Privacy Policy

Effective Date: August 24, 2021

Version: 5.1.0

 

Widgetpets.com (Website”) and its related WidgetPet! Application (App”), services, and products specific to WidgetPet (collectively WidgetPet”) are owned and operated by HAppile Interactive, LLC (HAppile Interactive”, our”, us”, we”).

 

HAppile Interactive is dedicated to protecting your privacy and being transparent with how we use your data and information. HAppile Interactive complies with all applicable laws, policies, and regulations related to the collection, usage, and sharing of all information. We take careful consideration and design into our privacy practices to protect our Users.

 

This Privacy Policy (Privacy Policy”) informs you of the data and Information, including Personal Information, we may collect when you use WidgetPet and explains in detail how this information is used. We strive to update and always keep this policy as clear and complete as possible. Please contact us directly with any questions or concerns after reviewing this policy.

 

HAPPILE INTERACTIVE MAY CHANGE, MODIFY, AMEND, SUSPEND, TERMINATE, OR REPLACE THIS PRIVACY POLICY FROM TIME TO TIME AND WITHIN ITS SOLE AND ABSOLUTE DISCRETION. IN THE EVENT HAPPILE INTERACTIVE CHANGES, MODIFIES, AMENDS, OR REPLACES THIS PRIVACY POLICY, THE EFFECTIVE DATE AND VERSION, LOCATED ABOVE, WILL CHANGE. YOUR CONTINUED USE OF WIDGETPET AFTER A CHANGE IN THE EFFECTIVE DATE OR VERSION OF THIS PRIVACY POLICY CONSTITUTES YOUR MANIFESTATION OF ASSENT TO THE CHANGE, MODIFICATION, AMENDMENT, OR REPLACEMENT CONTAINED WITHIN. THIS PRIVACY POLICY SHALL SUPERSEDE ANY PRIOR, AND APPLIES TO ALL VERSIONS OF WIDGETPET, INCLUDING FUTURE.

 

1 Definitions.

 

   "California Consumer Privacy Act" (CCPA”) means the California statute intended to enhance privacy rights and consumer protection for residents of California, United States.

   "General Data Protection Regulation" (GDPR”) means the European Union (EU”) law on data protection and privacy applicable to individuals within the EU.

   "Information" includes the literal definition of "information" and means any data, content, parameters, identifiers, etc.

   "Personal Information" or "Personal Data" is a subset of Information, and means any Information relating to an identified or identifiable natural person. An identifiable natural person is one who can be reasonably identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, behavioral, or social identity of that natural person.

   "Targeted Advertising" is advertising selected or curated based on known Information for the User and/or device, in an effort to be most relevant and appropriate for them. Targeted advertising has two forms, "Personalized" and "Contextual".

   "Personalized Advertising" for the purposes of this policy and when referenced within the App, if authorized/allowed, means with respect to use of the IDFA to track and behaviorally target interest based ads for you in WidgetPet, based on your tracked use across your device and third party apps/services.

   "Contextual Advertising" for the purposes of this policy may also be called "Contextualized Advertising", "Contextually Based Advertising","ads served contextually" etc. Contextual Advertising refers to advertising that doesn’t track user behavior or interests across third party apps (i.e. doesn’t use the IDFA). This advertising is limited to only using first party data obtained from and during the context of or environment of use of service(s) of WidgetPet and by H’Appile Interactive on your device.

   "Private Database" means a database that is only accessible by You and/or Your device, or any of those devices which share the same credentials (i.e. Apple ID) as You. (ex. iCloud)

   "Public Database" means a database that is accessible at various levels to the general WidgetPet user base. Public Databases we maintain are zoned and secured using security rules to limit access based on need, function, and appropriate user privilege or relationship. Such databases may be hosted on own servers and/or via a cloud provider such as Firebase.

   "Shared Database" means a database that may be available to a subset of the public (i.e. shared among friends or family, etc) and which you choose to share or control what records/data from you Private Database may be shared into such "Shared Database".

   "User(s)" means individuals that download and/or use WidgetPet.

   "You / Your / You’re" means Users.

   "WidgetPet" for purposes of this policy refers to the App, Website, and all related services/products.

   "Service" for the purposes of this policy has the same meaning as "WidgetPet".

   "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 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.

   "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 California, USA; < 16 in parts of the EEA, etc). Please refer to your states or jurisdiction’s specific requirements.

 

 

Children’s Privacy:

 

At H’Appile Interactive, we make apps that are for all audiences. WidgetPet is designed for a broad general audience of users. While we do not primarily direct the App or Website towards Children, we are committed to protecting all users’ privacy. Therefore, we’ve implemented the following features 1-5 specifically to protect any Children Users, in addition to the rest of our general privacy policy that follows in this document.

 

1)   An "Age Gate" upon launch.

 

For users deemed as Children based on the user specified Age Gate (1) input:

 

2)   We do not request, collect, or share personally identifiable "Device Persistent Identifiers" (i.e. IDFA).

