Privacy policy
This Privacy Policy was last updated on July 15th, 2020.
1.1. References in this Privacy Policy to “Applife”, “Service”, “Application”, “App” relate to the applications, available at https://games.applife.io and/or https://applife.io, operated by APPLIFE LIMITED, a limited liability company registered in Republic of Cyprus under number HE 390348, having its address 3106, Maximou Michailidi, 6, Maximos Plaza, Tower 3, 4th floor, Office 401, Limassol, Cyprus.
1.2. Applife is the data controller regarding the Personal Data processed within the framework of this Privacy Policy.
1.3. An individual can only become a Client of Applife and use its features if he/she is aged 4.
In a situation when processing of information (including personal data) of an individual under the age of 18 is based on the consent, such consent may be required to be given by at least one of parents or legal representatives of such an individual.
1.4. Applife is committed to protecting and respecting the privacy of its Clients and ensures their security when using the Service. This Privacy Policy is intended to help the Client to understand what data and for which purposes Service collects, how collected data is processed and protected.
1.5. Applife reserves the right to amend this Privacy Policy; therefore it is recommended that the Client of the Service checks Privacy Policy on a regular basis. The service will send a notice or an email regarding such changes to the Client.
1.6. All the changes to this Privacy Policy are effective as of the “Last updated” date. The Client who continues to use the Service after the Last updated date is deemed to accept the changes made to it.
2.1. Applife has designated a Data Protection Officer (DPO) who could be reached by emailing to legal@applife.io or by post at the address provided above.
2.2. By registering with the Service, the Client consents to the processing of his/her Personal Data by the Service in accordance with the provisions set below.
2.3. By registering with the Service, the Client gives consent to Applife to anonymize his/her Personal Data for the purposes of further use in anonymized form in order to improve the performance of the Service.
3.1. When using the Services, the Client agrees to the processing of the following Personal Data:
3.1.1. Personal Data that the Client provides to the Service:
Applife does not knowingly collect any sensitive personal data or special categories of personal data.
3.1.2. Personal Data collected through the use of the Service:
When the Client is using Applife’s App, the Service may collect data regarding the device(s) the Client uses to access the Service (such as his/her IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client).
Please be advised, that according to your local legislation (including Lei Geral de Protecao de Dados, Brazil’s General Data Protection law) such information may qualify as personal data.
3.2. By providing Personal Data to Applife, the Client warrants that such data is true, accurate and up to date.
4.1. Applife collects, process and uses Personal Data of Clients of the Service based on the following grounds:
4.2. Applife collects and processes Personal Data of the Service’s Clients in order to maintain the functionality of the Service and to ensure compliance with legal and business-related requirements.
The User’s/Client’s Personal Data is processed for the following purposes:
4.2.1. When processing of personal data is related to fulfilment of the contract between the Service and the Client:
4.3.2. Under legitimate interests of the Service:
4.3.3. Under an explicit consent from the Client:
5. Duration of the Сlient’s data retention
5.1. Applife retains the Client’s Personal Data for the period of time necessary to carry out relevant activities, specified in section 4 of this Privacy Policy and as permitted by applicable law.
Personal Data, that the Client has communicated to the Service upon registration and subsequently through the use of the Service, will be retained by the Service as long as the Client remains the Client of the Service.
5.2. To protect the safety and security of the Clients of the Service, App implements a safety retention window of 30 days following a Client’s account deletion.
5.3. Applife reserves the right to store the Client’s Personal Data for a longer period of time than provided in paragraph 5.1., when it is performed in order to fulfil the legal obligations of the Service (including law enforcement requests, dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).
6.1. Applife may share the Client’s Personal Data with third parties in the following cases:
The Client shares information with other Clients of Applife by way of voluntarily disclosing information on the Service (including but not limited to information in his/her Client’s profile).
It is in the Client’s discretion to choose the information to be disclosed with the Service and Applife rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.
Unity |
Google Adwords |
Google Play |
Google Admob |
Sociaro |
Snapchat |
Yeahmobi |
Mobvista |
Ironsource |
Applift |
Tiktok |
Facebook Audience Network |
Appodeal |
iTunes |
Apple Search Ads |
Appbi |
Appsflyer |
Adjust |
Kochava |
FreeAppAnalytics |
Soomla |
Appmetrica |
Appfigures |
Datamagic |
GameAnalytics |
Amplitude |
Facebook Analytics |
Amazon
Better O |
Pragmatix |
Rainbow |
Bad Boy Apps |
Apple Store In-App Payments
Google Play In-App Payments
Applife may disclose Client’s Personal Data when such disclosure is required by law and is reasonably necessary:
6.2. Applife ensures appropriate contractual control over third parties assisting the Service in processing the Client’s Personal Data, securing that rights of Clients of the Service are upheld, their Personal Data is secure, appropriate security and privacy arrangements are in place.
6.3. In the event of change in the corporate structure of the Service, resulting in transfer of the Client’s Personal Data to a third party, all the Clients of the Service would be notified of such changes via email and through a notice posted on the Service’s website. Respective notice would explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.
