The administrator of your personal data is Smooth Bytes with headquarters in Lublin, ul. Willowa 18/5. You can contact the Administrator:
- By e-mail: firstname.lastname@example.org
- By postal address: Smooth Bytes, ul. Willowa 18/5, 20-819 Lublin, Poland
For any inquiries or questions regarding this Policy please contact us at: email@example.com.
The above consent applies to any activities done while using the Website, including browsing content of the Website, ordering applications and other products or services available on the Website, as well as all information which may be gathered during such activity, including information about the User and computing device (including without limitation, a mobile device) through which the Website or the Service is used.
By agreeing to the Policy, including by using the Website or the Service without expressly declining the Policy, the User consents to the collection and use by the SB of information specified here below, as well as the disclosure and transfer of such information to third parties, including affiliates and partners of the SB, especially partners with whom the SB cooperates in relation to providing services available at the Website or the service.
|The purpose of data processing||Legal basis||Processing period|
|Implementation of the contract on the Smooth Bytes line “ the user (these agreements are usually the regulations that you accept before using the service), including providing services to you, matching services to your needs, analyzing and improving services and ensuring security when using services||Art. 6 par. 1 lit. b) GDPR “ essential to perform the contract to which the User is a party||Until the expiration of the contract with Smooth Bytes, with the provision that sometimes, these data may be processed also after the expiration of this contract, if it is allowed or required under applicable law, e.g. processing for statistics, billing or claims. In the case of personal data acquired at the moment of placing the purchase in the online store, the data will be stored for a period of 30 days after the purchase, except for payment data, which will be stored for 6 years.|
|Statistical measurements||Art. 6 par. 1 lit. f) GDPR “ legitimate interest of the administrator||until effective objections are made|
|Marketing of our products and services (including analyzing data for advertising and marketing purposes, ad targeting)||Article 6 paragraph 1 lit. a) “ voluntary consent||until the consent is withdrawn|
Apart from the above-mentioned data, as a result of using the Website or the Service the SB may also collect data which relate mostly to advertisements shown on the Website or the Service, but which permit to identify neither the User (as an individual) nor even the User’s device. Such information may include but are not limited to: (i) identification of displayed advertisements and their characteristics, including size, (ii) time during which the advertisement is displayed; (iii) User’s response to advertisement, esp. clicking banners, ads etc., (iv) application usage information, including in-game location, (v) Website or the Service usage data, (vi) information related to usage of the Website or the Service, including length of visit, viewed content, page interaction information, other websites to which the User turned after visiting the Website or the Service or from which the User directed to the Website or the Service, dates and times, errors during downloading etc.
Use of Data by the SB and its Partners
Information acquired about the Users, their activities and devices, as described in Article II above are used by the SB and also shared with our Partners, including subcontractors which whom the SB cooperates in rendering services via the Website or the Service and generally cooperates in operating the Website or the Service or running its business.
Information are used mainly for the purposes of providing services via Website or the Service or more generally running the SB’s business, including analyzing characteristics of usage of the Website or the Service, improving quality of SB online services and products, as well as providing customize communications and advertising. Examples of such use are the following:
- analyzing characteristics and trends of usage of the Website or the Service and its content, including analyzing Users preferences, habits etc.;
- gathering and analyzing information about User base, including demographic, geolocation, preferred devices etc.;
- delivering customized advertisements and recommended products, i.e. on the basis of analysis of User’s preferences, viewed content and browsed information the SB may seek to display advertisements and recommendations of products or services related to User’s preferences;
- analysis of Information for the purposes of improving SB offer, including on the basis of Users preferences and trends, errors occurring during previous usage or downloads etc.
Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent. Based on your consent we share information we collect from you that can be used to personally identify your device, e.g. persistent identifiers such as advertising ID, IP address and other information that may be personal to you, such as age and gender with our advertising partners and they can use such data for interest-based advertising. In addition, we may use and share such information with our advertising partners in order to target and optimize our advertising and promotions in our and other publisher’s apps. Example: device with your advertising ID has clicked on a fashion ad within other publisher’s app and show to you a fashion ad in our application. Our advertising partners use different technologies for the purposes of interest-based advertising that process your personal information in different ways, so please review their data processing practices before you provide your consent to sharing your persistent identifiers such as advertising ID, IDFA, IP address and other information that may be personal to you for the purpose of interest-based advertising.
Who can show interest-based ads?
The list of advertising providers that are allowed to show interest-based advertising and review their data processing practices, including the technologies they use for the purposes of interest-based advertising.
- Facebook Audience Network https://www.facebook.com/about/privacy/update?ref=old_policy
- Facebook Custom Audience https://www.facebook.com/about/privacy/update?ref=old_policy
- Vungle http://vungle.com/privacy/
- Applovin https://www.applovin.com/privacy/
In order to purchase SB products the User should have appropriate legal capacity according to applicable law and provisions of a separate regulations governing SB’s online store.
The SB does not control (and generally have no possibility to control) the age of Users browsing the Website or the Service. Nevertheless it is not SB’s intention to collect, store or use any personal information of children under the age of 13. If you are a legal representative of a child of under 13 and would like to delete the child’s personal information from the SB’s data base, the SB we will take all reasonable steps to do so. In the above respect you may contact us at firstname.lastname@example.org.
Sharing content on Facebook, Twitter, YouTube and other portals
Subject to specific options that the User chooses at his/her profile within the Portal (by clicking appropriate banners like I accept, I agree, I allow or similar), while sharing the content created within the Website or the Service on the Portal, the SB may have access to and may collect, store and use for the purposes indicated in this Policy some or all of User’s data contained within the profile, including contact data, User name and basic information available on the Portal, as well as User’s photos and videos.
