is used for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.

5.    Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new app features and content.

6.    Security. We use your information for enhancing the safety and security of our Apps, products and services.

7.    Customer Support. We use your information for providing customer support to you and to respond to your inquiries.

8.    Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.

 

2.2. In-App Purchases

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are completed through the app store via your Google Play account. Any post-purchase processes are controlled by the Google store and are subject to specific terms of such Google store. Please review privacy policy and terms of service of your Google store.

 

3. HOW WE SHARE YOUR INFORMATION

We cannot provide all services necessary for the successful operation of the Apps by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

·       Our analytics providers. We use third-party analytics such as Firebase and Fabric Answers, for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking purposes.

·       Our weather service providers. We may send location information from you to our third-party weather service providers such as Yahoo! Weather, OpenWeatherMap, yr.no, Dark Sky, Weather Underground, Apixu;

·       Third-party advertising and data intelligence partners. We have contracted with certain third-party advertising networks and data intelligence partners that assist us in delivering advertising to you and allow us to continue offering the Apps for free or at low cost. Such third-party advertising partners include but are not limited to advertising providers listed at below in Advertising Section of this Privacy Policy. The data intelligence partners are listed below in Data Intelligence Section of this Privacy Policy.

·       Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers.

 

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be promptly reflected in this Policy.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you, if it is necessary for the purposes of national security, law enforcement, or other issues of public importance. We may also disclose information about you, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience.

For any additional questions about third-party information collection, please refer to support@sunspotstudio.net

 

4. ADVERTISING

4.1. In General

We use advertising to fund our Services and to make our Apps available for free. We offer our Apps for free or at low cost and in order to do that we allow third-party advertising partners to collect certain types of information from you. The information types are listed in Section 1 above. The information collected helps us to improve our website and Apps and – at the same time – keep our Apps free for a wide user base.

If you are a European Economic Area (EEA) – based user be aware that:

(a) When you use our Apps, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads to EEA-based users is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. We also ensure to the best of our capabilities that our external service providers are committed to a high level of data protection and are GDPR compliant. 

(b) Before allowing any information collection by our advertising partners for the purposes of personalized advertising, we ask for your consent, given when you press accept at the relevant button at loading of the App. We allow our advertising partners to show personalized ads to you only if you have accepted in the relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you accept to show you personalized ads at loading of the App. The legal basis to show personalized ads to EEA-based users is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. We also ensure to the best of our capabilities that our external service providers are committed to a high level of data protection. The purpose is to improve our Apps and provide the user with more relevant ads. You have the option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the App’s Privacy Settings and switching off Personalized Ads. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they may not be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of our App.

 

4.2. Advertising ID

To enable us to show in-app ads, your advertising ID and IP-address may be sent to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our Apps and on third-party properties. You can control and limit the use of your advertising ID in your device settings. We do not control which specific ads are shown in our Apps (it is controlled by ad networks), but we do blacklist certain categories of ads.

Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

·       limit the number of times you see the same ad;

·       ensure they are dealing with humans with real devices and not ‘automated’ bots;

·       serve you with advertisements likely to be relevant to you (if personalized ads are enabled in Privacy Settings in the App) based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Apps. The ad network or ad exchange acts as intermediary between the other app companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;

·       keep track what Apps you have used to market you similar kind of Apps. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at city level).

 

4.3. WHO CAN SHOW PERSONALIZED ADS TO YOU?

Please see the following list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising.

·       Google (AdMob) https://support.google.com/admob/answer/7665968;

https://support.google.com/admanager/answer/9012903

·       Facebook Audience Network https://www.facebook.com/about/privacy

·       AdColony https://www.adcolony.com/privacy-policy/

·       AdinCube https://storage.googleapis.com/adincube-resources/doc/Privacy_policy.pdf

·       AerServ https://www.aerserv.com/privacy-policy/

·       AppNext https://www.appnext.com/policy/

·       Chartboost https://answers.chartboost.com/en-us/articles/115001489623

·       Vungle http://vungle.com/privacy/

·       MoPub https://www.mopub.com/legal/privacy/https://www.mopub.com/legal/partners/

·       MobVista https://www.mobvista.com/en/privacy/

·       Ogury https://www.ogury.com/privacy/

·       PubNative https://pubnative.net/privacy-policy/

·       StartApp https://www.startapp.com/policy/privacy-policy/

·       Applovin https://www.applovin.com/privacy/

 

4.4. HOW CAN YOU TURN OFF PERSONALIZED ADS?

Personalized ads can be enabled or disabled in Privacy Settings in the App. Besides this option, you can use your device settings.

 

Android

Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data.

