Privacy

Effective Date: January 31, 2021

v 3.2.5

 

H’Appile Interactive, LLC (“us”, “we”, or “our”) operates the WidgetPet application (hereinafter referred to as the “Service”).

 

H’Appile Interactive, LLC is dedicated to protecting your privacy and making transparent how we use your data and its purpose for our service.

 

We use data to provide and improve the Service. This document informs you of our policies regarding the collection, use, and disclosure of data when you use our Service and the choices you have associated with that data.

 

To use our Service we require you agree to our privacy policy and be at least 18 years old (or the legal age of majority in your jurisdiction if greater), or you be at least 13 years old (or the legal age to consent to personal data processing in your jurisdiction if greater, e.g. 16 years old in parts of the European Economic Area, 16 years old in California, etc.) and have a parent or legal guardian’s permission and consent/acceptance of the terms of this policy.

 

This is a legally binding click-wrap” agreement and you must have the ability to enter into a binding agreement to continue.  If you do not agree to the below policy terms, you may not use the Service. By accepting this policy, you are making an affirmative agreement to all policy terms herein, stating you meet the age requirements outlined above, have the ability to enter into this legally binding agreement with us, and grant WidgetPet and/or H’Appile Interactive, LLC the permissions and rights outlined herein. YOU ASSUME RESPONSIBILITY FOR ALL USERS OF THE SERVICE ON YOUR DEVICE.

 

1 / DEFINITIONS:

 

Unless otherwise defined in this Privacy Policy, the terms and language used in this Privacy Policy have the same meanings as in our Terms of Service.

 

Service, Service is the iOS, iPadOS, or MacOS based WidgetPet application operated by H’Appile Interactive, LLC, including all associated and/or affiliated backend services such as servers and/or data architectures/infrastructures, apis, extensions, websites, etc. Note: The Service may be referred to in product description, itself, the app, or advertising and for purposes of this policy by one or more of the following names: WidgetPet, WidgetPet!, WidgetPets, WidgetPets!; all of which are the same Service described in this policy.

You, You as referred to in this policy is meant to encompass the broad definition of a “user”. In some instances this may mean simply yourself as an individual and may in other cases encompass an individual, organization, or group of individuals if you are representing such and advocating the use of the service in place of and/or on behalf of.

Personal Data, Personal Data means data about, or directly linked to, a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).

Contextual/Device Data, Contextual/Device Data means data that is anonymous and not linked to any personal individual (i.e. like a device’s battery state of charge, network signal strength, software version, etc.)

Service Usage Data, Service Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit, action taken on a page or in the app, etc).

Cookies, Cookies are small files stored on your device (computer or mobile device).

Data Controller, Data Controller means the natural or legal person, or entity, who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers), Data Processor (or Service Provider) means any natural or legal person, or entity, who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User), Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Children/Child, for the purpose of this policy refers to individuals who are under the age of ability to consent to personal data processing in their jurisdiction (e.g. < 13 in the USA (< 16 in CA), < 16 in parts of the EEA, etc). Please refer to your state or jurisdiction’s specific requirements.

 

2 / INFORMATION COLLECTION AND USE:

 

We collect several different types of information for various purposes to provide and improve our Service to you.

 

Types of Data Collected:

 

2.1 / Personal Data

The WidgetPet app and service may collect personally identifiable information (i.e. data that can be linked back to your specific identity) as follows:

 

   Device Persistent Identifier(s):

   For personalization of advertising targeting and tracking if authorized or allowed on your device via the Advertising Identifier (IDFA) per section 2.5.3

   For consent attributions and/or analytics tracking via the Identifier for Vendor (IDFV) for the app installation on your device as described more in section 2.5.4

   Your Email and/or Name:

   Through customer service or support requests we may receive personally identifiable information such as your name or email during these communications in order to communicate with you

 

2.2 / Contextual/Device Data

When you access the Service, we may also collect certain anonymized and/or contextual information automatically, including, but not limited to, the type of device you use, network carrier, network signal strength, battery state of charge, keyboard language settings, the local timezone of your use, anonymized IP address, the coarse city/regional geolocation of your use (i.e. not at street level), your device’s operating system version, the currently installed app version, the type of Internet browser you use, the timestamp/date of your use, your actions taken on the Service, and other diagnostic data (“Usage Data”).

