T-Me Studios App Privacy Policy

1. Scope of This Policy

1. This Policy (together with our Terms of Service as set out at the web address http://timmystudios.com/terms-of-use.html and any additional terms of use incorporated by reference into the TOS, (our "TOS")) applies to your use of:

1. Our mobile application software ("Apps") available online from the app stores where we publish the Apps ("App Site"), once you have downloaded a copy of an App onto your mobile telephone or handheld device ("Device"); and

2. Any of the services accessible through the Apps ("Services") that are available on the App Site or other sites of ours ("Services Sites").

2. This Policy sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we will treat it.

3. For the purpose of the 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 (General Data Protection Regulation), the data controller is Lemur Labs SRL of Str. Jean Louis Calderon 70m, Bucuresti, 020039 Romania.

2. A Special Notice About Children

• Children Under 16 Years of Age
  Children under the age of 16 are not eligible to use the apps unsupervised, and we ask that children do not submit any personal information to us. If you are under the age of 16, you may only use this Platform in conjunction with, and under the supervision of your parents or guardians.

• Children Under 13 Years of Age
  Children under the age of 13 are not eligible to use the apps.  Only parents or legal guardians can submit personal information to us about a child.

By visiting our Site and/or using our apps, or by including children under the age of 13 years old in our provided services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

If we learn we have collected Personal Information from a User under the age of 13 without parental consent, we will delete that information as quickly as possible.

3. Data Processing & Your Consent

 In order for us to process your personal data and/or your sensitive personal data in the way described in this Policy, we will usually need your permission to do so.  There are, however, statutory exceptions to this requirement in certain circumstances.

 By registering, installing, activating, or using our Apps and/or the Services, you expressly consent to our collection, storage, use, and disclosure of your information as described in this Privacy Policy.

Under the TOS or any end-user license agreement or other agreement entered into between us in relation to the provision of the Services to you and/or your use of an App, the processing of your personal data will be further provided for and permitted to the extent reasonably necessary for the performance of that contract, subject to the terms of this Policy.

If you do not accept the terms of this Policy and/or our TOS, you must not use any of the Apps or the Services.

4. Information We May Collect from You

We may collect and process the following data about you:

Information you give us (“Submitted information”)
You may give us information about you by filling in forms on the App Site and the Services Sites (together the "Sites"), or by corresponding with us (for example, by e-mail). This includes information you provide when you register to use the App Site, download or register an App, subscribe to or use any of our Services, search for an App or Service, make an in-App purchase, share data via an Apps' social media functions, and when you report a problem with any App, our Services, or any of our Sites. The information you give us may include your name, address, e-mail address, and phone number, contact book data, the Device's phone number, age, username, password, and other registration information. If you use your Facebook account or other third-party social network accounts to register for the Services, we will collect your Facebook account or other third-party social network account information.

Information we collect about you and your Device (“Collected Information”)
Each time you visit one of our Sites, use one of our Apps or use any of our Services we may automatically collect information about you.  This may include the following information:

• technical information including the type or model of mobile Device you use;

• a unique Device identifier (for example but not limited to, your Device's IMEI number, the MAC address of the Device's wireless network interface, the mobile phone number used by the Device, or your Device’s Android identification number);

• mobile network information;

• your mobile operating system;

• the type of mobile browser you use;

• resolution, screen size;

• system version;

• Bluetooth settings;

• internet connection;

• RAM;

• history of app usage, the apps you have installed, the apps you have running in the background, the apps you launch, the apps you have running in the foreground;

• your mobile Device’s Android advertising identification number;

• your account activation time or time zone settings;

• the content displayed to you and whether you clicked on it;

• advertisements displayed to you and whether you clicked on them;

• notifications that have appeared on your mobile Device;

• your IP address;

• your mobile country code;

• your identity;

• and Device event information such as crashes, system activity, hardware settings, and the date and time of your request;

• if you access the Apps or Services through a mobile device, we may be able to identify the general location of your mobile device;

• details of your use of any of our Apps or any of our Services or your visits to any of our Sites and any other resources that you access or download;

• depending on the app/service you are using as well as the operating system on your Device we might also request access to your photos, media, and files, your Device’s camera, your Wi-Fi connection information, and your Device identification, missed calls, SMS and call information.

Information we receive from other sources (independent data controllers). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, search information providers, credit reference agencies) and may receive information about you from them. We may work with third-party analytics services, including for example Google/Firebase  Analytics, Facebook Analytics, Admob, Adjust, and Apps Flyer to help us understand how our Services are being used, such as tracking the frequency and duration of use of our Services. These services may collect information about the content you view, the websites you visit immediately prior to and after visiting an App Site or using the Services, and your system information and geographic information. The information generated about your use of the Services will be transmitted to and stored by the applicable analytics services based on their own Privacy Policies which we recommend that you read.

5. How We Use Your Information

We use information held about you in the following ways:

Submitted Information may be used for the following purposes:

•  to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us (contractual obligation);

•  to provide you with information about other goods and services we offer that are similar to those that you have already downloaded, used, purchased or enquired about (legitimate interest);

•  to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing user, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those you have previously used. (legitimate interest) If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;

•  to respond to inquiries, where in such circumstances, we may keep a record of your communication to help solve any issues you might be facing (legal obligation);

•  to notify you about changes to our service (contractual and legal obligation);

•  to ensure that content from our Services and Services Sites is presented in the most effective manner for you and for your Device (legitimate interest).