 

5. DATA INTELLIGENCE

5.1. In General

We partner with data intelligence companies to fund our Services and to make our Apps available for free. We offer our Apps for free or at low cost and in order to do that we allow third-party data intelligence partners to collect certain types of information from you. The information types are listed in Section 1 above. The information collected helps us to improve our websites and Apps and – at the same time – keep our Apps free for a wide player base.

Before allowing any information collection by our data intelligence partners, we ask for your consent, given when you press accept at the relevant button at loading of the App. We allow our data intelligence partners to collect data from you only if you have accepted in the relevant pop-up window and so consented to the sharing of your personal information. Our data intelligence partners use different technologies for the purposes of data collection that process your personal information in different ways, so please review their data processing practices before you accept to show you personalized ads at loading of the App. The legal basis to collect data to EEA-based users is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. We also ensure to the best of our capabilities that our external service providers are committed to a high level of data protection. You have an option to withdraw your consent to sharing your personal information for the purposes of data intelligence at all times. You can withdraw your consent by going to the App’s Privacy Settings and switching off Location Data.

 

5.2. WHO CAN COLLECT PERSONAL DATA FROM YOU?

Your installation and use of our Apps involves the collection and use of certain data by third parties, according to the terms set forth on the third-parties’ privacy policies.

Please see the following list of data intelligence partners that are allowed to collect personal data and review their data processing practices, including the technologies they use for data collection.

 

Cuebiq https://www.cuebiq.com/privacypolicy/ and its partners https://www.cuebiq.com/trusted-partners/

 

HSDG Technologies LP http://sunprivacy-policy.com

 

Huq Industries https://huq.io/terms/privacy/

 

5.3. HOW CAN YOU TURN OFF DATA COLLECTION FROM OUR DATA INTELLIGENCE PARTNERS?

If you want to withdraw your consent to share information, please go to the App’s Privacy settings and switching off Location data

 

 

6. COOKIES

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
We may use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options of our Service.

 

7. CHILDREN’S PRIVACY

Our Services do not address anyone under the age of 16 (“Children”). When we collect personal information, we do not know the age of our users. We do not knowingly collect personally identifiable information from children under 16. If you are a parent or guardian and you are aware that your Children have provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under age 16 without verification of parental consent, we will provide the child or parent / guardian with the necessary steps to switch off data collection.

 

8. YOUR RIGHTS

If you are EEA-based user you have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests to support@sunspotstudio.net

Your rights include:

·       Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you may withdraw your consent to show you personalized ads to you, please go to the App’s Privacy settings and switching off Personalized Ads)

·       Right to access your data in accordance with Art. 15 GDPR. Please contact the third-party partner you wish to access your data from or if you are experiencing difficulties, contact us at support@sunspotstudio.net

·       Right to correct your data in accordance with Art. 16 GDPR. Please contact the third-party partner you wish to correct your data in or if you are experiencing difficulties, contact us at support@sunspotstudio.net

·       Right to have your data deleted in accordance with Art. 17 GDPR. Please contact the third-party partner you wish to delete your data from or if you are experiencing difficulties, contact us at support@sunspotstudio.net

·       Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can do it by withdrawal of your consent in accordance with instructions above)

·       Right to take your data with you in accordance with Art. 20 GDPR Please contact the third-party partner you wish to take your data from or if you are experiencing difficulties, contact us at support@sunspotstudio.net

·       Right to object how your data is handled in accordance with Art. 21 GDPR Please contact the third-party partner you wish to object to or us at support@sunspotstudio.net

·       Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly).

 

9. GENERAL

Your information privacy and security is important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under EEA data protection laws that apply to EEA users. We have appointed data protection officer to help us ensure compliance with EEA data protection laws. We operate globally and we share your information with our Partners as for the purposes described above in “How We Share Your Information” Section, which may include a transfer of your personal information outside of the European Economic Area (the “EEA”). Please check regularly for changes to our Privacy Policy.

 

10. LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.

The legal bases that we rely upon are the following:

·       Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver features in our Apps, to deliver content of the in-app purchase you make.

·       Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when using our Apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications and contextual advertising purposes.

·       Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before sharing any information with our advertising partners for the purposes of personalized advertising and data intelligence and before conducting any surveys.

·       Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance, is to maintain records for tax purposes.

 

11. SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

 

12. INTERNATIONAL TRANSFER

Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

This means that, when collected, your personal information may be processed in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Notice. 

 

13. CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at http://sunspotstudio.net/privacy_policy.html.

For previous versions of this Privacy Policy, please contact us via support@sunspotstudio.net

 

15. CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us through one of the following ways:

1.    For privacy questions and exercising your rights via our privacy email: support@sunspotstudio.net;

2.    Our data protection officer: support@sunspotstudio.net;

3.    if you have a concern or compliance regarding our treatment of your personal data you can contact the relevant data protection authority. For more information on which authority to contact, please email us at support@sunspotstudio.net.