Privacy Policy

1. General

1.1. Your privacy and your Personal Data are very important to us, which is why we use our best endeavours in order to ensure a high standard protection of your Personal Data. This App is provided by Crowd Mobile QA Operations B.V, or any of our subsidiaries (“we”, “us” or “our”) which comply with all applicable international and national laws, provisions, guidelines, code of ethics and other obligatory provisions whatsoever. These principles are designed to protect the privacy of individuals and the confidentiality of Personal Data by regulating the way Personal Data is managed.

1.2. This Privacy Policy explains the ways in which we may collect, store, use and, in certain circumstances, disclose your Personal Data in accordance with all applicable laws. Unfortunately, the transmission of information over the Internet and/or any telecommunication network is not always completely safe, which is why we cannot guarantee the security of data transmitted over such gateways.

1.3. We secure our App, website(s), networks and/or other systems through technical and organizational measures against the loss, destruction, access, alteration or distribution of your data from unauthorized individuals and/or businesses.

1.4. By using our App or otherwise providing information to us, you agree to this Privacy Policy. Please read this Privacy Policy carefully before using the App and if you have any questions, feel free to contact us. You can find our contact details under section 11 of this Privacy Policy. If you do not agree to these terms, then do not use this App.

1.5. We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your Personal Data, we will update this Privacy Policy from time to time to reflect any changes to our use of your Personal Data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Therefore, we encourage you to review this Privacy Policy periodically to be informed of how we use your Personal Data.

1.6. We will not knowingly collect any Personal Data submitted by users below the legal age of majority in his or her country of residence, if the respective legal representative has not allowed the collection of said data. Upon notification of our collection of Personal Data of a minor without the respective representative’s consent, we will promptly stop usage of such data.

1.7. "Personal Data", as used in this Privacy Policy, means any information relating to an identifiable person who can be, directly or indirectly, identified in particular by reference to an identifier. To give you a clearer idea of the aforesaid definition, Personal Data may include your name, home address, home or mobile telephone number, e-mail address, age, personal preferences and opinions; basically, any information that may be personally associated with you. In section 2 below, we describe your personal data we process.

1.8. In case any Personal Data you provided us with will be identified as being “Sensitive Data” (such as, but not limited to, information with respect to your racial or ethnic origin, political opinion, sexual preference or religion), we will ask your explicit consent for the use of such Personal Data in case such is legally required.

2. Personal Data we collect and use

2.1. We collect and use the following types of Personal Data, but not limited to:

a) The date of the download and/or the respective date of use of the App;
b) Information regarding the App/website you used to access our App;
c) Your device “Identifier for Advertising”-ID (IDFA). Every iOS mobile device comes with such an identifier that allows developers and marketers to track activity for advertising purposes. It may be used by advertisers to run marketing campaigns and record purchasing or downloading conversions. You may reset/block said ID at any time within your mobile phone settings;
d) Your device “Identifier for Vendors”-ID (IDFV). IDFV is a device identification number uniquely assigned to each mobile application release to the Apple App Store or Google Play Store. It may be used by the application developer to identify your device for troubleshooting and analytics;
e) The respective status regarding the transmitted data volume processed within a respective request and/or usage situation/moment.

2.2. Additionally, information regarding your usage of our App including, but not limited to:

a) The name of the Stickers you are sharing within a respective situation/moment;
b) How often a respective Sticker has been/is being used by you;
c) The version of our App you are currently using;
d) The frequency and length of App usage;

2.3. Furthermore, information about your mobile phone (device information) including, but not limited to:

a) The brand type;
b) The model type;
c) The operating system of your mobile phone (e.g. Android, iOS).

3. How we collect Personal Data

3.1. In particular, we collect such Personal Data at any time you use the App, using third party analytic and advertising platforms (e.g. mixpanel, fyber), and during each instance in which you communicate with us in any given possible way.

4. Use of your Personal Data

4.1. We only use your Personal Data for the purposes described in this Privacy Policy. For any other purposes that are not described in this Privacy Policy, we will use your Personal Data only in case we have obtained an additional prior consent from you or in case we are otherwise authorized or required by law to use your Personal Data for that other purposes; in regard to the latter case, we will inform you about such a scenario.

4.2. We collect and use your Personal Data for the purposes set out below:

a) To operate our App, particularly to identify and remove any errors within our App and/or to determine how you utilize the App so we can make adjustments or improvements;
b) To conduct our business;
c) To fulfil our duties and obligations under any contracts between you and us and/or any contracts between a third party and us;
d) To comply with our legal duties and obligations;
e) To provide and market our services;
f) To communicate with you;
g) To ensure that our App is presented to you in the most effective and interesting way possible;
h) To protect any intellectual property in material within our App; and
i) To help us manage and enhance all other services we provide.

