Privacy Policy - HeadyApps

Mobile Analytics Poland sp. z o.o. (“Mobile Analytics Poland sp. z o.o.”, “we”, “us” and “our”) offers you access to its websites (“websites”), games, applications (“games”, “apps”) and related services – together, “Services”. Our Services include https://headyapps.com/ and all other platforms on which we place this Privacy Policy.

This Privacy Policy explains how we collect, use, secure, and/or disclose or otherwise process your Personal Data when you use our Services. Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it.

DATA CONTROLLER

Mobile Analytics Poland sp. z o.o.
Prosta street, building 20, postal code 00-850, Warsaw, Poland
headyapps@headyapps.com

1. PROCESSING OF PERSONAL DATA

1. Personal Data we collect

Personal Data means any information about an individual from which that person can be identified (“Personal Data”). It does not include data where the identity has been removed (“anonymous data”).

Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data unless you provide such data to us.

We may collect, use, store and transfer following kinds of Personal Data about you:

Technical Data such as IP Address, your device’s operating system, browser type, language, location, hardware type and reference site address.
Identity Data such as your unique device ID (persistent/non-persistent), IDFA (Identifier for advertisers).
Usage Data such as date and time you used Services, your interactions with the Services or game and with the other users or players inside the Services, in-app purchases, subscriptions, advertising that you click on, your game progress.
Contact Data such as name and email address.

We do not and will not process any special categories of Personal Data.

We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such case we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.

2. How do we collect Personal Data

We use different methods to collect Personal Data from and about you including through:

Direct interactions. You may give us your Contact Data when you contact our customer support services or give us some feedback.

Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical, Identity and Usage Data. We collect this Personal Data by using cookies, and other similar technologies. Please see our cookie clause below for further details.

3. How do we use your Personal Data

We have set out below a description of all the ways we use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4. How do we use your Personal Data

Purpose/Activity	Type of data	Lawful basis for processing
To administer and protect our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Technical (b) Identity (c) Usage	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
To provide you with a correct version of app or game	(a) Technical (b) Identity	Necessary to perform contract with you
To deliver relevant Service Content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Technical (b) Identity (c) Usage (d) Contact	Your explicit consent
To use data analytics to improve our Services, marketing, customer relationships and experiences	(a) Technical (b) Identity (c) Usage	Your explicit consent
To make suggestions and recommendations to you about goods or services that may be interest you	(a) Technical (b) Identity (c) Usage (d) Contact	Necessary for our legitimate interests (to provide you with the most advantageous offers)

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Cookies

At the first time you visit our Services, we ask for your consent to our use of cookies for marketing and other purposes.

We use third party analytics services in order to better understand user engagement with the Services. When a user uses the Services, these third party analytics services may collect the user’s IP address, browser type, and approximate location (based on the IP address). They may also use web logs or web beacons and may set and access cookies on your computer or other device. A list of the third parties that operate in our Services can be found in the APPENDIX A below. Please, read privacy policies of this services to better understand their policies and practices regarding your Personal Data.

You can set your browser or device to refuse all or some cookies, or contact our technical support team via headyapps@headyapps.com to request us to disable cookie. If you disable or refuse cookies, please note that some parts of Services may become inaccessible or not function properly.

To find our more information about cookies, including information about how to manage and delete cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/".

2. YOUR RIGHTS

You have the right to request the access and rectification or erasure of Personal Data or restriction of processing or to object to processing as well as the right to data portability. Further, you have a right to lodge a complaint with a respective supervisory authority.

the right to rectification is your right to obtain without undue delay the rectification of inaccurate Personal Data concerning you;
the right to erasure is your right to obtain the erasure of Personal Data concerning you without undue delay, where certain additional circumstances are fulfilled;
under certain circumstances you have the right to restrict the processing of Personal Data;
you have the right to receive the Personal Data concerning you, and that you have provided to us, and have the right to transmit those data to another controller, where technically feasible, where the processing is based on consent or on a contract and the processing is carried out by automated means;
you have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data concerning you which is based on respective provisions of the law, including profiling based on those provisions;
subject to the respective statutory limitations set by the applicable law, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
where the processing of Personal Data is based on your consent you can withdraw such consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.

Please contact us via headyapps@headyapps.com to exercise any of the above mentioned rights.

You may also contact your local data protection authority for unresolved complaints.

Opting out of receiving promotional emails

You may opt-out of receiving promotional emails from us by following the instructions in those emails or by emailing us via headyapps@headyapps.com. If you opt-out, we may still send you non-promotional emails, such as emails about our ongoing business relations.

Opting out of targeted advertising

To show you personalized advertisements in our apps we use third-party advertising networks and their partners, including those that need your consent and listed in APPENDIX A below, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple's ID for advertising (IDFA), and/or other tracking technologies to enable and optimize this advertising procedure.

You can opt-out from personalized advertisement experience, at any time by checking the Privacy Setting tab in any of our apps or under the privacy settings of your iOS or Android device.