 

2.3 / Crash Logs

To improve and diagnose crashes of our Service, we may also collect crash logs and information when/if the Service experiences a crash during your use. This anonymized information may include contextual data as defined in 2.2 and additional things such as operating system state (i.e. memory use, CPU use, etc), device state (like orientation, etc.) and specific “traces” or logs of activity (i.e. actions within the app like screen transitions/sequences, taps, etc.) leading up to and at the time of crash.

 

2.4 / Service Usage Data

We may collect anonymized Usage data and Service data generated from your use. This may include content that may be generated by your use of the Service, such as details about your widget pet, game place stats, etc. We may also track things such as the frequency of and/or use of the Service and/or specific features. We use this Service data and/or tracking metrics for the facilitation of our service and analytics to improve and better understand how the Service is used.

 

2.5 / Tracking Data

We may use cookies and/or similar tracking technologies to track the activity on our Service and hold/cache certain information.

 

2.5.1 / Cookies

 

Cookies usually exist in web and browser based environments.

 

Cookies are small pieces of data that are stored by your browser when a site is visited to track and store information associated with your activity to help improve your browsing experience, capture analytics, perform authentication, store cache records, etc.

 

Since our Service primarily exists on a native iOS, iPadOS, or MacOS application, we don’t directly use cookies in the WidgetPet app.

 

However, our adjacent platforms such as website (i.e. widgetpets.com ) or links from within our app that direct to widgetpets.com and/or any other subdomains or websites associated with our Service may use the following Cookies:

-Session Cookies.

-Preference Cookies.

-Security Cookies.

-Advertising Cookies.

 

2.5.2 / Others

 

Other tracking technologies may also be used such as beacons, tags, pixels, and scripts to collect and track information and to improve and analyze our Service’s use.

 

2.5.3 / Advertising Identifier (i.e. IDFA)

 

If allowed, the Advertising Identifier (IDFA) on your device may be shared with third party advertisers to track and target personalized advertisements based on your use and/or ad clicks across your device. This is again mentioned later section 12.3 for Advertising.

 

Starting in iOS14, for enhanced privacy control, Apple’s App Tracking Transparency (ATT) framework provides explicit means for opt-ing into sharing your device’s IDFA. If your device settings allow, you may be prompted during the use of the Service to opt-in to “Allow Tracking” so we can personalize advertising for you using the IDFA described here. You can also learn more here https://developer.apple.com/app-store/user-privacy-and-data-use/. If you choose to opt-in, this can help our advertisers provide more meaningful and personalized ads during your use.

 

You can also always choose to limit tracking or opt-out of the specific use of this IDFA by advertisers in regard to how they serve personalized ads. The setting can be modified within the “Settings>Privacy” on your devices. You can find additional instructions for limiting personalized advertising here https://support.apple.com/en-us/HT205223.

 

Note, disabling sharing of the IDFA on your device and/or opting out of ATT are not means to stop all advertising in our Service. Our right to advertise in the Service is part of our Terms of Service. Therefore, we may always still show general and/or “contextualized” advertisements, as these are in our legitimate interest and necessary to support the free tier of our Service.

 

2.5.4 / Identifier for Vendor (i.e. IDFV)

 

The identifier for vendor (IDFV) may be shared with third parties for analytics purposes and attributing stats for the WidgetPet app based on your use. This identifier is specific to and only identifies the WidgetPet app instance by us on your device. If you’ve opted out of personalized advertising/tracking we do not use this identifier to track your activity across other apps and we limit the data that is linked to this ID to respect your privacy. You can learn more here https://developer.apple.com/app-store/user-privacy-and-data-use/.

