Privacy Policy

Last updated: August 2025

Opt-out options: DO NOT USE MY DATA

To realize how we proceed the data you enter during the quiz on our Website please see Survey Data provisions

If you provide your email address to us for receiving newsletters please see Email newsletters section.

I. INTRODUCTION. REGIONAL PATTERNS

AIBY Inc. (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you access, use and/or interact with us via web pages available at links with domain name “https://futurio.app/” (hereinafter, the “Website”) or make purchases on it.

Please note that this Privacy policy applies only to data collected, stored, or processed when you access and/or use the Website or make purchases on it. This Privacy policy does not apply to data that is collected, stored, processed when you access and/or use Futurio: Horoscope & Astrology mobile App introduced on the Website (hereinafter, “Futurio: Horoscope & Astrology App”). Therefore, if you want to learn more about data processing practices applicable to Futurio: Horoscope & Astrology introduced on the Website, please visit the corresponding Futurio: Horoscope & Astrology App Privacy policy.

The Website is designed for general information and promotional purposes. It provides details about the Futurio: Horoscope & Astrology App’s paid subscription features, additional purchases, and some information about the App’s functions.

This Privacy policy (except for Annex below - “U.S. Multistate Privacy Notice”) applies to all users of the Website regardless of where they are located. The U.S. Multistate Privacy Notice included in the Annex to this Privacy policy supplementary applies to those users who:
a) are residents of U.S. states where corresponding U.S. State Privacy Laws were enacted; and
b) fall within the scope of the U.S. Multistate Privacy Notice applicability.

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

The scope of data we process may vary depending on the types of actions and operations you perform using the Website (see Section II for more details). Nevertheless, the provisions of this Privacy policy are applicable to any persons who visit or use the Website or make purchases on it (collectively, “users”).

For the purposes of the GDPR, we are the data controller, unless otherwise stated.

II. INFORMATION WE PROCESS

We may ask for and process the several categories of information when you access, use and/or interact with the Website. This information is necessary for the adequate performance of the contract between you and us. Without such information it is impossible to provide complete functionality of the Website and perform the requested services.

Information that you voluntarily provide to us

Survey Data. We may process the information you provide while answering the quiz on the Website, including, but not limited to, your gender, date and time of birth, place of birth, zodiac sign, and any other data you enter during the quiz (“Survey Data”). The exact set of Survey Data may vary depending on the type of quiz on the Website. Please review the questions before entering your answers to understand which information will be processed as Survey Data.

We collect Survey Data only if you complete the quiz on the Website and proceed with a purchase on the final screen. In all other cases, your data will not be collected or will be collected in anonymous form. If you change your mind during the quiz and decide not to make a purchase or share your data with us, simply close the webpage - Survey Data you previously entered will not be processed, except for your email address (if provided).

When you have completed your Website's quiz and feel ready to purchase your subscription we ask you to provide your Email Address - we use it to identify your purchase and send you the relevant confirmations. Once you purchase a subscription you will be able to perform a Sign In function in the Futurio: Horoscope & Astrology App.

Survey Data and your email address are processed to provide our services under the Terms of Use and End User License Agreement based on the purchased offerings.

Also, we may collect, store and process some information when you use the form available within the “Contact us” section or link on the Website (hereinafter, “Contact us” form) or via email at [email protected]. In particular, if you decide to make a request via the “Contact us” form or via email, the following categories of information are voluntarily provided by you: your name, email address, the text of your message and/or any files that you optionally choose to attach to your request (“Contact Data”). We use the Contact Data solely for the purpose of considering and responding to your requests (if necessary).

We use the Information you voluntarily provide to us to (a) make our service available and ensure the efficient operation of the Website and (c) communicate with you while we deliver our in-app, as well as the Website-based services to you. We process this information based on the performance of our contracts, as outlined in the Website’s Terms of Use and End User License Agreement, as well as the App’s Terms of Use and End User License Agreement.
We use your Email Address to (c) communicate with you by sending necessary information, updates, guides, articles, and news related to the Futurio: Horoscope & Astrology App and the Website. For more details, please refer to the subsection "Email Newsletters" below.

