Privacy Policy

Privacy Policy

LAST UPDATED AND EFFECTIVE: January 27, 2023

Preamble

Please read the following terms of this Privacy Policy (this “Policy” or these “Terms”) carefully. The Policy describes to users (“User,” or “Users,” or “you”) how the DataClue GmbH (“Company”, “Plearny”, “DataClue”, “DataClue GmbH”, “we,” “us” or “our”) collects, uses, discloses, safeguards, or otherwise processes personal information (the terms “personal data” and “personal information” will be used to mean any information that is able to directly or indirectly identify you, which might differ slightly depending on the laws that apply where you are located) and other data we receive from Users using the Company’s website, mobile app, products and services (the “Services”). If you do not agree with the terms of this Policy, please do not access the website.

The Company is committed to protecting the privacy and security of visitors to this website. The Company does not collect personal information when you visit this website unless you choose to provide that information. Outlined below is the Company’s online privacy policy. If you have questions about this policy, please contact support@plearny.io.

This Privacy Policy (this “Policy” or these “Terms”) applies to the Company’s hosted product platforms and websites owned and operated by the Company, including, but not limited to all mobile game apps and the website plearny.io. Throughout this document, this website, and all other Plearny websites and services like mobile games and mobile apps will be collectively referred to as the (“Websites”). Services provided by or enabled via the Websites will be referred to as the (“Services”).

This Policy shall become effective when the User clicks on button during the app installation process and/or account creation process and by doing so, you agree that you have read and understood the terms of this Policy. If you do not agree with these terms or if you are younger than eighteen (18), you are prohibited from registering for any of our user accounts or from using any of our apps or Services.

Company may update this Policy when necessary to provide greater transparency or in response to:

-Feedback from customers, regulators, industry or other stakeholders

-Changes in our products

-Changes in our data processing activities or policies

The Company reserves the right to make changes to this Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Policy. You are encouraged to periodically review this Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the websites and Services after the date such Privacy Policy is posted.

 

1. Controller

The controller and provider of our mobile apps held under DataClue GmbH, including “Plearny” or variants, (each and jointly “App”) is

DataClue GmbH and its brand Plearny

DataClue GmbH
Bavariafilmplatz 8
D-82031 Grünwald
Germany

This Policy also names other controllers that process your personal data.

E-mail address: contact@plearny.io

Phone: +49 89 9542 864-30

2. Data Protection Officer

We appointed a data protection officer who can be reached via email at: dataprotection@plearny.io

Robin Eckardt
DataClue GmbH
Bavariafilmplatz 8
D-82031 Grünwald

3. Personal Data and Processing Purposes

Personal data includes any information relating to an identified or identifiable natural person. We collect information you provide directly or indirectly to us, such as when you create or modify your account, request on-demand services, redeem your rewards in our online shop, contact customer support, or otherwise communicate with us. This information may include: name, email, mailing address, age, gender, social media profiles, phone number, Amazon and PayPal information. During the registration process, we will also collect information such as your IP address and Google Advertising ID (together, the “ID”).

We will only collect your personal data as described in this Policy and will not use or otherwise process your information for any other purposes than described in this Policy.

When you use our Services, we may also collect information about how you interact with the games advertised on our platform. The type of information we collect relates to: i) achievements that are unlocked, ii) in-game purchases, iii) other apps on your device, iv) the time you spend playing games, v) the units you’ve earned in various games, and vi) the game experience earned (collectively “User Gaming Profile”).

For all users eighteen (18) years old or above, when redeeming a reward through the Company’s shop, we may verify your face via a ‘video selfie’ using a third-party face verification technology. We use this information exclusively for the purpose of fraud prevention and to ensure that prizes are not earned through bots, automated processes or fraudulent use of software.

By using our mobile application and accepting this Policy, you understand that requesting a reward within the shop in our mobile application will only be possible upon additional user authentication obtained via face verification technology.

Upon redeeming a reward from our shop, you will be prompted to provide a video selfie using your mobile device’s camera. This video selfie provides us with a face map (a mathematical representation of your face generated through our third-party provider, Facetec, Microsoft or AWS). This video selfie is encrypted on your mobile device before being sent to our servers for processing, and is linked to your user account to ensure the uniqueness of your user registration within the mobile application. If you do not want to redeem rewards through the shop, you can use all other features of the mobile application without providing a video selfie to the Company.