 

3 / USE OF DATA:

 

H’Appile Interactive, LLC uses collected data for various purposes:

-To provide and maintain our Service

-To notify you about changes to our Service

-To allow you to participate in interactive features of our Service when you choose to do so

-To provide customer support

-To gather analysis/stats or valuable information so we can improve and learn about our Service

-To monitor the usage and/or compliance of our Service and its features

-To detect, prevent, and address technical issues

 

4 / LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR):

 

If you are from the European Economic Area (EEA), the legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

 

We may process your Personal Data because:

-We need to perform a contract with you

-You have given us permission to do so

-The processing is in our legitimate interests and it is not overridden by your rights

-For payment processing purposes

-To comply with the law

 

5 / RETENTION OF DATA:

 

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

 

6 / TRANSFER OF DATA:

 

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

 

If you are located outside The United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to The United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

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

 

7 / DISCLOSURE OF DATA:

 

7.1 / Business Transaction

If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

 

7.2 / Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

7.3 / Legal Requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

 

-To comply with a legal obligation

-To protect and defend the rights or property of H’Appile Interactive, LLC

-To prevent or investigate possible wrongdoing in connection with the Service

-To protect the personal safety of users of the Service or the public

-To protect against legal liability

 

8 / SECURITY OF DATA:

 

The security of your data is very important to us.

 

For personal and/or sensitive data transmission to/from the app and our servers or any third party apis, we use commercial and industry wide standard encryption protocols such as https calls (i.e. http using SSL or TLS) to protect your data.

 

For data storage we always design database schema and security rules with careful privacy considerations. We employ security rules on our Firebase database (see 12.2 for more on Firebase database) to ensure only you have access to your personally identifiable information.

 

In the unforeseen event of breach or database integrity being compromised, and we become aware of such that personally identifiable information is at risk or has been exposed, we will take appropriate steps to notify all users impacted.

 

It is important though to remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we always strive and dedicated ourselves to protecting your Personal Data, we cannot guarantee its absolute security.

 

9 / OUR POLICY ON “DO NOT TRACK” SIGNALS UNDER THE CALIFORNIA PROTECTION ACT (CalOPPA):

 

We do not support Do Not Track (DNT”) signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

 

10 / YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR):

 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

 

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact our Data Protection Officer (DPO) provided in section 15.

 

In certain circumstances, you have the following data protection rights:

 

-The right to access, update or delete the information we have on you.

-The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

-The right to object. You have the right to object to our processing of your Personal Data.

-The right of restriction. You have the right to request that we restrict the processing of your personal information.

-The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

-The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

11 / CALIFORNIA PRIVACY DISCLOSURES (CCPA):

 

We do not knowingly collect or sell any personal information from any individual below the legal age of consent to personal data processing in their respective jurisdiction, e.g. 16 years of age in California.

 

In the literal sense of a “sale”, we will never actually directly sell any of your personal information. However, as we do use advertising in our service, we may share your personal information to better serve these ads and personalize them for you. Under some definitions this could be interpreted as a “sale” since we use these ads to help monetize and support and the free version of our app. You have the right to opt out of us disclosing and/or selling any of your personal information. You can opt-out via a button at the bottom of the “paw print” settings page in the app labeled “Do Not Sell My Personal Information”.

 

You have a right to request to have your personal data deleted and removed (unless if we’re required to maintain any such for compliance), and can request so by contacting us at privacy@happileinteractive.com.

 

You have the right to know what information we collect and who we share it with, as is defined by this privacy policy. Additionally, you may request a copy of any of your personal information we have collected by contacting us at privacy@happileinteractive.com at any time.

 

12 / SERVICES & THIRD PARTY DATA PROCESSORS:

 

We may employ third party companies and individuals to help facilitate our Service (Service Providers”), to provide one or more services on our behalf, perform or improve Service-related services, or assist us in analyzing how our Service is used.

 

These third parties have access to your data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

12.1 / ANALYTICS:

 

We may use third-party Service Providers to monitor and analyze the use of our Service including,

 

Apple. We distribute our Service on the Apple App Store. Apple may collect and/or we may share one or more of the following: Contextual/Device Data, Service Usage Data, and Crash Logs with Apple for analytics purposes and/or product trend/sales reporting in our legitimate interests of providing and maintaining the Service effectively. You can learn more about all the details of Apple’s privacy policies here https://www.apple.com/privacy/.

