Effective: 2023/8/10
Your privacy and data security are extremely important to us. We are
committed to the responsible management, protection, and use of your
personal information.
This Privacy Policy (the "Policy") serves to explain what information
Appsky Hong Kong Limited and its affiliates and subsidiaries
(collectively, "we", "us", or "our") collect, and how we use and protect
your information when you use any mobile applications that we develop
and are available for download in the Google Play Store and App Store.
i. Device information
We collect your device and network connection information in order to provide you better experience when you use our app.
This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:
ii. Data about your use of the Services
iii. Monetization and Analytical Information from Other Sources
Third-party SDKs integrated in our app may access your information,
including:
The information collected by third-party SDKs is governed by the providers of these SDKs and we have no control over such third parties. The third-parties include monetization partners, such as Google Admob, Facebook Audience Network, Applovin, Mintegral etc., and also analytical tools partners, such as Firebase, Google Analytics, Facebook Analytics, AppsFlyer and our self-built data statistics system (ECS) . The links to the above-mentioned platforms' privacy policy are attached in the section "Third-party Privacy Policy".
iv. Android Advertising ID
We use your Android advertising identifier in order to provide you with
customized advertisement experience. It is used exclusively for
advertising and analytics. Please note that the advertising identifier
does not contain any user sensitive information that can be used to
identify you as a user or your device. It is not connected to
personally-identifiable information or associated with any persistent
device identifier (for example: SSAID, MAC address, IMEI, etc.).
v. Other Information
We may collect the information you provide to us directly and
voluntarily. This information includes but is not limited to: your email
address, the content of your feedback (and the uploaded pictures), and
the content of the questionnaire you answered.
vi. Designated Countries
For all information listed above, pursuant to the EU General Data
Protection Regulation ("GDPR") or any equivalent legislation
(collectively "Data Protection Laws"), we process the personal
information of users located in the European Economic Area ("EEA"),
United Kingdom and Switzerland (collectively, the "Designated
Countries") based on our contract with you.
i. To improve and optimize the Services
To provide better Services to you, we have a legitimate interest to
collect and process necessary data to:
ii. To provide the Services
To provider the Services, we process data necessary to:
iii. To carry out activities related to advertisements and
marketing
To send you personalized advertising and marketing materials, we may
use the information collected from you such as ad identifiers, age,
country, region, gender, language, games played by you, information
related to the interaction of you with the Services and with other
users, and so forth.
We may also use various third party advertising and marketing
partners to assist us on our behalf and may share information
collected from you with such third parties for this purpose.
Hence, we have a legitimate interest to process necessary data to:
By accepting this Privacy Policy and downloading or continuing to
use the Services, you consent to us and our advertising and
marketing partners collecting and using information about you to
personalize advertising and marketing materials and to improve
your experience unless you opt out of receiving this service.
We encourage you to review the privacy policies of our third party
advertising and marketing partners so that you can understand how
these third parties collect, use and share your information. We
are not responsible for the privacy policies of any third party
whether accessed through the Services or otherwise.
iv. To secure the Services
Ensuring the security in the course of performing the Services is a
top priority for us. We take appropriate security and technical
measures to protect your information from unauthorized access, loss
and misuse. To achieve this purpose, we also request our suppliers
who process personal information on our behalf to take appropriate
security measures.
In order to keep the Service safe, to fight fraud and to ensure
acceptable use otherwise, we have a legitimate interest to process
necessary data to
Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions answers, comments, submissions that you post in the forum will be publicly available.
v. Designated Countries
For all purposes listed above, pursuant to the EU General Data
Protection Regulation ("GDPR") or any equivalent legislation
(collectively "Data Protection Laws"), we process the personal
information of users located in the European Economic Area ("EEA"),
United Kingdom and Switzerland (collectively, the "Designated
Countries") based on our contract with you.
As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners' use of the information that we disclose to them will be governed by their privacy policies.
Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we ask are listed below:
We process Personal Data for the purposes set out in this Privacy
Policy, as described above. Our legal basis to process personal data
includes processing that is: necessary for the performance of the
contract with you (for example, to provide you with the services you
request and to identify and authenticate you); necessary to comply
with legal requirements (for example, to comply with applicable
accounting rules and to make mandatory disclosures to law
enforcement); necessary for our legitimate interests (for example,
to manage our relationship with you, to ensure the security of our
services, to communicate with you about our products and services);
and based on consent by our customers (for example, to place certain
cookies and to share your information with third parties for
advertising purposes).
In some instances, you may be required to provide us with Personal
Data for processing as described above, in order for us to be able
to provide you all of our services, and for you to use all the
features of our apps. of our app.