Upon accessing and when using the Services, certain information will be required to provide the Services and automatically collected, such as:

  • usage information;
  • the session ID;
  • the time and date you access the mobile app; and
  • device information and geolocation data.

We will only collect, use and/or pass on personal data if this is permitted by law or if you give your prior written consent. Applicable legal provisions are, in particular, those of the regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, repealing the directive 95/46/EC, on the protection of individuals with regard to the processing of personal data, on the free movement of such data (“General Data Protection Regulation”, GDPR) as well as in the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the German Telemedia Act (Telemediengesetz, TMG).

Your data will be used for the following purposes:

  • to create and manage your accounts,
  • to provide you with the functionality of the App,
  • to facilitate your access to and use of the Services, including personalizing the Services, features and content,
  • to answer any written requests, you send to us or to send you emails regarding your account,
  • to implement this Policy and carrying out the contractual relationship with you,
  • to analyze your use of our App and improve our App and Services with our legitimate interests of quality assurance and marketing,
  • to analyze your use of the App and cooperate with our advertising partners with the legitimate interest of marketing,
  • as otherwise explained in this Policy or by any communication by us,
  • to compile anonymous statistical data and analysis for use internally,
  • account creation,
  • to ship items that you have ordered from our online shop,
  • enabling you to redeem rewards earned on our platform,
  • to perform internal operations, including, conducting data analysis, testing and research and to troubleshooting software bugs and operational problems,
  • to monitor and analyze usage and activity trends,
  • personalization of ads to provide you with better recommendations of advertised games in your country and to help you earn rewards,
  • to increase the efficiency and operation of the application and Services,
  • to resolve disputes and troubleshoot problems or issues,
  • to help diagnose technical problems,
  • for legitimate interests under section 6(1)(f) of the General Data Protection Regulation (GDPR), including fraud prevention purposes, protection against abuse of our Services, and to guarantee that the use of our Services are in accordance with the Company’s Terms of Use, and
  • to communicate with you about our products, Services, promotions and news (we will only send you these materials if we have your written consent and you can unsubscribe any time);

Additionally, personal data may be used and disclosed to the extent Company may deem reasonably necessary to enforce the terms of any agreement between you and Company, or to protect the rights, property or safety of any person or entity, or if required by law, specifically in response to a demand from government authorities.

In the event you refrain from providing such data you may face disadvantages, for example, limited or no possibility of using our App or Services.

 

4. Download and Usage of the App

When using our App, we collect the personal data described below to enable convenient use of the functions. If you want to use our App, we collect the following data, which is technically necessary for us to offer you the functions of our App and to guarantee stability and security (legal basis is Art. 6 (1) f. GDPR): IP address, unique device ID, location, date and time of the request, time zone difference to Greenwich Mean Time (GMT), content of the request (specific page), access status/HTTP status code, amount of data transmitted in each case, app usage data, operating system and its interface language.

The legal basis for our processing of this data is Art. 6 (1) b. GDPR on the basis of the existing contract with the app store and us.

 

5. Registration for the App; Facebook Connect; Google

Furthermore, we need your email address in order to create and manage your account, to process your enquiries and, if necessary, to be able to contact you.

If you register via Facebook (facebook.com) we process your email address and name from your user profile on Facebook after you have clicked the respective button. For further details on data processing on Facebook please refer to: https://www.facebook.com/full_data_use_policy

The legal basis for our processing of data is Art. 6 (1) b. GDPR based on the existing contract with us or your consent to use such data based on Art. 6 (1) a. GDPR.

You may change the email address provided by contacting support@plearny.io at any time.

 

6. Usage of the App

For using additional functions of the App or Services you may be asked to provide us with certain data. Such data will only be sent and provided to us after you clicked the respective submit button to grant permission within the App.

If you are using additional paid options in our App we may ask for your full name and address details. However, please note that we do not process your payment data and bank account details, but use external providers that handle the payments.

You may delete and change entered data at any time via message to:

dataprotection@plearny.io

If the data processed for providing the App services are considered personal data, such data processing is based on Art. 6 (1) b. or f. GDPR for the purpose of providing our service and analyzing those data based on our legitimate interests of improving our product and research purposes.

