Contact detail of personal data controller: WeMakeStuff, ID no. 0012435, with its registered seat at Estonia (“we”).

Contact information for communication with: privacy@readfluffy.com 

We are creators of ReadFluffy application (“App”) which is available on iOS and Andorid and by this Privacy policy, we would like to inform you about how we process your personal data through this App and when you use this App.

We recommend that you read this information carefully. If you have any questions, you can contact us at any time using the contact details below. As we are company located in European union, the processing of personal data is governed by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”). We do not have appointed data protection officer as we are not required to have it under GDPR.

• TABLE OF CONTENTS

Our goal is to ensure maximum transparency in the processing of your personal data. We have divided this document into the following sections:

• the personal data processed, including examples of the data processed (part B);
• the purposes of the processing of personal data, as well as the legal bases and periods of processing (part C);
• data retention (part D);
• sharing of personal data (part E);
• Your rights in data processing and how to exercise them (part F);
• amendments to this document (part G).

• PERSONAL DATA PROCESSED

When you use our App, personal data may be processed. As we want to be as transparent as possible, we divided personal data that we process about you as personal data controller into these categories:

• Identifiers, such as your name/nickname.
• Contact info, such as your e-mail address.
• Purchases information, such as payments made and records of payments made according to the subscription.
• User content, such as text, messages, created content, characters, stories and other content data created by you.
• Usage data, such as launches, taps, clicks, scrolling, views.
• Diagnostics data, such as crash logs, launch time, energy use, technical information about your device.

Please, do not use our App to upload any sensitive information about you, such as health data, genetic data, biometric data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning sexual orientation. If you decide to use the App and create story or character about existing natural person, you are solely responsible for having legal grounds of processing of his/her personal data.

By downloading or installing the App, you declare that you are older than 13 years old and are solely responsible for any damage or loss that we may suffer because of his untruthful declaration. If you are younger than 13 years old, only your legal representative may create you an account.

Data are gathered directly from you or from your usage of the App (from your device). The App does not use data from HealthKit, HomeKit, the Clinical Health Records API, MovementDisorder APIs, or depth/facial mapping tools.

• PURPOSES OF THE PROCESSING OF PERSONAL DATA

We will use your personal data to provide you with the services you requested, which may also include e-mail notification and newsletters, ensure customer communication and functionalities of the App etc. All purposes and usage of data is stipulated in this part C of the Privacy policy where you can find for what purposes we use your data, what type of data is processed and what is the data retention for processing. 

We will not sell your data to third parties, but we may share it with our partners who help us provide our services (see Part D of this Privacy Policy).

In this section, we describe the processing of your data related to the provision of our App.

Processing of personal data in our App

• Provision of App functionalities

We primarily process personal data to provide you with our App and to treat you as a customer, when you download the App and agree with our Terms & Conditions, use functionalities of the App, create stories and characters, or when you pay for any service connected with App. Personal data is processed to authenticate you as the user, enable our features, customize what you use, ensure functionality of our App. As part of this, we may also send you messages and e-mails (e.g. e-mail verification, notification about changes in this privacy policy etc.).

For this purpose, we process these categories of personal data:

• Identifiers, Contact info, Purchases information, User content, Usage data.

The legal basis for this processing is the performance of the contract between you and us and the need to take steps at your request before entering the contract.

The data are processed for the duration of the mutual relationship and for the period necessary for the performance of the obligations under such contract, or if no contract is concluded, until the expiry of 6 months from the acquisition of the data. You can delete your account at any time in the App.

• Internal records, statistics, and protection of our rights

We may process your data for the purposes of keeping internal records within our company, recording payments made, producing statistical reports, protecting our rights and legal claims, and to ensure that you use our App in accordance with their terms and with general legal obligations.

For this purpose, we process these categories of personal data:

• Identifiers, Contact info, Purchases information, User content, Usage data, Diagnostics data.

The legal basis for this processing is our legitimate interest in keeping internal records, statistics, and the protection of our rights. The data is processed until a maximum of 10 years after the termination of the concluded contract (or longer in the event of a dispute).

• Support and promotion of our products and services

We may process the data you provide when you register your user account in the App.

For this purpose, we process these categories of personal data:

• Contact info.

The legal basis for this processing is our legitimate interest in supporting and promoting our products and services or your consent that you will provide to us when subscribe on our website or in the App. The data is processed until a user account in the App is terminated or as stipulated in the consent.

In addition to objecting to the processing of data for this purpose (see F.7), you may opt out of receiving any newsletters at any time by using the unsubscribe links provided in the footer of each message sent.

• Fulfilling legal obligations

We may also process your personal data to comply with our legal obligations, particularly in the area of tax and accounting. At the same time, we need to be prepared to provide cooperation to state authorities if we are required to do so by law.

For this purpose, we process these categories of personal data:

• Identifiers, Purchases information, Usage data.