The Website or the Service may also ask you to allow the SB to post on the Portal on your behalf (photos, videos, status updates etc.) and to access and handle your notifications, including marking them as read. In doing so the SB only performs your previous commands or directions. For the purposes thereof the SB may store certain information within application on User’s device, for the period necessary to communicate with the Portal and execute User’s commands. The SB shall not store such information thereafter on its servers.
Newsletters and Push Notifications
Any newsletters and push notifications require User’s specific consent and the User may also at any time unsubscribe or change settings at such newsletters or push notifications.
For the purposes of providing the User with the required newsletters and push notifications the SB shall use necessary information provided by the User for such purposes, including all or some of the following: (i) name, (ii) e-mail address, (iii) telephone number (IMEI), (iv) other contact information.
In order to unsubscribe from e-mail newsletters you may send an e-mail to email@example.com which shall result in deleting your e-mail by the SB. To disable push notifications for which the User previously agreed, the User should choose appropriate settings on the mobile phone, depending on operating systems.
Your e-mail, telephone number (IMEI) or other alike information provided for the purposes of receipt of newsletters and push notifications shall not be shared by the SB with third parties, except for possible subcontractors of the SB who support the SB in providing the service in question.
Length of Storing of Information
Length of storing of information collected according to this Policy may differ depending on the nature of information in question and provisions of applicable law governing such information.
Generally, the SB stores information as long as it is needed for the provision of services or other purposes resulting from Article III thereof. Information constituting personal data are erased always if a person to whom they pertain requests such deletion, subject to applicable law. To make such request you may contact the SB at: firstname.lastname@example.org.
Traffic data and other alike information are erased or made anonymous when they are no longer needed for the purposes of rendering services or other applicable purposes specified in this Policy, unless otherwise provided for by applicable provisions of law.
Please note that data provided for in relation to a complaint or dispute are generally stored during time needed to finally resolve the dispute and/or expiry of claim, whereas information required for billing purposes, if any, may be stored for accounting purposes during period required by applicable law.
Certain applications available at the Website or the Service, although free, may include in-app purchases. In order to secure the Users against unintended purchases, any in-app purchases require entering the app store password. The User should keep the password secure and not reveal it to any third persons. Such passwords should also not be revealed to User’s children or other family members, unless the User consents that they make in-app purchases on User’s behalf.
Information about cookies
What are cookies
The administrator and his partners (i.e., partners providing analytical services, advertisers, application developers, network advertising agencies) can post and access information in the form of cookies and other similar technologies on your terminal device (e.g. computer, laptop, smartphone).
Cookies are small text files, stored on the terminal device, containing some information related to your use of our websites and the online store. The website places a cookie file in the browser if the browser allows it. The browser allows the website to access only the cookies placed by this website, not to files placed by other websites.
We use the following types of cookies:
- enabling the use of services available under SB, e.g. authentication cookies used for services requiring authentication
- performance cookies, enabling the collection of information on the use of websites
- functional cookies, allowing remembering the settings selected by the user and personalizing the user interface
Due to the lifetime of cookies and other similar technologies, we use two basic types of these files:
- session “ temporary files stored on the User’s end device until logging out, leaving the website and application or turning off the software (web browser);
- permanent “ stored in the User’s terminal device for the time specified in the cookie file parameters or until they are deleted by the User.
- provision of services;
- customizing the content of websites and applications to your preferences and optimizing the use of websites; e.g. recognizing your device to display a website tailored to your individual needs;
- creating statistics and reports that help you understand how you use our services, which allows us to improve them;
- maintaining the User’s session (after logging in), so you do not have to re-enter your login and password on every subpage of the website and application;
- the possibility of presenting advertisements and content tailored to your preferences, including in a way that takes into account your interests, using online advertising tools, including Google Adwords (cookie administrator: Google Inc. with its registered office in the USA, more about using data by Google: https://policies.google.com/technologies/partner-sites?hl=pl ), or Facebook Ads (administrator cookies: Facebook Inc based in the USA or Facebook Ireland based in Ireland). The above partners can combine information with other data received from you or obtained while using their services.
- implementation of surveys, quizzes, competitions and other activities involving the User “ in particular to avoid repeatedly presenting you to the same activities
- in order to collect general and anonymous statistical data via analytical tools: Google Analytics (cookie administrator: Google Inc. with its registered office in the USA),
- to use interactive functions to popularize the website using social networking sites: twitter.com (cookie administrator: Twitter Inc. based in the USA), plus.google.com (cookie administrator: Google Inc. with its registered office in the USA), Facebook.com [ cookie administrator: Facebook Inc with its registered office in the USA or Facebook Ireland based in Ireland],
Managing browser settings
In many cases, software used for browsing websites (web browser) allows for the storage of information in the form of cookies and other similar technologies by default in the User’ end device. However, you can change these settings at any time. Failure to change them means that the above information can be posted and stored on your end device, and thus that we will store information on your terminal equipment and access this information. From the level of the web browser you use, for example, you can manage cookies manually. The most popular browsers include the possibility of:
- cookie files management at the level of individual, selected sites;
- defining settings for different types of cookies, for example accepting files as permanent as session, etc.;
- blocking or deleting cookies.
Where to find help?
Comprehensive information is available in the software (web browser) settings. Details for people using individual web browsers, including: