I. INTRODUCTION.

Elsa Kaspersen (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or our software application for mobile devices.

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy policy applies to all users, and others who access the App (“Users”).

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

II. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Information that you submit 

We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the App and perform the requested services. 

Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request.

Information That Is Processed Automatically 

When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data we may not be able to provide you with all the features of the App.

Device Details. When you use a mobile device (tablet / phone / smartwatch) to access our App, some of details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

What data can be processed:

Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.

In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Payment Information 

Our e-commerce provider (Apple) is responsible for billing, processing and charging for the in-app purchases, handles your personal information and keeps it absolutely safe and secure. We cannot access or use you credit or debit card information. You may access the applicable “in-app” purchase rules and policies directly from the app stores.

III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

To make our service available. We use the information that you submit and information that is processed automatically to provide you with all requested services.

To improve, test and monitor the effectiveness of our App. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.

To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account. 

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

V. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

Data Access and Portability. You can request copies of your personal information.

Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct change, update or rectify your data.

Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.

Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through contact form. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

VI. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through email or contact form displayed below.

VII. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

VIII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us at NannaLindegaard41995@icloud.com.