Filtroo Privacy Policy
- INTRODUCTORY PROVISIONS
1.1. Filtroo ÖÜ (“Filtroo”, “Company”, “us”, “our” or “we”) is dedicated to protecting the privacy rights of our users (“User(s)”, “you”). This Privacy Policy (this “Policy”) describes how and why we collect, store, use, and manage the information, and data, including personal data, that you provide or we collect when you visit our website www.filtroo.co (“Site”) or use any Filtroo´s application or games provided on any mobile platform (for example, iOS and Android) (collectively, the “Service(s)”). It also tells you how you can access and update personal information and/or data and make certain choices about how personal information and/or data that you provide to Filtroo is used.
1.2. Please note that the scope of this Policy is limited to information and data collected or received by Filtroo through or in relation to your use of the Service. Filtroo is not responsible for the actions of third parties, the content of third party websites, the use of information or data you provide to third parties, or any products or services they may offer. Any link to third party websites does not constitute our sponsorship of, or affiliation with, such third parties.
1.3. Filtroo acts as a Data Controller in relation to personal data that you provide to Us.
1.4. By using our Services you agree to our Privacy Policy and confirm that you are at least 16 years old. We do not knowingly collect or solicit personal data from or direct or target interest based advertising to anyone under the age of 16 or knowingly allow such persons to use Our Services. If you are under the age of 16, please do not send any personal data to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal data from an individual under 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about an individual under the age of 16, please contact us by sending an email to info@filtroo.co
1.5. Filtroo ÖÜ as Data Controller does not and will not process any special categories of personal data.
1.6. From time to time, We can update this Privacy Policy. We may notify you about changes to this Policy by placing a notice on the Site. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically check back and review this Policy so that you always know Our current privacy practices.
2. INFORMATION THAT WE COLLECT
2.1. We collect and combine different types of information and/or data (including personal data) together. Here you can find more about what information and/or data We collect about you, when We collect it and what information and/or data We do not collect about you:
2.1.1. Registration, account, and sign-up information.
We collect data in the course of your use of, or registration with Filtroo. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal data. This type of personal data can include: name, postal address, telephone number or email address. We can also receive data about your interest in and use of various products, programs, services, and content available.
2.1.2. Product/service purchase.
Where you make a purchase on our Site, We provide you third party services for purchasing and your payment data (e.g. credit/debit card, billing information and delivery address) is not collected by Us.
2.1.3. From other sources.
We, on occasion, combine data We receive online with other information, including usage information from Our other websites and Our online advertising and media. We also supplement or combine data with data from a variety of other sources or outside records, such as demographic and transaction history, and we use that combined data in accordance with this Privacy Policy.
2.1.4. Social media.
You can engage with some of Our content and offerings, such as videos, games, applications, and other offerings on or through third party communities, forums, and social media websites, services, plug-ins, and applications (“Social Media Sites”). When you link to or interact with Us or Our content through SocialMedia Sites, you allow Us to receive certain data from your social media account (e.g., your name, user ID, email address, profile photo, photos and videos, gender, date of birth, your list of friends and their contact details, people whom you follow and/or who follow you, the posts or the ‘likes’ you make). We also receive data from your interaction with Our content (e.g., data regarding content viewed, game performance, high scores, and information about advertisements you have been shown or have clicked on). Where permitted by law, by providing this data or otherwise interacting with Our websites through Social Media Sites, you consent to our use of data from Social Media Sites in accordance with this Privacy Policy.
2.1.5. Location information.
We have access to certain data about your location, such as your country or address, when you provide it to Us directly or when we receive it via device information (such as an IP address). With your consent (where required by law), we can also collect data about your device’s precise location (e.g. geolocation via mobile device(s)) for the purpose of tailoring content specific to your area (such as area based content packages), and to match your device location to certain points of interest for purposes of interest based advertising as described in this Policy. Please note, participation in this part of the Service is not a requirement for all Our applications and games. You may at any time opt-out from sharing your location by turning it off in the settings of your device.
2.1.6. Technical and usage information.
We also collect certain technical and usage information such as your application data (including interaction with in-app facial mapping tools used for facial manipulation features and with other Users inside the application via server log files and your user ID), access, session times and in-app purchases, device type, browser, and operating system you are using, your Internet service provider and/or mobile carrier, unique device ID (persistent/non-persistent), device hardware type, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for interest based advertising as described elsewhere in this Policy.See “Cookies and Other Technical Information” section for more information on how we may use these technologies to collect this data.
