Privacy Policy

Revision date: 12th August 2019

This page is used to inform users regarding our policies on the collection, use, and disclosure of personal information for anyone deciding to use the application.

If you choose to use the application, then you agree to the collection and use of information in relation to this policy. The personal information that we collect is used for providing and improving the application. We will not use or share your information with anyone except as described in this privacy policy.

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at dataprotection@192soft.com.

What Information do we collect?

Information collected through our Apps

For a better experience, while using our application, we collect anonymous usage information which consists of:

To collect the above information we use the following third party services that may collect information used to identify you:

Log Data

We want to inform you that whenever you use our application, in the case of an error in the application we collect data and information on your phone called log data. This log data may include information such as your device internet protocol (“IP”) address, device name, operating system version, the configuration of the app when utilising our application, the time and date of your use of the application, and other statistics.

To collect the above information we use the following third party services that may collect information used to identify you:

Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

The application does not use “cookies” itself, however the app may use third party code and libraries that use “cookies” to collect information and improve the third parties services.

Service Providers

We may employ third-party companies and individuals for the following reasons:

We want to inform users of this application that these third parties may have access to your personal information. The reason is to perform the tasks assigned to them on our behalf, however they are obligated not to disclose or use the information for any other purpose.

Information collected from other sources

We currently don’t collect information about our application users from any other sources apart from those listed above.

How we use your information

We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products, services, marketing and your experience.

Will your information be shared with anyone?

We may process or share data based on the following legal basis:

More specifically, we may need to process your data or share your personal information in the following situations:

Who will your information be shared with?

We only share and disclose your information with the following third parties. We have categorised each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us at dataprotection@192soft.com.

How long do we keep your data?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than fourteen months after you have ceased using our applications.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How we keep your information safe

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our application is at your own risk. You should only access the services within a secure environment.

Do we collect information from minors?

We do not knowingly solicit data from or market to children under thirteen years of age. By using our application, you represent that you are at least thirteen years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the application. If we learn that personal information from users less than eighteen years of age has been collected, we will deactivate any account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under the age of thirteen, please contact us at dataprotection@192soft.com.

What are your privacy rights?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right:

In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

National Data Protection Authorities

Privacy rights for California residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to us using the contact information provided below.

If you are under eighteen years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted data that you publicly post on our applications and services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on our applications and other services, but please be aware that the data may not be completely or comprehensively removed from our systems.

Updates to this policy

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

Contact Us

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Nicholas Llewellyn, by email at:

dataprotection@192soft.com