Last modified: 21 AUGUST 2023

Effective date: 28 DECEMBER 2021

This Privacy and Data Protection Policy (“Policy”) is effective as of the date set forth above. VAKU APPS LTD (“Company”, “VAKU APPS  LTD”, “We”, “Us”, “Our”), operating with Phone Wallpapers application (“App”) and website https://vaku.app/ (“Website”), is committed to honoring and encouraging the protection of your privacy as a user who uses the App (“you”, “your”, “User”). You may print a copy of this Policy for your records.

Information Collected through the Services

This page serves as a means to inform visitors about the policies regarding the collection, use, and disclosure of Personal Information when using our app's Services. In this Policy, the term 'personal information' refers to any data that can be used to identify or make an individual identifiable. When you interact with or utilize our Services, we may collect the personal information outlined below. By choosing to use our Services, you agree to the collection and use of information in accordance with this policy. The Personal Information we collect is used to provide and improve the Service. The information that we and/or our partners collect is listed below. Our Partners collect personal data related to your activity on the respective app store or distribution platform and within the App/Website by means they determine to be appropriate for that. Full list of our Partners you can find in a “Cross-border Transfer of Data” block.

1. Device information

To enhance your app experience, we collect device information. 

The specific data we collect depends on your interactions with us, your privacy settings, and the products you use. It may include:

• We may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model in order to analyze usage statistics of our app.

• Some of your personal data is collected by our Partners. Our Partners collect personal data related to your activity on the respective app store or distribution platform and within the App/Website by means they determine to be appropriate for that in order to provide us with analytical statistics, SDK for features such as Antivirus feature, etc., to provide you with customized advertisement experience. Full list of our Partners you can find in a “Cross-border Transfer of Data” block.

2. Data about your use of the Services 

• Data related to session activity;

• Number pages viewed and order of those pages 

• Cookies;

• Location data;

• Data regarding your device.

• Number of users and sessions;

• Session duration;

• Operating systems;

• Device models;

• Geography;

• First launches;

• App/Website opens;

• App/Website updates;

• In-app purchases.

• First open time timestamp

• App brand

• App model

• System language, etc.

3. Monetization and Analytical Information from Other Sources

Third-party SDKs integrated into our app may access certain information, including:

• Google Advertising ID

• Demographic data, such as your IP address

• Data to combat fraud, such as click fraud in advertising

• Data associated with your device, such as device type, technological information, and country

• Data for advertising, marketing, and analysis purposes

• The ability for advertisers to store or read cookies

Please note that the information collected by these third-party SDKs is governed by the providers of these SDKs, and we have no control over their practices. These third parties include monetization partners like Google AdMob, Facebook Audience Network, Applovin, Mintegral etc., as well as analytical tools partners like Firebase and Facebook Analytics, Yandex Metrica, etc. Links to the privacy policies of these platforms can be found in the "Cross-border Transfer of Data and Third-party Partner's Privacy Policy" section.

4. Android Advertising ID

We utilize your Android advertising identifier to deliver personalized advertising experiences. This identifier is used solely for advertising and analytics purposes. It does not contain any sensitive user information that can personally identify you or your device. Furthermore, it is not linked to personally-identifiable information or associated with any persistent device identifiers such as SSAID, MAC address, IMEI, and others.

5. Other Information

We may gather information that you provide to us directly and voluntarily. This can include, but is not limited to, your email address, feedback content, and responses to questionnaires.

How Do We Use the Information

Our Purposes

Our App is aimed at allowing you Wallpapers and Backgrounds with 3D and Life effect for your main or block screen of your devices, according to Our Terms of Use. Thus, We need your data to provide you with the respective services.

Likewise, We will use your personal data for the following purposes:

• to make the functionality of Our App available to you;

• to enhance the App;

• for marketing purposes, e.g. to determine the Users’ traffic regarding the App/Website, the Users’ locations and geography, the statistics of User’s actions within the App/Website.

Processing personal data for marketing purposes

Our Partners process your personal data and allow Us to process your personal data for marketing purposes on a basis of your consent. Our Partners warrants they have received your consent for receiving of marketing communications from us. Marketing communication may include the right of the Company to notify the User about the App updates, new services, marketing proposals and related notifications.

