The Popappa Services are not intended for or designed to attract anyone under the age of 18.
Interpretation and Definitions
Unless otherwise stated in the context, the following terms have the following meanings, and they shall have the same meaning regardless of whether they appear in singular or in plural.
- “Business” refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of this information. The type of information collected determines the purposes and means of the processing, either on its own or in conjunction with other parties.
- “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to:
Popappa and all the apps released on the store: https://play.google.com/store/apps/dev?id=5615469560374835644&gl=ITand in particular to: https://play.google.com/store/apps/details?id=com.popappa.gipityaichatbot
- “Country” refers to Italy.
- “Device” means any device that can access the Service.
- “Data” is any information that relates to a User of any of Our Services.
- “Sale”, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
- “Service(s)” refers to any of Popappa applications and/or Caller ID technology.
- “Data Partner” means any natural or legal person to whom data is transferred making it possible for the Data Partner to – via Popappa ‘s Services – provide advertising to the end-user (also defined as Business Partners in accordance with CCPA, see above).
- “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
- “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. You can be referred to as the Data Subject or as the User as You are the individual using the Service.
Data Collection and Processing
Types of Data Collected
While using Our Service We may ask You to provide Us with some necessary technical information. Technical information may include, but is not limited to: IP-address, Your country, Usage Data, device language, device internet speed, and device information number from Your device so that the Services can be provided to You. This collected information is required for Popappa to verify that Your device is accurately registered.
Popappa accesses and processes phone numbers of, and duration of, incoming and outgoing calls and contact lists with Your explicit consent, to be able to provide You with Our caller ID service. Popappa also accesses and makes use of the Advertising Identifier (Advertiser ID) connected to the installed app and may access and use the documentation on Your consent within Your Google Account setting regarding personalized advertisements. Documentation on this consent only entails a unique ID, which is generated when You install the mobile application and make Your choice.
Furthermore, when You use Our Service, Our Data Partners may, only with Your explicit consent, collect certain device and location data (both approximate and precise location) to be able to offer a range of services that include, but are not limited to, a more customized ad experience, and improved app functionality and user experience through analytics. You can withdraw Your consent at any time.
For end-users of an application with Our Services integrated
If You have installed an application on Your device which has Our service integrated, We may ask Your app provider to provide Us access to some necessary technical information. Technical information may include but is not limited to: device information number from Your device so that the Services can be provided to You. This collected information is required for Popappa to verify that the device of the User (= You) is accurately registered.
Similarly, Popappa also accesses and makes use of the advertiser ID and the documentation on Your consent within Your Google Account setting regarding personalized advertisements. Documentation on Your consent only entails a unique ID, which is generated when You install the mobile application and you can make Your choice regarding advertisements and deny any personalization of ads from the App settings. Popappa cannot trace advertiser IDs, or the unique ID related to a consent back to the identity of a specific user.
Use of Your Data
Popappa commits itself to the terms of the Google Play Developer Program Policies and reserves the right to use anonymous data for statistics and user support without restrictions regarding applicability in time.
Popappa may use Your Data for the following purposes:
- To provide and maintain Our Service, including monitoring the usage of Our Service for the purpose of improving the technical functionalities.
- To contact You: To contact You through electronic communications, such as push notifications.
- To manage Your requests: To attend to, and manage a request from You on the deletion of the App and all Your personal data.
We may share Your Data in the following situations:
- With business partners (Data Partners): We may – with Your consent – share Your information with Our business partners. Our business partners may merge the collected data elements to offer You certain services when You click on ads delivered via Our Services in accordance with their stated purposes in their respective privacy policies.
- See the list of Our Data Partners.
Retention of Your Data
Popappa will process and retain anonymized Usage Data for 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.
Legal Basis for the Processing of Your Data
Popappa processes personal data to pursue Our legitimate interest in managing Our business – including being able to handle contracts and purchases of various products and licenses for Our business and to improve, develop and market Our Services, and comply with Our legal obligations. The legal basis for Our processing is thus the following articles in the general data protection regulation:
- Article 6 (1), litra a, according to which personal data may be processed with express consent.
- Article 6 (1), litra b, according to which personal data may be processed if this is necessary to fulfill a contract.
- Article 6 (1), litra c, according to which personal data may be processed if this is necessary to comply with a legal obligation.
- Article 6 (1), litra f, according to which personal data may be processed if this is necessary to pursue a legitimate interest unless the interests of the data subject precede this.
