Privacy Notice
Last updated March 02, 2021
Thank you for choosing to be part of our community at Opala Studios Soluções
Tecnológicas Ltda. ("Company", "we", "us", "our"). We are committed to protecting your
personal information and your right to privacy. If you have any questions or concerns
about this privacy notice, or our practices with regards to your personal information, please
contact us at [email protected].
When you use our mobile application, as the case may be (the "App") and more generally,
use any of our services (the "Services", which include the App), we appreciate that you are
trusting us with your personal information. We take your privacy very seriously. In this
privacy notice, we seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights you have in relation to it. We hope you take some
time to read through it carefully, as it is important. If there are any terms in this privacy
notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as
described above, includes our App), as well as, any related services, sales, marketing or
events.
Please read this privacy notice carefully as it will help you understand what we do
with the information that we collect.
1. WHAT INFORMATION DO WE COLLECT?
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser
and device characteristics — is collected automatically when you use our App.
We automatically collect certain information when you use the App. This information does
not reveal your specific identity (like your name or contact information) but may include
device and usage information, such as your IP address, device characteristics, operating
system, language preferences, referring URLs, device name, country, location, information
about how and when you use our App and other technical information. This information is
primarily needed to maintain the security and operation of our App, and for our internal
analytics and reporting purposes.
The information we collect includes:
▪ Log and Usage Data. Log and usage data is service-related, diagnostic, usage and
performance information our servers automatically collect when you access or use
our App and which we record in log files. Depending on how you interact with us,
this log data may include your IP address, device information, settings and
information about your activity in the App (such as the date/time stamps associated
with your usage, pages and files viewed, searches and other actions you take such
as which features you use), device event information (such as system activity, error
reports - sometimes called 'crash dumps’ -, and hardware settings), your in-app
purchases history, subscriptions, and your interaction with advertisements.
▪ Device Data. We collect device data such as information about your phone, tablet
or other device you use to access the App. Depending on the device used, this
device data may include information such as your IP address (or proxy server),
resolution, language, time zone, device and application identification numbers,
location, hardware model Internet service provider and/or mobile carrier, operating
system and system configuration information.
▪ Location Data. We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the App. For
example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing access to the information or
by disabling your Location setting on your device. Note however, if you choose to
opt out, you may not be able to use certain aspects of the Services.
▪ Basic Identifiers and Contact Information. We collect some information from you
when you provide it to us directly, such as via an email or online form, through the
support feature embedded in our Services, or through another form of inquiry. This
information may include your name, email, and phone number.
Information collected through our App
In Short: We collect information regarding your mobile device, push notifications, when
you use our App.
If you use our App, we also collect the following information:
▪ Mobile Device Access. We may request access or permission to certain features
from your mobile device, including your mobile device's microphone, storage, and
other features. If you wish to change our access or permissions, you may do so in
your device's settings.
▪ Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model and manufacturer), operating system, version information
and system configuration information, device and application identification numbers,
hardware model Internet service provider and/or mobile carrier, and Internet
Protocol (IP) address (or proxy server). If you are using our App, we may also
collect information about the phone network associated with your mobile device,
your mobile device’s operating system or platform, the type of mobile device you
use, your mobile device’s unique device ID and information about the features of
our App you accessed.
▪ Push Notifications. We may request to send you push notifications regarding your
account or certain features of the App. If you wish to opt-out from receiving these
types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our App, for
troubleshooting and for our internal analytics and reporting purposes.
Besides that, we use your information to perform our own analytics and to enable analytics
provided by third parties and other essential functions. We use analytical information for
supporting business analysis and operations, business intelligence, product development,
improving the Services, personalizing content, providing advertising, and making
recommendations. These are the third-party Service Providers that we use for analytics
purpose:
Facebook Audience Network
- Provided by: Facebook, Inc. (US)
- Collected information: Device attributes (information such as the operating system,
hardware and software versions, battery level, signal strength, available storage space,
browser type, app and file names and types, and plugins); Device operations
(information about operations and behaviors performed on the device); Identifiers
(unique identifiers, device IDs, and other identifiers, such as from games, apps or
accounts you use, and Family Device IDs); Device signals (Bluetooth signals, and
information about nearby Wi-Fi access points, beacons, and cell towers); Data from
device settings (information you allow us to receive through device settings you turn on,
such as access to your GPS location, camera or photos); Network and connections
(Information such as the name of your mobile operator or ISP, language, time zone,
mobile phone number, IP address, connection speed and, in some cases, information
about other devices that are nearby or on your network); Cookie data (data from cookies
stored on your device, including cookie IDs and settings).
