Version 1.0 | Created: 2018-09-07
1. Your privacy is important to us
This is where we, ARROUND INC ("ARROUND", "us", "we", "our"), describe how we process the personal data that you provide to us when accessing or using our application ("App").
We care about privacy and have put in place technical and organizational measures to protect your personal data when accessing and using our App
What type of personal data do we process, and why do we do it?
Access and use of the App
In order to access and use our App you may need to create a user account or, alternatively, login through a Facebook account using Facebook Connect, via VK or via other social networks. In connection with creating a user account we collect your e-mail address. If you choose to login using your Facebook account, we collect the information that you allow Facebook through your privacy settings to disclose to us. This normally includes your Facebook username, name, e-mail address, gender, locale, currency, timezone, picture and your list of friends.
Data provided by the Users and minimally necessary for registration in the App: name, surname, gender, date of birth, mobile phone number and / or email address;
The collection of User’s personal data is carried out in the App during registration, as well as in the future when the user, on his own initiative, makes additional information about himself using the App's tools.
When using the App, we may collect further information that you provide to us and which relate to the use of the App as such, including your mobile device's geographic position at a specific time, virtual items associated with your user profile and other content that you upload using the App, e.g. photographs and text. Moreover, if you make an in-app purchase in the App, we will collect purchase, transaction and payment information relating to your in-app purchase. Additionally, we may process technical information regarding your mobile device, e.g. device ID, operating system, version of our App and similar.
We are using face tracking information (TrueDepth API) to attach some 3D content to the your face. We do not store any user or device data which we do not disclose or give any access to third parties.
To the extent that you have disclosed personal data of somebody else in connection with using the App, you are obligated to inform and, where necessary, obtain the individual's consent regarding our processing of the individual's personal data in accordance with this notice.
Communications with you
We may use your e-mail address in order to communicate with you regarding the App that your user profile is associated with, e.g. in order to inform you of updates and other changes to the App, new features and in-app events. The processing of your personal data for these purposes above is necessary in order to satisfy our legitimate interest of keeping in contact with you regarding the App that your profile is associated with.
Additionally, based on your consent, we may process your e-mail address to send direct marketing information to you relating to us and our our App. You have the right to at any time to oppose to our processing of your personal data for direct marketing purposes and de-register from future communications from us, please see contact details below.
We may also process the personal data that you provide to us in connection with accessing and using our App and in your interactions with us for statistical purposes. The processing of your personal data is based on our legitimate interest of aggregating statistics in order to understand how our App is being used and to develop and improve our App.
Development, testing and improvement of our App
We may, where necessary, use the personal data that you provide to us, e.g. user name, geographic position, photographs, social connections made in the App in order to develop, test and improve our App. We process your personal data in order to satisfy our legitimate interest of continuously improving our App.
3. How long do you keep my data for?
We retain your personal data for as long as necessary in order to provide you with the service, and for the minimum time required by law in the state where our servers may be located. Your personal data will thus, as a starting point, be stored until you decide to delete your user account. However, if you have not logged into the App during a period of 12 months, we will send you an e-mail to the e-mail address that you have registered requesting that you confirm whether you wish to continue to access and use the App. If you do not respond to this request within 3 months thereafter your user account and profile associated with the App will be deleted, meaning that it will no longer be possible to log into App using your user account.
Any content, which does not include your personal data, that you have uploaded to or created in the App will be stored until further notice, unless you request that we delete the content. Your personal data may be retained for such additional period that is necessary if we are required by law to retain the information, or in order to establish, defend or exercise legal claims. When your personal data is no longer necessary for these purposes, we will securely delete the data.
4. TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EU/EEA
We use private, secure servers located in Russia and follow the same secure processes that offer a high level of protection for personal data that exist in the EU/EEA and the U.S. We ensure that there are appropriate safeguards in place by way of data transfer agreements which include standard data protection clauses adopted by the EU Commission. As of 25 May 2018 you have the right to receive a copy of the clauses by contacting us on the contact details below.
5. How is my data shared?
Upon your request and based on your consent, we may share your personal data on social networks, e.g. if you wish to make a post from the App to your social networks.
We may disclose aggregated statistics to business partners of how our App is being used. This allows us to create experiences and events together with our business partners in our App. We only disclose personal data to business partners with your prior consent in which case we inform you which categories of personal data and for which purpose(s) that we ask to disclose.
Other Third Parties
Finally, we may process and disclose the personal data that you have provided to other third parties than outlined above in order to fulfill our legitimate interest of complying with applicable law and regulations and lawful regulatory requests or relevant orders from competent courts and public authorities and to establish, exercise and defend legal claims. Additionally, we may disclose your personal data to third parties in case of a merger or a transfer of assets in order to fulfill our legitimate interest of carrying out such merger or transfer of assets.
6. Your Rights
You have the right to request access to the personal data that we store about you. Some information is directly available in your profile in the App. You also have the right to request that incorrect or incomplete personal data is corrected.
Furthermore, you have the right, to the extent our processing is based on your consent, to at any time revoke your consent to our processing of your personal data. If you revoke your consent, we still have a right to continue to process the personal data that we already have collected based on your previous consent.
If we make any changes to this information, we will notify you through our App and or by sending you an e-mail to the e-mail address that you have registered for your user account.
If you have any questions or concerns about our processing of personal data, please contact us on using the following contact details.
ARROUND INC, Certificate: 169,693
New Horizon Building, Ground Floor, 3½ Miles Philip S.W. Goldson Highway, Belize City, Belize