PRIVACY POLICY

INTRODUCTION
Varmacon Dzmitry Kaushovik ("we," "us" or "our") really care about keeping your information safe. This Privacy Policy outlines how we handle data protection and details the kinds of information we might collect and process when you download and/or use the Watch Faces Lab software application on mobile devices ("the App"). It also describes how we work with our partners to manage this information.

When we talk about personal data or personal information, we mean any type of data that can identify a person either directly or indirectly, especially through that data.

It concerns to individuals who can be identified by an identification number or factors unique to their physical, physiological, mental, economic, cultural or social status.

This Privacy Policy is applicable to everyone who uses the App ("Users").

For the General Data Protection Regulation (GDPR) purposes, we act as the data controller, unless indicated otherwise.

PLEASE READ THIS PRIVACY POLICY CAREFULLY FOR INFORMATION ABOUT THE WAYS YOUR PERSONAL INFORMATION MAY BE HANDLED. BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THESE TERMS.

INFORMATION WE PROCESS
There are two general categories of information we can process.

1 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 this information it is impossible to provide complete functionality of the App and perform the requested services: 1) Authorization and/or Account Information. When you create/sign up for an account, we require your email. 2) Other Information directly related to your use of the App, such as photos and documents you upload to the App. Upon your consent we also may have access to your camera roll.

2 Automatically Processed Information

When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, meaning it does not allow direct association with any specific individual. 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 requested services and features of the App.

We use third-party automatic data processing technologies which helps us analyze information from your device or the App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties process your personal data, that might be collected by their own means (not through our App). As some of our third parties declare themselves as controllers for GDPR purposes, any requests regarding your personal data should be directed to these third parties.

Device-related information: When you use a mobile device (tablet / phone / smartwatch) to access our App, we may monitor one or more "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. Device identifier enables generalized reporting or personalized content and ads by the third parties. Data that may be processed include:
  1. Your mobile device type and the operating system versionwhich is installed on your mobile device;
  2. Your mobile device's regional settings;
  3. The region tied to your SIM card;
  4. Your Internet Protocol ("IP") address;
  5. An Identity For Advertisers/Advertising ID, which is a string of numbers and letters that identifies your individual smartphone or tablet.
Log File Data: Automatically captured each time you request access to the App and when the App is installed on your device. Our analytics tools also automatically record specific log file data, such as the time and date of your App usage, along with your interaction with the App.

The App may engage in automated processing of your personal data, including profiling, which is used to analyze or predict personal preferences, interests, behavior, location, or movements. This process begins automatically when you start using the App.

Cookies and Similar Technologies: To improve your experience, we may use cookies and technologies like pixels and web beacons when you use the App. A cookie is a small file downloaded to your device upon accessing the App, which is then sent back to our servers with each use of the App. This helps us operate the App efficiently, understanding which areas or features are popular and the content users are clicking on. We may partner with advertisers or other third parties to deliver ads and services in the App, which may use cookies or similar technologies.

THE PURPOSES OF PROCESSING YOUR PERSONAL DATA
Our goal is to continually improve our App and introduce new experiences. In line with this mission, we use your information for the following purposes:

1) To provide our service. We use both submitted information and automatically processed information to offer all services you request.

2) To improve, test and monitor the effectiveness of our App. We use automatically processed information to better understand user behavior and trends, detect potential issues, and optimize our App.

3) For personalized advertising and content. We may use automatically processed information for marketing purposes and to provide personalized, interest-based (behavioral) targeted content and ads.

4) To communicate with you. We use the information we have to communicate with you through newsletters, marketing notifications, to receive your feedback about our App, and respond to you when you contact us.

5) 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 we start processing your personal data for new purposes, we will inform you by updating this Privacy Policy accordingly.


SHARING YOUR INFORMATION
We are committed to sharing your information in accordance with the guidelines outlined in this Privacy Policy. Our practices align with the Self-Regulatory Principles for the Mobile Environment established by the U.S. Digital Advertising Alliance.

Rest assured, we do not engage in renting or selling your personal data to any third parties. However, we may share your information, including data from cookies, log files, device identifiers, and location data, with third-party organizations that provide automatic data processing technologies for the App. It's important to note that we do not have control over these third-party tracking technologies or their usage.

Additionally, we may share specific information, such as cookie data, with third-party advertising partners. This sharing enables third-party ad networks to deliver targeted advertisements they believe will be most relevant to you.

For the enhancement and maintenance of our services, we may collaborate with the following third-party providers to ensure we have the necessary infrastructure:

Admob (Google LLC)
Analytics service provider, USA
https://support.google.com/admob/answer/7665968

Analytics (Google LLC)
Analytics service provider, USA
https://www.google.com/analytics/terms/us.html
Facebook Inc.
Analytics service provider, USA
https://www.facebook.com/privacy/explanation

Google Inc.
Analytics service provider, USA
http://www.google.com/intl/en/policies/privacy/par...