- Privacy Policy: https://www.facebook.com/about/privacy/
Google Analytics for Firebase
- Provided by: Google Inc. (US)
- Collected information: Number of users and sessions; Session duration; Operating
systems; Device models; Geography; First launches; App opens; App updates; In-app
purchases.
- Privacy Policy: https://www.google.com/intl/en/policies/privacy/
Adjust
- Provided by: Adjust GmbH
- Collected information: Device identifier, Purchase history, Product interaction;
Advertising data; Other usage data; device metadata, such as operating system version
and AdJust SDK version.
- Privacy Policy: https://www.adjust.com/privacy-policy/
App Figures
- Provided by: Appfigures, Inc.
- Collected information: Receives Data from GooglePlay and AppStore.
- Privacy Policy: https://appfigures.com/privacy
App Tweak
- Provided by: Apptweak SA
- Collected information: Receives Data from GooglePlay and AppStore.
- Privacy Policy: https://www.apptweak.com/en/legal/privacy-policy
TikTok Business
- Provided by: ByteDance Ltd.
- Collected information: IP address, device information including, but not limited to,
identifier, name, and type of operating system, information obtained from Cookies and
other tracking technologies, time zone, and locale setting, and server logs (which can
include information like access dates and times).
- Privacy Policy: https://ads.tiktok.com/i18n/official/policy/privacy
And, to keep and protect all the content of the app (including content created by users),
these are the third-party Service Providers that we use for cloud computing services
purpose:
Amazon Web Services
- Provided by: Amazon Web Services, Inc. (US)
- Collected information: users generated content (audio kits created by users).
- Privacy Policy: https://aws.amazon.com/privacy/
Cloudflare
- Provided by: Cloudflare, Inc.
- Collected information: User IP.
- Privacy Policy: https://www.cloudflare.com/pt-br/privacypolicy/
Google Cloud
- Provided by: Google Inc. (US)
- Collected information: User ID; Device ID.
- Privacy Policy: https://www.google.com/intl/en/policies/privacy/
We also use third-party Service Providers to show advertisements to you to help support
and maintain our App:
Facebook Ads
- Provided by: Facebook, Inc. (US)
- Collected information: Device attributes (information such as the operating system,
hardware and software versions, battery level, signal strength, available storage space,
browser type, app and file names and types, and plugins); Device operations
(information about operations and behaviors performed on the device); Identifiers
(unique identifiers, device IDs, and other identifiers, such as from games, apps or
accounts you use, and Family Device IDs); Device signals (Bluetooth signals, and
information about nearby Wi-Fi access points, beacons, and cell towers); Data from
device settings (information you allow us to receive through device settings you turn on,
such as access to your GPS location, camera or photos); Network and connections
(Information such as the name of your mobile operator or ISP, language, time zone,
mobile phone number, IP address, connection speed and, in some cases, information
about other devices that are nearby or on your network); Cookie data (data from cookies
stored on your device, including cookie IDs and settings).
- Privacy Policy: https://www.facebook.com/about/privacy/
AdMob
- Provided by: Google Inc. (US)
- Collected information: IP address, which can be used to estimate the general location of
a device; Non-user-related crash logs, which can be used to diagnose problems and
improve the SDK; Performance data associated with the user, such as application
startup time, suspension rate, or power usage, which can be used to assess user
behavior, understand the effectiveness of existing product features, and plan for new
features; A device ID, such as the advertising identifier of the device or other device
identifiers linked to the application; Advertising data, such as advertisements that the
user saw; Other user interactions with the product, such as taps to launch the
application, and interaction information, such as video views.
- Privacy Policy: http://www.google.com/policies/privacy/
AdColony
- Provided by: AdColony, Inc.