The legal basis for this processing is the fulfilment of our legal obligations. The data is processed for the period required by law.

Processing related to technical functioning of App

• App operation and security (a necessity)

We process your personal data for the operation of the App and its security, i.e. for the presentation of information in the App, the internal functioning of the App, your identification as a user when using and repeated visits to the App, and for ensuring your security.

For this purpose, we process your:

• Usage data and Diagnostics data

The legal basis for this processing is our legitimate interest in the proper functioning and safe operation of our App. Data are processed, as a rule, for the duration of your visit the App, for a maximum of 1 year from the date of collection.

• DATA RETENTION

Personal data are stored within the period stipulated for each purpose in part C of this Privacy policy. Generally, we will retain your personal data for the length of time needed to fulfill the purposes outlined in this Privacy policy unless a longer retention period is required or permitted by law (e.g., for the establishment, exercise or defense of legal claims). When the data retention period expires for a given type of data, we will delete or destroy it.

You may also request for your data to be deleted by contacting us on contact e-mail stipulated above. We will assess your request in accordance with part F.4 of this Privacy Policy.

• SHARING OF PERSONAL DATA

We may share your personal data with other companies in our group who also process data in accordance with this document and helps us with better analytics.

At the same time, we may share personal information with third parties who help us provide our App to you. These parties act as our data processors and process personal data for us, within the scope of our processing purposes set out above. Those data processors may be:

• HubSpot Ireland Limited - CRM and marketing automation platform used for email campaigns, notifications and tracking user interactions. Data may be transferred from the EU/EEA to HubSpot, Inc. in the United States. Transfers rely on the EU–US Data Privacy Framework.
• Google Ireland Limited – Google Analytics – EU based company. Personal data may be transferred to Google LLC in the United States. Google LLC is certified under the EU–US Data Privacy Framework.
• Functional Software, Inc. - Error and crash monitoring service (Sentry) used to log application errors and performance issues. Provider established in the United States. Functional Software, Inc. participates in the EU–US Data Privacy Framework.
• Google Ireland Limited and Apple Distribution International Limited for payment services – EU based companies.
• Convex, Inc. - Backend platform and database/storage provider (Convex) used to host application data, including user account data and other personal data processed within the app. Part of the Data Processing Agreement are also SCCs.

In addition to this, if we process your personal data for fulfilling legal obligations, we may share your personal data with certain third parties as data controllers for this purpose where we are obliged to do so under applicable legislation (in particular, administrative authorities, police authorities and judicial authorities). Similarly, we may be obliged to share your data with persons who claim to have been harmed by your conduct.

We hereby confirm that any third party with whom our App shares personal data, such as analytics tools, advertising networks (if used) and third-party SDKs, as well as any parent, subsidiary or other related entities that will have access to personal data, will provide equal protection of personal data as stated in this Privacy policy. We do not transfer or disclose your information to third parties for purposes other than the ones provided in this Privacy Policy (Part C of the Privacy policy)

Where we share your personal data with controllers and processors in third countries (outside the EEA), we only do so where there is a decision by the European Commission that a particular country outside the EEA provides an adequate level of data protection, including where controllers or processors have adopted additional data protection measures such as Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs).

• YOUR RIGHTS IN PROCESSING AND THE POSSIBILITY OF EXERCISING THEM

Just as we have rights and obligations when processing your personal data, you have certain rights when processing your personal data as set out in the following paragraphs.

In all matters related to the processing of your personal data, whether it is a question, the exercise of rights, sending a complaint to our hands, etc., you can contact us at privacy@readfluffy.com.

Your request will be processed without undue delay, at most within 1 month. In exceptional cases, due to the complexity of your request, we are entitled to extend this period by a further 2 months. We will, of course, always inform you of any such extension and the reason for it.

You also have the right to lodge a complaint with the supervisory authority as described below.

• Right of access

You have the right to obtain confirmation from us as to whether we are processing your personal data.

If we process your personal data, you also have the right to request access to information about the purpose and scope of the processing, the recipients of the data, the duration of the processing, the right to rectification, erasure, restriction of processing and to object to the processing, the right to lodge a complaint with a supervisory authority and the sources of the personal data (this information is already provided in this document).

You can also ask us for a copy of the personal data we process. We provide the first copy free of charge; further copies may be subject to a fee. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.

• Right to withdraw consent

You have the right to withdraw your consent to the processing of personal data at any time. However, the withdrawal of consent does not affect the lawfulness of the processing prior to such consent, nor does it lead to the termination of the processing of personal data that has already been anonymized.

• Right to repair

You have the right to request us to correct inaccurate personal data concerning you. Depending on the purpose of the processing, you may also have the right to have incomplete personal data completed, including by providing an additional declaration.

• Right to erasure (right to be forgotten)

You have the right to request the deletion of your personal data in cases where:

• we no longer need your personal data for the purposes for which it was collected or processed;
• you withdraw the consent based on which the personal data was processed and there is no further reason for processing it:
• you object to processing and there are no other overriding reasons for processing, or you object to processing for direct marketing purposes;
• personal data is processed in violation of the law.

