Privacy policy

DATA CONTROLLER

For the purposes of applicable data protection laws (including the GDPR/UK GDPR), the data controller is CyBearSoft (“we”, “us”, “our”). If you have questions about this Privacy Policy or your personal data, or want to exercise your rights, contact: dev@cybersoft.com.

1. Introduction

This Privacy Policy explains what personal data is collected when you use the all of Cybersoft mobile apps (the “ App”) and the services provided through it (together with the App, the “ Service”), how such personal data will be used, shared.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account using the functionality found in “Settings” in the App, or contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android); and (c) delete the App from your devices.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Economic Area . For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

1) We are committed to safeguarding the privacy of our website and mobile applications visitors; in this policy we explain how we will treat your personal information. 2) We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. 3) CyBearSoft’s mobile applications: Secure Articles, Cryptarise, HabitGlyph, EcomRead, Earningo, FitFoodLens, Listwisp, Crypseye.

CHILDREN

The Service is not intended for children under 16, and we do not knowingly collect personal data from children under 16. If you believe a child has provided personal data to us, please contact dev@cybersoft.com.

2. Collecting personal information

Below is an overview of the categories of Personal Information we may collect, along with specific examples. We collect personal data related to current, prospective, and former customers (“users”) of our Services. A – SOURCES OF PERSONAL DATA We may obtain your personal data from the following sources:

1. from you directly (through the App, website or online forms); and/or
2. from other entities, service providers that are assisting us in providing you with a service (including data analytics providers, operating systems, and internet services providers), or from your social networks accounts you used to sign in to our online services (for example, Facebook, Google, Weibo).

B – PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data relating to our users:

1. Contact information (such as name or nickname or email you submit as part of your register for our Services or log-in or via social networks);
2. Data about your account and App progress, we create a specific ID for you when you use the Services;
3. Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);
4. Data about your device, such as manufacturer, operating system, CPU, RAM, browser type and language;
5. Broad location data (e.g. country or city-level location);
6. Precise geolocation data (GPS, with your consent);
7. Usage data, such as data we collect with cookies and similar technologies Cookies Notice;
8. Data (such as your nickname, profile picture) we receive if you link another provider’s tool with the Service (such as Facebook, Google or Weibo);
9. purchase history, including details of orders (amount spent, date, time, vouchers or offers used);
10. Data to fight fraud (such as refund abuse in Apps or click fraud in advertising);
11. Data from platforms that the Apps run on (such as to verify payment);
12. Data for advertising and analytics purposes, so we can provide you a better Service;
13. Other data you choose to give us.

In the preceding 12 months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

• Directly from you (for example, when you fill out a form on our Services or communicate with us).
• Indirectly from you (for example, through cookies or other tracking technologies when you use our Services).
• From third parties (for example, advertisers, social media platforms, recruitment agencies, headhunters, and data analytics providers).

3. Using personal information

We process your personal data:

To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. To host personal data and enable our App to operate and be distributed we use Amazon Web Services, which is a hosting and backend service. We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.

Subscriptions and purchase management (RevenueCat)

We use RevenueCat to help manage in-app subscriptions, entitlement status, and related purchase events. RevenueCat may process device identifiers and purchase/subscription-related information to provide its services.

To customize your experience

We process your personal data to adjust the content of the Service and make offers tailored to your personal preferences. As a result of such processing, we may create a recommendations for you.

To manage your account and provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

To communicate with you regarding your use of our Service

We communicate with you by push notifications. These may include information on special offers or other information about the App. To opt out of receiving push notifications, you need to change the settings on your device. The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our App’s users, as well as when they interacted with it, such as by clicking on links included in the message. To communicate with you we also use Firebase Cloud Messaging and Firebase Notifications , which are message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send reminders only to users who used the App more frequently. Google’s privacy policy. We use Apple Push Notification service (“APNs”), that is a notifications service provided by Apple. APNs allows us to send information to iOS devices. Apple’s privacy policy. Learn more how to control notifications on Android devices and on iOS devices.

To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the App and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the App our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing. For example, if we discover that users are keen to take quizzes, we may focus on creating new quizzes and improving the existing ones. To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy, Opt Out. We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our App, how often users make purchases, how many users were born in Berlin, and other interactions. Learn more about Facebook’s approach to data from its Privacy Policy. To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase. Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions that occur in our App. Amplitude provides more information on how they process data in its Privacy Policy. We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google’s use of data, consult Google’s partner policy . Firebase Privacy information. Google’s Privacy Policy.

