HOLOTECH STUDIOS, INC. PRIVACY POLICY - EUROPEAN ECONOMIC AREA
1. WHO IS THE DATA CONTROLLER?
3. HOW WE PROCESS YOUR PERSONAL DATA?
4. TO WHOM WE DISCLOSE YOUR PERSONAL DATA?
5. TRANSFER OF PERSONAL DATA ABROAD
6. PERSONAL DATA RETENTION PERIOD
8. YOUR RIGHTS AS DATA SUBJECT
9. ANALYTICS TOOLS FOR ANIMAZE APP
This privacy policy (the “Privacy Policy”) provides information on what types of personal data are processed, how they are used, what are your options regarding such processing, and what are your rights as data subject and how you can exercise them.
This Privacy Policy applies to you only if you are a resident of a member state of the European Economic Area. If you are a resident of the United States of America or elsewhere, please see our other policy https://www.animaze.us/international-privacy-policy
BEFORE USING THE APPLICATION (HEREINAFTER “ANIMAZE APP”), WE RECOMMEND YOU TO CAREFULLY READ THIS INFORMATION NOTE.
Your data controller is Holotech Studios Inc. headquartered in 501 2nd Street, Suite 100, San Francisco, CA 94107, USA.
Holotech Studios S.R.L. headquartered in Bucureşti, Sectorul 3, Strada HALELOR, Nr. 5, BIROUL NR. 5, Etaj 1, shall act as the EU representative for the processing of personal data in connection with Animaze App, whenever UE law shall apply.
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CONTACT DETAILS
Should you require further information on how Holotech is processing your personal data or should you wish to exercise your rights as data subject, please contact us at the following contact details: privacy@animaze.us or Bucureşti Sectorul 3, Strada HALELOR, Nr. 5, BIROUL NR. 5, Etaj 1,
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HOW WE PROCESS YOUR PERSONAL DATA?
3.1. PROVIDING YOU WITH OUR SERVICES
3.1.1. We process personal data to provide you the services you’ve requested, including to verify virtual purchases you make and provide in-app virtual purchase opportunities. Our services through Animaze App can only be provided to individuals which download and use the Animaze app.
3.1.2. We will process the following categories of personal data:
a) Your unique ID generated whenever you download and install the Animaze App on your device (Animaze Account ID). This is the unique identifier which allows us to know that a certain device has been used to install and use the Animaze App;
b) The device IDs (hashed IDs) generated by the third-party operators providing application distribution platforms, namely:
(i) Apple entities, such as Apple Distribution International or Apple Inc., as applicable, acting as the iTunes platform operators;
and
(ii) Google LLC, Google Ireland Limited, Google Commerce Limited, or Google Asia Pacific Pte., as applicable, acting as the Google Play platform operators.
WHEN YOU USE THE SERVICES OFFERED BY EITHER OF THESE OPERATORS, THEY MAY ALSO PROCESS OTHER PERSONAL DATA ABOUT YOU / PROCESS YOUR DATA FOR OTHER PURPOSES. THE COMPANY NEITHER CONTROLS NOR INFLUENCES SUCH PROCESSING. BEFORE USING SUCH OPERATORS’ SERVICES, WE RECOMMEND THAT YOU READ THE PERSONAL DATA PROCESSING POLICIES MADE AVAILABLE BY SUCH OPERATORS.
c) your approximate location (i.e. country/ region / postal code), the type of purchases made, the value of the purchases made as provided to us by the operators providing application distribution platforms;
d) the avatars / avatars customizations in the Animaze App;
e) the virtual currencies purchased and used by you in the Animaze App;
f) first name, last name, alias / username, e-mail address, any other information which you provide to us through the contact forms.
One of the core functionalities of the Animaze App consists in providing you with the possibility to animate your Animaze App avatars. To do so, we make use of certain technologies allowing to track your facial expression (including True Depth API Data). Such technologies are connected to your device through the device operating system. For this functionality to be possible, the Animaze App requires access to your device's camera.
The camera images and animation data are only used for gameplay purposes whenever you use the Animaze App. We do not collect, record, or store any images collected via your device camera, or any facial tracking data gathered by the said image processing technologies. Such data is used solely at run-time to allow you to animate your avatars via your device.
LEGAL BASIS:
a) The entering into and performance of the agreement.
b) Our legitimate interest to monitor and manage our relationship with the app platform providers in relation to the provision to you with the services you’ve requested (such as downloading the Animaze App from the platforms, purchasing the avatars, purchasing and using the virtual currencies etc.).
3.2. ANALYSIS AND MANAGEMENT OF THE COMPANY’S ACTIVITY
We process some personal data to organize in the best way and make the Holotech’s activities more efficient, namely, to analyse how customers use the services and perform their contractual obligations.