However, you cannot exercise this right where the processing is necessary for compliance with our legal obligations or tasks entrusted to us in the public interest or for the establishment, exercise, or defense of legal claims.

• Right to restriction of processing

You have the right to request restriction of the processing of your personal data in cases where:

• you contest the accuracy of your personal data; in this case, you may request a restriction of processing until the accuracy of the personal data has been verified;
• the processing is contrary to the law and instead of erasure, you request a restriction of the processing of personal data;
• we no longer need your personal data for the purposes for which it was collected or processed, but you require it for the establishment, exercise, or defense of legal claims;
• you have objected to the processing of your personal data; in this case, you may request a restriction of processing until it is verified that our legitimate interests prevail.

• Right to portability

You have the right to obtain a copy of your personal data that we process by automated means based on your consent or for the performance of a contract. We will transmit this data in a commonly used and machine-readable format to you or to a controller designated by you, if technically feasible. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.

• Right to object

You have the right to object to the processing of your personal data that we process based on our legitimate interest. We will stop processing your data if there are no other overriding reasons for processing or if the processing is not necessary for the establishment, exercise, or defense of legal claims or if you object to processing for direct marketing purposes.

• Right to file a complaint

In addition to the possibility of exercising your rights with our company, you can also file a complaint with the relevant supervisory authority, which is the Office for Personal Data Protection located at Pplk. Sochora 27, 170 00 Prague 7.

• CHANGES TO THIS INFORMATION

We are entitled to change this processing information from time to time, so please check it regularly. We will post any changes to this document on our website.

COOKIES POLICY

Contact e-mail for privacy matters: privacy@readfluffy.com

This Cookie Policy explains how we use cookies and similar technologies on our website https://readfluffy.com (“Website”). It should be read together with our Privacy Policy, which explains in more detail how we process personal data in general.

By “cookies” we also mean other technologies that may store or read information from your device (such as local storage or similar identifiers), unless stated otherwise.

WHAT ARE COOKIES AND WHAT TYPES DO WE USE?

Cookies are small text files that are stored on your device when you visit a website. On each subsequent visit, the browser sends cookies back to the website or to another website that recognizes them.

Cookies can perform a number of functions, such as enabling the proper functioning of the Website, remembering your choices and preferences, or helping us and our partners analyze how the Website is used and display relevant advertising.

We use the following basic types of cookies:

1. Strictly necessary cookies

These cookies are essential for the proper functioning and security of the Website and cannot be switched off in our systems. Without them, the Website may not work properly. They are usually set in response to actions made by you, such as setting your privacy preferences or filling in forms.

1. Preference (functional) cookies

These cookies allow the Website to remember your choices (such as language or region) and provide more personal features. If you disable them, some parts of the Website may not function properly or in a personalized way.

1. Analytics cookies

These cookies help us understand how visitors use our Website, which pages are most popular and how users move around the Website. The information collected is aggregated and used to improve our services and user experience.

1. Marketing cookies

These cookies may be set through our Website by us or our partners to build a profile of your interests and show you relevant advertising on other sites. They work by uniquely identifying your browser and internet device.

PURPOSES OF USING COOKIES

Strictly necessary cookies

• Purpose: To ensure the operation, security and basic functionalities of the Website, to prevent abuse, to remember your cookie choices.
• Legal basis: Our legitimate interest in operating a secure and functional Website, or the necessity for the provision of an online service you request.

These cookies are set automatically when you visit the Website and cannot be refused via the cookie banner. You can, however, disable them in your browser, but the Website may then not function properly.

Preference, analytics and marketing cookies

• Purpose:
  • to remember your preferences and settings;
  • to create statistics about the use of the Website and understand how visitors interact with it;
  • to personalize marketing communication and show you relevant advertising on our Website or third-party websites.
• Legal basis: Your consent.

These cookies are only used if you give your consent via the cookie banner or through our cookie settings tool (once implemented). You can withdraw your consent at any time.

COOKIES USED ON OUR WEBSITE

Below you will find an overview of the main cookies we use. The list may change as we update or extend the Website and our tools.

1. Strictly necessary cookies

2. Preference (functional) cookies

3. Analytics cookies

4. Marketing (and related analytics) cookies

Note: The exact cookies, their lifetimes and providers may change over time. The current list will be updated in this Cookie Policy when we make significant changes.

Where legally required, we will use a consent management mechanism which allows you to:

• accept all cookies;
• refuse all non-essential cookies;
• customize your preferences by cookie category.

You can change your preferences or withdraw your consent at any time through the cookie settings link available on the Website (for example in the footer or via a visible icon). Withdrawing consent will not affect the lawfulness of processing before the withdrawal, but we will stop using the relevant cookies from that moment onwards.