ChipoCreated Privacy

PRIVACY POLICY

PRIVACY POLICY

Effective date: March 4, 2019

Chipo Created(also referred to as “Company”, “we”, “us”, or “our”) attaches great importance to protecting your privacy. This Privacy Policy (the “Policy”) describes how we collect, store, use and disclose your information that could identify an individual (“Personal Data”), and what choices you (“you”, “your”) have with respect to the information when you use our mobile applications, our services, our sites. Any mobile applications that hyperlink to this Policy and are available for download in the Google Play Store or any other third-party app store, or are pre-installed on third-party devices (the “Application” or “Applications”), the related services we provide (“Services”) or any other websites (“Sites”), pages, features, or content owned or operated by Chipo Created.

This Policy does not cover any collection, use or disclosure by third-parties through any Applications, Sites, or Services that we do not control or own, such as Facebook or any third-party features or services made available via an Application, the Services or the Sites.

The protection of your personal data is very important to us, and we understand our responsibilities to handle your personal data with care, to keep it secure and to comply with legal requirements. Please read this policy carefully. this policy is not intended to override the terms of any contract that you have with us or any rights you might have available under applicable data protection laws.

We may make changes to this Policy from time to time for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business. We encourage you to regularly check and review this policy so that you will always know what information we collect, how we use it, and who we share it with.

Updates in this version of the Policy reflect changes in data protection law. In addition, we have worked to make the Policy clearer and more understandable by:

· Organizing it into the sections listed in the Table Of Contents below.

· Providing a series of examples that help illustrate how to policies may be implemented by Chipo Created.

· Defining and capitalizing a few terms that are used more than once for simplicity and brevity.

1. Applicability Of This Privacy Policy

This Policy applies to all Chipo Created’s apps. If you do not agree with the terms, do not download & install & use Chipo Created’s apps or any other aspect of Chipo Created

If you have any questions and privacy practices, please contact us at our mailing address in app store.

2. Permissions On Your Device

Permission

Relate functions

Purpose of Permission

Device status & User identity permission

Major feature

Analyze product data & improve User Experience

Camera

Major feature

Allows you to take photos and edit them

Storage

Major feature

Access the gallery, edit and then save them

You can check if such permissions are allowed or not for our product and service, which can be done by checking “Settings – Apps” and / or “Settings – Permissions” in your device, and thereby decide whether each permission will continue to be allowed or will be denied. The specific way to review the status of such permissions and deny them may vary in different devices, and please refer to the notes or instructions provided by relevant device OEMs and OS developers. In case that you’re unable to carry out relevant steps and adjust the settings in your currently-used product or device, please contact us or the OEM of you device.

Please note that allowing these permissions will be deemed as your consent to allow us collect and use relevant information to realize relevant functions; when you deny or disable the permissions in whole or in part, it means you have refused to provide related information to us, therefore also making us unable to provide you those functions relevant to such permissions. To the extent allowed by applicable laws, your decision to deny a certain permission on your device does not affect or invalidate our previous handling of your relevant information which has been based on your prior consent to allow such permission.

3. WHO is responsible for looking after your personal data?

You should be aware that although Chipo Createdmay be principally responsible for looking after your personal data, information may be held in databases which can be only accessed by Chipo Created. The personal data collected will be processed fairly and lawfully inside or outside the European Union but only in accordance with the provisions of the GDPR. (Read more about GDPR)

4. WHAT information do we collect?

We collect two basic types of information: Personal Information & Non-Personally Identifiable Information. Other Service Providers who might have access to your personal data in order to provide services on our behalf will be contractually obliged to keep such data in confidence, implement adequate data security measures, and may not use that personal information for any other purpose.

We will retain your personal information for a reasonable period or as long as the law requires and we commit that we do not sell your information.

4.1. Personal Information

Personal Information is information that identifies you or another person, which may be transmitted or received when you use an Application, the Services and/or the Site. Personal Information includes your geographic area information, email addresses, unique device identifier (Android ID, IMEI,...), billing or shipping information (for Google Play In-app Purchase), information stored within your device and other information you transmit or receive using an Application, the Service and/ or the Site which identifies you or another person.

When submitting a complaint or suggestion, the user needs to provide email address or other contact information. For example, we maybe collect your name, email address, username, social network information and other information you provide us when you register, set up an account, contact us by e-mail or use our services.

We collect information about the product and services that you use and how you use them in order to properly provide the core or important features of our product and service, or to improve our product and service, or to provide additional features to our product (such as socializing functions or value-added services and promotions, etc.). Some of the typical reasons that we collect personal data include:

- Provide our product and services, including our app and related website (if any), and improve them over time;

- Allow you to download and purchase products and services;

- Personalize and manage our relationship with you, including introducing you to products or services that may be of interest to you or to provide customer support;

- Investigate, respond to, and manage inquiries or events;

- Work with and respond to law enforcement and regulators;

- Research matters relating to our prod and business, such as security threats and vulnerabilities, or conducting internal audit, data analysis, and research.