We use the Survey Data (specifically age, weight, and height) to (a) to make our service available and ensure the efficient operation of the Website and the App, while personalizing our in-app services for you. This means that we use this information to pre-fill matched basic information in the App for streamlining your onboarding process and enhancing your experience.

Note that if you don’t purchase a subscription or make additional purchases on the Website after completing the Website's quiz, you may also voluntarily provide us with an email address to (c) communicate with you by sending necessary information, updates, reminders, guides, articles, and news related to the Futurio: Horoscope & Astrology App and the Website. The processing is based on our legitimate interest. If you do not wish to receive information via email or do not want your Survey Data to be used to personalize our in-app services, please See Opt-out options

Email newsletters

If you subscribe to newsletters we may use the information about your email address to send you such newsletters regarding special subscription offers, new features and functionalities and other news related to Futurio: Horoscope & Astrology App and/or the Website on the grounds of our legitimate interests. Sending you newsletters will allow you to stay up to date and receive the latest news about Futurio: Horoscope & Astrology App and the Website, including about the best price offers. You may unsubscribe, opt-out of receiving newsletters to your email address at any time by using the resignation link provided in each email you receive from us. Your unsubscribe request shall be honored within a reasonable period of time.

To collect, store and process the information that you voluntarily provide us, we use the services of Advanced Hosters B.V.

To enable automated management of your Subscription, we receive some data from our payment provider. This process helps us immediately process your request when you initiate cancellation of your subscription in the App's settings. The data includes details such as your subscription plan and status, charge amount, payment date, transaction ID. This information is also used to activate your access to our services and to provide customer support. The legal basis for processing your subscription details is performance of our contracts.

We may use certain information related to the Survey Data in an aggregated form as part of Information that is processed automatically to (b) improve, test and monitor the effectiveness of the Website (see below). This information is used to analyze groups of people who interact with our Website in a non-personalized manner (aggregated Survey Data).

To collect, store, and process aggregated Survey Data, we use the services of Adapty Tech, Inc. and Amplitude, Inc. We manage this automatic processing so that we do not link, nor are we able to link, your email address or any other identifiers that you voluntarily provide to us with this aggregated Survey Data. If you reasonably believe that this information could be casually linkable to you (for example, due to the actions of our service providers or specifics of the automatic algorithms used), please contact us via our “Contact Us” form available on the Website or via email at [email protected]. We will review your case, check for any matches, and delete any of your identifiers if confirmed.

Information that is processed automatically

When you access, use and/or interact with the Website, some information about your device and your user behavior may be processed automatically to (b) improve, test and monitor the effectiveness of the Website. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest for improving the Website and giving our users the best experience unless another basis is specified in this Privacy Policy or the Cookies Policy.

We may use third-party automatic data processing technologies to analyze certain information sent by your device via the Website (analytics tools). Some of them may launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time access the Website.

• Device Details. When you use a device (computer, laptop / tablet / phone) to access the Website, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your device, which uniquely identify your device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

  What data may be processed:

  • Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, battery life, loading time, latency, framerate, device memory usage.
  • Information about the Internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser and version, browser language.
  • Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone.
  • Device identifiers: advertising identifiers, Identity For Advertisers for iOS devices.
    
• Cookies and similar technologies. When you access, use and/or interact with the Website, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the Website. The text file is then sent back to the server each time you use the Website. This enables us to operate the Website more effectively. For example, we will know how many users access specific areas, content, or features within the Website, which links they clicked on, and how many users select particular quiz options (see above regarding aggregated Survey Data). We use this aggregated information to understand and optimize how the Website is used, improve our marketing efforts, and provide content and features that are of interest to you. Third party analytics tools use cookies or similar technologies for the purpose of analyzing the Website traffic. For further details regarding how we use cookies, please refer to our Cookies Policy.
• Log file information. Log file information is automatically reported each time you make a request to access the Website. When you use the Website, analytics tools automatically record certain log file information, including time and date when you start and stop using the Website, and how you interact with the Website.
  
