Privacy Policy

The Red Crown Ltd. (“TRC”, “we”, “our” or “us”) offers a number of apps (“Apps”, and each an “App”) which provide you with services (the “Service(s)”) allowing you, among other things, to create content and to share it via texting or social media.

TRC is dedicated to protecting the privacy rights of our users. This Privacy Notice (the "Notice ") describes how we collect and use your personal data through our Apps. It also describes the rights and options available to you with respect to your personal information.

 Please note that the scope of this Policy is limited to information and data collected or received by TRC through your use of the Service. TRC is not responsible for the actions of third party people or companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.

 By using our Services you agree to our Privacy Policy and confirm that you are at least 13 years old.

DATA WE COLLECT

We may collect the following information and data from you:

When you use our Service, we may record and collect the following information:

1. Device information, including device type, a unique device ID, operating system version, time zone and your preferred languages.
2. Usage information, such as the time and date you accessed the Apps, the features you used, your preferences and for how long you use an App every time you launch it.
3. If you have purchased something via mobile In-App Purchases (e.g., a Premium or Unlocked feature): The information provided by Apple on the respective invoice
4. Unique advertising identifiers – see below in this Notice under Advertising
5. IP address from which you access the Apps. We can also identify a rough geo-location of your Internet Service Provider via your IP address.

We are not collecting all of the above all the time, and we aim to minimize the amount of data in general, and to focus on aggregated and non-personal data when available. For example, if an App is not involved with ads, we skip Unique advertising identifiers.

The overall personal data outlined above will be referred to as the " Information ".

We do not collect the Information we disclosed above only by ourselves. We obtain some of it from third parties who may also collect your Information through their designated code incorporated in our Apps, examples of which include Google Firebase and Fabric. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device-related data and information on our behalf. The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies. We use their services for the purposes set forth below.

HOW WE USE THE DATA

Our primary goals in using information are to provide Services to you, improve our Service, conduct marketing and research and create reports for internal use. We store information on servers located in the United States via Google Cloud Platform and may store information on servers and equipment in other countries.

We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service, based on your consent, for compliance with a legal obligation to which TRC is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by TRC or a third party to whom it may be necessary to disclose information. We may use your information to:

• Maintain and improve our Service
• Create and develop new content, features and services
• Enrich the content and features available in our Service
• Operate and improve our Service
• Adapt the Service to your and to our users’ preferences
• Analysis of marketing efficiency
• Respond to your comments and questions and provide customer service
• Provide and deliver products and services you request
• Deliver advertising and marketing and promotional information to you
• Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages
• Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by TRC and our selected partners
• Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.

The legal basis under EU law for processing and collecting the Information is our legitimate interests in operating our Service, ongoing management of our business and business development. Our employees have access to your information only to the extent their functions are required to provide our Service or otherwise act on our behalf as set forth in this Policy.

WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS

We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent:

• We will share your Information with our service providers who assist us to operate our Apps. Our service providers are authorized to use your Information only as necessary to provide us with their services and not for their own purposes. We do not sell your Information to third parties
• If you have breached the terms of use of the Services, this Notice or any other agreement you have with us, abused your rights to use the Service, or violated any applicable law – the Information may be shared with third parties (such as legal counsels and advisors), who handle the matter on our behalf, or with the competent authorities
• If we are bound to disclose your information by a judicial order or by a governmental or regulatory authority acting within its legal authority, we will comply and share the Information
• If we organize the operation of our company within a different framework, or through another legal structure or entity (such as due to a merger or acquisition) – we will share the Information to enable the structural change. However, the receiving party will be bound by this Notice.

ADVERTISING

We may feature advertisements in our Services, both ourselves and with the help of our partners, and collect and use data and information about you and your device in connection with such advertising, including your viewing of and interaction with any such advertising. Advertisers on mobile devices and our third party partners sometimes collect and use Advertising IDs to enable and optimize advertising. Advertising IDs are non-permanent device identifiers such as the Android advertising ID and Apple’s IDFA.

These advertisers and third party advertising and analytics partners may collect and use data and information about you, such as your Service session activity, viewing of and interaction with an advertisement, device identifier, geo-location information and IP address for the purposes of analyzing, tracking and measuring advertisement performance and to provide interest based advertising.

In addition, you may see our applications and games advertised in other services. After clicking on one of these advertisements and installing our application or game, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser or third party advertiser or analytics partner.

You can exercise an opt-out for interest based advertising services on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android).

SECURITY AND DATA RETENTION

We retain personal data as long as we need it for the purposes for which it was obtained or until you ask to delete it. If you ask us to delete the Information, we may still have to retain it to comply with our legal obligations, resolve disputes and enforce our agreements.

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immuned to information security risks.

INTERNATIONAL DATA TRANSFERS

We are based in the State of Israel. The Information we collect from you will be processed in Israel, which is recognized by the European Union ("EU") as having adequate protection for personal data. We will only transfer your Information from within the EU to other jurisdictions if they have been deemed to have an adequate level of data protection by the EU, or as otherwise permitted by the applicable data protection laws.

CONTACT US

If you have any questions or requests concerning your personal data or about our privacy practices and policies, you may contact our Data Protection Officer at: [e-mail]

CHANGES TO THIS PRIVACY POLICY

From time to time, we may change this Notice. If you are a registered user, we will provide you notice of such changes through the Apps. In case of a legal requirement, we may also introduce immediate changes to the Notice and require that you accept them. In any event, if you do not consent to the amended Notice, we may terminate your user account. The latest version of the Notice will always be accessible on the Apps.

Last update: August 5, 2019