7.1. Every Client of the Service is a data subject and thus has ultimate rights over his/her Personal Data.
7.2. The rights of data subject over his/her Personal Data are as follows:
Your right | Description |
Information and Access | The right to know whether your Personal Data is being processed, right to get information regarding processing of personal data, right to request a copy of Personal Data being processed. The right to information about public and private entities with which the controller has shared data. |
Rectification (correction) | The right to correct your Personal Data in a situation when such data available to the Controller or disclosed to third parties is inaccurate or incomplete. |
Erasure | The right to request deletion of your Personal Data from the database of the Controller so that the Service is not able to continue processing and storing of such data, with exceptions, provided by applicable law. The right to delete personal data processed with the consent of the data subject when the data is processed in accordance with Brazil’s General Data Protection law. The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with Brazil’s General Data Protection law. |
Restrict processing | The right to introduce the restriction regime on the processing of your Personal Data, so that in each case the data may be processed only upon your separate consent. |
Data portability | The right to request for the Personal Data to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by you. |
Object | The right to object to processing of your Personal Data in a case when the corresponding processing is not performed on the basis of the your consent. |
Withdraw consent | Right to withdraw consent to processing of your Personal Data and/or third party processors of Personal Data. |
7.3. The abovementioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.
7.4. For more information regarding his/her rights over Personal Data, the Client/User of the Service should contact legal@applife.io. In order to exercise his/her rights, the Client should submit a request to legal@applife.io.
7.5. The Client/User of the Service should also be acknowledged of his/her right to complain to a data protection regulator in his/her jurisdiction.
8.1. When using the App, Client’s personal data is transferred to the Amazon Cloud Services server (more information could be found on this link: https://aws.amazon.com/)
8.2. Applife works hard to protect its Clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although Applife takes steps to secure Clients’ information, it could not be promised or guaranteed, that unauthorised access, hacking, data loss, or other breaches will never occur.
Applife reserves the right to suspend the Client’s account without notice if there is a reasonable suspicion of breach of security or unauthorised access to such an account. If you believe that your account or information is no longer secure, please notify Applife immediately by sending a message to info@applife.io.
8.3. The Client should take reasonable steps in order to keep his/her Personal Data (including the account’s password) safe. It is recommended that the Client does not share account’s password with anyone.
9.1. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, Applife uses cookies and similar technologies in order to track the interaction of Clients with the App. This section explains the different types of cookies that may be set when the Client uses the App, helping to understand and manage them as he/she wishes.
9.2. A cookie is a small file that is stored locally at the Client’s technical device as soon as the App is being used. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the App again later, a cookie will transmit this data back to the App. The App’s cookies don't store personal information like the Client’s name or address.
9.3. Types of Cookies
Applife uses different types of cookies:
9.4. The Client can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device.
9.5. Below is information about how Applife uses Clients’ cookies in the App:
Necessary cookies
These cookies are strictly necessary to provide the Client App’s services.
Authentication cookies
These persistent cookies help the Service to identify the Clients so that the Client could log into the App automatically.
Analytics cookies
These cookies help the Service to understand how the App is being used, and help us customize and improve the Service.
Advertising cookies
These cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
Social networking cookies
These cookies are used to enable the Client to connect the Client’s account to third party social networks.
10.1. Disclosure of Applife’s Clients’ Personal Data, as provided in section 6 of these Terms of Use sometimes involves cross-border data transfers, for instance to the United States of America, Russian Federation and other jurisdictions. Applife uses standard contract clauses approved by the European Commission and/or other regulatory bodies (for example, as provided by Brazil’s General Data Protection law) or other suitable safeguard to permit data transfers from the EEA to other countries.
Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of Client’s Personal Data.
Privacy Notice for California residents
Effective date: July 15th, 2020
This Privacy Notice for California Residents (this “Privacy Notice”) supplements the information contained in Applife Limited (“Company”, “us” or “our”, or “we”) Privacy Policy (“Site Privacy Policy”) and applies solely to all visitors, users and others who reside in the State of California (“consumers”, “you” or “your”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. All capitalized terms not herein defined will have the meaning set forth in Company’s Privacy Policy. In case on any inconsistencies with Company’s Privacy Policy, this Privacy Notice shall prevail.
1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
1.1. In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
A. Identifiers.
Examples: A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, physical characteristics or description, address, telephone number. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Examples: Age, citizenship, marital status, sex (including gender, gender identity).
D. Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Examples: Physical location or movements.
H. Sensory data.
Examples: Audio, electronic, visual, or similar information.
K. Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
1.2. Personal information does not include:
1.3. We obtain the categories of personal information listed above from the following categories of sources:
2. USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following purposes:
3. SHARING PERSONAL INFORMATION
3.1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
3.2. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Personal information categories listed in the California Customer Records statute
Category F: Internet or other similar network activity
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
3.3. We disclose your personal information for a business purpose to the following categories of third parties:
3.4. We share your personal information for the following general purposes:
In the preceding twelve (12) months, we have not sold any personal information.
4. YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
4.1. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will disclose to you:
4.2. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
4.3. Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by emailing us at legal@applife.io
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
4.3.1. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
4.4. Personal Information Sales Opt-Out and Opt-In Rights
If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a variable notice to legal@applife.io
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
5. NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
6. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on our Site and update the Privacy Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
7. CONTACT INFORMATION
If you have any questions or comments about this Privacy Notice, the ways in which the Company collects and uses your information described here and in our Site Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our representative responsible for personal information as follows: legal@applife.io