  Information provided automatically to analytics or advertising tools does not generally come to our control, therefore, we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility.

III. THE PURPOSES OF PROCESSING YOUR DATA

Our mission is to constantly improve the Website and provide you with better user experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available and ensure the efficient operation of the Website and the App. We use the information you voluntarily provide, along with the information processed automatically, to fulfill our contract, deliver the requested services, tailor those services to you, provide them through the App and the Website, and ensure the efficient operation of the Website according to its intended purpose.

(b) To improve, test and monitor the effectiveness of the Website. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize the Website.

(c) To communicate with you. We may use information that you voluntarily provide to us via our support channels and contact forms for the purposes of processing and responding (if necessary) to your requests, receiving your feedback, comments or suggestions, also to send you marketing notifications about the operation of the Website, Futurio: Horoscope & Astrology App or on other matters.

(d) To prevent fraud and spam, to enforce the law. We really want the Website 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, enforce our Terms of Use and End User License Agreement and applicable law.

Details about specific categories of information processed for various purposes can be found in Section II of this Privacy policy. Please note that, in order to prevent fraud and spam or to enforce the law (d), we may process all categories of information if required by law.

If any new purpose for processing your data arises, we will let you know when we start to process information for that other purpose by introducing the corresponding changes to this Privacy policy.

IV. SHARING OF YOUR INFORMATION

We will not rent or sell your personal data to third parties, but we may share your information obtained via tools like cookies, log files, and device identifiers with third-party organizations that provide automatic data processing technologies for the Website. We do not control or influence these third parties’ tracking technologies or how they may be used.

Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your data, we cannot guarantee the absolute security of any information transmitted from the Website directly to such third parties. We are not responsible for any accidental loss or unauthorized access to your data through a fault of third parties.

We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of the Website:

Third-party service providers may engage their own third-party service providers. To view a list of these providers, please refer to the Privacy Policy links above and the Data Processing Agreement with our service provider, available at https://adapty.io/data-processing-agreement/.

As it is indicated above we use Google Analytics service that tracks and reports the Website traffic. Google Analytics service uses different types of cookies to analyze user activity on the Website. If you want to learn more about the types of cookies and other data collected and processed by Google Analytics service provider (Google LLC) please visit https://support.google.com/analytics/answer/6004245 and https://policies.google.com/technologies/cookies. Note that we are not responsible for any usage of your data by the abovementioned third-party service provider (Google LLC) in violation of our instructions.

If you don’t want Google Analytics to use cookies you can block data collection following the instructions provided in Section IX of the present Privacy policy.

The Website may contain links to third party sites/services. You also may visit the Website following a link from a third party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

• as required by law;
• when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our Website of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide the Website to users around the world.

We and third-party organizations that provide automatic data processing technologies for the Website or our third-party partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as in your home jurisdiction. We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information.

By using the Website, 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 where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

VI. HOW DO WE STORE YOUR DATA

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

In particular, we recourse to the services of Advanced Hosters B.V. and Adapty Tech Inc. that have adopted technical and organizational measures to protect your personal data against unauthorized/unlawful processing and accidental loss, destruction or other damage (please refer to the Privacy policy links in Section IV and the Data Processing Agreement with our service provider, available at https://adapty.io/data-processing-agreement/).

VII. HOW LONG WE USE YOUR PERSONAL DATA

We generally retain your personal information for as long as is necessary for performing the functional service of the Website and to comply with our 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/or close your account (if applicable).

The information you provide when answering questions in the Website's quiz (such as gender, weight, age, and height) is stored and used in the App for the duration of your active subscription, or until you request its deletion. If you do not subscribe or make a purchase, this information will be deleted immediately.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

VIII. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following rights in relation to your personal information that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. Where you cannot update data by yourself, you have the right to ask to correct, change, update or rectify your data.
• Data Retention and Deletion. Specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
• Exercising the right to know about data sharing. You have the right to know whether your data is shared with third parties. Detailed information on this issue is contained in section IV of the present Privacy policy, however, if you have further questions in this regard, you can contact us at any time.