- Collected information: IP address used to access the Internet, device advertising
identifiers (Google Advertising ID, Apple Identifier for Advertisers), the type of phone or
other mobile device used (e.g., iPhone, iPad etc.), the operating system (Android, iOS),
the date and time a particular ad is served, whether one of the ads we facilitate was
delivered and, if applicable, a record if that ad was “clicked” or if it originated from a
follow-up action to a third party such as a “conversion” event. AdColony also collect and
uses precise location data about a device from mobile applications and advertising
exchanges and may match the device location to certain residential or commercial
points for interest-based advertising, ad targeting, analytics and market research
purposes. AdColony sometimes work with third-party data partners and advertising
exchanges to enhance our advertising and targeting capabilities on the Platform. As
determined by their partners’ business and privacy policies, AdColony may also receive
and retain information from partners’ Publishers including but not limited to: the current
location of the device, third-party applications on the device or in use at the time of our
advertising transaction with the device, the Users age, gender or other demographic
indicator, and they may use or derive data obtained from third parties such as
approximate location based on IP address to help match data sets, although such data
is processed outside of their Platform. AdColony also collect Pseudonymous Identifiers
and other personal data over time and across multiple Publishers and use that
information to provide reports to advertisers and others and to help them display
advertisements that may be of interest to Users. This information is then used to deliver
advertisements and promotional information to the specific device identified based on
the User’s online behavior or interests.
- Privacy Policy: http://www.adcolony.com/privacy-policy/
AppLovin
- Provided by: AppLovin Corporation
- Collected information: Device make, model and operating system; Device properties
related to screen size & orientation, audio and battery, device memory usage, boot time;
Device settings related to accessibility features, font size, theme; Carrier; Operating
system; Name and properties of mobile application through which a consumer interacts
with the Services; Country, time zone and locale settings (country and preferred
language); City- and/or country-level geolocation data; Network connection type and
speed; IP Address; Internet browser user-agent used to access the Services; and
Advertising IDs (IDFA/GAID).
- Privacy Policy: https://www.applovin.com/privacy/
Vungle
- Provided by: Vungle Inc.
- Collected information: Information about your device, such as the type and model,
manufacturer, operating system (e.g. iOS, Android, etc.), carrier name, time zone,
network connection type (e.g., Wi-Fi, cellular), IP address, Vungle SDK version,
information about the Publisher Client’s app currently active on your device (but not any
other apps), and identifiers assigned to your device, such as its iOS Identifier for
Advertising (IDFA), Android Advertising ID (AAID or GAID), or other unique device
identifier (a number uniquely allocated to your device by your device manufacturer or
Publisher Client’s app). Information about your behavior on our Publisher Client’s app,
such as information about the activities or actions on those apps, and session start/stop
time. Historic versions of Vungle technology may also collect geolocation information
(e.g., latitude and longitude co-ordinates), but only (i) if the Publisher Client’s app has
enabled location services on your device and (ii) you have granted the Publisher
permission to collect this information). However, versions that are current as of the date
of this Notice no longer collect geolocation information. Information about ads served,
viewed, or clicked on, such as the type of ad, where the ad was served, whether you
clicked on it, the number of times you have seen the ad, the number of Vungle ads
viewed per session, and whether you visited the Advertiser’s website or relevant app
store and/or purchased or installed the product or service advertised.
- Privacy Policy: http://vungle.com/privacy/
Unity Ads
- Provided by: Unity Technologies
- Collected information: IP Adress; Customer Support; User ID; Device ID; Purchase
History; Product Interaction; Advertising Data; Performance Data.
- Privacy Policy: https://unity3d.com/legal/privacy-policy
TapJoy
- Provided by: TapJoy, Inc.