You are not under any obligation to provide our Partners with your personal data for marketing purposes. You can withdraw your consent to your personal data being processed for the purposes of marketing communications at any time by contacting Us at email address help@vaku.app or directly via the App.

If you do choose to withdraw your consent, this will not mean that Our processing of your personal data before you withdraw your consent was unlawful.

Our advertising and marketing Partners (Google Admob, Facebook Audience Network etc.) can collect or use your personal information (for ex. ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the Services and with other users, and so on) and  collect Your cookies to show you personalized  advertisements based on your interests. By accepting this PRIVACY AND DATA PROTECTION POLICY, you agree that our Partners may collect and use information about you to personalize advertising and marketing materials.

We encourage you to review the privacy policies of our advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.

Disclosure of Your Personal Data

We ensure We always include the controls and warranties embodied in this Policy to the contracts and agreements. We work under the respective contracts and agreements with our Partners and contractors whom We grant access to your personal data.

Your Age

Before using Our Services, you have to reach the age recommended/established under the Terms of Use and Privacy Policy of our partners. 

By using or accessing Our App/Website, We believe that such Data Subjects have reached the age recommended/established under the Terms of Use and Privacy Policy of our partners and have all rights to enter into an agreement with Us as to the receipt of Services and use of App, as well as process personal data under Data Subjects’ consent for the purposes We mention in this Policy.

If you know that our Partners process personal data of User of inappropriate age , please inform Us by sending email at help@vaku.app.

Retention of Personal Data

Our Partners and We store your personal data collected during your activity on the respective app store or distribution platform and within the App/Website.

We will process your personal data for as long as you will use the App/Website or for as long as needed to provide you with the Services. In case you will stop to use the App and delete the App from your device we will not process your personal data anymore, except when it is properly justified under Our business needs.

State authorities, enforcement agencies, courts

We may be legally obliged to disclose your personal data to the competent state authority, enforcement agency or a court in case We receive a mandatory request for such disclosure from them.

We may be proactive and address the competent authority in case We suspect a violation of law to be committed in association with your use of Our App/Website.

What Information Do We Share

As previously stated, we may share your personal information with our trusted third-party partners. This includes disclosing your personal information to our business partners, such as advertisers, publishers, and data tracking companies. These partners may utilize your personal information to display targeted advertisements, analyze your interactions with ads and websites, and gain insights into website and app usage or user behavior to enhance their services. It's important to note that the use of information by these partners is governed by their respective privacy policies, that are listed below.

Cross-border Transfer of Data and Third-party Partner's Privacy Policy

Our headquarters is in the Cyprus. We make every possible effort to protect entrusted data against unauthorized access, including two-factor authentication procedures, regular password changes, due diligence of privacy procedures and other appropriate and reliable measures provided by Our Partners.

Some data may be accessed and processed by the following companies:

Google LLC (Google Ads, Google Admob, Google Firebase)

Country: Ireland, USA

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://policies.google.com/privacy?hl=en 

Yandex LLC (Yandex Appmetrica)

Country: Russia

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://metrica.yandex.com/about/info/privacy-policy 

Adjust

Country: Germany

Purpose: Analysis of the Users' experience within the App and how Users use the Services and App

Policy link: https://www.adjust.com/terms/privacy-policy/

Unity Technologies

Country: USA

Purpose: Monetization partner

Policy link: https://unity3d.com/legal/privacy-policy 

Meta

Country: USA

Purpose: Monetization partner

Policy link: https://www.facebook.com/privacy/explanation 

AdinPlay BV

Country: The Netherlands

Purpose: Monetization partner 

Policy link: https://adinplay.com/privacy-and-cookies-policy/ 

AppLovin Inc.

Country: USA

Purpose: Monetization partner

Policy link: https://www.applovin.com/privacy/ 

Pollfish Inc.

Country: USA

Purpose: Monetization partner

Policy link: https://www.pollfish.com/terms/researcher 

Startapp

Country: USA 

Purpose: Monetization partner

Policy link: https://www.start.io/policy/

Inmoby

Country: India

Purpose: Monetization partner

Policy link: https://www.inmobi.com/website-privacy-policy

Ironsourse

Country: Israel

Purpose: Monetization partner

Policy link: https://www.is.com/privacy-policy/

Amazon ads

Country: USA

Purpose: Monetization partner

Policy link: https://advertising.amazon.com/legal/privacy-notice?ref_=a20m_us_fnav_l_prvcy

Chartboost

Country: USA

Purpose: Monetization partner

Policy link: https://answers.chartboost.com/en-us/articles/200780269

Mintegral

Country: Hong Kong

Purpose: Monetization partner

Policy link: https://www.mintegral.com/en/privacy

Verizon

Country: Monetization partner

Purpose: USA

Policy link: https://www.verizon.com/privacy/your-privacy-choices#/

Kidoz

Country: Israel

Purpose: Monetization partner

Policy link: https://kidoz.net/privacy-policies

Monetag

Country: Cyprus 

Purpose: Monetization partner

Policy link: https://monetag.com/privacy/

Adcolony

Country: USA

Purpose: Monetization partner

Policy link: https://www.adcolony.com/privacy-policy/

Csjplatform

Country: Beijing

Purpose: Monetization partner

Policy link: https://www.csjplatform.com/en/privacy

Hyprmx

Country: USA

Purpose: Monetization partner

Policy link: https://jungroup.com/pp/

Smaato

Country: USA

Purpose: Monetization partner

Policy link: https://www.smaato.com/cookie-policy/

Tapjoy

Country: USA

Purpose: Monetization partner

Policy link: https://www.is.com/privacy-policy/

Tencent

Country: Cayman

Purpose: Monetization partner 

Policy link: https://www.tencent.com/en-us/privacy-policy.html

Pangle

Country: Beijing

Purpose: Monetization partner

Policy link: https://www.pangleglobal.com/privacy/partner-en

Liftoff

Country: USA

Purpose: Monetization partner

Policy link: https://liftoff.io/privacy-policy/

Acp-edge.fyber

Country: USA

Purpose: Monetization partner

Policy link: Digital Turbine's Data Protection Addendum

Cleveradssolutions

Country: Cyprus

Purpose: Monetization partner

Policy link: https://cleveradssolutions.com/PrivacyPolicyCAS.html 

Appodeal

Country: USA

Purpose: Monetization partner

Policy link: https://appodeal.com/privacy-policy

Mopub

Country: USA

Purpose: Monetization partner

Policy link: https://www.applovin.com/privacy/

MobFox

Country: Austria

Purpose: Monetization partner

Policy link: https://www.mobfox.com/cookies-policy

We also may use support from the specialists skilled in performing tasks to enhance our Services as well as other independent contractors, e.g. IT specialists, accountants, auditors, lawyers, etc, provided that all adequate safeguards are put in place.

In order to secure the adequate level of protection, We implemented the Standard Contractual Clauses as well as signed Data Processing Agreements in the relationships with the engaged contractors, so they are bound to preserve at least the same level of personal data protection as it is granted by the law applicable to us.

Data Breaches

We take all reasonable steps to minimize the risk of the personal data breach while processing the personal data. The risk assessment We have to carry out has to determine whether the risk to the rights and freedoms of the Data Subjects affected is judged to be sufficiently high to justify notification to them.

In the case of a personal data breach, We will without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent authority, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the Data Subjects. Also, in the case of a personal data breach, which is likely to result in a high risk to the rights and freedoms of the Data Subjects, We will without undue delay notify the appropriate Data Subject the personal data of which were breached. If measures that have subsequently been taken to mitigate the high risk to the Data Subjects, so that it is no longer likely to happen, then communication with the Data Subject is not required.

We will document all personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. That documentation shall enable the competent authority to verify compliance with the GDPR if necessary.

Your Rights

There is a scope of rights you may enjoy as to personal data protection with regard to GDPR and CCPA.

The list of rights protected under GDPR is as follows:

• right of access (i.e. you may ask Us to send you a copy of the data about you that our Partners collected);

• right to rectification (i.e. you may ask Us to correct the outdated or false data, or complete the data which is missing or incomplete)

• right to erasure (i.e. you may ask us to delete the personal data Our partners retain, provided that you are allowed to do so);

• right to restriction of processing (if processing may be restricted)

• right to object to processing (if you have a right to object as to certain kinds of processing or in certain circumstances)

• right to data portability (i.e. you may ask Us to transfer a copy of your data to another organization or to you provided that the circumstances comply with the data protection law).