2.1.7. Customer enquiries.
Where you contact Us through one of our customer helpdesks or customer support centers, We may collect and process contents (including data) of your correspondence with Us and/or your contact details.
2.1.8. Tracking Technologies.
We and Our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify User’s computer/device and to “remember” things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal data, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable all cookies apart from the cookies necessary for the functioning of the site and/or an app.
3. HOW WE USE THE INFORMATION
3.1. We use collected information and/or data (including personal data) for the following purposes.
3.1.1. Providing and marketing products and services.
We use the information and/or data that we collect about you in order to analyze your use of our products, applications, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalize, protect, and improve your experience and our offerings.For example, we use information and/or data that we collect from you to enable you to:
(i) watch trailers and video clips;
(ii) get entertainment news and updates;
(iii) get information about our products, services, and content;
(iv) locate and access personalized information, ads or functionality based on your interests and location (e.g., find stores, theaters, or show times);
(v) play games;
(vi) engage with interactive features, activities, and Social Media Sites;
(vii) read and post comments, content, and reviews, or enter promotions, contests, and sweepstakes.
In addition to this, we use this information and/or data for us and our affiliates, business partners, and third parties to target, offer, market, or advertise products, programs, or services.
Legal basis:
• Fulfilling contractual obligations;
• Legal obligations;
• Your consent (where required);
• Our legitimate interests:
– improving and developing new products and services;
– being more efficient;
– preventing fraud;
– retaining your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which We believe you will also be interested in.
3.1.2. Communicating with you.
We use information and/or data that we collect about you to communicate with you, in order to:
(i) notify you when you win one of our contests or sweepstakes, or when We make changes to our policies or terms of use;
(ii) respond to your inquiries;
(iii) communicate with you about your purchases or transactions;
(iv) contact you about your account; or
(v) send you information about promotions, offerings, and Our features. You can also choose to receive push notifications from Us on your mobile device.
Legal basis:
• Fulfilling contractual obligations;
• Legal obligations;
• Your consent (where required);
• Our legitimate interests:
– Communicating important information;
– Improving and developing actual and prospective products and services;
– Compiling statistics.
3.1.3. Third party social networks.
We use information and/or data that we collect about you when you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social network.
Legal basis:
• Your consent (where required);
• Our legitimate interests:
– Defining types of customers for new products or services;
– Developing a profile on you and your interactions with Us so that we can provide tailored offers, opportunities and services that may be of interest to you.
3.1.4. Use of technical and usage information.
We use technical and usage information to improve Our design, functionality and content and to enable Us to personalize your experience with Our content and offerings. We use this Information in order to:
(i) provide, develop, maintain, personalize, protect, and improve our products, applications, services and video games, and to operate our business,
(ii) perform analytics, including to analyze and report on usage and performance,
(iii) protect against, identify, and prevent fraud and other unlawful activity,
(iv) create aggregate data about groups or categories of Our Users.
3.1.5. Compliance.
We use information and/or data that we collect about our Users to detect, investigate, and prevent activities that violate Our terms of use, could be fraudulent, violating copyright or otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our Users and third parties.Legal basis:
• Legal obligations
• Our legitimate interests:
– Protecting our business interests and rights, privacy, safety and property, or that of the public;
– Sharing your data with third parties in order to permit us to pursue available remedies or limit damage that We may sustain.
4. INFORMATION SHARING AND DISCLOSURE
4.1. We share and disclose information and/or data (including personal data) for the following purposes:
4.1.1. Law enforcement bodies and courts.We disclose information and/or data when provided by law, for example in response to a court order or a subpoena, or in response to a law enforcement body’s request. We also disclose information and/or data to third parties:
(i) in connection with fraud prevention activities;
(ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities;
(iii) in situations that can involve violations of Our terms of use or other applicable rules and policies;
(iv) to protect Our rights and the rights and safety of third parties; and
(v) as otherwise required by law.
4.1.2. Change of control.
We will transfer information and/or data regarding our Users in the event of a business transaction, such as if We or one of Our business units or Our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.
4.1.3. Service providers.
Our agents and contractors have access to information and/or data regarding our Users in order to carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, marketing, processing of payments, email and order fulfillment, administration of contests, research and analytics, and customer service.
4.1.4. Advertising networks.
We share certain information and/or data regarding our Users with third parties to provide advertising to you based on your interests. For more information, please see “Cookies and Other Technical Information” and “Ad Choices” sections below.
5. YOUR CHOICES
5.1. Marketing communications and sharing with third parties.
We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from Us, and Our sharing of information and/or data relating to you with Our trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at info@filtroo.co.
5.2. Ad Choices.
We work with reputable third parties to present advertisements, and engage in data collection, reporting, ad delivery and response measurement, and website analytics on our websites and applications and on third party websites and applications. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from your device(s) and browser(s) in order to help serve advertising that will be more relevant to your interests on and off our sites and across your device(s) and browser(s). This type of advertising is known as interest-based advertising. For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please contact info@filtroo.co.You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
5.3. Precise location information.
To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.
6. COOKIES AND OTHER TECHNICAL INFORMATION
6.1. Cookies and other technologies.
6.1.1. We, and Our affiliates, third party service providers, and trusted partners send “cookies” to your device and use similar technologies in order to analyze and enhance your user experience with Us, as well as for advertising purposes and social features.
6.1.2. Cookies are small text files placed in your browser. We may also use pixels or “web beacons” that monitor your use of Our websites. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.
6.1.3. We may also integrate “Software Development Kits” (“SDKs”), java script or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with Our app.
6.1.4. Our websites may use locally stored objects (“LSOs”) to provide certain content, such as video on demand, video clips, or animation, and better user experience.
6.2. We can use cookies and other technologies to help recognize your browser or device, maintain your preferences, provide certain features, and collect information and/or data about your online interactions with Us, and you communication(s) with Us. For example, when corresponding with you via HTML capable email, web beacons and other technologies let Us know about your activity, including whether you received and opened our email, clicked through a link, or otherwise interacted with Our content, and this information can be associated with Information previously collected.
6.3. We also use cookies and other technologies:
(i) to provide, develop, maintain, personalize, protect, and improve Our websites, products, apps, services and video games, and to operate Our business;
(ii) to perform analytics, including to analyze and report on usage and performance of Our content and marketing materials;
(iii) to protect against, identify, and prevent fraud and other unlawful activity;
(iv) to create aggregate data about groups or categories of our users;
(v) to synchronize users across devices, affiliates, and trusted partners; and
(vi) for Us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps, services or video games. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through Us.
6.4. We use following types of cookies and similar technologies:
6.4.1. Strictly necessary cookies or similar technologies.
They are essential in order to enable you to move around Our websites and apps and use their features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
6.4.2. Performance cookies or similar technologies.
They collect information about how you use Our websites and apps, so that We can analyze traffic and understand Users’ interactions. We may use third party service providers such as Google Analytics, who may use their own cookies or similar technologies, for this purpose.
6.4.3. Functionality cookies or similar technologies.
They allow Our websites and apps to remember choices that you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog.
6.4.4. Social media cookies or similar technologies.
They are used when you share information using a social media sharing button or “like” button on Our websites or apps, or when you link your account or engage with Our content on or through a social media site such as Facebook, Twitter or Google+. The corresponding social network will record that you have done this. This information may be linked to targeting/advertising activities.
6.4.5. Advertising cookies or similar technologies.
Some of Our websites or apps may use a third party advertising networks to deliver targeted advertising. They may also have the capability to track your browsing across websites, apps and Social Media Sites.
7. DATA RETENTION
7.1. We will only retain your personal data for as long as is necessary for the purposes described in this Policy. This means that the retention periods will vary according to the reason of collection. Generally, your service-related personal data will be kept for as long as you remain Our User. Yet, some personal data relating to the provision of services to you will be kept for a longer period, as long as necessary to comply with various finance- and tax-related legal obligations. After a retention period has elapsed, the personal data is securely deleted.
8. HOW YOU CAN EXERCISE RIGHTS IN RELATION TO YOUR DATA
8.1. Under certain conditions, you have the right to ask Us for a copy of your personal data, as well as to correct it, delete it or restrict its processing, and to obtain the personal data that you provided to Us in a structured, machine-readable format. You have the right to object to the processing of personal data on the basis of Our legitimate interests.Where We have asked for your consent to process your personal data, you have the right to withdraw this consent at any time.
8.2. To exercise any of the above rights, please contact Us at info@filtroo.co.
8.3. In addition to the above rights, as a resident of EU/EEA you also have a right to lodge a complaint to your local supervisory authority.
8.4. In cases permitted by law We reserve the right not to allow access to your personal data or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal data even if you withdraw your consent.
10. HOW TO CONTACT US
10.1.
Filtroo Oü
Harju maakond
Tallin 11415 Lasnamäe linnaosa Lootsa tn 5
Tallin ESTONIA NRT.EE102381229
Email: info@filtroo.co
10.2. If you have any questions about this Privacy Policy you can contact us at: info@filtroo.co