We will process the following categories of personal data:
Your unique ID generated whenever you download and install the Animaze App on your device (Animaze Account ID);
Your approximate location (i.e. country/ region), the type of purchases made, the value of the purchases made as provided to us by the operators providing application distribution platforms;
the alias / avatars generated by us and used by you in the Animaze App;
the virtual currencies purchased and used by you in the Animaze App.
LEGAL BASIS:
Our legitimate interest to ensure the provision of quality services to our customers.
3.3. CUSTOMER SUPPORT SERVICES
3.3.1. We collect and process some personal data in order to provide support services to our customers, and to any other persons contacting us through the available channels seeking answers to their requests.
3.3.2. We will process the following categories of personal data:
your unique ID generated whenever you download and install the Animaze App on your device;
first name, last name, alias / username, e-mail address, any other information which you provide to us through the contact forms.
LEGAL BASIS:
Our legitimate interest to properly manage any requests regarding the services provided by us, and to keep our customers informed on any relevant aspects regarding the services provided to them.
3.4 MARKETING & COMMERCIAL COMMUNICATIONS
3.4.1. We wish to keep you up to date on our services by means of our commercial communications sent via e-mail. We will send you such communications if we have your permission.
LEGAL BASIS:
We will send you our commercial communications whenever you have given your permission for this.
You can always unsubscribe from such communications by clicking “Unsubscribe” in any communication sent by automated means. Also, you can always object to the processing, by using the contact details in Section 2 (Contact Details).
If you do not give your consent or, as applicable, you object to the processing in any way, you will no longer benefit from advertisements regarding our offers.
3.5. FUNCTIONING OF THE IT SYSTEMS, SECURITY AND ABUSIVE USE
3.5.1. When you use or access the Animaze App application, our systems automatically collect certain data (such as, the unique ID, device ID the date and time of accessing / logging in to the system, the operating system used) which are used to prevent and investigate potential abuses/ frauds in using our IT systems / services provided by us, as well as to ensure the long-term viability of our IT systems.
LEGAL BASIS:
Our legitimate interest to ensure the viability of the IT systems, the prevention and investigation of fraudulent and abusive use of our systems / Services.
3.6. ANALYTICS AND OTHER STATISTICS REGARDING USE OF OUR SERVICES
3.6.1. We can use the personal data provided by Animaze APP users to carry out analyses and statistics on how our Services are used or otherwise how you interact with them. The analyses and statistics carried out help us better understand how we could improve our Services including our Animaze App.
3.6.2. Such analyses are carried out by means of analytics tools for Animaze App. For details on such technologies, please refer to Analytics Tools for Animaze App section.
3.6.3. For the Animaze App we also use the Advertising Identifier (IDFA) which is a random device identifier assigned by Apple to a user’s device. The iOS IDFA allows us to uniquely distinguish the Animaze App users.
We rely on the IDFA to gather insights on how the users interact with the Animaze App, namely: to understand what install purchase channels has generated conversion of the Animaze App users, to optimize attribution through events in the app.
Please note that Apple may also use your IDFA to serve you customised ads, through Apple advertising platform. For details on such use please see https://support.apple.com/en-us/HT205223. You can Opt Out of Targeted Advertising or reset your Advertising Identifier through settings of your iOS device:
Settings > Privacy > Advertising > Limit Ad tracking;
Settings > Privacy > Advertising > Reset Advertising Identifier.
LEGAL BASIS:
The processing shall rely on our legitimate interest to optimize our activity / services.
3.7. COMPLIANCE WITH THE LEGAL OBLIGATIONS
3.7.1. The processing of your Personal Data may also rely on our legitimate interest to comply with our legal obligations (an obligation binding upon us, but not deemed a legal obligation under Member States or EU legislation), such as:
a) the compliance with our specific obligations under the financial and fiscal legislation;
b) the compliance with the document archiving requirements (including financial and fiscal documents).
3.8. DEFENCE OF OUR RIGHTS AND INTERESTS IN COURT / ADMINISTRATIVE PROCEEDINGS
3.8.1. The Company may also process your personal data for the exercise or defence of its rights and interest in any legal proceedings, administrative proceedings or other official proceedings in which the Company is involved.
LEGAL BASIS:
The Company’s legitimate interest consisting in the defence of our rights and interests in court / other administrative proceedings.
4. TO WHOM WE DISCLOSE YOUR PERSONAL DATA?
4.1. We may disclose your Personal Data to:
a) The providers of the operation system platforms for your device, or other third-party operators providing application distribution platforms. This includes Apple or Google;
b) The providers of electronic communication services – such as companies providing e-mail services in connection with various functional aspects related to the Services provided by the Company;
c) The providers of the facial expression tracking technologies we use to provide the functionality of our Animaze App;
d) The providers of app analytics services, as described in the Analytics tools for Animaze App section;
e) The providers of payment services for processing the payments made by customers;
f) Our proxies helping us manage the applications or offering us data storage services;
g) The public authorities, as provided by law (e.g. when the laws require the disclosure or when we have a legitimate interest to make the disclosure);
h) To potential acquirers of our business or of Animaze App, or to any other acquirer, when the Company is subject to an acquisition and/or restructuring process, in observance of the legal provisions.
