Effective Date: January 31, 2021
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.
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:
–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 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
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.
However, our adjacent platforms such as website (i.e.) or links from within our app that direct to and/or any other subdomains or websites associated with our Service may use the following 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 .
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):
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 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.
7 / DISCLOSURE OF DATA:
7.1 / Business Transaction
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 firstname.lastname@example.org.
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/.
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.
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
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.
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).
12.5 / LINKS TO OTHER SITES:
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.
15 / CONTACT US:
-By email: email@example.com
-Via our website: widgetpets.com/contact
Data Protection Officer Contact:
H’Appile Interactive, LLC
2711 Legion Rd
PO Box 8184
Erie, PA 16506
16 / THIRD PARTY DATA PROCESSOR CONTACT & LOCATIONS
1600 Amphitheatre Parkway
Mountain View, CA 94043
One Apple Park Way
Cupertino, CA 95014
1100 Page Mill Road
Palo Alto, CA 94304
1255 Battery Street Suite 500
San Francisco, CA 94111
Suite 420, 475 Brannan Street
San Francisco, CA 94107
90 New Montgomery Street, Suite 500
San Francisco, CA 94105
240 Page St
San Francisco, CA 94102
240 Stockton St, 9th Floor
San Francisco, CA 94108
41 Madison Ave 30th Floor
New York, NY 10010
1 Hacker Way
Menlo Park, CA
44 Montgomery Street,
CA, USA 94104