5. Disclosing your Personal Data

5.1. We do not sell, market or rent your Personal Data. Subject to applicable laws, we may share your Personal Data with our staff, our websites or apps hosting and maintenance, storage, processing and transmission of data persons and entities and third parties involved in providing Apps services. However, we cannot assure or guarantee you that such persons and entities will comply with their obligations.

5.2. We do not disclose your Personal Data to any third party without your prior (written) consent, except in cases where we are constrained by any law and/or order to publish and/or divulge such information to any governmental and/or regulatory body or in case we need to disclose it in order to be able to provide our service to you to the full extent.

5.3. Furthermore, we may forward any necessary information, such as the IDVA- and IDVF-ID, to any third party that is needed in order to be able to properly advertise content to you.

5.4. Once you have used our App, we may contact and communicate with you via the App. By using our App you agree to such communications. Don’t worry, in most cases we will only communicate with you if we are legally obligated to do so or if such communication serves for your benefit. If you no longer wish to receive communications from us at all, notify us through our contact details set out in section 11.

6. Data retention

6.1. We will only process your Personal Data for as long as we need it in order to be able to provide our services to you, to execute any other functions as described herein and/or to fulfill any legal requirements. We retain your Personal Data for as long as required to satisfy the purpose for which they were collected and use, unless a longer period is necessary for our legal obligations or to defend a legal claim. As statutory retention periods can vary depending on the record at stake, please contact us for more information.

7. Security

7.1. We will take all reasonable steps to ensure that the information we collect, use, disclose and transfer is accurate, complete and up to date.

7.2. You may request the Personal Data we hold about you and if you believe that it is out of date, incomplete, incorrect, and/or if you believe that we have not dealt with your Personal Data in a manner that complies with the privacy laws, you may request to update, amend or delete that information. Please see section 11 regarding our contact information.

8. Data transfer

8.1. Your Personal Data may be transferred to -and maintained on- computers located outside of your state, province, country or governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Where we are legally required to do so, we have legally acceptable mechanisms in place that ensure an adequate level of protection for the transfers of Personal Data to parties outside your jurisdiction. For example, for data transfers from EU/EEA to countries outside this region, we have European Commission-approved Standard Contractual Clauses or similar safeguards in place, allowing such data transfers.

9. Your rights in regard to your Personal Data

9.1. In the following you will find a list with all individual rights you have in regard to the Personal Data we hold about you:

• Your right of access
If you ask us, we will confirm whether we are processing your Personal Data and, if necessary, provide you with a copy of that Personal Data (along with certain other details). Please note that you might need to send us a copy of your passport ID or any other legal document that may verify your identity, too; this verification procedure is necessary in order to protect your Personal Data from unauthorized access through any other person.
• Your right to rectification
If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we have shared your Personal Data with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
• Your right to erasure
In certain circumstances, you can ask us to delete or remove your Personal Data such as where we no longer need it or if you withdraw your consent (where applicable), provided there is no overriding legitimate interest for continuing the processing. If you are entitled to erasure and if we have shared your Personal Data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
• Your right to restrict processing
In certain circumstances, you can ask us to 'block' or suppress the processing of your Personal Data, such as where you contest the accuracy of that Personal Data or you object to us. If you are entitled to restriction and if we have shared your Personal Data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal Data with so that you can contact them directly.
• Your right to data portability
In certain circumstances, you have the right to obtain Personal Data you have provided us with (in a structured, commonly used and machine readable format such as Microsoft Excel) and to reuse it elsewhere or to ask us to transfer this to a third-party of your choice.
• Your right to object
You can ask us to stop processing your Personal Data, and we will do so, if we are: o relying on our own or some else’s legitimate interest to process your Personal Data, except if we can demonstrate compelling legal grounds for the processing; or o processing your Personal Data for direct marketing purposes.
• Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority
You have, at any time moving forward and in any case, the right to lodge a complaint with your relevant data protection authority if you think that we have violated your rights and/or are not in compliance with any applicable Personal Data protection regulation.

10. Third-Party Links

10.1. We may include or offer third-party links, products or services on the App. Such third-party sites have their own separate privacy policy and terms of use and may also collect Personal Data about you. Despite the integration, mentioning and description of third-party links, we have no responsibility or liability whatsoever for the content and/or activities of these linked sites. Our Privacy Policy does not apply to your interactions with other Apps/websites, even if you find such links to such third-party Apps/websites within our App or if we send you such links via any kind of communications channel whatsoever. If you click upon a link/social-plugin that links you to a different App/website, you should read the privacy policy of the third-party App/website providers to see how your private information is treated by them.

11. Contact Information

11.1. For complaints regarding our App please contact us at:
support[at]mobile-support.zendesk.com

11.2. We welcome your comments regarding this Privacy Policy. In this regard, you may contact us by sending:
(a) an e-mail to: privacy[at]crowdmobile.com
(b) a letter to us at the following address:
Crowd Mobile QA Operations B.V.
Piet Heinkade 95B
1019 GM Amsterdam
The Netherlands