5. TRANSFER OF PERSONAL DATA ABROAD
5.1. THE COMPANY’S SERVICES ARE LOCATED IN THE UNITED STATES. PLEASE BE AWARE THAT INFORMATION YOU PROVIDE TO US OR THAT WE OBTAIN AS A RESULT OF YOUR USE OF THE SERVICES MAY BE COLLECTED IN YOUR COUNTRY AND SUBSEQUENTLY TRANSFERRED TO THE UNITED STATES OR TO ANOTHER COUNTRY IN ACCORDANCE WITH APPLICABLE LAW. BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, INTERNATIONAL TRANSFER, STORAGE, AND PROCESSING OF YOUR INFORMATION
5.2. Also, some of our partners have servers based in third countries and, therefore, your personal data may be transferred to such third countries. In such cases, we will make sure that the personal data will be transferred under adequate guarantees (i.e. by using Standard Contractual Clauses adopted by the competent authority, certification procedures, such as Privacy Shield for USA entities) or, in any other case, in observance of the requirements of the data protection legislation.
5.3. Our partners to which we transfer the personal data, and whose servers are based in third States are:
a) Google LLC1600 Amphitheatre Parkway, Mountain View, California 94043 USA (a provider of cookies and similar technologies analysis services) – the data can be transferred to US based servers and other servers based in third States. The associated guarantees for the data transfer: US-EU Privacy Shield;
5.4. The list of our partners to which we transfer personal data may change from time to time. You can request us to provide you with a complete list of the States outside the European Economic Area, where your personal data may be transferred, as well as details regarding the measures adopted for such transfers, by using the contact details provided in Section 2 Contact Details.
6. PERSONAL DATA RETENTION PERIOD
6.1. We will retain your personal data for as long as it is necessary in order to achieve the purposes for which they were collected, in observance of the internal procedures on data retention, including the applicable archiving rules. Please find below a few rules used by the Company in determining the personal data retention periods:
a) Generally, the personal data of the customers who are Animaze App users are retained for as long as they have an active user account on Animaze App. To protect the safety and security of our users on and off our Services, we implement a safety retention window of 60 days following the user account deletion. During this period, user account information will be retained although the account will not be visible on the Services anymore.
Also, after the termination of the contractual relationship with the User, some personal data related to the user accounts (e.g. purchased items, purchases made) can be retained for an additional period 3 years to be used in case of any disputes / liability in connection with the Services we provide to the users. Such information shall be retained in a secure environment and used only for such purposes;
b) The personal data of the persons registered in our marketing database will be retained until such data subjects exercise their right to withdraw consent / respectively their right to object;
c) The data related to the analytics technologies will be retained according to the specific periods set for such technologies, with a storage period which may range between the period of the app usage session and a period of up to 3 years. We may further keep aggregate / anonymised analytics data. We are using such information for the development and enhancement of various updates and functionalities of Animaze App.
7. CHILDREN’S PRIVACY
7.1. Our Services are intended for general audiences. We do not knowingly collect or otherwise process any personal information of children. Please note that whenever you download our App from the app platforms (such as App Store or Google Store) we do not receive any specific personal data allowing us to determine or otherwise infer your age. Also, will not use the information available to us following your use / interaction with Animaze App / Service to further determine or make inferences on the users age with a view to target children.
7.2. If any party becomes aware that a child under the age of 13, or equivalent minimum age in the relevant jurisdiction, has provided us with personal information, they should contact us using the contact details provided in Section 2 Contact Details. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.
8. YOUR RIGHTS AS DATA SUBJECT
8.1. Whenever the EU General Data Protection Regulation is applicable to you as data subject, you will have the following rights related to the processing of your personal data carried by or on behalf of Holotech:
a) Right of access: you may obtain from us the confirmation that we process your personal data, as well as information on the specific nature of the processing. Such right allows you to obtain free of charge a copy olf the processed personal data, as well as, against payment, any additional copies.
b) Right to rectification of data: you may request us to change your incorrect personal data or, as applicable, to supplement incomplete data.
c) Right to erasure: you may request the erasure of your personal data where: (i) the personal data are no longer necessary in relation to the purposes for which we collected and process them; (ii) you withdrew consent for the personal data processing and we have no other legal grounds for the processing; (iii) the personal data are unlawfully processed; respectively (iv) the personal data have to be erased according to the relevant legislation.
d) Right to object and to withdraw consent: you can withdraw at any time your consent for the personal data processing based on consent, without this affecting in any way the processing carried out prior to the withdrawal of consent.
