Last Updated: November 16, 2021

Privacy Policy

This Privacy Policy covers what data AppLavia LLC ("we" or "our" or "us") or our service provider (“third-party” or “third-parties”) collect(s), how data are collected, and the purposes of collecting those data from users (“user” or "you") through our app/service.

We care about the privacy of your data and are committed to protecting it. Your privacy is very much important to us.

This Privacy Policy covers:

  • what data we or our service provider collects,
  • how data are collected
  • uses of collected data
  • third-party with whom we may share user data.
  • data retention/deletion policies
  • guidelines from the government and industry sources
  • sharing personal data on special cases
  • children's privacy
  • changes to this privacy policy

i. WHAT DATA WE OR OUR SERVICE PROVIDER COLLECTS

We may collect limited personal information under consent agreed by the you. Third-parties including analytics tools, advertising networks, third-party SDKs etc. associated with our app may also collect several data.

Personal Data

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but are not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data may be collected automatically when using the service.

Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Information Collected while Using the App

While using our app, in order to provide features of our app, we may collect, with your prior permission:

  • Information regarding your location
  • Information from your Device's phone book (contacts list)
  • Pictures and other information from your Device's camera and photo library

We use this information to provide features of the app, to improve and customize our service. The information may be uploaded to our servers and/or a third-party’s server or it may be simply stored on your device.

You can enable or disable access to this information at any time, through your Device settings.

ii. HOW DATA ARE COLLECTED

We may collect data from the following sources:

  • Directly from you. For example, from the forms you complete on our service, preferences you express or provide through our service, or from your purchases on our service.
  • Indirectly from you. For example, from observing your activity on our service.
  • Automatically from you. For example, through cookies we or our service providers set on your Device as you navigate through our service.
  • From service providers. For example, third-party vendors to monitor and analyze the use of our service, third-party vendors to provide advertising on our service.

iii. USES OF COLLECTED DATA

We may use Personal Data for the following purposes:

  • To provide and maintain our service, including to monitor the usage of our service.
  • To manage your Account: to manage your registration as a user of the service. The Personal Data you provide can give you access to different functionalities of the service that are available to you as a registered User.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the service.
  • To contact you: To contact you by email or telephone calls or SMS or other equivalent forms of electronic communication, such as a mobile app's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news or special offers or general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  • To manage your requests: To attend and manage your requests to Us.
  • For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our service users is among the assets transferred.
  • For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing and your experience.

iv. THIRD-PARTY WITH WHOM WE MAY SHARE USER DATA

Some third-party applications and services that work with us may ask for permission to access your information. These third-party vendors collect, store, use, process and transfer information about your activity on our service in accordance with their Privacy Policies.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

We also encourage you to review Google's Policy for safeguarding your data: https://support.google.com/analytics/answer/6004245

For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sites

Facebook analytics

Their Privacy Policy can be viewed at https://www.facebook.com/about/privacy/previous

Appsflyer

Their Privacy Policy can be viewed at https://www.appsflyer.com/legal/privacy-policy

Advertising

We may use service providers to show advertisements to you to help support and maintain our service.

AdMob by Google

AdMob by Google is provided by Google Inc.

For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app."

page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy

v. DATA RETENTION/DELETION POLICIES

We may retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We may retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We may retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

HOW A USER CAN REVOKE CONSENT AND/OR REQUEST DELETION OF THE USER'S DATA

All personal data are removed or deleted from our database right after you opt-out and unsubscribe from our services.

You may opt-out or revoke consent with our service any time you want. In that scenario, you may request deletion of your personal data that are stored in our database. For that purpose, contact us at: [email protected]

If your data are stored in any database of our service providers, you can go through their Privacy policies. If you feel that you have to delete your personal information from their database and it is your responsibility to contact them directly to delete your information.

Note:

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

vi. GUIDELINES FROM THE GOVERNMENT AND INDUSTRY SOURCES

The rights highlighted below go parallel with the Federal Trade Commission (FTC), which enforces federal consumer protection laws. These are applicable to users subject to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and Children's Online Privacy and Protection Act (COPPA):

Federal Trade Commission Regulations

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
  • Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
  • Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the service.

If you need any further assistance regarding exercising any of these rights, communicate via our email: [email protected]. In your request, please clarify: (I) what Personal Data is concerned; and (ii) which of the above rights you would like to exercise.

Note:

We do not practice discrimination against any user (providing inferior services or charging extra for products) who exercises any of those rights mentioned above.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

• Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

• Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

• Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

• Category F: Internet or other similar network activity.

Examples: Interaction with our service or advertisement.

Collected: Yes.

• Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

• Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

• Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.

Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

• Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA's scope, such as:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information we collect for "business purposes" or "commercial purposes", which may include the following examples:

  • To operate our service and provide you with our service.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our service.
  • To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Uses of collected Data" section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
    • The categories of personal information we collected about you
    • The categories of sources for the personal information we collected about you
    • Our business or commercial purpose for collecting or selling that personal information
    • The categories of third-parties with whom we share that personal information
    • The specific pieces of personal information we collected about you
    • If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
      • The categories of personal information categories sold
      • The categories of personal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request please contact Us. However, we don’t sell any personal data.
  • The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, 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 providers to:
    • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
    • Denying goods or services to you
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to you
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

"Do Not Track" Policy

Do Not Track (DNT) is a concept that has been promoted by us regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

vii. SHARING PERSONAL DATA ON SPECIAL CASES

We may disclose or share your Personal Data in good faith that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights of our services
  • Prevent or investigate possible wrongdoing in connection with the service
  • Protect the personal safety of users enjoying our services
  • Protect against frauds

viii. CHILDREN'S PRIVACY

The service may contain content appropriate for children under the age of 13. As a parent, you should know that through the service children under the age of 13 may participate in activities that involve the collection or use of personal information. We use reasonable efforts to ensure that before we collect any personal information from a child, the child's parent receives notice of and consents to our personal information practices.

We also may limit how we collect, use, and store some of the information of users between 13 and 18 years old. In some cases, this means we will be unable to provide certain functionality of the service to these users. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

We may ask a user to verify its date of birth before collecting any personal information from them. If the user is under the age of 13, the service may be either blocked or redirected to a parental consent process.

ix. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT INFORMATION

If you have queries, concerns, complaints about our Policy, data collection procedures, or data processing practices, we are always there for you. If you want to report any privacy or security violations, please feel free to contact us at [email protected]