Last updated: 25th Novermber 2019
Information we collect
Information automatically collected
In Short: We collect information about how the app is used to understand our audience and make better content recommendations. If permission is given, we use location to assist this process, but we do not store this information.
Some data is automatically collected for the purpose of understanding how users interact with the App, and for security reasons.
This information is non-sensitive, and is only linked to you through a pseudonymous device identifier that cannot practically be attributed to your person. Location, if used, is not linked to any device identifier.
Below are some examples of what we may collect:
Identifiers: a unique, pseudonymous identifier for the device running the App.
Device sensor data: location, acceleration, rate of rotation, external magnetic field, ambient light, barometric pressure, humidity, screen lock status.
Derived usage information: user motion, device position, physical place category, overall user situation, local weather, habitual behaviours.
Device statistics: Wi-Fi/cellular connection statistics.
How we use collected information
In Short: We process data for internal aggregated reports about our audience and to recommend content.
We use information collected via the App for a variety of business purposes described below.
We process your information for these purposes in reliance on our legitimate business interests ("Legitimate Interests"), in order to enter into or fulfill a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons").
We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To recommend content by app usage behaviour. Collected information is processed within the App to personalise content to your usage habits. This is for Legitmate Interests.
To generate anonymised reports of in-app behaviour. This is for Legitmate Interests.
To improve our technology. Anonymous data may be used to improve our methodologies for the above uses. This is for Legitmate Interests.
To enforce our terms, conditions and policies. This is for Legal Reasons.
How your information is shared
In Short: We only share information with your consent, to comply with laws, or to fulfill business obligations.
Reasons we may share your data:
Consent: We may share your data if you have given us explicit consent to use it for a particular purpose.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
How long we keep information
In Short: Information within the App is discarded after 1 month, and information sent to us from the App is kept for no longer than 6 months.
Information that is processed within the App is either discarded after a few seconds, or stored inside the App for up to 1 month. Due to technological limitations, old information cannot be deleted until the App is opened, uninstalled, or its data is cleared.
Information sent to us for the purposes of anonymous audience reports is kept for no longer than 6 months.
We will only keep information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process personal information, we will either delete or fully anonymise it by removing all identifiers.
How we keep your information safe
In Short: We anonymise all information we collect, and only identify it by a non-reversible pseudonymous device identifier.
Information is either short-lived, or stored using appropriate technological measures to ensure that only our App may access the information.
Any data sent to us is pseudonymised to minimise the amount of personal information we store. We also have appropriate technical and organisational measures to further limit access to this information.
Do we collect information from minors?
In Short: Not knowingly.
We do not knowingly solicit data from or market to children under 13 years of age. By using the App, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the 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 age 13, please contact us at firstname.lastname@example.org.
Your privacy rights
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. 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: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Your privacy rights
If you would at any time like to review or change the information we hold about you, you can:
Uninstall the App, or clear its data.
Contact us using the contact information provided.
Upon a request to erase any information, we will deactivate or delete any related information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms and conditions and/or comply with legal requirements.
Specific rights for California residents
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
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 in writing to us using the contact information provided below. 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 in writing to us using the contact information provided below.
Updates to this policy
If you have questions or comments about this policy, you may email us at or by post to:
NumberEight Technologies Ltd.
1-15 Clere Street