 

Google Analytics is a service offered by Google that tracks and reports app/web traffic. Google may collect and/or we may share one or more of the following: IDFV, Contextual/Device Data, Service Usage Data, and Crash Logs with Google for analytics purposes. Google uses the data collected to track and monitor the use of our Service to provide us with analytics monitoring and insights in our legitimate interests of maintaining and improving the Service. This data may be shared with other Google services we use (e.g. Firebase, Admob, etc). Google may also use the collected data to contextualize the ads served by its own advertising network within our service. You may opt-out of certain Google Analytics features through your device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en and https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008.

 

Firebase Analytics is a service provided by Google Inc. Google Firebase may collect and/or we may share one or more of the following: IDFV, Contextual/Device Data, Service Usage Data, and Crash Logs with Google Firebase for analytics purposes. Google Firebase uses the data collected to track and monitor the use of our Service to provide us with analytics monitoring and insights in our legitimate interests of maintaining and improving the Service. You may review Google’s privacy policy and learn about opting-out of certain Firebase features through your device settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en. We also encourage you to review the Googles policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en and https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008.

 

Firebase Crashlytics is an analytics service offered by Google that monitors, collects, logs, tracks, and analyzes crash reports (such as those outlined previously in section 2.3) so we can better understand and improve our service as we grow and work to keep the platform robust. Google may collect and/or we may share one or more of the following: IDFV, Contextual/Device Data, Service Usage Data, and Crash Logs with Google for this crash reporting and understanding purposes. Google uses the data collected to track and monitor the stability of the Service to provide us with crash monitoring and insights in our legitimate interests of maintaining and improving the Service. You may review Google’s privacy policy and learn about opting-out of certain Firebase features through your device settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en.

 

Facebook Pixel is an analytics and marketing optimization tool provided by Facebook that captures analytics and metrics from the use of the service. Facebook may collect and/or we may share one or more of the following: IDFV, Contextual/Device Data, and Service Usage Data with Facebook. This data is used to help attribute installations from our advertising campaigns, appropriately target audiences for our marketing using contextualized parameters, and collect analytics from the service in our legitimate interests of growing, improving, sustaining the Service. You can find the details of Facebook’s privacy policy here https://www.facebook.com/about/privacy.

 

AppLovin is is a mobile marketing platform. We use AppLovin as an advertising mediation and UA platform partner to help grow and sustain our Service in our legitimate interest. AppLovin may collect and/or we may share one or more of the following: IDFV, Contextual/Device Data, Service Usage Data, and Crash Logs with AppLovin. This data is used in our legitimate interests of growing, improving, and sustaining the Service by providing insights and learning to us on our Service’s use and marketing/monetization performance. You can find the details of AppLovin’s privacy policy here https://www.applovin.com/privacy/.

 

12.2 / DATABASE:

 

Firebase by Google Inc. – We may use third-party service provider Firebase to store and maintain content and data for our service.

 

We encourage you to review the Firebase privacy and security standards https://firebase.google.com/support/privacy.

 

12.3 / ADVERTISING:

 

We may show advertisements in our Service to help support and maintain our Service and keep it free. We partner with industry leading third party ad services and companies that may include the following,

 

AdMob by Google Inc. https://policies.google.com/technologies/partner-sites

Vungle https://vungle.com/privacy/

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

InMobi https://www.inmobi.com/privacy-policy/

Fyber https://www.fyber.com/privacy-policy/

Unity https://unity3d.com/legal/privacy-policy

Smaato https://www.smaato.com/privacy/

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

AdColony https://www.adcolony.com/privacy-policy/

Mintegral – https://www.mintegral.com/en/privacy/

 

You can also find additional contact details for the above data processors in section 16.

 

These third party providers may have access to process your data as defined here for the legitimate interest of advertising in order to serve you best, and to contextualize and personalize ads for you. Data processed may include,

 

   Contextual/Device Data parameters (i.e. aforementioned in section 2.2)

   Service Usage Data (i.e. aforementioned in section 2.4), if available for a specific network’s integration (e.g. Google Analytics in the case of Google AdMob, etc.)