The list of rights protected under CCPA is as follows:

• the right to request that a business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of personal information the business has collected;

• the right to request that a business delete any personal information about the consumer which the business has collected from the consumer;

• the right to request that a business that sells the consumer’s personal information;

• the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information (“Right to opt-out”).

We pay your attention to the fact that depending on your request regarding the exercising any of your rights provided hereinabove you may need to contact our Partners to exercise such right. You are able to check the details of procedure of exercising any of your rights provided hereinabove at (full list of our Partners you can find in a “Cross-border Transfer of Data” block).

We do not charge any fees in relation to exercising your rights (unless We receive repetitive requests without a clear justification behind the need to request the information within such short periods of time; in this case, We may charge you a small fee to compensate the expenses that incur due to the repetitive and excessive character of requests). We typically do Our best to answer you as soon as possible or within the reasonable period taking into account the complexity of the request, but in case We are processing a large amount of requests the answer may took Us longer than you might expect.

You can send Us the request via email help@vaku.app or directly via the App. Please verify that your request comprises the details:

• your name;

• contact information;

• right you want to exercise, and, where applicable;

• your personal data in Our processing;

• reason/justification behind such request.

We may ask you to provide Us with some information We already have to verify that it is you or holder of parental responsibility on your behalf.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell your personal data or disclose your personal data for business purposes.

You might provide us with the affirmative authorization to sell your data (the “right to opt-in”). If you are between 13 and 16 years of age, you can provide such personally. If you are less than 13 years of age, such affirmative authorization has to be provided by your parent or guardian. If you opt-in to personal information sales you may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to Us by sending Us a message via email

hepl@vaku.app or directly via the App.

After you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by visiting Our App/Website and sending Us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Data Controller

VAKU APPS LTD ("VAKU APPS", "VAKU", "we", "us", or "our"), holds the privacy of your personal information in high regard and is devoted to safeguarding it. To provide you with the most effective and up-to-date security tools, we may need to gather your personal data. VAKU APPS LTD understands the importance of your trust and does not consider it automatically given. Therefore, in our Privacy Policy, we delineate what we do, how we do it, your choices, and how we may require your collaboration to ensure your safety.

By accepting this Privacy Policy and downloading or continuing to use the Services, you provide your consent for us and our partners to collect and use the information about you that is listed on this page.

The VAKU APPS LTD Privacy Policy applies to VAKU APPS LTD and, unless otherwise stated, its subsidiaries, including any contractors, representatives, agents, and resellers acting on our behalf (collectively referred to as "we," "us", or "our").

Questions, comments and complaints about the data practices related to the App can be submitted to the following email: help@vaku.app.

Complaint Lodgement

In case you are convinced We are somehow infringing your personal data rights granted by the GDPR, you may lodge a complaint with the supervisory authority. Our lead authority is:

Name: Office of the Commissioner for Personal Data Protection

Address: Iasonos 1, 1082 Nicosia, Cyprus

Telephone: +357 22818456

E-mail: http://commissionerdataprotection.gov.cy/. 

We kindly invite you to share your concerns with Us first regarding any issue related to processing of your personal data. You may use the following channels to address your inquiries:

Email address:  help@vaku.app

Updates to the Policy

In order to improve the quality of Services and to comply with legal requirements, the Company may may update or amend this Privacy Policy at our sole discretion and at any time without providing direct notice to you. It is your responsibility to review this Privacy Policy periodically for any updates or changes. By continuing to use our Service after any such amendments are made, you acknowledge and agree to such amendments and to be bound by the updated Privacy Policy. Please check the following URL for the latest version of our Terms of Use: https://sites.google.com/view/3dwallpaper-privacy-policy/home

Continued use of the app after any amendments to the Privacy Policy, and after we have provided you notice of the amended Privacy Policy, constitutes your acceptance of the new Privacy Policy. If you do not agree to the Privacy Policy, you may not access or use the Services and should therefore immediately cease any use of the Services.