From 5da2139d2e5adb6e0f339616901cd65a1d870d33 Mon Sep 17 00:00:00 2001 From: Katarina Sheremet Date: Fri, 13 Nov 2020 08:36:12 +0100 Subject: [PATCH 1/5] Add Amplidude --- delern/privacy.md | 49 +++++++++++++++++++++++++++++------------------ 1 file changed, 30 insertions(+), 19 deletions(-) diff --git a/delern/privacy.md b/delern/privacy.md index 9432b3b..7eaeec4 100644 --- a/delern/privacy.md +++ b/delern/privacy.md @@ -1,8 +1,8 @@ ## Privacy Policy of Delern Flashcards -*Last Updated: August 16, 2020* +_Last Updated: November 13, 2020_ -*This Application collects some Personal Data from its Users.* +_This Application collects some Personal Data from its Users._ ### Owner and Data Controller @@ -23,7 +23,7 @@ email address; profile picture. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts -displayed prior to the Data collection. Personal Data may be freely provided +displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. @@ -31,7 +31,7 @@ Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without -consequences to the availability or the functioning of the Service. Users who +consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. @@ -66,19 +66,19 @@ parties may be requested from the Owner at any time. The Owner may process Personal Data relating to Users if one of the following applies: -* Users have given their consent for one or more specific purposes. Note: Under +- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; -* provision of Data is necessary for the performance of an agreement with the +- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; -* processing is necessary for compliance with a legal obligation to which the +- processing is necessary for compliance with a legal obligation to which the Owner is subject; -* processing is related to a task that is carried out in the public interest or +- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; -* processing is necessary for the purposes of the legitimate interests pursued +- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis @@ -113,10 +113,10 @@ purpose they have been collected for. Therefore: -* Personal Data collected for purposes related to the performance of a contract +- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. -* Personal Data collected for the purposes of the Owner’s legitimate interests +- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner. @@ -153,6 +153,17 @@ services: The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. +**Amplitude Analytics** + +Amplitude Analytics is an analytics service provided by Ampliture Inc. + +We use these cookies to collect information about how you interact with our +services to help us improve them. We may use these cookies to determine if +you have interacted with certain content or features. We use these cookies +to learn more about what features are the most popular with our users. + +Amplitude's Privacy Policy can be found [here](https://amplitude.com/privacy). + **Google Analytics for Firebase (Google LLC)** Google Analytics for Firebase or Firebase Analytics is an analytics service @@ -246,33 +257,33 @@ Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following: -* **Withdraw their consent at any time**. Users have the right to withdraw +- **Withdraw their consent at any time**. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. -* **Object to processing of their Data**. Users have the right to object to the +- **Object to processing of their Data**. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. -* **Access their Data**. Users have the right to learn if Data is being +- **Access their Data**. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. -* **Verify and seek rectification**. Users have the right to verify the +- **Verify and seek rectification**. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. -* **Restrict the processing of their Data**. Users have the right, under +- **Restrict the processing of their Data**. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. -* **Have their Personal Data deleted or otherwise removed**. Users have the +- **Have their Personal Data deleted or otherwise removed**. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. -* **Receive their Data and have it transferred to another controller**. Users +- **Receive their Data and have it transferred to another controller**. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof. -* **Lodge a complaint**. Users have the right to bring a claim before their +- **Lodge a complaint**. Users have the right to bring a claim before their competent data protection authority. #### Details about the right to object to processing From d5ef8c7cbd4bae2c03173cc2f74080303a362ea7 Mon Sep 17 00:00:00 2001 From: Katarina Sheremet Date: Fri, 13 Nov 2020 08:48:51 +0100 Subject: [PATCH 2/5] Add payment data --- delern/privacy.md | 9 +++++++++ 1 file changed, 9 insertions(+) diff --git a/delern/privacy.md b/delern/privacy.md index 7eaeec4..64b282c 100644 --- a/delern/privacy.md +++ b/delern/privacy.md @@ -251,6 +251,15 @@ policy of the service. Place of processing: United States – [Privacy Policy](https://policies.google.com/privacy). Privacy Shield participant. +#### Payment Data + +The app uses Apple and Google Play as payment providers for paid subscriptions. +Apple's Privacy Policy can be found [here](https://www.apple.com/legal/privacy/en-ww/). +Google's Payment Privacy Notice can be found [here](https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB) + +The App uses RevenueCat to manage paid subscriptions. +For more detail, please see RevenueCat's [privacy policy](https://www.revenuecat.com/privacy). + ### The rights of Users Users may exercise certain rights regarding their Data processed by the Owner. From 682cf2c6fe3e03a48ebd77c3ebefd200a9432c8a Mon Sep 17 00:00:00 2001 From: Katarina Sheremet Date: Fri, 13 Nov 2020 09:01:52 +0100 Subject: [PATCH 3/5] Add Adverticement info --- delern/privacy.md | 10 ++++++++++ 1 file changed, 10 insertions(+) diff --git a/delern/privacy.md b/delern/privacy.md index 64b282c..6e24ff8 100644 --- a/delern/privacy.md +++ b/delern/privacy.md @@ -260,6 +260,16 @@ Google's Payment Privacy Notice can be found [here](https://payments.google.com/ The App uses RevenueCat to manage paid subscriptions. For more detail, please see RevenueCat's [privacy policy](https://www.revenuecat.com/privacy). +#### Adverticement + +We may also use Google Admob to display advertising to you while using +the Service. AdMob uses the devices advertising id to serve personalized +ads based on the users interests (which includes collecting and analyzing +user data). +Information how ads can be personalized can be found [here](https://adssettings.google.com/u/0/authenticated) + +For more details, please see [Google Privacy and Terms](https://policies.google.com/technologies/partner-sites) + ### The rights of Users Users may exercise certain rights regarding their Data processed by the Owner. From deebd0b2fd9cb6d0077f5f91a4877abc61073bd1 Mon Sep 17 00:00:00 2001 From: Katarina Sheremet Date: Sun, 21 Mar 2021 15:37:23 +0100 Subject: [PATCH 4/5] Put dots in the end of sentences, update 'last updated' date --- delern/privacy.md | 10 +++++----- 1 file changed, 5 insertions(+), 5 deletions(-) diff --git a/delern/privacy.md b/delern/privacy.md index 6e24ff8..f0831d3 100644 --- a/delern/privacy.md +++ b/delern/privacy.md @@ -1,6 +1,6 @@ ## Privacy Policy of Delern Flashcards -_Last Updated: November 13, 2020_ +_Last Updated: March 21, 2021_ _This Application collects some Personal Data from its Users._ @@ -13,7 +13,7 @@ Gulerstrasse 26 Switzerland ``` -Owner contact email: [katarina@sheremet.ch](mailto:katarina@sheremet.ch). +Owner contact email: [contact@futureware.dev](mailto:contact@futureware.dev). ### Types of Data collected @@ -255,7 +255,7 @@ Policy](https://policies.google.com/privacy). Privacy Shield participant. The app uses Apple and Google Play as payment providers for paid subscriptions. Apple's Privacy Policy can be found [here](https://www.apple.com/legal/privacy/en-ww/). -Google's Payment Privacy Notice can be found [here](https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB) +Google's Payment Privacy Notice can be found [here](https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB). The App uses RevenueCat to manage paid subscriptions. For more detail, please see RevenueCat's [privacy policy](https://www.revenuecat.com/privacy). @@ -266,9 +266,9 @@ We may also use Google Admob to display advertising to you while using the Service. AdMob uses the devices advertising id to serve personalized ads based on the users interests (which includes collecting and analyzing user data). -Information how ads can be personalized can be found [here](https://adssettings.google.com/u/0/authenticated) +Information how ads can be personalized can be found [here](https://adssettings.google.com/u/0/authenticated). -For more details, please see [Google Privacy and Terms](https://policies.google.com/technologies/partner-sites) +For more details, please see [Google Privacy and Terms](https://policies.google.com/technologies/partner-sites). ### The rights of Users From f8a0977c00461dc3f733e119a8b88fabe546d788 Mon Sep 17 00:00:00 2001 From: Katarina Sheremet Date: Tue, 23 Mar 2021 15:53:00 +0100 Subject: [PATCH 5/5] Fix typos --- delern/privacy.md | 30 ++++++++++++++++++------------ 1 file changed, 18 insertions(+), 12 deletions(-) diff --git a/delern/privacy.md b/delern/privacy.md index f0831d3..2989225 100644 --- a/delern/privacy.md +++ b/delern/privacy.md @@ -1,6 +1,6 @@ ## Privacy Policy of Delern Flashcards -_Last Updated: March 21, 2021_ +_Last Updated: March 23, 2021_ _This Application collects some Personal Data from its Users._ @@ -129,8 +129,8 @@ obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the -right to data portability cannot be enforced after expiration of the retention -period. +right to data portability cannot be enforced after the expiration of the +retention period. ### The purposes of processing @@ -254,21 +254,26 @@ Policy](https://policies.google.com/privacy). Privacy Shield participant. #### Payment Data The app uses Apple and Google Play as payment providers for paid subscriptions. -Apple's Privacy Policy can be found [here](https://www.apple.com/legal/privacy/en-ww/). -Google's Payment Privacy Notice can be found [here](https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB). +Apple's Privacy Policy can be found +[here](https://www.apple.com/legal/privacy/en-ww/). +Google's Payment Privacy Notice can be found +[here](https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB). The App uses RevenueCat to manage paid subscriptions. -For more detail, please see RevenueCat's [privacy policy](https://www.revenuecat.com/privacy). +For more detail, please see RevenueCat's +[privacy policy](https://www.revenuecat.com/privacy). -#### Adverticement +#### Advertisement We may also use Google Admob to display advertising to you while using -the Service. AdMob uses the devices advertising id to serve personalized -ads based on the users interests (which includes collecting and analyzing +the Service. AdMob uses the device's advertising id to serve personalized +ads based on the user's interests (which includes collecting and analyzing user data). -Information how ads can be personalized can be found [here](https://adssettings.google.com/u/0/authenticated). +Information how ads can be personalized can be found +[here](https://adssettings.google.com/u/0/authenticated). -For more details, please see [Google Privacy and Terms](https://policies.google.com/technologies/partner-sites). +For more details, please see +[Google Privacy and Terms](https://policies.google.com/technologies/partner-sites). ### The rights of Users @@ -294,7 +299,8 @@ In particular, Users have the right to do the following: storing it. - **Have their Personal Data deleted or otherwise removed**. Users have the right, under certain circumstances, to obtain the erasure of their Data from - the Owner. + the Owner. To remove your data, please reach out to us at + [contact@futureware.dev](mailto:contact@futureware.dev). - **Receive their Data and have it transferred to another controller**. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted