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Privacy Policy
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Last updated: November 25, 2024
This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.
Interpretation and Definitions
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Interpretation
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The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.
Definitions
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For the purposes of this Privacy Policy:
* Affiliate means an entity that controls, is controlled by or is under
common control with a party, where "control" means ownership of 50% or
more of the shares, equity interest or other securities entitled to vote
for election of directors or other managing authority.
* Application refers to Crossword Flow, the software program provided by the
Company.
* Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to Sole Proprietor Ihor Ryzhkov, Ukraine, city Lviv,
Studynskoho street 6/18.
* Country refers to: Ukraine
* Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.
* Personal Data is any information that relates to an identified or
identifiable individual.
* Service refers to the Application.
* Service Provider means any natural or legal person who processes the data
on behalf of the Company. It refers to third-party companies or
individuals employed by the Company to facilitate the Service, to provide
the Service on behalf of the Company, to perform services related to the
Service or to assist the Company in analyzing how the Service is used.
* Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example,
the duration of a page visit).
* You means the individual accessing or using the Service, or the company,
or other legal entity on behalf of which such individual is accessing or
using the Service, as applicable.
Collecting and Using Your Personal Data
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Types of Data Collected
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Personal Data
~~~~~~~~~~~~~
We collect personal information that you voluntarily provide to us when you
express an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services, or otherwise
when you contact us.
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:
* Usage Data
Usage Data
~~~~~~~~~~
Usage Data is collected automatically when using the Service.
Platform providers and underlying operating systems (iOS, iPadOS, web
browsers, app store) may collect information about the Application (crash
reports, usage stats) and make those avaliable to this Application’s
developer, who may use those data to improve product development, to fix
bugs, and to improve the Application.
Usage Data may include information such as Your Device's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile operating system, and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.
This Application uses Firebase Analytics, a third-party analytics provider,
to track usage. Application sends data to Firebase Analytics in order to
track certain actions, like when the app is run for the first time or when
an in-app offer is purchased. It is not used for cross-app tracking,
fingerprinting, or audience building. For more detail, please see Google
Analytics for Firebase Use Policy
(https://marketingplatform.google.com/about/analytics/terms/us/).
This Application uses Amplitude, a third-party analytics provider, to track
usage. Application sends data to Amplitude in order to track certain actions,
like when the app is run for the first time or when an in-app offer is
purchased. It is not used for cross-app tracking, fingerprinting, or audience
building. For more detail, please see Amplitude's Acceptable Use Policy
(https://amplitude.com/aup).
This Application also integrates the RevenueCat SDK which captures some
analytics related to in app purchases and subscriptions.
You can find RevenueCat’s privacy Policy here:
(https://www.revenuecat.com/privacy/).
In order to make the handwriting recognition, this Application will use
ML Kit provided by Google LLC, but it will not be used for any purpose other
than to make the handwriting recognition to work, and the Service will not
store the data or share it with any third party. The processing of the input
data fully happens on-device, and ML Kit does not send that data to Google
servers. For more detail, please see
Google ML Kit Terms & Privacy (https://developers.google.com/ml-kit/terms).
Use of Your Personal Data
-------------------------
We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law.
The Company may use Personal Data for the following purposes:
* To provide and maintain our Service, including to monitor the usage of
our Service.
* To manage Your requests: To attend and manage Your requests to Us. When you
contact us by email (for technical support, etc.), we will only use your
contact information for the purposes of replying to you.
* For business transfers: We may use Your information to evaluate or conduct
a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of Our assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by Us about our Service users is among the assets
transferred.
* For other purposes: We may use Your information for other purposes, such
as data analysis, identifying usage trends, determining the effectiveness
of our promotional campaigns and to evaluate and improve our Service,
products, services, marketing and your experience.
Consent to Share Consumption Data with Apple for Refund Requests
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By making in-app purchases, you consent to our sharing your usage data
with Apple when you request a refund, to assist with reviewing your refund
request. This information may include details about how you have accessed and
interacted with the purchased content. The purpose of sharing this data is to
help Apple make an informed decision regarding your refund request, and we ensure
that such sharing complies with Apple's policies and is only done as necessary
to process your request.
What Legal Bases Do We Rely On To Process Your Information?
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We only process your personal information when we believe it is necessary and
we have a valid legal reason (i.e. legal basis) to do so under applicable law,
like with your consent, to comply with laws, to provide you with services to
enter into or fulfil our contractual obligations, to protect your rights, or
to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information.
As such, we may rely on the following legal bases to process your personal
information:
* Consent. We may process your information if you have given us permission
(i.e. consent) to use your personal information for a specific purpose.
You can withdraw your consent at any time.
* Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate
with a law enforcement body or regulatory agency, exercise or defend our
legal rights, or disclose your information as evidence in litigation in which
we are involved.
* Vital Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a third
party, such as situations involving potential threats to the safety of any
person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e. express consent) to use your personal information for a specific purpose,
or in situations where your permission can be inferred (i.e. implied consent).
You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
* If collection is clearly in the interests of an individual and consent
cannot be obtained in a timely way
* For investigations and fraud detection and prevention
* For business transactions provided certain conditions are met
* If it is contained in a witness statement and the collection is necessary
to assess, process, or settle an insurance claim
* For identifying injured, ill, or deceased persons and communicating with
next of kin
* If we have reasonable grounds to believe an individual has been, is, or may
be victim of financial abuse
* If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach
of an agreement or a contravention of the laws of Canada or a province
* If disclosure is required to comply with a subpoena, warrant, court order,
or rules of the court relating to the production of records
* If it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the purposes
for which the information was produced
* If the collection is solely for journalistic, artistic, or literary purposes
* If the information is publicly available and is specified by the regulations
We May Share Your Personal Information in the Following Situations
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* For business transfers: We may share or transfer Your personal 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.
* With business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.
* With Your consent: We may disclose Your personal information for any
other purpose with Your consent.
Retention of Your Personal Data
-------------------------------
The Company 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.
The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time
periods.
Transfer of Your Personal Data
------------------------------
Your personal information might be transferred to a country outside the EEA,
the United Kingdom or Switzerland, including, but not limited to, the United
States or other countries, which may have data protection laws that are
different from the laws where you live. We endeavor to safeguard your
information consistent with the requirements of applicable laws.
Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data
is treated securely and in accordance with this Privacy Policy and no transfer
of Your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.
If we transfer personal information which originates in the EEA, Switzerland,
and/or the United Kingdom to a country that has not been found to provide an
adequate level of protection under applicable data protection laws, one of the
safeguards we may use to support such transfer is the EU Standard Contractual
Clauses or similar contractual safeguards, and, if necessary, the implementation
of further technical and organizational measures.
Delete Your Personal Data
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You have the right to delete or request that We assist in deleting the
Personal Data that We have collected about You.
If we are relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can withdraw your
consent at any time by contacting us by using the contact details provided in
the section "Contact Us" below.
Please note, however, that We may need to retain certain information when we
have a legal obligation or lawful basis to do so.
Do California Residents Have Specific Privacy Rights?
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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.
If you are under 18 years of age, reside in California, and have a registered
account with Services, you have the right to request removal of unwanted data
that you publicly post on the 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 the
Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g. backups, etc.).
Disclosure of Your Personal Data
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Business Transactions
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If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
~~~~~~~~~~~~~~~
Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).
Other legal requirements
~~~~~~~~~~~~~~~~~~~~~~~~
The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:
* Comply with a legal obligation
* Protect and defend the rights or property of the Company
* Prevent or investigate possible wrongdoing in connection with the Service
* Protect the personal safety of Users of the Service or the public
* Protect against legal liability
Security of Your Personal Data
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The security of Your Personal Data is important to Us, but remember that no
method of transmission over the Internet, or method of electronic storage is
100% secure. While We strive to use commercially acceptable means to protect
Your Personal Data, We cannot guarantee its absolute security.
Children's Privacy
==================
Our Services are designed for a general audience and require all players to
be above the minimum age to consent for data processing (for example, 13 years
old in the United States, and 16 years old in some parts of the EU) as a
condition of access. We do not knowingly
collect personally identifiable information from children through the Services
or knowingly allow them to use our Services.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from a child, We will delete that information.
If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent's
consent before We collect and use that information.
Links to Other Websites
=======================
Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party's
site. We strongly advise You to review the Privacy Policy of every site You
visit.
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Changes to this Privacy Policy
==============================
We may update Our Privacy Policy from time to time. We will notify You of any
changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.
Contact Us
==========
Your privacy and trust matters to us. If you have any questions about this
Privacy Policy, You can contact us:
* By email: legal@crosswordflow.com