If you do not provide some of the information mentioned below, you may not be able to continue using the product and / or services that we provide, and if you do not agree that the information to be collected after your installation or use of the product, you may stop using or uninstall our product and / or services, or contact with us for advice; for the other types of information, your refusal to provide or opt-out option may cause you unable to access certain specific features or get the best experience.

4.2. Non-Personally Identifiable Information

Non-personally identifiable Information means information from which an individual cannot directly be identified. Additionally, non-personal data means "aggregate" and "de-personalized" information.

We may use tools or third party analytical software to automatically collect non-personal identifiable information about users whenever they interact with our apps. Non-personal identification information may include the type of your phone and technical information about users means of connection to our apps, such as the versions of phone model and other similar information.

Log Data: When you interact with us using the Application, our systems may automatically collect your unique User Device number, the IP address, or operating system you use, and the dates and times of your use ("Log Data").

Aggregate Information: "Aggregate Information" is data we collect about a group or category of services or Users from which individual User identities have been removed. In other words, information on how you use the Application may be collected and combined with information about how others use the Application, but no personally identifiable information will be included in the resulting Aggregate Information. Aggregate Information helps us understand trends in our Users' needs so that we can better consider new features or otherwise tailor of the Application.

5. HOW we use personal information?

5.1. We will use your personal information:

· To keep you posted on software updates, technical updates, security alerts and support and administrative messages;

· Research matters relating to our prod and business, such as security threats and vulnerabilities, or conducting internal audit, data analysis, and research.

· To allow you to download and purchase our products and services such as our apps and related websites;

· To help us analyze, create, provide, develop, operate, deliver, maintain and improve our products, services, content, advertising and continually improve your user experience;

· To assess customer satisfaction and link or combine with information we get from others to help understand your needs and provide you with better user experience;

· To process transactions and send you related information, including confirmations and invoices;

· To respond to your comments, inquiries, questions, provide customer service and support and fulfill your requests;

· To verify identity, assist with identification of users, and to determine appropriate services;

· To communicate with you and send you important notices or personalized messages, such as communications about purchases and changes to our terms, conditions, and policies;

· To monitor, evaluate and analyze trends, data, transactions, usage and activities in connection with our products and services;

· To facilitate internal purposes such as big data analysis, and research to improve our products, services, and customer communications;

· To detect, investigate and prevent fraudulent transactions and other illegal activities and protect our rights and property;

· To use your personal data for purposes associated with our legal and regulatory obligations.

In order for us to provide you with our services when you use certain applications, we may collect special categories of data from you. For our collection or use of your special categories of data, we will establish an additional lawful ground to those set out above which will allow us to use that information. This additional exemption will typically be:

· your explicit consent;

· the establishment, exercise or defense by us or third parties of legal claims; or

· a specific exemption provided under local laws of EU Member States and other countries implementing the GDPR, or other laws of jurisdictions which are applicable to our handling of your personal data.

PLEASE NOTE: If we have previously advised that we are relying on consent as the basis of our processing activities, going forward we will not be relying on that legal basis except where this has been explicitly set out to you. For the types information you’ve consented to provide us while using our product or service, you’re deemed to have granted us authorization to continuously use such information throughout the period you use our product or service- unless you have deleted such information (either by yourself or by informing us, pursuant to this Privacy Policy) or, by effective settings or notice, refused our continued usage of the information. When you cancel your user account and / or completely uninstall our product (or stop using our service), we will, pursuant to applicable laws and according to this Policy, stop using and / or delete such information of you.

5.2. We will use your non-personally identifiable information for any purpose as below:

· To personalize user experience: understand Demographics, Customer interest, and other trends among our users.

· To help develop our service: provide, maintain, improve the Applications, Services and the Site.

· To grow-up our business: we may use your non-personally identifiable information for our promotion and marketing purposes.

6. HOW your information maybe disclosed?

6.1. Personal Information

Personal information (and non-personal information) collected through the Services may be shared with companies and organizations that perform services on our behalf (for example, companies that provide data management or other support services to us such as data storage and Web hosting services). We may share your personal information (and non-personal information) with third parties to serve you relevant advertising and market our products, but we won't sell your personal information.

Also, we may disclose the personal information we collect through the Services when we, in good faith, believe disclosure is appropriate to:

· comply with applicable law (e.g., in response to a valid court order or subpoena);

· prevent or investigate a possible crime, such as fraud or identity theft;

· enforce or to apply our Terms of Service and other agreements;

· to protect the rights, property or safety of us, our users or others; or

· to protect your vital interests.

We do not disclose your images, which you have uploaded for editing and manipulation to any of the Services unless you provide explicit consent to show your images at our Site, Mobile and other Services, or at third party services.

Your personal information and other data collected by us may be transferred to another company that has acquired our stock or assets, for example, as a result of a sale, merger, reorganization, dissolution or liquidation. If such a transfer occurs, the acquiring company's use of your personal information will still be subject to this Privacy Policy.

6.2. Non-Personal Information

We may disclose Non-Personal Information to our trusted partners who shall comply with this privacy policy and the relevant privacy laws. We do not combine Non-Personal Information with Personal Information (such as combining your name with your unique User Device number).

7. HOW we PROTECT your personal data?

We endeavor to protect us and you from unauthorized access to or unauthorized alteration, disclosure or destruction of personal data that we hold.

In particular:

· We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems;

· We use encryption where appropriate;

· We use password protection where appropriate; and

· We restrict access to personal data to our employees, contractors and agents who need access to the relevant personal data in order to for them to process it for us and who are subject to strict contractual confidentiality obligations.

You are responsible for the personal data that you choose to share, disclose or submit voluntarily while using our website or devices and which can be viewed by members of third party applications or sites such as chat applications or messengers.

When you utilize third-party social media services, email, text messages etc. which you accessed via using our product, and to interact with other users or service providers and exchange personal contact, geographic location or track of traveling etc., please note that we cannot verify if such third-party services have made such information transmission to be fully encrypted. Please take care to protect the security of your personal data, and especially avoid sharing sensitive personal data when you’re uncertain about the security of data transfer.

Please understand that due to the rapid development of computer and internet technologies, various measures of attack may exist or be created, whether vicious or not, which renders no applications or internet transmission to be 100% secure. While we continuously take reasonable technical, administrative, and physical measures to protect the information you provided, we still may not be able to guarantee absolute security of your information at all times. Where the relevant information and data collected is stored on your device, security is also dependent on your device’s own secure storage functionality. You should also take care to protect the secrecy of your account username and password and to protect the information stored on your device.

8. WHAT are your rights?

You have a number of rights in relation to your personal data. In summary, you may request access to your data, rectification of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any automated decision making and profiling or the basis for international transfers. You also have the right to complain to your supervisory authority.

Access

You can ask us to:

· confirm whether we are processing your personal data;

· give you a copy of that data;

· provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out automated decision making or profiling, to the extent that information has not already been provided to you in this Policy.

Rectification

You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it.

Erasure

You can ask us to erase your personal data, but only where:

· it is no longer needed for the purposes for which it was collected; or

· you have withdrawn your consent (where the data processing was based on consent); or

· following a successful right to object (see “objection” below); or

· it has been processed unlawfully; or

· to comply with a legal obligation which we are subject to.

We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances where we would deny that request.

Restriction

You can ask us to restrict (i.e. keep but not use) your personal data, but only where:

· its accuracy is contested (see “rectification” below), to allow us to verify its accuracy; or

· the processing is unlawful, but you do not want it erased; or

· it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

· you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:

· we have your consent; or

· to establish, exercise or defend legal claims; or

· to protect the rights of another natural or legal person.

9. HOW we handle information of children?

9.1. Notwithstanding different definition of “children” in the laws and customs in your place of residence, we regard all persons under 14 year of age as children. In case that you or your child is 14 years or older in age, but still considered as children under applicable laws in your place of residence, the terms below shall still apply.

9.2. Except as otherwise stated, our product, website and service are primarily directed to adults. Children shall not create their own user accounts except with relevant consent from their parent(s) or other lawful guardian(s); without guidance and consent from their guardian(s), children shall not independently confirm and accept this Privacy Policy and use our product or service.

9.3. We’ll comply with local laws regarding children’s right protection applicable to our product and service (such as Children’s Online Privacy Protection Act of the USA).

9.4. We do not knowingly collect information from children in the absence of consent of their lawful guardians. If you believe we have collected information from any child in error or have questions or concerns about our any other practices relating to children, please notify us and we will take proper actions to investigate and promptly solve relevant issues In case we find out that we’ve collected children’s information without prior consents from their lawful guardians, we’ll make efforts to quickly delete relevant data.

10. Direct Marketing

We may use your personal data to send you direct marketing communications about our own or third party products and services or our related services including our latest product announcements and upcoming events. This may be in the form of email, post, SMS, telephone or targeted online advertisements. We limit direct marketing to a reasonable and proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.