 

7. Advertising Partners and use of the Advertising ID

We and our advertising partners may also use the information collected, including your personal data, for marketing/advertising purposes.

For these purposes, the following data may be collected and used:

GAID / IDFA, IP address, location / time zone and locale settings (country and preferred language), carrier, operating system, network connection type and speed, device properties related to screen size and orientation, audio volume and battery, device memory usage, Internet browser user-agent used to access the services, device make, model and operating system.

The so-called ‘Advertising Identifier’ (IDFA) or ‘Google Advertising Identifier’ (GAID) is a unique, but non-personalized and non-permanent identifier for a specific device provided by iOS or Android. Data collected through such identifier is not linked to any other device-related information. We as well as our advertising partners use the identifier to provide you with personalized advertising and to evaluate your use. If you activate the option [‘no ad tracking’ / ‘Ads’] in the iOS/Android settings, we can only take the following actions: Measuring your interaction with banners by counting the number of times a banner is displayed without clicking (‘frequency capping’), click rate, unique user detection, security measures, fraud prevention and troubleshooting. You can delete the IDFA / GAID at any time in the device settings, then a new IDFA / GAID will be created which is not merged with the previously collected data. Please note that if you limit the use of the identifier, you may not be able to use all the features of our Apps.

For more information, contacting details about such advertising partners as well as their privacy guidelines please refer to:

  • AppLovin by AppLovin Corporation, 849 High St., Palo Alto, CA 94301, USA: https://www.applovin.com/privacy/ and https://dash.applovin.com/assets/pdf/dpa.pdf;
  • Facebook by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA / Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland: https://www.facebook.com/full_data_use_policy; https://www.facebook.com/ads/manage/audience_network/publisher_tos/ and https://www.facebook.com/legal/terms/dataprocessing;
  • Google by Google LLC, Mountain View, CA, USA / Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland: https://policies.google.com/privacy?hl=en;
  • Fyber by the Fyber Group (Fyber N.V., Fyber Monetization Ltd., Fyber GmbH, Fyber Media GmbH, Fyber RTB GmbH, Advertile Mobile GmbH, and Heyzap Ltd.): https://www.fyber.com/privacy-policy/;
  • InMobi by InMobi Pte Ltd, Embassy Tech Square, 7th Floor, Block Delta, B Block, Kadubeesanahallli Village Outer Ring Road, Varthur Hobi, Bengaluru, 560103, India: https://www.inmobi.com/privacy-policy-for-eea/;
  • IronSource by ironSource Mobile Ltd. 121 Menachem Begin Rd., Tel Aviv, Israel: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/;
  • MoPub by MoPub Inc. as a division of Twitter, Inc., 1355 Market Street #900, San Francisco, CA 94103, USA: https://www.mopub.com/legal/privacy/;
  • AdColony Inc, 1888 Century Park East, Suite 1450, Century City, CA 90067:

Privacy Policy

  • Vungle by Vungle Inc, 1255 Battery Street, Suite 500, San Francisco, CA, 94111, United States:
    https://vungle.com/privacy
  • MyTarget by My.com B.V. located at Barbara Strozzilaan 201, 1083HN, Amsterdam, the Netherlands:
    https://legal.my.com/us/mytarget/privacy/

Such data processing is performed to ensure the technical functionality of our services fulfillment of contractual or pre-contractual obligations (based on Art. 6 (1) b. GDPR or TMG and as otherwise explained in this privacy policy) or improving our product and perform marketing activities (based on Art. 6 (1) f. GDPR). Regarding the data processing based on Art. 6 (1) f. GDPR we wish to achieve the legitimate interests of marketing. If legally required such data processing shall be based on your explicit consent (Art. 6 (1) a. GDPR).

OPT-OUT:

You may de-activate the processing of data for such advertising and marketing purposes via message to:

dataprotection@plearny.io

 

8. Analysis of your data

We (as well as third party providers engaged by us) may also use the information collected, including your personal data, for the purpose of marketing and improving our Apps. For this purpose, your personal data, such as the IP address, the ‘Advertising Identifier’ (IDFA) or ‘Google Advertising Identifier’ (GAID) as well as further use data may be used.