To exercise any of the rights described above, you can contact us via our “Contact Us” form available on the Website or via email at [email protected]. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store. We also would like to draw your attention to the fact that in order to process your request we first have to identify you as a user of the Website or Futurio: Horoscope & Astrology App.

You also have the right to lodge a complaint with your local data protection or a supervisory authority if you reasonably believe that your rights under applicable data protection laws have been breached. Please note that when you exercise your right to lodge a complaint with your local data protection or a supervisory authority, you may be required to provide additional information and support your complaint with sufficient objective evidence. By lodging a complaint you agree to provide sufficient explanation as to what you believe impaired your rights. Additionally, in some cases prior to lodging a complaint to your local data protection or a supervisory authority, you may be required to send your initial claim directly to us and ask for clarifications if necessary.

When your information is processed automatically you may object to such processing in some circumstances. Where your information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise this right please contact the third party service providers listed in the Section IV of this Privacy policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

If you are located in the European Union, you may address our representative when you have questions on privacy issues: Konrad Gutowski, privacy @ aiby.com.

IX. HOW TO OPT OUT

You may prevent and/or manage the collection and processing of some information related to your use of the Website following the instructions provided below. Note that it is applicable only with respect to the Information that is processed automatically.

Google Analytics. If you want to opt-out of being tracked by Google Analytics you can install and enable Google Analytics Opt-out Browser Add-on. Additionally, you can manage cookies and/or delete cookies already set by Google Analytics through your browser settings. Further information on Google Analytics’ data practices and relevant instructions can be found at https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’).

TikTok Events API.If you want to opt-out of being tracked by the TikTok Events API, you can refuse or disable cookies for the Website by adjusting your device's browser settings. Because each browser is different, please see the instructions provided by your browser. Please note that your opt-out selection is specific to the particular browser or device you are using when you opt out, so you may need to opt out separately for each browser or device.

Cookies. You may prevent your browser from accepting cookies entirely by adjusting your browser's cookie settings. These settings are typically found in the "Options" or "Preferences" menu. Please refer to the instructions on our cloud service provider's website (Section 3.6, "To personalize our ads": https://adapty.io/privacy/) or consult the instructions related to your browser.
Bear in mind that if you choose to disable all cookies, this can affect the Website functions, some of the features that make the Website more efficient may not function.

The information you provide when answering questions on the Website's quiz. If you do not wish for the information you provide when answering questions in the Website's quiz to be used for personalizing our in-App services, you may replace this information with alternative information in the App`s settings, or contact us via the “Contact Us” form available on the Website.

Newsletters and other communication with you by sending necessary information, updates, guides, articles, and news related to the Futurio: Horoscope & Astrology App and the Website. If you subscribe to newsletters, you may unsubscribe, opt-out of receiving newsletters to your email address by using the resignation link provided in each email you receive from us. Your unsubscribe request shall be honored within a reasonable period of time. Even if you unsubscribe from newsletters, we may still use your email address to send you some necessary information related to the Futurio: Horoscope & Astrology App and/or the Website functioning.

Advertising Industry Opt Out Tools. You may also limit the collection of cross-app data for interest-based ads and exercise your right to opt out using the following Advertising Industry Opt Out Tools:

• Digital Advertising Alliance for Websites: https://optout.aboutads.info;
• European Interactive Digital Advertising Alliance (EDAA) https://youronlinechoices.eu/;
• Network Advertising Initiative: https://optout.networkadvertising.org/.

X. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information provided to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of the Website, you can contact us with the corresponding message via our support channels or contact forms.

XI. CHILDREN’S PRIVACY

Our Website is not intended for children. Therefore, we do not knowingly or intentionally collect or solicit any personal information from children. For the purposes of this Section XI the terms “child” and/or “children” in the context of data processing activities may be interpreted on a case-by-case basis as prescribed by applicable data protection laws. No one who is considered a “child” under applicable data protection laws is allowed to directly provide any personal information to the Website.
As a general rule we consider a person under the age of 16 to be regarded as “a child” until we have legal grounds to conclude that a person under 16 should be treated as an adult as per provisions of local data protection rules or based on the parent authorization provided to us directly.
Solely the holders of parental responsibility are liable for preventing their children from providing personal information via the Website without relevant verifiable parental consent. If we learn that we have collected personal information from a child without verification of parental consent, we will erase that information as quickly as possible. If you reasonably believe that we might have any information from or about a child, or a child has directly provided us with personal information via the Website without verifiable parental consent, please contact us.

XII. CHANGES TO THE PRIVACY POLICY

In case we change our Privacy policy, we will post the changes on this page. Please check the Website regularly for any changes.

XIII. HOW TO CONTACT US

If you have any questions about this Privacy policy, please feel free to contact us via our “Contact Us” form available on the Website or via email at [email protected].

Copyright © 2018-2025 AIBY Inc.

Annex to Privacy Policy

U.S. Multistate Privacy Notice

INTRODUCTION. THE SCOPE OF APPLICATION

This U.S. Multistate Privacy Notice (“Notice”) supplements the information contained in Privacy Policy and may apply to individual residents of the U.S. states (“Covered U.S. Individual Residents”) that have enacted comprehensive data privacy laws including but not limited to California Consumer Privacy Act of 2018 (CCPA) as amended by California Privacy Rights Act of 2020 (CPRA), Texas Data Privacy and Security Act of 2023 (TDPSA), Virginia Consumer Data Protection Act of 2021 (VCDPA), Colorado Privacy Act of 2021 (CPA), Connecticut Data Privacy Act of 2022 (CTDPA) and others (collectively referred to as “U.S. State Privacy Laws” and separately as “U.S. State Privacy Law”). Notice addresses specific requirements common to U.S. State Privacy Laws and outlines additional information on the rights of Covered U.S. Individual Residents. It also describes how we collect, use, disclose and protect your personal information in compliance with these U.S. State Privacy Laws.

Applicability. Please note that if you are a user of our Website and a resident of one of the U.S. states where the corresponding U.S. State Privacy Law was enacted, you’ll be regarded a Covered U.S. Individual Resident and this Notice shall apply to you only if the processing of your personal data in connection with your use of the Website falls within the scope of such U.S. State Privacy Law. Please refer to the corresponding U.S. State Privacy Law for further details. If you are still unsure whether this Notice is applicable to you, please do not hesitate to contact us and we will spare no effort to assist you.

The correlation between Privacy Policy and Notice. This Notice does not replace and cannot be used interchangeably with Privacy Policy. On the contrary, Notice serves as a supplemental part of Privacy Policy for Covered U.S. Individual Residents.

The concept of personal data under U.S. State Privacy Laws. Applying Notice, you should also bear in mind that it pertains only to the processing of personal data which is understood as information linked or reasonably linkable to an identified or identifiable individual. Generally U.S. State Privacy Laws do not apply to the processing of de-identified, aggregated data or publicly available information, as these categories fall outside the scope of personal data.

THE CATEGORIES OF PERSONAL DATA PROCESSED. PURPOSES OF PROCESSING

Detailed information about the categories of personal data that may be processed when you use the Website is contained in Section II of Privacy Policy >>

To learn about the purposes of personal data processing please review Section III of Privacy Policy >>.