For the purposes of GDPR our processing of your personal data for direct marketing purposes is based on our legitimate interests (as further detailed in applicable Appendix), but where opt-in consent is required by the relevant laws such as the Privacy and Electronic Communications Regulations of Europe, we may ask you for your consent. You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out or unsubscribe links in electronic communications (such as emails), or by contacting us if you find problems in making such settings by yourself. Please also note that, when necessary (e.g., certain service is suspended due to system maintenance), we may send to you relevant announcements. You may not be able to cancel the announcements related to the services that are not promotional in nature.

We also use your personal data for customizing or personalizing ads, offers and content made available to you based on your usage of our mobile applications, websites, platforms or services, and analyzing the performance of those ads, offers and content, as well as your interaction with them. We may also recommend content to you based on information we have collected about you and your viewing habits.

11. Third-Party Products and Integrations

The General Data Protection Regulation (GDPR), which goes into effect on 25 May 2018, creates consistent data protection rules across Europe. It applies to all companies that process personal data about individuals in the EU, regardless of where the company is based. Processing is defined broadly and refers to anything related to personal data, including how a company handles and manages data, such as collecting, storing, using and destroying data.

In general, the Applications, the Services and the Site access third party information (such as your Facebook, Google account information) through application interfaces. We may provide links to third-party websites, such as Facebook, Google as a service to our users. The Site may also carry advertisements from other companies. When you click on links of third parties in an Application, the Services, you may leave the Application, the Services.

We do not collect your information through the third party. Although they are linked to us for accessible from our Application & Services, we are not responsible for the privacy practices of Websites operated by third parties. Therefore, this Policy does not address and we are not responsible for any problem caused by them.

The information that you transfer and share through the Application may be intercepted, collected, used and disclosed by third parties. We are not responsible for any interception, collection, use and disclosure of your information by any third party. Please choose other ways to transfer and share if you have higher security requirements.

We work closely with third-party service providers and may receive information about you from them. These services providers collect usage data in compliance with their privacy policies. These service providers are described below:

+ About how Google manages data in ads products: https://www.google.com/policies/technologies/partner-sites/ and

+ About Google comply with Europe’s new General Data Protection Regulation (GDPR): https://support.google.com/admob/answer/7666366

+ Firebase Analytics: our Android application uses Firebase Analytics service. Firebase’s privacy policy is available at

https://firebase.google.com/terms/analytics

Firebase Analytics is a mobile analytics services also provided by Google and governed by the Firebase Analytics terms of service. This service helps us understand our users and how they use our apps including information about interactions with the user's mobile applications. Firebase Analytics uses identifiers for advertising on mobile applications (for example, Android Advertising ID and Advertising Identifier for iOS), and they will collect the AAID and AIiOS to understand our users, but users who wish to opt-out of the AAID and AIiOS advertisement tracking can do so through device advertising settings for mobile apps and Users who wish to avoid tracking by Firebase Analytics can opt-out in application settings. Data collected will be transmitted to and stored by Google on servers globally.

+ Google Analytics: for information regarding how Google uses data please visit "How Google uses data when you use our partners' sites or apps": http://www.google.com/intl/en/policies/privacy/partners/

Google Analytics is a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this, you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

+ Google AdMob: our Android application uses Google’s AdMob advertising service. AdMob’s privacy policy is available at https://www.google.com/intl/en/policies/privacy

12. Contact & Complaints

If you have any issue arising from this policy, including requests to exercise data subject rights, you can contact us at our mailing address in app store.

If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time. We do ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

APPENDIX I – COOKIE POLICY

1. We or our third party partners may collect and use your information via tracking technology such as Cookies, which information may be stored as log information.

2. We use such technologies to provide more tailored services and user experiences, and for purposes such as remembering your account identity or analyzing your account’s security; analyzing your usage of our product and service; advertisement optimization (helping us to provide you with more targeted advertisements instead of general advertisements based on your information). We may also process and summarize the non-personal data collected via tracking technology and provide the same to advertisers or other partners to be used to analyze how users use our services and for advertisement purpose.

3. There may be tracking technology placed by advertisers or other partners in our products and service. Such tracking technology may collect the non-person information related to you for the purpose of analyzing how users use the services and sending to you the advertisements you might find interest in, or evaluating the effects of the advertisements. Collection and use of such information via third party tracking technology will not be subject to our Privacy Policy, but will be subject to third-party privacy policies applicable to the users, and we will not be liable for the third-party Cookies or web beacon.

4. You may use browser and personal device settings to refuse or manage tracking technology. However, for technical reasons beyond our control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access to our website or applications from another browser or device, your cookie settings may be lost.

5. You shall be aware that when ceasing to use Cookie or other tracking technology, you may not be able to enjoy the best service experiences, or parts of our product or service may no longer function correctly (please contact us in case of any such problems). Furthermore, you mays still receive the same amount of commercial information such as advertisements which will have lower relevancy to you.