Note: Because We process Your data partly on basis of Article 6 (1) litra f, (legitimate interests) You may in certain cases object to Our otherwise lawful processing of Your personal data if You find that Your interests in not having Your data processed exceeds Our legitimate interests in processing Your data, cf. article 21 in the general data protection regulation. See further below on Your rights under the data protection regulation.
Transfer of Your Data
Your Personal Data (the advertiser ID and unique ID regarding consent), may be processed in any place where Our Data Partners are located. It means that this information may be transferred to — and maintained on — servers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.
If Your data is transferred to a country outside the EU/EEA, and if the country in question has not been approved by the European Commission as providing adequate protection (See list of adequacy decisions here) Our data transfers will be based on Standard Contractual Clauses (SCC) also approved by the European Commission.
We have agreements with the following Data Partners. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their own Privacy Policies. We are currently partnered with the following Data Partners who all act as independent Data Controllers to whom Your data will be transferred:
We will therefore only transfer data with Your specific consent.
Other Disclosure of Your Data
Under certain circumstances, Popappa may be required to disclose Your Data in accordance with law or in response to valid requests from public authorities (e.g. a court or a government agency). Popappa may also disclose information associated with You, as well as contact information to third parties if required by law. Popappa will comply with all applicable data protection provisions, including section 5 of the italian Act on Personal Data.
Opt-Out from Data Collection and Inquiries
Users have the right to ask Popappa not to continue the processing of Personal Data. Users can exercise their rights to prevent processing by contacting Popappa at firstname.lastname@example.org
The Services may present and contain links to and from the websites of partners and affiliates. If You follow a link to any third-party websites, please note that these websites have their own privacy policies and that Popappa does not accept any responsibility or liability for these policies. You may check such policies before submitting any personal data to such websites at Your own discretion.
Security of Your Data
The security of Your Data is important to Us.
We have implemented the appropriate technical security measures to ensure data protection in all contexts, also taking into consideration the category of the Personal Data that We process. We have further ensured contractual-based instructions to Our Data Partners regarding necessary security measures to supplement the Standard Contractual Clauses approved by the European Commission.
For Users Within the European Economic Area (EEA)
Popappa undertakes to respect the confidentiality of Your Data and to guarantee You can exercise Your rights.
- Access Your Personal Data and update or delete the information We have on You. Please contact Us to assist You.
- Correct 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 the processing of Your Personal Data.. This right exists where We are relying on 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 to where We are processing Your Personal Data for direct marketing purposes.
- Erasure. 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.
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Users can exercise their rights to prevent processing by contacting Popappa at email@example.com. Please note that We may ask You to verify Your identity before responding to such requests.
For Users Within California (CCPA Area)
Categories of Personal Information Collected, Disclosed, or Sold
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 Consumer or Device.
Please note that the categories and examples provided are those defined in the CCPA. Certain categories of personal information will only be collected if You provide such personal information directly to Us.
- Identifiers: A unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
- Internet or other similar network activity: Interaction with Our Service or advertisement.
- Geolocation data: Approximate and precise physical location.
Popappa only collects and makes use of the advertiser ID and the documentation on Your consent within Your Google account setting regarding personalized advertisements. Documentation on Your consent entails a unique ID, which is generated when You install the mobile application and make Your choice regarding advertisements. Popappa cannot trace advertiser IDs or the unique ID related to a consent back to the identity of a specific user.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from Your device when You install the App, or;
- Indirectly via Your App-provider, if You have an application with Our Services integrated.
Use of Personal Information
We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA). For more details on how We use this information, please refer to the “Use of Your Data” section. When We disclose personal information for a business purpose or a commercial purpose, We will enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that, for example, a sale can happen whenever an application runs ads or makes statistical analyses on the traffic or views.
Opt-Out of Sale of Personal Information
You have the right to opt out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, We will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers We partner with may use technology in the Service that sells personal information as defined by the CCPA law. If You wish to opt-out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, You may do so on Your mobile device.
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 of 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 the information We have on You.
- The right to say no to the sale of Personal Data (opt-out). You have the right to instruct Us to not sell Your personal information. To submit an opt-out request please contact Us.
- 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 instruct 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 deemed necessary for Us or Our Service Providers.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer rights.
Our Services do not address anyone under the age of 18.
Exercise Your CCPA Rights
In order to exercise any of Your rights, You can contact Us at: firstname.lastname@example.org
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information, or that You are an authorized representative.
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to Your request or provide You with the required information if We cannot:
- Verify Your identity or authority to make the request.
- Confirm that the personal information relates to You
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.