To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as for example, special offers. We may show you advertisements in our App, and send you push notifications for marketing purposes.

To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

In this section, we explain the legal bases we rely on for each purpose of processing. For more information on specific purposes, please refer to Section 2. This section applies only to users located in the EEA. We process your personal data under the following legal bases:

1. Your consentUnder this legal basis, we may track your geolocation and communicate with you by sending push notifications.
2. To perform our contract with youUnder this legal basis, we:
   • Provide our Service in accordance with our Terms and Conditions of Use
   • Customize your experience
   • Manage your account and provide customer support
   • Communicate with you regarding your use of our Service
3. For our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedomsWe rely on legitimate interests for the following purposes:
   • Communication related to your use of the ServiceThis includes sending push notifications reminding you to check new information. Our legitimate interest is to encourage more frequent use of the Service.
   • Research and analysis of Service usageOur legitimate interest for this purpose is improving our Service by understanding user preferences and providing a better experience (e.g., making the App easier to use or introducing and testing new features).
   • Sending marketing communicationsOur legitimate interest is to promote our Service in a measured and appropriate way.
   • Personalizing advertisementsOur legitimate interest is to promote our Service in a reasonably targeted manner.
   • Enforcing our Terms and Conditions of Use and preventing fraudOur legitimate interests include enforcing legal rights, preventing fraud, and addressing unauthorized use or non-compliance with our Terms.
4. To comply with legal obligations

OPT-OUT / WITHDRAWING CONSENT

You can withdraw consent or change your choices at any time, where processing is based on consent or where you have choices available:

• Push notifications: turn off notifications in your device settings (Android/iOS).
• Precise location (GPS): disable location permissions in your device settings.
• Advertising identifiers: you can reset/limit ad tracking in your device settings (availability depends on OS version).
• Appsflyer opt-out: https://www.appsflyer.com/optout/

On iOS, if we (or our partners) engage in tracking as defined by Apple, we will request permission via Apple’s App Tracking Transparency (ATT) prompt. You can change your choice at any time in iOS settings.

5. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 and 5 of this Privacy Policy. The types of third parties we share information with include, in particular:

Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• cloud storage providers (Amazon)
• data analytics providers (Facebook, Appsflyer, Firebase, Amplitude)
• marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, IronSource, Appodeal)

We also use RevenueCat to support subscription management and entitlement status for the Service.

Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

6. International data transfers

1) Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. 2) You expressly agree to the transfers of personal information described in this Section 5. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details availablehere), or (ii) the European Commission adequacy decisions about certain countries (details available here).

7. Retaining personal information

1) This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information. 2) Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 3) Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data: (a) to the extent that we are required to do so by law; (b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

8. Security of personal information

1) We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

9. Amendments

1) We may update this policy from time to time by publishing a new version on our website. 2) You should check this page occasionally to ensure you are happy with any changes to this policy. 3) We may notify you of changes to this policy by email.

10. Your rights

1) You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: (a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor). 2) We may withhold personal information that you request to the extent permitted by law. 3) You may instruct us at any time not to process your personal information for marketing purposes. 4) In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

EEA/UK (GDPR/UK GDPR) ADDITIONAL RIGHTS INFORMATION

If you are in the EEA or the UK, you may have the right to:

• request access to your personal data
• request correction of inaccurate or incomplete personal data
• request deletion of your personal data (where applicable)
• object to processing based on legitimate interests
• request restriction of processing
• request data portability
• withdraw consent at any time (where processing is based on consent)
• lodge a complaint with your local data protection authority

To exercise these rights, contact us at dev@cybersoft.com.

11. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. CALIFORNIA PRIVACY RIGHTS

California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be personal information under the statute. To obtain this information from us, please send an email message to dev@cybersoft.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email addressin the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

CALIFORNIA (CCPA/CPRA) NOTICE

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”) may provide you with rights regarding your personal information, including the right to know, access, correct, or delete personal information, and the right to opt out of certain uses or disclosures, as applicable. “Sale” / “Share” (Targeted Advertising): Some disclosures of identifiers and usage data to advertising and measurement partners may be considered “sharing” for cross-context behavioral advertising under California law. To submit a request, contact us at dev@cybersoft.com. We may need to verify your request. We will not discriminate against you for exercising your rights.

13. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

14. CONTACT US

You may contact us at any time for details regarding this Privacy Policy. For any questions concerning your account or your personal data please contact us at dev@cybersoft.com.