Delern update

delern/privacy.md

@@ -1,8 +1,8 @@
 ## Privacy Policy of Delern Flashcards
 
-*Last Updated: August 16, 2020*
+_Last Updated: March 23, 2021_
 
-*This Application collects some Personal Data from its Users.*
+_This Application collects some Personal Data from its Users._
 
 ### Owner and Data Controller
 
@@ -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
 
@@ -23,15 +23,15 @@ 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.
 
 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.
@@ -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
 
@@ -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
@@ -240,39 +251,64 @@ 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).
+
+#### Advertisement
+
+We may also use Google Admob to display advertising to you while using
+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).
+
+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.
 
 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
+  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
   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