You may object at any time to the processing for marketing purposes, without providing any justification, as well as to other data processing in reliance on the company’s legitimate interest, for reasons related to your specific situation.
e) Right to restriction: you may request the restriction of your personal data processing if : (i) you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data at issue; (ii) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; (iii) we no longer need the personal data for the purposes of the processing, but they are required by you for a legal claim; respectively (iv) if you have objected to processing, pending the verification whether the Company’s legitimate interests as controller override your rights as data subject.
f) Right to portability: you may request us, as provide by law, to provide you with the personal data that you provided to us in a structured, commonly used and machine-readable format. Also, if you expressly request us, we may transmit your personal data to another entity, where technically feasible.
g) Rights related to the automated decision-making, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her: The Company does not make such profiling followed by automated decision-making with significant legal or similar effect concerning the data subject. When we make such decisions / profiling, we will inform you and we will change this information note.
h) Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the supervisory authority for personal data processing of the EU Member State of your habitual residence.
8.2. TO EXERCISE THE RIGHTS MENTIONED UNDER ITEMS A)-G) ABOVE, YOU CAN CONTACT US AT THE CONTACT DETAILS MENTIONED UNDER SECTION 2 (CONTACT DETAILS) ABOVE. ALSO, YOU CAN CONTACT THE COMPANY BY USING THE CONTACT DETAILS AND MECHANISMS AVAILABLE ON ANIMAZE APP.
8.3. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services, as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain Services provided through the Animaze APP may lose full functionality.
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ANALYTICS TOOLS FOR ANIMAZE APP
We use analytics tools (such as libraries, APIs, etc.) to monitor how such our app is used to ensure performance and improve the Animaze App.
Analyses and assessments are made in an aggregate manner, using data such as: the types of avatars chosen by the users, users’ purchases, the type of operating system, the aggregate number of application users per zones / intervals of time.
We use the Firebase services from Google LLC. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) with a view to implement and operate the Animaze App. Firebase is part of the Google Cloud Platform and offers numerous services for developers. A list can be found here: https://firebase.google.com/terms/.
The services we use include:
- Google Analytics for Firebase
- Crashalytics
- A/B Testing
- Cloud Messaging
- Push notifications
Analytics
Google Analytics helps us understand how people use our app. The SDK automatically captures a number of events and user properties and also allows us to measure and analyze how you interacted with the app.
Please see below a few examples of data collected via the Google Analytics:
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Google Analytics for Firebase |
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How it helps: Google Analytics uses the data to provide analytics and attribution information. The precise information collected can vary by the device and environment. For more information see Data collection. Retention: Google Analytics retains certain advertising identifier associated data (e.g., Apple’s Identifier for Advertisers and Identifier for Vendors, Android’s Advertising ID) for 60 days, and retains aggregate reporting and certain user-level campaign data without automatic expiration. |
For Analytics for Firebase, Google does not only use the “Instance ID” described above, but also the advertising ID of the end device. You can restrict the use of the advertising ID in the device settings of your mobile device.
For Android: Settings > Google > Ads > Reset Ad ID
For iOS: Settings > Privacy > Advertising > Limit Ad tracking
Crashalytics
We use the Crashlytics to obtain information regarding the installation, use of and engagement with, and the functionality of Animaze App, including reporting on errors or bugs, improving the functionality of Animaze App and related services, and/or (iv) communicating with users about the Animaze App.
Categories of data used: Instance IDs
For more information on Crashlytics and end-user data processing, see the Crashlytics Data Collection Policies.
LEGAL BASIS:
Considering the aforementioned method and purpose for which we use the data collected, we deem that we can process your personal data in reliance on our legitimate interest without such interest overriding your fundamental rights and interests which could be affected by the data processing.
Cloud Messaging
Firebase Cloud Messaging is used to transmit push messages or so-called in-app messages (messages that are only displayed within the respective app). A pseudonymized push reference is assigned to the mobile device, which serves as a target for the push messages or in-app messages. The push messages can be deactivated and reactivated at any time in the settings of the mobile device.
Cloud Messaging uses Instance IDs. Please see below the details on such use:
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Firebase Cloud Messaging |
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How it helps: Firebase Cloud Messaging uses Instance IDs to determine which devices to deliver messages to. Retention: Firebase retains Instance IDs until the Firebase customer makes an API call to delete the ID. After the call, data is removed from live and backup systems within 180 days. |
For additional details on our relationship with Google in connection with Firebase services please see https://firebase.google.com/support/privacy.
Google is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation
http://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Therefore, any transfer of personal data outside EEA shall be performed with adequate safeguards.
LEGAL BASIS:
Considering the aforementioned method and purpose for which we use the data collected, we deem that we can process your personal data in reliance on our legitimate interest without such interest overriding your fundamental rights and interests which could be affected by the data processing.