- Collected information: I - Device identifiers (a device identifier is a string of numbers and
letters unique to your smartphone or tablet assigned by the manufacturer or platform
provider), such as: a) Advertising identifier – this is a resettable identifier for advertising
use, such as Google Android Advertising ID (GAAID), for Android devices, and ID for
Advertisers (IDFA), for iOS devices; b) Publishers of Android apps have the option of
sending other identifiers, such as Google Android ID or MAC address, for use as a
fallback identifier or for analytics use; c) The publisher’s user identifier: II - Information
about the device itself, including: a) Whether it is a smartphone or tablet; b) What
operating system and version it uses (example: iOS, version 11.0); c) Whether the
device’s “opt-out” options related to advertising have been enabled; d) Model and
manufacturer (example: Apple iPhone X, Samsung Galaxy S8); e) Screen size, screen
density, and other information relevant to ad formatting and display; III - Information
about the internet connection used to access our services, including: a) Mobile carrier;
b) Network provider; c) Whether the network type is wifi or cellular; d) IP address; e)
Timestamp and duration (when the device connected to our services and how long the
connection lasted, for a given session); IV - Information about the app used to access
our services and your use of it, and about our SDK, including: a) Which version of the
app is being used ,and which version of our SDK is integrated in the app; b) API key
(identifier for application); c) How frequently and for how long you use the app, and, at
the publisher’s option, information about what level of the game you’re on and your in-
app purchases; d) If the publisher uses mediation to connect with ad networks, it may
opt to send or enable collection of parameters related to mediation services; e) Signals
relating to eligibility for behavioral advertising; V - Location-related information - We do
not request or receive precise (sometimes referred to as “lat-long”) geolocation data; we
infer the perceived general location of the device based on: a) The IP address used to
access our services b) Location-related device settings, such as the device’s country
code, language setting, and time zone; VI - Information relating to campaign content -
We collect information about the campaign content you view, such as: a) What the
campaign content is about; b) What type of campaign content it is (example: video); c)
The reward offered in exchange for your engagement with the campaign content; d)
Which placement is involved (meaning, where and how the campaign content is
displayed in the mobile app where you accessed it); e) Whether you respond to the
campaign content’s “call to action” - for example, did you click through to the
advertiser’s website? – or complete its requirements (examples: watching a 30-second
video; making a purchase); f) Market research information; VII - Responses to market
research surveys accessed through our platform are voluntary and opt-in. Responses
voluntarily provided by you may include: a) Demographic information (such as age,
household income, gender, highest education completed, household composition); b)
General location (such as postal code, or city and state); c) Other information you
voluntarily provide, which may include product preferences and opinions, employment
status, marital status, veteran status, health information, race or ethnic origin, political
opinions, membership information, sexual orientation, religious beliefs - in each case,
subject to applicable law.
- Privacy Policy: https://www.tapjoy.com/legal/players/privacy-policy/
Iron Source
- Provided by: IronSource Ltd.
- Collected information: Device ID; Product Interaction; Advertising Data; Performance
Data;
- Privacy Policy: https://www.is.com/privacy-policy/
Pangle
- Provided by: ByteDance Ltd.
- Collected information: I - Identifiers such as your IP address, mobile advertising
identifier (such as the "Google Advertising ID" on Android phones or the "ID for
Advertisers" on iOS devices), or a Pangle-specific identifier which their SDK has
assigned to your device; they may also process other information about your device,
such as the device model, operating system (e.g. iOS or Android), system language and
region, time zone, network type, ROM version, screen resolution, mobile country code
and mobile network code; your approximate geo-location from your device's IP address;
your precise latitude and longitude using your phone's GPS data; information about the
app and website usage, including the name and version of the app or website that has
integrated Pangle; information about your interactions with any advertisements they
deliver (e.g. information about the advertisements served, viewed, or clicked on, such
as the type of ad, where and when the ad was served, whether you clicked on it, and
whether you visited the advertiser's website or downloaded the advertiser's app, as well
as any preferences you may have expressed in respect of that advertisement);
information obtained from other source.
- Privacy Policy: https://www.pangleglobal.com/privacy
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our legal obligations,
and/or your consent.
We use personal information collected via our App for a variety of business purposes
described below. We process your personal information for these purposes in reliance on
our legitimate business interests, in order to enter into or perform a contract with you, with
your consent, and/or for compliance with our legal obligations. We indicate the specific
processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
▪ To send you marketing and promotional communications. We and/or our third-party
marketing partners may use the personal information you send to us for our
marketing purposes, if this is in accordance with your marketing preferences. For
example, when expressing an interest in obtaining information about us or our App,
subscribing to marketing or otherwise contacting us, we will collect personal
information from you. You can opt-out of our marketing emails at any time (see the
"WHAT ARE YOUR PRIVACY RIGHTS" below).
▪ Deliver targeted advertising to you. We may use your information to develop and
display personalized content and advertising (and work with third parties who do so)
tailored to your interests and/or location and to measure its effectiveness.
▪ For other business purposes. We may use your information for other business
purposes, such as data analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns and to evaluate and improve our App,
products, marketing and your experience. We may use and store this information in
aggregated and anonymized form so that it is not associated with individual end
users and does not include personal information. We will not use identifiable
personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you
with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
▪ Consent: We may process your data if you have given us specific consent to use
your personal information for a specific purpose.
▪ Legitimate Interests: We may process your data when it is reasonably necessary to
achieve our legitimate business interests.
▪ Performance of a Contract: Where we have entered into a contract with you, we
may process your personal information to fulfill the terms of our contract.
▪ Legal Obligations: We may disclose your information where we are legally required
to do so in order to comply with applicable law, governmental requests, a judicial
proceeding, court order, or legal process, such as in response to a court order or a
subpoena (including in response to public authorities to meet national security or
law enforcement requirements).
▪ Vital Interests: We may disclose your information where we believe it is necessary
to investigate, prevent, or take action regarding potential violations of our policies,
suspected fraud, situations involving potential threats to the safety of any person
and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in
the following situations:
▪ Business Transfers. We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
▪ Business Partners. We may share your information with our business partners to
offer you certain products, services or promotions.
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than
your own.
Our servers are located in US East - South Carolina. If you are accessing our App from
outside, please be aware that your information may be transferred to, stored, and
processed by us in our facilities and by those third parties with whom we may share your
personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?"
above), in and other countries.
If you are a resident in the European Economic Area, then these countries may not
necessarily have data protection laws or other similar laws as comprehensive as those in
your country. We will however take all necessary measures to protect your personal
information in accordance with this privacy notice and applicable law.
5. WHAT IS OUR STANCE ON THIRD-PARTY SERVICE PROVIDER?
In Short: We are not responsible for the safety of any information that you share with third-
party providers who advertise, but are not affiliated with, our Website.
The App may contain advertisements from third parties that are not affiliated with us and
which may link to other websites, online services or mobile applications. We cannot
guarantee the safety and privacy of data you provide to any third parties. Any data
collected by third parties is not covered by this privacy notice. We are not responsible for
the content or privacy and security practices and policies of any third parties, including
other websites, services or applications that may be linked to or from the App. You should
review the policies of such third parties and contact them directly to respond to your
questions.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or permitted by
law (such as tax, accounting or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than 2 years.
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational
and technical security measures.
We have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process. However, despite
our safeguards and efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security, and improperly collect, access, steal, or
modify your information. Although we will do our best to protect your personal information,
transmission of personal information to and from our App is at your own risk. You should
only access the App within a secure environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are a resident in the European Economic Area and you believe we are unlawfully
processing your personal information, you also have the right to complain to your local
data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities
are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this
stage no uniform technology standard for recognizing and implementing DNT signals has
been finalized. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding
access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits
our users who are California residents to request and obtain from us, once a year and free
of charge, information about categories of personal information (if any) we disclosed to
third parties for direct marketing purposes and the names and addresses of all third parties
with which we shared personal information in the immediately preceding calendar year. If
you are a California resident and would like to make such a request, please submit your
request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with
the App, you have the right to request removal of unwanted data that you publicly post on
the App. To request removal of such data, please contact us using the contact information
provided below, and include the email address associated with your account and a
statement that you reside in California. We will make sure the data is not publicly displayed
on the App, but please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g. backups, etc.).
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated
by an updated "Revised" date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we are
protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
[email protected] or by post to:
Opala Studios Soluções Tecnológicas Ltda.
Rua Emiliano Perneta 680
Cj. 1006
Curitiba, Paraná 80710-570
Brazil
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your personal information, please
submit a request form by clicking here. We will respond to your request within 30 days.