For more information, contacting details about such third party service providers engaged by us for such purposes as well as their privacy guidelines please refer to:

  • ‘Tenjin’ by Tenjin, Inc., 333 Bryant St., Suite 100, San Francisco, CA 94107; more information:

https://www.tenjin.io/privacy/;

  • ‘Unity 3D’ by Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland / Unity Technologies, 30 3rd Street, San Francisco, CA 94103, USA; more information:

https://unity3d.com/legal/privacy-policy; https://unity3d.com/legal/Controller_DPA_Monetization_Advertising and

https://unity3d.com/de/legal/gdpr;

  • ‘Google Firebase’ by Google LLC, Mountain View, CA, USA / Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland: more information:

https://fi rebase.google.com/

and

https://policies.google.com/privacy?hl=en;

  • ‘Flurry Analytics’ by Flurry Inc. / Oath Inc., 701 First Avenue, Sunnyvale, CA 94089, USA / Oath (EMEA) Ltd., 5-7 Point Square, North Wall Quay, Dublin 1, Ireland; more information:

https://developer.yahoo.com/fl urry/legal-privacy/terms-service/ ; https://developer.yahoo.com/fl urry/legal-privacy/fl urry-analytics-dpa.html

and

https://policies.oath.com/us/en/oath/privacy/index.html

  • ‘Facebook Analytics’ by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland; more information:

https://www.facebook.com/policy.php ; https://www.facebook.com/legal/terms/dataprocessing;

https://www.facebook.com/ads/preferences

or https://www.facebook.com/settings;

  • ‘AppLovin’ by AppLovin Corporation, 849 High St., Palo Alto, CA 94301, USA; more information:

https://www.applovin.com/privacy/

and

  • Microsoft, One Microsoft Way Redmond, WA 98052, USA; more information:

https://www.microsoft.com/en-us/trust-center/privacy/gdpr-overview

and

  • Amazon Webservices Inc. (AWS), 410 Terry Avenue North Seattle, WA 98109, USA; more information:

https://aws.amazon.com/de/compliance/gdpr-center/and

https://dash.applovin.com/assets/pdf/dpa.pdfSuch data processing is performed to ensure the technical functionality of our services fulfillment of contractual or pre-contractual obligations (based on Art. 6 (1) b. GDPR or TMG and as otherwise explained in this privacy policy) or improving our product and perform marketing activities (based on Art. 6 (1) f. GDPR). Regarding the data processing based on Art. 6 (1) f. GDPR we wish to achieve the legitimate interests of quality assurance and marketing. If legally required such data processing shall be based on your explicit consent (Art. 6 (1) a. GDPR).

OPT-OUT:

You may de-activate the processing of data for such analytics purposes any time in the App via message to

dataprotection@plearny.io

 

9. Contacting us; Sending Messages

When contacting us via the App/email, your details are stored for the purpose of processing the enquiry and, if applicable, follow-up questions based on your consent based on the legal basis of Art. 6 (1) a. GDPR or fulfilling your request based on Art. 6 (1) b. GDPR.

We may also contact you via App/email for purposes related to the use of the App or similar services based on Art. 6 (1) b. or f. GDPR, TMG, or German Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb, UWG) if you did not object to such messages.

 

 

10. Your Rights

You have certain rights referring to the use of your personal data, which you may act upon at any time without any disadvantages:

  • You have the right to withdraw your consent relating to the use of data at any time with effect for the future when such data processing is based on your consent.
  • You are entitled to access the data stored by us and are also entitled to amend or rectify your data if such data are incorrect.
  • You have the right to object to the processing of your personal data, for example if your personal data are processed for direct marketing purposes.
  • You are entitled to request in writing the erasure of your data.
  • You are entitled to receive information about the stored data (in a structured, current and machine-readable format) at any time and to provide a written request for the correction or deletion of the data in case of incorrect data storage.

For acting according to your rights as set forth above please contact us via message at:

dataprotection@plearny.io

You also have the right to lodge a complaint with a supervisory authority of your choice (for example for Berlin

https://www.datenschutz-berlin.de/kontakt.html). An overview of the European National Data Protection Authorities may be found here:

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

 

11. Third Party Providers used by us; data processing outside the EU/EEA

When using the App, your data may be processed by third party providers engaged by us, for example cloud service provider(s) and advertising partners.