3)   We never provide Personalized Advertising to Children, and all interest based advertising or re-marketing ads are disabled.

4)   We only display advertisements from Google Admob, which we provide flags to indicating that users are Children and to filter ads to a "G-Rated" audience.

5)   We place extra parental/guardian gate(s) throughout the app to help prevent inadvertent purchases by accidental clicks from a user.

 

While we’ve worked hard and carefully to design the above measures, we still always encourage parents and guardians to discuss safe internet and mobile device use with Child users and to monitor their Children’s safe mobile application use.

 

 

 

2 What Information We Collect or Receive.

 

2.1 Personal Information

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

 

   Device Persistent Identifier(s):

   Advertising Identifier (IDFA) if authorized and allowed for WidgetPet on your device, as described more in section 4.2.

   Identifier for Vendor (IDFV)* for the App installation on your device, as described more in section 4.3.

   Email Address, Name, Device Screenshots:

   Through customer service or support requests initiated by You we may receive Personally Information such as your name or email during these communications in order to communicate with You. Additionally during the course of a communication, we may receive device screenshot(s) (which may or may not contain Personal Data) You provide to us to aid in resolving issues and troubleshooting. If we gain knowledge any communication is from a Child we always promptly delete the communication and all associated contents after one-time contact with accordance to COPPA 16 C.F.R. § 312.5(c)(3).

   Email Address:

   If sign-in feature is provided/available in the App, through authentication with such.

 

*For completeness, and to cover all varying use cases of, we include the IDFV as "Personal Information" here. However, the IDFV only becomes considered "Personally Identifiable" when linked with other information that may personally identify the User or illustrate a user’s behavioral actions/tracking across other third party apps and services not operated by H’Appile Interactive. In cases of "Limited Ad Tracking"(LAT), Children users, or not opting-in to "App Tracking Transparency"(ATT) (see section 4.2 on IDFA for more details), we always respect privacy rights and our data processors limit the use of and data linked to the IDFV. In these LAT cases, the IDFV may more accurately be classified as "Contextual Data" since this only identifies information in the context of the App instance and use of first party services by H’Appile Interactive on your device.

 

2.2 Consent and Compliance Parameters

   Age:

   To protect Children’s Privacy rights and determine how to serve users appropriately.

   Country/State of Location and/or Residence:

   To configure the App properly for your privacy protections and regional specific compliances.

   Data Sharing Preferences/Consent Acknowledgements:

   To save your settings and preferences.

   To maintain compliance with logs/traceability of consent captures.

 

2.3 Contextual/Device Data

When you access WidgetPet or services by H’Appile Interactive, we may also collect certain anonymized information automatically about the "context" of, or device of, your use, including, but not limited to, the type of device you use, network carrier, do not disturb or silenced mode, airplane mode, bluetooth connection state, network signal strength, battery state of charge, keyboard language settings, UI mode (i.e. light/dark theme, etc), device orientation, the local timezone of your use, identifiers (i.e. IDFV), anonymized IP address (i.e. last octet masked), disk space, 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, and other diagnostic data. This information helps us understand the "context" of, and track analytics from, use of WidgetPet so we can serve you best.

 

2.4 Crash Data/Logs

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

 

2.5 App Data/Service Usage Data

We may collect software level App Data or parameters such as unique identifiers, session or authentication tokens, settings, flags, etc. that are created based on your selection, use, or are auto generated in your App. These may be used to provide or secure connection of the App with our, or third-party, servers and/or to to maintain and configure the App for you.

 

We may also collect anonymized Service Usage data from your use of WidgetPet. We may collect/track things such as the frequency of your use of WidgetPet (i.e. session/launch instance dates and/or time stamps), the count or frequency of specific feature(s) use and/or action(s) you take or have taken within WidgetPet, screen gestures or inputs, software and/or algorithm states, variables, metrics, run-time actions, etc. We may use these stats to learn about how the Service is used and to improve the Service through analytics, insights, etc.

 

2.6 User Generated Content

We may collect user generated content from your use of WidgetPet. This may include content such as details about your widget pet (i.e. their name, gender, customizations), game play stats, etc.

 

2.7 Ad/UA Performance Data

We may collect advertising and user acquisition(UA) metrics through the duration of an App session and use, including click through rates on advertising impressions, completion percentages on video based ads, impression volumes, domains of previously shown ads, install stats/attributions, media sources (i.e. Facebook, Google, etc) and/or campaign identifiers retained from the link the app was installed or opened from, etc. This Ad/UA Performance Data is not linked to your personal identify and cannot be used to behaviorally track you across third party apps or websites, unless you’ve granted permission for App Tracking Transparency and sharing of your device’s IDFA. Your privacy here is very important to us, and you’re always in control of this IDFA setting as detailed in section 4.2.