If you want to explore more about these services and their privacy options (including opt-out), please refer to the respective websites and privacy policies. Please note that we cannot be held responsible for any misuse of your personal data by third parties in violation of our guidelines.

Our App might feature links to third-party websites/services, or you may access the App from a third-party platform. We do not take responsibility for the privacy practices of these third-party sites or services, nor do we endorse the information or content they contain.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances such as:
  • Compliance with legal requirements.
  • When we genuinely believe that disclosure is necessary to safeguard our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.
  • In the event of a merger, acquisition, or sale of all or part of our assets, you will receive notification via email and/or a prominent notice in our App regarding any changes in ownership or the use of your personal information, along with any options you may have concerning your personal data.

INTERNATIONAL DATA TRANSFERS
We operate globally, providing our App to users worldwide.

Both we and external entities that offer automated data processing services for the App, as well as our advertising partners, might move information processed automatically from your country or legal territory across international borders to various locations globally.

If you are located in regions with data processing laws different from U.S. law, note that we may transfer information, including personal information, to a jurisdiction with different data protection laws.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where the data privacy and security might not match the level of protection provided in your country.

By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

US REGIONAL PATTERNS
Residents of the State of California (USA) have the right to request a list of all third parties to whom our App disclosed certain personal information (in accordance with the laws of the State of California) in the previous year for the purposes of direct marketing of such third parties. If you are a resident of the State of California and want to receive such a list, please contact us through email or contact form displayed below. When submitting a request, please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California", as well as your name, address, city, state, and zip code. In the text of your request, please provide us with sufficient information so that we can determine if the above requirements of the law apply to your situation.

DATA RETENTION
We retain your personal information as long as necessary for the App's functionality and to comply with 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.

Nevertheless, certain information might be retained for a specific duration (not exceeding the necessary period for storage) if retaining such data is essential for meeting legal requirements (such as for tax, accounting, or auditing purposes) or to ensure security and backup of data, as well as to deter fraud or any harmful activities.

EXERCISING YOUR RIGHTS
Regarding the personal data we collect and access, you have the right to address us for the following concerns:
Data Access and Portability: You can request copies of your personal information that we hold.
Data Modification or Correction: If you are unable to update data yourself via your account, you have the right to ask us to correct change, update or rectify your data.
Data Retention and Deletion: We typically retain data as long as your account is active or as needed to provide the services of the App. However, specific retention periods may vary depending on the processing context and legal obligations. You can request us to delete some or all of your personal data. If you have an account, you can also delete it at any time. We may need to retain some of your personal data even after account closure if necessary to comply with legal obligations or for legitimate interests (e.g., fraud prevention, security maintenance).
Restriction of Processing: Under certain circumstances, you may have the right to limit the ways how we use your personal information.

Please note that the rights mentioned above apply only to the information you provide to us.

When your personal information is automatically processed, you have the right to object to such processing under certain circumstances. If your personal information is processed for direct marketing purposes, you can request to stop processing your data for these purposes. To exercise your rights, please contact the third-party services listed in Section IV of this Privacy Policy to learn how to object to the processing of your data. Most of them provide clear instructions on their privacy pages, functional API, or other options.

Please be aware that you can opt-out of marketing tracking by selecting the "Limit Ad Tracking" option on your iOS device in Settings/Privacy/Advertising. For additional information, please visit: https://support.apple.com/en-us/HT202074;

Please note that even if you opt out of certain interest-based advertising, you may still receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

CALIFORNIA PRIVACY RIGHTS (CPRA)
If you are a California resident, you have the following rights under the California Privacy Rights Act (CPRA):
Right to Know: You can request details about the personal information we collect, use, and share, including the specific data we hold about you.
Right to Delete: You may ask us to delete your personal information, subject to legal exceptions.
Right to Correct: You can request that we correct any inaccurate personal data we have about you.
Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information.
To exercise any of these rights, contact us at [contact email].

OPT-OUT OF THE LOCATION DATA PROCESSING
Some third-party advertising partners may collect precise location data or street-level location information about you ("Precise Location Data"). Your mobile device may allow you to opt out of the collection of Precise Location Data as described below.

For iOS 11 or later: To disable the collection of Precise Location Data on iOS, you can turn off Location Services for the applicable Product via "Settings > Privacy > Location Services". Then select the applicable App and set the "Share My Location" status to "Never". For more information, please visit: https://support.apple.com/en-us/HT203033.

SECURITY
We prioritize the security of your Personal Information, therefore we are striving to use commercially acceptable means of protecting it. But unfortunately, no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

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

CHILDREN'S PRIVACY
These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18 years of age. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.

CHANGES TO THE PRIVACY POLICY
We may update our Privacy Policy from time to time. We advise you to review this page periodically for any changes. But also we will notify you of any changes by posting the new Privacy Policy on this page.

Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at: hello@watchfaceslab.com