 Collected Information may be used for the following purposes:

• to administer our Services and Services Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (legitimate interest);

•  to help us better understand how our products and services are being used (legitimate interest);

• to improve our Services and Services Sites to ensure that content is presented in the most effective manner for you and for your computer. This could include automatic decision-making, for example showing different content inside the app in different countries, based on what kind of content other users from each country engaged more with (legitimate interest);

• to improve the design of our products and services and improve user experience (legitimate interest);

• to allow you to participate in interactive features of the Services, when you choose to do so (consent);

• as part of our efforts to keep our Services and Services Sites safe and secure (legitimate interest);

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them (consent through course of action). Clicking on the links is your own choice and you will be taken to sites not controlled by Us.

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

6. When We Share Your Information

We may disclose personal data to third parties in the following circumstances:

a) Our entities within the Mocha Global group of companies.

b) Affiliated Entities: In order to provide our services and for our marketing attribution purposes. Media attribution is the practice of establishing which media channels are the most efficient with regard to advertising engagement.

c) Service Providers: We share Personal Data with some of our service providers such as Google Firebase, subject to contract terms that limit their use of Personal Data. We may have service providers that provide services on our behalf, such as media attribution, identity verification services, website hosting, data analysis, marketing services, information technology, and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf and will always comply with legal requirements. We require such service providers to contractually commit to protecting the security and confidentiality of Personal Data they process on our behalf. Our service providers are located in the European Union and the United States of America.

d) Corporate Transactions: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, subject to the terms of this Privacy Policy.

e) Compliance & Harm Prevention: We share Personal Data as we believe necessary: (i) to comply with applicable laws such as GDPR, CCPA, and others; (ii) to enforce our contractual rights; (iii) to protect our Services, rights, privacy, safety, and property; and (iv) to respond to a request from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

Some of the service providers mentioned above may be located abroad and, in this case, we adopt additional safeguards to guarantee an adequate level of protection for your personal data.

7. Where We Store Your Personal Data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

In accordance with the GDPR, when we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific controls approved by the European Commission which give personal data the same protection it has in Europe.

8. For How Long We Store Your Personal Data

8.1 The data that we collect from you may be stored and processed for up to 180 days after you stop using our apps.

8.2 You have the right to request the deletion of your personal data, and you can do so from inside the app's menu. If you request the deletion of your personal data, we will retain your personal data for no longer than 30 days after you request deletion.

8.3 You have the right to withdraw consent for the processing of your personal data, and you can do so from inside the app's menu. If you withdraw your consent, your data will no longer be collected, and we will retain your personal data for no longer than 30 days.

9. Security

To ensure that your personal information is secure, we communicate our privacy and security guidelines to all employees and business partners and strictly follow precautionary measures regarding privacy within the company.

We strive to protect your personal information through physical, technical, and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure, and improper alteration of this data.

We make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical technical or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on our Site or through other forms of communication.

10. Your Rights Under the GDPR (If You Are a Data Subject in the EU)

Under the law, you are granted six fundamental rights when data about you is being processed. We will ensure to reach out without undue delay (no more than 30 days) when you submit a request related to exercising your data subject rights. Although uncommon, when applicable for official or legal reasons we may be unable to address the specific request you make related to your rights.

Also, if a request is manifestly unfounded or excessive, in particular, because of their repetitive character, we may either:

• charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested; or

• refuse to act on the request.

In this scenario we will inform you of the reasons we believe your request is manifestly unfounded or excessive character of the request.

As a data subject, you have the right to:

a) The right to request confirmation of whether we processes Personal Data relating to you, and if so, to request a copy of that Personal Data;

b) The right to request that we rectify or updates your Personal Data that is inaccurate, incomplete, or outdated;

c) The right to request that we erase your Personal Data in certain circumstances provided by law;

d) The right to request that we restrict the use of your Personal Data in certain circumstances, such as while we consider another request that you have submitted (including a request that we make an update to your Personal Data);

e) The right to request that we export your Personal Data that we hold to another company, where technically feasible;

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or:

• In some cases, you may also have the right to object to the processing of your Personal Data.

• To exercise your data protection rights please contact our DPO at dpo@tappa.com.  

We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.

11. California Privacy Rights

This section applies only to California consumers. The California Consumer Privacy Act (CCPA) is a data protection law that ensures you have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

• Right of Access: you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months. 

• Right of Deletion: you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

• Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.

You also have the right to opt out of the sale of personal information. In the preceding 12 months, we have not disclosed your personal information to any third party in a manner that would be considered a sale under the CCPA.

For more details on the personal information collected in the preceding 12 months, see our sections above How We Collect Your Information and Which Information We Collect About You. We collect this information for business and commercial purposes as described above in How We Use Your Data section. Information about which categories of third parties we share this information with is described above in How We Disclose Personal Data.

California consumers can make a request related to the above-noted rights by emailing us at dpo@tappa.com.  

12. Third-party Websites & Social Media Services

 The Services may include links to third-party websites and social media services where you will be able to post comments, stories, reviews, or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

We accept no liability howsoever arising for the content, accuracy, or reliability of any third-party materials or websites, or social media services, or any part of them, which may be referenced from time to time by link or other means at this site or otherwise via the Services or for the data collection and use practices or security measures exercised by third parties.

13.  Changes to This Policy

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next start an App or log onto the Services or one of the Sites. The new terms may be displayed on-screen, and you may be required to read and accept them to continue your use of the Apps or the Services.

14.  Contact Us

14.1  Questions, comments, and requests regarding this Policy are welcomed and should be addressed to dpo@tappa.com.