We provide you with the rights described below when you use our
Services. Please contact us at
developer@appskyhk.com
if you would like to exercise your rights under applicable law. When
we receive an individual rights request from you, please make sure
you are ready to verify your identity. Please be advised that there
are limitations to your individual rights. We may limit your
individual rights in the following ways:
Where denial of access is required or authorized by law;
When granting access would have a negative impact on other's
privacy;
To protect our rights and properties; and Where the request is
frivolous or burdensome.
i. Right to withdraw consent
If we rely on consent to process your personal information, you have
the right to withdraw your consent at any time. A withdrawal of
consent will not affect the lawfulness of our processing or the
processing of any third parties based on consent before your
withdrawal.
ii. Right of access and rectification
If you request a copy of your personal information that we hold, we
will provide you with a copy without undue delay and free of charge,
except where we are permitted by law to charge a fee. We may limit
your access if such access would adversely affect the rights and
freedoms of other individuals. You may also request to correct or
update any of your personal information held by us, unless you can
already do so directly via the Services.
iii. Right to erasure (the "Right to be Forgotten")
You may request us to erase any of your personal information held by
us that: is no longer necessary in relation to the purposes for
which it was collected or otherwise processed; was collected in
relation to processing that you previously consented to, but later
withdrew such consent; or was collected in relation to processing
activities to which you object, and there are no overriding
legitimate grounds for our processing.
iv. Right to restriction
You have the right to restrict our processing your personal
information where one of the following applies:
You contest the accuracy of your personal information that we
processed. We will restrict the processing of your personal
information, which may result in an interruption of some or all of
the Services, during the period necessary for us to verify the
accuracy of your personal information;
The processing is unlawful and you oppose the erasure of your
personal information and request the restriction of its use
instead;
We no longer need your personal information for the purposes of the
processing, but it is required by you to establish, exercise or
defense of legal claims; or
You have objected to processing, pending the verification whether
the legitimate grounds of our processing override your rights.
We will only process your restricted personal information shall with
your consent or for the establishment, exercise or defense of legal
claims or for the protection of the rights of another natural or
legal person or for reasons of important public interest. We will
inform you if or when the restriction is lifted.
v. Right to object to processing
You may object to our processing at any time and as permitted by
applicable law if we process your personal information on the legal
basis of consent, contract or legitimate interests. We can continue
to process your personal information if it is necessary for the
defense of legal claims, or for any other exceptions permitted by
applicable law.
vi. Right to data portability
If we process your personal information based on a contract with you
or based on your consent, or the processing is carried out by
automated means, you may request to receive your personal
information in a structured, commonly used and machine-readable
format, and to have us transfer your personal information directly
to another "controller", where technically feasible, unless exercise
of this right adversely affects the rights and freedoms of others.
vii. Notification to third-parties
If we share your personal information with third parties, we will
notify them of any requests for rectification, erasure or
restriction of your personal information, unless this proves
impossible or involves disproportionate effort. Upon your request,
we will identify such third parties.
viii. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on
automated processing of your personal information, including
profiling, which produces legal or similarly significant effects on
you, unless an exception applies under applicable law.
ix. Right to lodge a complaint
If you believe we have infringed or violated your privacy rights,
please contact us at
developer@appskyhk.com
so that we can work to resolve your concerns. You also have a right
to lodge a complaint with a competent supervisory authority situated
in a Member State of your habitual residence, place of work, or
place of alleged infringement.
Here we list the links to the third-party partners' privacy policy. Please note that these policies are governed by the third parties and we have no control over them. Check the following links to get details about how user data is collected, used and shared.
We prepare this separate Privacy Notice for California Consumers to
comply with the California Consumer Privacy Act of 2018 ("CCPA") and
other California privacy laws.This notice is designed to supplement
the information described in our and applies solely to users who reside in the State of California
("consumers" or "you").
IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS POLICY DOES NOT APPLY
TO YOU. PLEASE REFER TO OUR MAIN PRIVACY NOTICE HERE
INSTEAD.
i. Your Right to Request for Information
As required by CCPA, you( or your authorized agent) have the right to
request us to disclose information to you about how we collect, use
and share your personal information over the past 12 months.These
information include: the categories of personal information we
collected; the categories of sources for personal information we
collected; our business purpose for collecting that personal
information; the categories of third parties with whom we share that
personal information.
ii. Your Right to Delete Information
Under the CCPA, You( or your authorized agent) have the right to opt
out of having your information sold or shared.You (or your agent)have
the right to request that we delete your specific personal information
that we collected from you and retained, except in the following cases
Such cases include:
iii. How You Exercise Your Rights
To exercise your rights described above, please submit a verifiable
consumer request to us by
developer@appskyhk.com
Only you or your authorized agent may make a verifiable consumer
request related to your personal information. You may only make a
verifiable consumer request for request for information twice within a
12-month period. A verifiable consumer request must:Provide sufficient
information that allows us to reasonably verify you identity and make
us confirm we collected personal information about you.Describe your
request with sufficient details that allows us to understand and
respond to it.
We cannot respond to your request accurately if we cannot verify your
identity.
iv. How We Respond Your Request
We endeavor to respond to a verifiable consumer request within 45 days
of receipt. If we require more time (up to 90 days), we will inform
you of the reason and extension period by email ,telephone or other
electronic means.
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.
v. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA
rights. Such discrimination include: denying you our services;
charging you different prices or rates for our services; providing you
a different level or quality of our services; suggesting that you may
receive a different price or rate for services or a different level or
quality of services.
vi. Data collection instructions for minors
These Services do not address anyone under the age of 13. We do not
knowingly collect personally identifiable information from children
under 13. In the case we discover that a child under 13 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 necessary actions. For users aged 13~16,
they have the right to opt in, and if you are the parent or guardian
of users who are aged 13~16, you can also contact us.
These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 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 necessary actions.
Any information that is collected is subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.
If you have any questions or concerns about the Policy, you may contact us at email: developer@appskyhk.com