   The ID for Vendor (IDFV) for the WidgetPet app instance on your device (i.e. aforementioned in section 2.5.4)

   The Advertising Identifier (IDFA) of your device (if tracking is allowed on your device as discussed in 2.5.3)

 

You always have the right to limit interest based and behavioral ad tracking on your device. You can find instructions on how to limit tracking and personalized ads by disabling and restricting the use of your device’s Advertising Identifier (i.e. IDFA) here https://support.apple.com/en-us/HT205223.

 

12.4 / PAYMENTS:

 

We may provide paid products and/or services within the Service. In this case, we use third-party services for payment processing (e.g. payment processors).

 

We will NEVER store or collect your payment card details and/or any personal banking information directly. We will also NEVER contact your regarding such details or ask for them. If you have provided this to our third party payment processors outside of our Service, then this information is stored directly by our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

 

Apple In-App Payments/Purchases – We work with Apple as a payment processor for in-app purchases. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/.

 

12.5 / LINKS TO OTHER SITES:

 

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third partys site. We strongly advise you to review the Privacy Policy of every site you visit.

 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

13 / CHILDREN’S PRIVACY:

 

Our Service is a General Audience platform and app, and is not directed at Children. Use of the Service in accordance with our terms of Service requires users be at least 13 years of age (or the legal age of able to consent to personal data processing in their jurisdiction if greater, e.g. 16 in parts of the EEA).

 

We never knowingly collect personal data from Children, or anyone under the age of 13 (or the legal age of able to consent to personal data processing in their jurisdiction if greater, e.g. 16 in parts of the EEA) in our Service. If we gain actual knowledge we’ve collected personal data from Children under any circumstance we take prompt action to remove the information from our Service.

 

If you are a parent or guardian and you are concerned that your Child has somehow provided us with Personal Data, please contact us so we may remove it.

 

14 / CHANGES TO THIS PRIVACY POLICY:

 

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via a prominent notice on our Service, and update the effective date” and version at the top of this Privacy Policy. Where applicable, the latest version of this privacy policy always covers and applies to all instances of the Service, regardless of the version of the Service in use.

 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

15 / CONTACT US:

 

If you have any questions about this Privacy Policy, please contact us:

-By email: privacy@happileinteractive.com

-Via our website: widgetpets.com/contact

 

Data Protection Officer Contact:

DPO Officer

H’Appile Interactive, LLC

2711 Legion Rd

PO Box 8184

Erie,  PA  16506

privacy@happileinteractive.com

 

16 / THIRD PARTY DATA PROCESSOR CONTACT & LOCATIONS

 

Google

1600 Amphitheatre Parkway

Mountain View, CA 94043

https://support.google.com/policies/contact/general_privacy_form

 

Apple

One Apple Park Way

Cupertino, CA 95014

https://www.apple.com/privacy/contact/

 

AppLovin

1100 Page Mill Road

Palo Alto, CA 94304

info@applovin.com

 

Vungle

1255 Battery Street Suite 500

San Francisco, CA 94111

https://vungle.com/contact-us/

 

InMobi

Suite 420, 475 Brannan Street

San Francisco, CA 94107

https://www.inmobi.com/company/contact/

 

Fyber

90 New Montgomery Street, Suite 500

San Francisco, CA 94105

https://www.fyber.com/about-us/

 

Unity

240 Page St

San Francisco, CA 94102

https://unity.com/help

 

Smaato

240 Stockton St, 9th Floor

San Francisco, CA 94108

https://www.smaato.com/contact/

 

AdColony

41 Madison Ave 30th Floor

New York, NY 10010

https://www.adcolony.com/consumer-privacy/

 

Facebook

1 Hacker Way

Menlo Park, CA

https://www.facebook.com/help/

 

Mintegral

44 Montgomery Street,

San Francisco,

CA, USA 94104

https://www.mintegral.com/en/privacy/

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