For iOS Devices:

Open Settings
Select Privacy
Select Advertising and enable "Limit Ad Tracking"

For Android Devices:

Open Settings
Select Privacy
Select Ads and enable "Opt out of Ads Personalization"

When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests. Note: Irrespective of your choice and/or your device settings, you will continue to see non-customized advertising (e.g. “contextual” advertising) and you may continue to receive personalized ads from our third-party ad networks that obtain your consent on other apps and/or websites. For more information go to APPENDIX A.

DO NOT SELL MY PERSONAL DATA

We do not sell your Personal Data. We are not making money from selling your Personal Data. Particularly, in the last 12 months we have not you’re your Personal Data, but we have disclosed some categories of Personal Data we collect to our subsidiaries and third parties (as set forth in the APPENDIX A below) for business purposes described in the clause named “How do we use your Personal Data” above.

No discrimination

You are protected against any discrimination based on the exercising of your rights. Unless permitted by the applicable law, we will not:

Deny you Services,
Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties,
Provide you a different level or quality of Services,
Suggest that you may receive a different price or rate for Services or a different level or quality of Services.

3. DATA RETENTION

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analytics purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Your Personal Data collected through our Services will be deleted when they no longer serve one of the above-mentioned purposes but in any event we will review the data stored each 1 (one) year to determine if we still need this Personal Data. If we establish that we no longer need your Personal Data, we will delete it. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

4. OUR POLICY CONCERNING CHILDREN

Use of Services is limited to users aged 13 years and above, except in European Economic Area, where the Services are limited to users aged 16 years and above (“children”). We do not knowingly collect or Personal Data from or direct or target interest based advertising to children or knowingly allow children to use our Services. If you are a child, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Data from a child, we will delete that Personal Data as quickly as possible. If you believe that we might have any information from or about a child, please contact us.

5. SUBCONTRACTING AND EXPORTING PERSONAL DATA

We may transfer Personal Data that we collect about you to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of Personal Data and the use and disclosure of Personal Data.

1. How we may disclose your Personal Data to third parties

Mobile Analytics Poland sp. z o.o. does not share your Personal Data except as approved by you or as described below:

Mobile Analytics Poland sp. z o.o. may engage other companies and individuals to perform services on our behalf. An example of these services may include analyzing data and providing customer support. They may have access to your Personal Data in connection with the performance of services for Mobile Analytics Poland sp. z o.o.. A list of the third parties that operate in our Services can be found in the APPENDIX A below.
we may release your Personal Data as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, Mobile Analytics Poland sp. z o.o. may be required to disclose Personal Data in response to lawful requests by public authorities or for local law enforcement requirements.
Mobile Analytics Poland sp. z o.o. may share your Personal Data in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our websites of any change in ownership or users of your Personal Data.

We may share anonymous Personal Data with advertisers, publishers, business partners, sponsors, and other third parties however such information is not considered as Personal Data since it is not possible to connect such information with certain user.

2. Links to other sites

For your convenience, the Services may contain links to other platforms, such as those of our partners or vendors, which are subject to different privacy policies. The Privacy Policy will not apply to your use of other platforms. While we generally try to link only to platforms that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent platforms We encourage you to ask questions and review the applicable privacy policies found on such other platforms to understand how your information may be collected and used on these independent platforms before disclosing information to them.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may change from time to time, and we encourage you to review it periodically. Any changes to this Privacy Policy will be effective immediately by posting on our Services. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.

8. CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy or your Personal Data, or if you want to exercise any of your rights, then please contact us:

via e-mail at: Mobile Analytics Poland sp. z o.o.;
Prosta street, building 20, postal code 00-850, Warsaw, Poland.

APPENDIX A: Analytics and Other Service Providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

Firebase

Firebase is an analytics service provided by Google Inc. (US)

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: http://www.google.com/intl/en/policies/privacy/

Facebook Ads conversion

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects data from the Facebook advertising network with actions performed on the Services.

Facebook Analytics

Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Appmetrica

Appmetrica is an analytics tool by Yandex, LLC (Russia) that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

For personalized advertising, the advertising networks and their partners, that are listed below, and would like your consent, if you reside in EEA, unless they have another legal basis for processing, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA).

Appsflyer

Appsflyer is an analytics tool by AppsFlyer Ltd. that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Facebook Audience Network

Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement Services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service.

You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.

Google AdMob and their partners

AdMob by Google is provided by Google Inc. (US)

For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/

For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903

You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

IronSource

IronSource is an advertising service provided by IronSource, Inc. (US).

Unity Ads

Unity Ads is an advertising service provided by Unity Ads Inc. (US).

Adjust

Adjust is an analytics tool by Adjust GmbH that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

AppLovin

AppLovin is an advertising service provided by AppLovin Corporation that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Liftoff

Liftoff is an advertising service provided by Liftoff Mobile, Inc. that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Digital Turbine

Digital Turbine is an advertising service provided by Digital Turbine, Inc. that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Chartboost

Chartboost is an advertising service provided by Chartboost, Inc., Inc. that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Mintegral

Mintegral is an advertising service provided by Mintegral entities that may collect or receive information from our apps and other apps and use that information to provide measurement Services.

Inmobi

Inmobi is an advertising service provided by Inmobi that may collect or receive information from our apps and other apps and use that information to provide measurement Services.