SHARING OF PERSONAL INFORMATION WITH SERVICE PROVIDERS (PROCESSORS). CLARIFICATIONS ON ISSUES OF DATA SELLING

U.S. State Privacy Laws require us to provide you with information about who we share your personal data with and for what purposes. You can find comprehensive data in this regard in Section IV of Privacy Policy >>. The legal entities indicated in Section IV of our Privacy Policy act as our “service providers” or “processors” within the meaning of U.S. State Privacy Laws and process your information on our behalf for business purposes. The examples of business purposes are the following: auditing related to current interaction with users, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions; providing customer service, advertising, marketing, analytic services; detecting security incidents; debugging; provision of Website services to users; improving, enhancing, upgrading the Website functionality. Please refer to the table in Section IV of our Privacy Policy to learn what specific services the processors/service providers perform for the Website. When we use the services of our processors/service providers and disclose your information for business purposes, we enter into corresponding written contracts with them. These contracts incorporate data processing provisions, parts, sections or annexes that require our processors/service providers not to use personal information transferred by us other than for the purpose of performing the services specified in the contracts. Additionally, the contracts with our processors/service providers specifically prohibit them from and/or do not contain permissions for selling the personal information transferred by us.

We do not “sell” you personal information for monetary gain, which means that we do not and will not disclose your personal information to third parties in direct exchange for money or some other form of payment. However, certain U.S. State Privacy Laws provide expansive definition of the term “sell”, which leads to cases where some disclosures of personal information to a third party even for non-monetary benefit of the disclosing party (“valuable consideration”) may qualify as data selling. In particular, sharing of personal information with third parties for the purposes of “interest-based advertising”/ “cross-context behavioral advertising” may constitute a sale under broad definition and interpretation of this and similar terms (“sell”/”selling”/”sold”) according to some U.S. State Privacy Laws. Even if such kind of data sharing qualifies as sale under U.S. State Privacy Law applicable to you, you’ll always have an option to opt out (see the subsection Instructions on Online Tracking Opt Out below for more details on available opt out mechanisms).

PRIVACY RIGHTS

If you are a Covered U.S. Individual Resident and this Notice applies to you, you’ll be able to exercise all user privacy rights specified in Section VII of Privacy Policy >>, particularly:

• the Right to Know (also referred to as the Right to Access);
• the Right to Data Portability;
• the Right to Correct Inaccuracies (also referred to as the Right to Rectification);
• the Right to Data Deletion (also referred to as the Right to Erasure or the Right to Be Forgotten);
• the Right to Restriction of Processing;
• the Right to Object to Processing of Personal Data.

User privacy rights listed above have similar content and exceptions in different jurisdictions. Their general meaning is addressed in Section VII of Privacy Policy. However, some minor aspects related to these rights may vary slightly from one jurisdiction/state to another, therefore, you may want to consider these differences when submitting your user privacy request.

Besides the rights referred to above, U.S. State Privacy Laws specifically mention the following additional data privacy rights you have:

The Right to Opt Out of the processing of the personal data for purposes of (a) targeted advertising, sometimes also referred to as “cross-contextual behavioral advertising” or “interest-based advertising”; (b) the “sale” or “sharing” of your personal data; (c) profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you. The specified Right to Opt Outis exercised with due regard to the context of our interaction with you as with the user of our Website and accompanying data processing activities. To learn the details on how you can exercise your Right to Opt Out, please refer to the subsection Instructions on Online Tracking Opt Out below.

The Right to Non-Discrimination. This right means that you will not receive discriminatory treatment for exercising your privacy right(s). Inter alia, we will not deny you the Website services, charge different prices or rates, or provide a different level or quality of services for you if you choose to exercise your user privacy right(s).

The Right to Appeal. If we deny and refuse to take an action on your initial user privacy request, you may have the right to appeal that decision under some U.S. State Privacy Laws. See the subsection How to Appeal Initial Decision Regarding Privacy Request below for more details.

HOW TO EXERCISE YOUR PRIVACY RIGHTS

Depending on the specific user privacy right you choose to exercise, different methods may be available to you.

In particular, when appropriate technical capabilities are accessible to you within the App and/or in your device settings, some rights (e.g. the Right to Correct Inaccuracies, the Right to Data Deletion, the Right to Opt Out) can be exercised by you independently without our assistance and the need to submit us the corresponding request. For instance, in certain circumstances the Website may provide you with a possibility to change, update, correct inaccuracies or delete certain pieces of your personal data via your Website account settings.