We use Google Cloud Services, Microsoft and AWS as hosting service providers that processes data on servers in the EU/EEA.

The third party providers and advertising partners named in this privacy policy engaged by us (Google, Facebook, AppLovin, Flurry/Oath, MoPub, Tapjoy, IronSource, inMobi, Vungle, Mytarget, Adcolony) may process data outside the EU/EEA.

The US companies offering the services by Google, Facebook, AppLovin, Tenjin, MoPub Inc./Twitter, Inc. and Tapjoy are each certified according to the “EU-US-Privacy-Shield” to guarantee the compliance with EU data protection standards. For more information, please refer to:

https://www.privacyshield.gov/

To guarantee the compliance with EU data protection standards the companies offering the services of Flurry are either also certified according to the “EU-US-Privacy-Shield” or EU Standard Contractual Clauses; for more information see

https://policies.oath.com/ie/en/oath/privacy/topics/datatransfer/index.html

ironSource Mobile Ltd., Israel guarantees the compliance with EU data protection standards via the respective adequacy decision by the EU Commission (see: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061).

The provider of inMobi has submitted to EU Standard Contractual Clauses for the international transfer of personal data (see:

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).

For further information (on engaged third party providers) please contact us via

dataprotection@plearny.io

 

12. Deletion of Data; Retention Periods

The data collected shall be deleted if such data is no longer necessary for the purpose of processing by the Company.

Your profile and account data shall be deleted after you delete such data in your App account or delete the entire account via the respective button in the App.

In the case of long-term contractual relationships, such as the use of our App, these storage periods may vary, but are generally limited to the duration of the contractual relationship or, with regard to the inventory data, to the maximum legal retention periods (e.g. in accordance with the German Commercial Code (Handelsgesetzbuch, HGB) and the Tax Code (Abgabenordnung, AO)). Criteria for the storage period include whether the data are still up-to-date, whether the contractual relationship with us still exists, whether an inquiry has already been processed, whether a process has been completed or not, and whether legal retention periods for the personal data concerned are relevant or not.

Under some circumstances we may, in our sole discretion, anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

 

13. Minor’s Privacy

We restrict the use of our Services to individuals age eighteen (18) and above. In compliance with COPPA, we do not knowingly solicit Information from or market our Services to individuals under the age of eighteen (18). If we learn we have collected or received personal information from an individual under eighteen (18) without verification of parental consent, we will delete that information. If you become aware of any data we have collected from or about an individual under eighteen (18), please contact us using the contact information provided below.

 

14. Sharing Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

  • By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
  • Affiliated Service Providers: We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Third-party advertisers. We may use third party advertising companies to serve ads. These companies may use information about your visits to the website and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
  • Statistical Analysis: We may share anonymized User ratings and review of apps and aggregated anonymized information with third parties, including but not limited to, for statistical, machine learning, advertising, or marketing purposes.
  • Transactions: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition, or in any other situation where personal information may be disclosed or transferred as one of our business assets. However, under no circumstances will such transactions result in your information being used for other purposes than those for which you gave us your consent.

For additional information regarding the type of third-party services that are used, please review the categories of personal information that we may share with third-party service providers and our business and commercial uses of such personal information on under https://plearny.io//privacy-policy/

 

15. Data Security and Encryption

We have implemented sufficient measures to ensure data and IT security. The App is operated through a safe TLS-connection, which is a protocol used to encrypt the connection from your device to our servers.

16. Data processing on our Facebook Page

We operate a “Social Media Page” on Facebook, facebook.com or mobile app by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to privacy policy

https://www.facebook.com/policy.php

, opt-out:

https://www.facebook.com/ads/preferences

or

https://www.facebook.com/settings

When you visit our Social Media Page, data is processed both by us and by the responsible social media provider as the responsible party.

The respective provider of Social Media assumes the data protection obligations towards you as the user, such as information on data processing, and is the contact person for your rights. This follows from the fact that such provider has direct access to the relevant information on the Social Media Page and the processing of your data. However, you are also welcome to contact us if this should become necessary and we will then forward the request to the respective provider if necessary.

When using Facebook and Instagram data may also be processed outside the EU. The US company of Facebook is certified in accordance with the EU-US Privacy Shield agreement, which guarantees compliance with data protection regulations in the EU. For more information please refer to:

https://www.privacyshield.gov

With our Social Media Pages, we can communicate with you and provide you with interesting information. We may receive further data from you through your comments, shared images, messages and reactions, which we then process to answer or communicate with you. If you use Social Media on several end devices, a cross-device analysis of the data can take place.

Furthermore, the providers of the Social Media Pages may also use cookies and tracking technologies to analyse and improve their services.

Data processing takes place with your consent or for the purpose of answering your enquiry (Art. 6 (1) a, b GDPR) or on the basis of legitimate interests in improving the services, advertising and marketing activities and presentation to the outside world (Art. 6 (1) f GDPR).

 

 

17. Page Insights and Cookies on Facebook:

Facebook and we use the page insights function to process statistical data from Users of our Facebook pages (see also the agreement at:

https://www.facebook.com/legal/terms/page_controller_addendum

). This involves the processing of data in the form of so-called ‘page insights’, which are described in more detail at

https://www.facebook.com/business/a/page/page-insights

Evaluations and statistics are generated in the form of page insights from the usage data of the Facebook pages, which support us in improving our marketing activities and our external presence. We may also learn about users and their behavior who interact with or use our Facebook Pages to display relevant content and develop features that may be of interest to them. These page statistics show us, for example, which people from certain target groups interact most with our Facebook Page or which content on the Facebook Page was visited, shared or licked when and how often. When classifying people into target groups, demographic data or data about the location of a person is also included in order to place targeted advertisements with these people. If you use Facebook on several end devices, a cross-device analysis of the data can take place. The data collected in this way is statistically processed and usually anonymous, i.e. we cannot establish any reference to the individual person.

Information on these page insights and data processing can be found, for example, in Facebook’s data protection statement at https://www.facebook.com/policy.php or at

https://www.facebook.com/business/a/page/page-insights

Facebook also uses cookies and storage technologies. More information can be found here:

https://www.facebook.com/policies/cookies/

As a Facebook user, you can at any time influence how your user behavior is recorded when you visit Facebook pages. To do this, you can manage the settings for advertising preferences in your Facebook account or at

https://www.facebook.com/ads/preferences, or the Facebook settings in your account or at https://www.facebook.com/setting.

Facebook also provides opportunities to contact or exercise rights at https://www.facebook.com/help/

 

 

18. External Links

Our Services may link to other websites or apps such as the Google PlayStore, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours. We are not responsible for and have no control over these third-parties and their practices, including the information or content contained within them. Please make sure you review and understand how these sites or businesses use and collect your information by reading their privacy statements before using the site.

19. International Transfer

We are based in Germany and the information that we process is protected by German privacy laws. The information that we collect may be transferred, stored, or used in other jurisdictions, such as the United States, where some of our service providers may be located. While we protect your information by choosing appropriate service providers and having contractual safeguards in place with those vendors, the privacy laws in such jurisdictions may not be as protective as in, for example, Canada or the EEA, SUI & UK, and may be subject to access by foreign governments, with or without your knowledge.
The information collected in the EEA, SUI & UK is transferred and stored behind firewalls on our secure servers that are located on Amazon AWS in the United States in accordance with the GDPR adequacy standards. Any other transfers to third countries will be done using mechanisms such as the “model clauses”. We are committed to protecting the privacy of personal data and adherence to Global Data Protection laws.

20. Terms Of Use

This Policy is incorporated into and forms part of our Terms of Use, which outlines the terms and conditions you agree to when using the Services, and which can be found at the bottom of most pages of our website.

21. Contact Information and Challenging Compliance

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Data Privacy Officer at:

Data Privacy Officer

DataClue GmbH
Holzstr. 30
80469 Munich
Germany
address
or via email at privacy@plearny.io

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt out by:
-noting your preferences at the time you register your account;
-logging into your account settings and updating your preferences; or
-contacting us using the contact information provided below.
If you no longer wish to receive correspondence, emails, or other communications from thies parties, you are responible for contacting the third party directly.

 

22. Contact

If you have questions or comments about this Policy, please contact us at support@plearny.io. The contact details can also be found via the App’s settings menu.