Privacy Policy

Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.


This Privacy Policy (the “Policy”) serves to explain what information Smart Utils Dev Team and their affiliates and subsidiaries (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.


1. What Information Do We Collect?


i. Device Information


We integrated Facebook Analytics sdk, it collects users' installed applications information and transmits to Facebook server when app is in use. It is also used to support advertising.


We collect your device and network connection information in order to provide you with a better experience when you use our app. 


This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:


SDK/API/JS code version, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent deice identifier, the terminal manufacturer, the terminal device operating system version, the location of the language, the time zone and the network state (Wi-Fi and so on), the CPU, and the battery use, Screen resolution, Memory usage, Storage usage, sim operator, sim card country, Application release status in google play, Ad loading strategy, Ad platform and advertising placement id, anonymous web browsing behavior, hidden app(Anonymous), Download error information (url and error log).


We store the information collected through the Android ID tied to the device you are using. In this way, we can retain your advertising behavior while you are using the app. We will treat this information as personal information.


ii. Data about your use of the Services



We collect the app package names used by users in the app lock function, in order to analyze how to improve the experience of locking the app process.

We collect the URLs of user's failed download when app is in use or not, in order to analyze the reason for the download failure.

We collect the app package name that the user is currently using when an in-app file is deleted by other software, in order to analyze how to better protect the user's files.

We collect the app package names which are hidden by the user in Hide Apps function, in order to analyze how to improve the experience of hiding app processes.


We collect the app package names that installed by the user from in-app recommend content, in order to improve the quality of personalized recommendations and the user experience.

We collect the web domain names visited by browser users, so as to analyze how to better meet the needs of browser users.

We collect the file path and file name information when an error occurs in the file operation , so as to analyze the reason for the file operation failure.


These data only be passed to the certified third-party statistical platform: Firebase, Facebook Analytics and our self-built data statistics system (ECS). 


The above information is only used to improve the product experience and will not be sold to any third parties. We will not use this information for purposes other than improving the product experience and ad performance. 


iii. Monetization and Analytical Information from Other Sources


Third-party SDKs integrated in our app may access your information, including:



The information collected by third-party SDKs is governed by the providers of these SDKs and we have no control over such third parties. The third-parties include monetization partners, such as Google AdMob, Facebook AudienceNetwork, MoPub, Smaato, PubNative, IronSource, ChartBoost, Pixalate, Mintegral etc., and also analytical tools partners, such as Firebase, Facebook Analytics and our self-built data statistics system (ECS) . 


iv. Android Advertising ID


We use your Android advertising identifier in order to provide you with customized advertisement experience. It is used exclusively for advertising and analytics. Please note that the advertising identifier does not contain any user sensitive information that can be used to identify you as a user or your device. It is not connected to personally-identifiable information or associated with any persistent device identifier (for example: SSAID, MAC address, IMEI, etc.). 


v. Other Information


We may collect information that you directly and voluntarily provide to us. The information includes but is not limited to: your email address, the content of feedback, your location(for analyzing location accuracy) and the content of questionnaire answered by you. When you forget your password and send us an email to request a temporary password, we will collect your device id, send time, a random code, which is only used to generate a unique and temporary password.


vi. Designated Countries


For all information listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.


vii.    Account Information


When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number and a photo, if you choose to have a photo associated with your account. 




2. How Do We Use the Information?


i. To improve and optimize the Services


To provide better Services to you, we have a legitimate interest to collect and process necessary data to:


ii. To provide the Services


To provider the Services, we process data necessary to:


iii. To carry out activities related to advertisements and marketing


To send you personalized advertising and marketing materials, we may use the information collected from you such as 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 forth.


We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.


Hence, we have a legitimate interest to process necessary data to:


Track the content you access in connection with the Services and your online behavior


Deliver, target and improve our advertising and marketing materials


Pass the information collected from you to third party advertising and marketing partners


By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.


We encourage you to review the privacy policies of our third party 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. 


iv. To secure the Services


Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.


In order to keep the Service safe, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to


Analyze and monitor use of the Services


Prevent cheating, crime or fraud


Take action against fraudulent or misbehaving users 


Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions answers, comments, submissions that you post in the forum will be publicly available.


v. Designated Countries


For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.


3. What Information Do We Share?


As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.


4. What Are the Important Permissions We Request?


Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we ask are listed below:



For the permission of Nearby Wi-Fi devices, when we target Android 13 or higher and use Wi-Fi APIs, we request this permission to enable "File Transfer" feature when user using this feature to transfer files to others. We strongly assert that our app never derives physical location information from Wi-Fi APIs. To do so, we have set the android:usesPermissionFlags attribute to neverForLocation. 


5. Legal Basis of Your Personal Data


We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).


In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our app.


6. Your Rights


Individual rights for users live in the European Economic Area, United Kingdom, and Switzerland, we provide you with the rights described below when you use our Services. Please contact us at smartutilsteam@gmail.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:


Where denial of access is required or authorized by law;


When granting access would have a negative impact on other's privacy;


To protect our rights and properties; and


Where the request is frivolous or burdensome.


i. Right to withdraw consent


If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.


ii. Right of access and rectification


If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.


iii. Right to erasure (the “Right to be Forgotten”)


You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.


iv. Right to restriction


You have the right to restrict our processing your personal information where one of the following applies:


You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;


The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;


We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or


You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.


We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.


v. Right to object to processing


You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.


vi. Right to data portability


If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.


vii. Notification to third-parties


If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.


viii. Automated individual decision-making, including profiling


You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.


ix. Right to lodge a complaint


If you believe we have infringed or violated your privacy rights, please contact us at smartutilsteam@gmail.com so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

Mintegral


7. Third-party Partners’ Privacy Policy


Here we list the links to the third-party partners’ privacy policy. Please note that these policies are governed by the third parties and we have no control over them.


i. Google AdMob & Firebase


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


ii. How Google uses information from sites or apps that use Google’s services


https://policies.google.com/technologies/partner-sites


iii. Facebook Audience Network & Facebook Analytics


https://www.facebook.com/about/privacy


iv. MoPub


https://www.mopub.com/en/legal/privacy


v. Smaato


https://www.smaato.com/privacy/


vi. PubNative


https://pubnative.net/privacy-policy/


vii. ironSource


https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/


viii. ChartBoost


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


ix. Pixalate


https://www.pixalate.com/privacypolicy/


x. Inmobi


https://www.inmobi.com/privacy-policy/


xi. Pangle


https://www.pangleglobal.com/privacy/enduser-en


xii. Pubmatic


https://pubmatic.com/legal/privacy-policy/


xiii. Unity


https://unity.com/legal/privacy-policy


xiv. Taboola


https://www.taboola.com/policies/privacy-policy 


xv.  Mintegral

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


8. Children’s Privacy


These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.


9. Special Information for California Residents


For California Residents, We provide <Privacy Policy for California Residents> separately which addresses how we respect California's users' privacy. 


10. Changes to the Policy


Any information that is collected is subject to the Policy in effect at the time such information is c·n made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.


11. Contact Us


If you have any questions or concerns about the Policy, you may contact us at email: smartutilsteam@gmail.com