(Last Updated on 3 April 2019)
Our Privacy Commitment
We, From Left To Right LLC (“FLTR”) respect your privacy and recognize the importance of protecting your personal information. This is why we will do everything to protect and handle your private information with upmost care and keep it confidential. In order to fulfil our commitment to you, we will observe and take the measures set out below.
In order to fulfil our commitment to you, we will observe and take the measures set out below.
– Inform you of personal information that will be collected and/or stored.
– Seek your consent to use, collect, store and/or disclose your personal information.
– Only collect information that we believe is necessary to carry on with our purposes of use.
– Only use and/or disclose your personal information for the purposes it is collected, except with your consent or as required or permitted by law, and will store your information as necessary to fulfil those purposes.
– Ensure that your information is accurate and up-to-date in accordance to your latest records.
– Protect your information with appropriate and necessary safeguards as one would protect their own.
Note: Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.
2. Information Collected by Us
While using the Application you are accessing our Services (referred to as “Services”). In using our Services, we may ask you to provide us with certain personal information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data unless you provide such data to us by creating an account with us or through other means.
a. We outline below, the types of information that FLTR uses and collects.
(i) We collect personal information that you provide us when you register or create a FLTR Account for the purposes of using our Services or the Application or Apps.
(ii) We collect device information and user log data as you use or enter our website and Services. For example, we may store your electronic identification, IP address, browser information, operating system of your device when you download our applications, application version, location, and the mobile device identifiers (such as your device ID and IP address). This information is stored to detect unauthorised logins to our website and use of our Services.
(iii) We collect any information that is submitted through our Contact Form on our website and the Application. We automatically collect information from you when you provide it to us directly by contacting us through our in-app support feature or when you send us an email directly from our Contact Form located on our website.
(iv) We collect personal information that you provide us such as your responses to questionnaires or surveys that you participate to complete.
(v) We may collect your user-generated content that you have created using the Application or Apps.
(vi) We may collect your activity history data such as which features you use, track your engagement and what in-purchases you make. For example, we may collect
how long you are using our application per day, features you have used, in-app purchases history, subscription activated, and number of advertising that you view.
(vii) We may collect and use your personal information to send you technical notices, updates and support information.
(viii) To provide you access to the Application and the Service, your email and encrypted password may be stored.
(ix) If you provide personal information for a particular reason, we collect and use that information for the reason it was provided. If you provide personal information in order to obtain access or use the Application, we will use your personal information to provide you access.
(x) We may collect with your permission other information such as precise geolocation using information from your Wi-Fi connections. If you decline permission for us to collect your geolocation, we will never collect that data. Similarly, we may ask for access to your camera in case you want to use certain features of our Services. If you agree to allow us permission to access our camera, then we will only collect information to facilitate your continued use of our Service.
(xi) We may receive your personal data from our analytic service providers with data they collect through our Services in accordance with their own privacy policies. A list of the third parties that operate in our Services can be found in the Appendix A.
NOTE: If you make an in-app purchase, your complete credit card information is not collected or stored. This will be done anonymously to ensure user privacy.
Such information is collected to improve user experience, to improve the content, to understand user behaviours and provide users a better service.
You acknowledge and agree that any questions, comments, suggestions, ideas, feedback or other information (“Submissions”) that is provided by you to FLTR are non-confidential and FLTR will be entitled to the unrestricted use and dissemination of these Submissions for any purpose, commercial or otherwise, without acknowledgment or compensation to you.
By creating an account or signing up to use the Application, you understand and permit FLTR to email you news, updates, promotions and other material related to the Application that we believe will be of interest to you. You understand that at anytime you can unsubscribe from receiving further emails by clicking the unsubscribe option at the bottom of the email. If at any time, you wish not to receive any future marketing communications or you wish to have your name removed from our mailing list, please message us through the Contact page.
Note: The personal information that you submit may not always be deleted. For this reason, please be aware of the information you provide. We will always do our best to destroy information where necessary to the great extent possible to protect our users.
3. How We Use Your Information
We have set out below a description of the ways in which we plan to use your information, how you may at any time opt-out, where applicable:
- To provide and maintain our Services and to perform essential operation to continue serving our users.
- To administer and protect our Services (including troubleshooting, information analysis, testing, support, fraud, reporting and hosting of data).
- To notify you about changes to our Services, to allow you to participate in new features of our Services when you choose to do so and to understand how you use our Services so that we can continuously improve our offerings.
- To advertise our Services and products and to send push notifications. You can opt-out of from receiving push notifications by turning them off at the device level through the settings of the device. Alternatively, to opt-out of receiving advertisements for our Services and products, send us request through the in-app support feature or message us from our Contact form located on our website.