Instructions on Online Tracking Opt Out.

Further, there are a number of ways you can exercise the Right to Opt Out of data processing for the purposes of activities that under U.S. State Privacy Laws may qualify as targeted advertising; “sale” (under broad interpretation) or “sharing” of personal data; profiling. Follow the instructions below to stop online tracking activities across third party apps and websites and sharing your data with third parties for personalized ads.

Blocking Advertising ID use in your mobile device settings. Your mobile device settings enable you to make choices about the collection, use or transfer of your Advertising ID to third parties for the purposes of targeted advertising and/or ad measurement. To manage your activity tracking permissions and the use of your Advertising ID, please follow the relevant instructions in Section IX of our Privacy Policy >>.

Advertising Industry Opt Out Tools. Even if you block the access to and use of your Advertising ID, you might still see personalized ads from other companies and ad networks. You have an opportunity to send your opt out request to some of such other companies and ad networks who participate in self-regulatory programs using special Advertising Industry Opt Out Tools. See Section IX of our Privacy Policy to know which Advertising Industry Opt Out Tools you may choose to use >>.

Ad and Analytics Platforms Opt Out Mechanisms. Some third party ad platforms and analytics service providers have their own privacy management tools that allow you opt out and/or make your privacy choices directly. Here there are some examples:

• Google My Ad Center
• “About Facebook Ads” page
• AppsFlyer Opt Out page

Therefore, we recommend you to check the privacy options of our service providers (processors) regularly. The up to date list of our service providers (processors) is presented in Section IV of Privacy Policy >>.

Submission of a user privacy request to exercise privacy right(s)

To exercise any user privacy right that cannot be managed by you independently, please contact us anytime through our contact form with the corresponding privacy request. When submitting your request, please include in its text the phrase “Exercising my rights to maintain confidentiality in … State”, replacing '...' with the name of the state of your residence. We will make every effort to satisfy any request you make to exercise any of your privacy rights.

AUTHENTICATION OF USER PRIVACY REQUESTS. INSTRUCTIONS ON HOW TO APPEAL OUR INITIAL DECISION REGARDING YOUR PRIVACY REQUEST

When you submit any user privacy request via our contact form in order to exercise your privacy right(s), the relevant procedure of request authentication shall be put in place. The details and rules for such authentication procedure are provided below.

We shall comply with your user privacy request only if we are able to authenticate you as the user of our Website and as a Covered U.S. Individual Resident. Therefore, when submitting a verifiable user privacy request, you should be ready to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or such person’s authorized agent, which (depending on the circumstances) may include: name, address, city, state, zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming their authority to represent your interests or a power of attorney, signed by you.
• Describe your privacy request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your privacy request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity before taking any action with your privacy request. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scam request.

We ensure that personal information provided in a verifiable user privacy request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable user privacy request within forty-five (45) days of its receipt. If we require more time and it is reasonably necessary, we may extend the response period. In this case we will inform you of the reason and the applicable extension period in writing.

How to Appeal Initial Decision Regarding Privacy Request.

In cases when we have a reasonable basis, we may choose to decline to take an action regarding the user privacy request. For example, this may happen when we are unable to authenticate a request, or when the request is manifestly unfounded or fraudulent. In this particular case we’ll inform you of the justification for declining to take action within a reasonable period of time after receiving your initial request.

If we decline to take action with respect to your initial request, you may be entitled to appeal our decision under some U.S. State Privacy Laws. To do so, you will need to provide us with the missing information and explanations reasonably necessary to address your request effectively. Within the term prescribed by the applicable U.S. State Privacy Law we’ll inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for our decision.

CHANGES TO THIS NOTICE. FINAL PROVISIONS

We may update this Notice from time to time. To stay informed of updates, please review the latest published version of Notice regularly.

If you reasonably believe that certain U.S. State Privacy Law provides you with additional rights or options not outlined or referred to in this Notice, please contact us through our contact form. We will do our best to address all your concerns and reply to your request effectively.

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