- To serve personalized advertisements in our Services using third-party advertising networks. For European Economic Area, our third-party advertising networks, rely on your consent to process Personal Data in order to provide personalized advertising to you, therefore you will be asked whether you consent to the tracking that enables personalized advertisement experience. To opt-out of receiving personalized advertisements, see below section 4.1 for ‘Opt-out of Targeted Advertising’.We rely on the your acceptance of our contract with you which you entered into with us when you downloaded the Application or accessed our Services and therefore also accept our Terms of Service for use of our Services. We collect data for the
legitimate interests to keep our users updated about our Services and our new features in accordance with your preference, and to continue to improve the Services we offer.
4. Your Rights and Options
We provide you various ways to manage and obtain the data we store about you. Below we set out these options:
- You have the right to request access to your personal data. This can be done by completing our Contact form located on our website or through the in-app support feature inside the Application. Following your request, we will provide you a copy of your personal data in an electronic format upon authenticating your identity and user information.
- You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your personal data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such a withdrawal.4.1. Opt-out of Targeted AdvertisingTo show you personalized advertisements in our apps we use specific advertising networks and their partners to deliver advertisements that are tailored to you based on your interests.To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple’s ID for advertising (IDFA), and/or other tracking technologies to enable and optimize this advertising procedure. For further information on advertising networks go to Appendix A.You can opt-out from personalized advertisement experience, at any time by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android).
When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show only non-personalized advertisements and not targeted advertisements based on your interests.
4.2. Exercise Your Rights
Any requests to exercise your rights should be made through our support feature located the Application or directly through or Contact form located on our website. These requests will be addressed by us as soon as possible as we prioritise such requests over other general requests. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
5. Disclosure & Sharing of Your Information
- We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.
- We may also share information if we also under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.
- We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
- We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
- Some of our Services offer social sharing features which let you share actions you take in our Services with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in our Services. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.Our Services has social features from the following providers: – Facebook – https://www.facebook.com/about/privacy/
– Instagram – https://help.instagram.com/519522125107875?helpref=page_content – Twitter – https://twitter.com/en/privacy
6. Age Restrictions
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for use only by those aged 13 and over. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf). We do not knowingly collect personal information from children under 13 years of age.
If you would like us to delete your personal data, for any reason, please use the in- app support feature in our Services or submit a message through our website Contact form. We will take reasonable measures to promptly delete such personal data from our records and inform you when your data is destroyed.
7. Other Important Privacy Related Questions
7.1. Will FLTR provide my personal information to third parties or anyone else?
The simple answer is no. We will never supply or provide any information that you give to us to a third party without first obtaining your consent unless you have already consented to do so. We may disclose your personal information if required to do so by law or in good faith where we believe that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of FLTR, to act in certain circumstances to protect the safety of users, or to protect us against legal liability. Nonetheless, we will take every endeavour to ensure your privacy is protected to the maximum extent possible.
Certain user or profile information, including your name, username, location, and any content that such user has uploaded to our Services, including the Application, our website, or Apps may be made available to the public and displayed to users to facilitate and encourage user interaction within our Services. This may also help users identify your work and allow us to attribute authorship to you.
You may request to hide or limit profile information. However some information is necessary and must be made visible to others to be able to provide our Services.
may email you from time to time to notify you of any updates and promotional opportunities that may benefit you.
8. Third-Party Links
10. Contact Us
Below you will find a list of all third-party advertising networks and analytics service providers we may use and may have used in the past. We work with advertising networks to provide you a personalised advertisements beached on your interests and characteristics. We use analytical data to support our business activities and improve our Services for our users. To learn more about our third-party partners, please read their respective privacy polices.
AdMob by Google and their partners
AdMob by Google is provided by Google Inc. (US).
For more information on AdMob Partners, please visit: https://support.google.com/ admob/answer/9012903
You can opt-out from AdMob services by following these instructions: https:// support.google.com/ads/ answer/2662922?hl=en
Facebook Ads conversion
Facebook Audience Network
Firebase is analytics service provided by Google Inc. (US).
Flurry Analytics service is provided by Yahoo! Inc. (US).
IBM Cloud Services
IBM Cloud infrastructure cloud solutions and data storage.
MoPub and their partners
MoPub is provided by MoPub, Inc. (US)
For more information on MoPub Partners, please visit: https://www.mopub.com/ legal/partners/
You can opt-out from MoPub service by following the instructions on MoPub Opt- out page: http:// www.mopub.com/optout/
Vungle is provided by Vungle, Inc. (US)