 

3 How and When We Collect Information.

 

HAppile Interactive may collect this Information from you through various channels, including, but not limited to, through your voluntary submission of information to WidgetPet or HAppile Interactive, through requests initiated by you through WidgetPet, through the collection and analysis of information concerning your computer and browsing activities, automatically through the use of WidgetPet, through the use of cookies, web beacons, pixel tags, analytics services detailed in section 7.1, and through other sources permitted by law. The following table describes more the specific methods that are used to collect various data and information:

 

Data or Information

How and When Collected

IDFA

Automatically in the App (ONLY after your consent has been provided, see section 4.2)

Cookies

Automatically on the Website (if required or consent is provided, see section 4.1)

IDFV, Contextual/Device Data, Crash Data/Logs, App Data/Service Usage Data, Ad/UA Performance Data

Automatically in the App

Consent & Compliance Parameters

Automatically and/or through your input in the App

Name, Email Address, Device Screenshots

You providing to us via web contact form and/or email correspondences

Email Address

If one is present, you choosing to use a sign in feature within the app

User Generated Content

From your inputs and/or actions of using WidgetPet, creation of a widget pet and/or care for, associated game play and interactions, etc.

 

 

4 About Tracking Technologies.

 

4.1 Cookies

Cookies are small pieces of data that are stored by your browser when a website 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 WidgetPet primarily exists on a native iOS, iPadOS, watchOS, or MacOS application, we dont directly use cookies in the App. However, some of our adjacent platforms, such as the Website, links found within the App that direct to the Website, and any other subdomains or websites associated with WidgetPet may use Cookies, web beacons, pixels, and other similar technologies from third-party service providers.

 

You have a variety of tools available to control the data collected by Cookies, web beacons, pixels, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use Cookies and to withdraw your consent by clearing or blocking Cookies. You can also stop HAppile Interactive from placing Cookies (other than those required for the Website and/or App to function) on your device by referencing the instructions below.

 

The table below sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

 

Type of Cookie

Description

Managing Settings

Required Cookies (Strictly Necessary)

Required – or strictly necessary – cookies enable you to navigate the Website or App and use its features.

Because required cookies are essential to operate the Website or App there is no option to opt out of these cookies.

Functional Cookies (Non-Strictly Necessary)

Functional – or non-strictly necessary cookies – allow us to remember information you have entered or choices you make, and provide enhanced, more personal features.

 

We use Google Analytics and/or Facebook Pixel to help us analyze how our Website and App is used, including the number of visitors, where the website visitors have come from, and the pages they visit. This information is used by us to improve our Website and App.

 

To manage the use of functional cookies on the Website and App, please consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our Website and/or App.

 

To learn more about safeguarding your data for websites using Google Analytics, visit here. To opt of our data collection by Google Analytics, you can download and install a Google Analytics opt-out browser add-on here.

 

To learn more about how Google Analytics may use cookies on the Website and/or App visit here.

 

To learn more about how Facebook Pixel may use cookies on the Website and/or App visit here.

 

You can also adjust your individual browser settings relating to cookies by visiting these pages:

 

·       Google Chrome

·       Internet Explorer

·       Microsoft Edge

·       Mozilla Firefox

·       Safari (Desktop)

·       Safari (Mobile)

·       Android Browser

 

For other browsers not listed, please consult the documentation that your browser manufacturer provides.

Targeting or Attribution based Advertising Cookies (Non-Strictly Necessary)

We use Google Analytics and/or Facebook Pixel to log when users view specific pages or take specific actions on or getting to the Website.

 

We may also use Google AdWords as a tool to acquire relevant new clients who are looking for our service and Google AdSense to show our clients other relevant advertising that may assist them while they are using our site.

To learn more about How Google uses cookies targeted advertising, visit here. To adjust your Google Ad Settings and learn how opt out of particular targeted advertising visit here or the Network Advertising Initiative opt-out page here (desktop) or here (mobile).

 

To learn more about how Facebook Pixel may use cookies on the Website and/or App visit here.

 

 

4.2 Advertising Identifier (IDFA”)

The Advertising Identifier (IDFA”) on your device can be used to track your ad clicks and behavioral actions across your device’s use (i.e. third party app usage, etc). This can help us understand and track your interests and preferences. If your device settings allow and you’ve provided opt-in permission, the IDFA may be shared with third-party advertisers to track and target Personalized Advertisements. You understand and consent that if you allow this tracking/targeting, this may also use automated decision making and algorithms to serve you behaviorally targeted ads. You can restrict this IDFA access, as detailed below, by either (1) choosing not to opt-in to ATT, or (2) if already opted into ATT for WidgetPet, then modifying in your device privacy settings:

 

(1) For enhanced privacy control, as of iOS 14.5 Apples App Tracking Transparency (ATT) framework provides explicit means for choosing to opt-in to sharing your devices IDFA at the app level. If your device settings allow, you may be asked during the use of WidgetPet if you’d like 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.

 

(2) If you’ve already opted into ATT for WidgetPet, you can always view your current App Tracking permission setting and change this preference to control sharing of your IDFA within the Settings>Privacy” on your device. You can find additional instructions for limiting Personalized Advertising here https://support.apple.com/en-us/HT205223.

 

Note, disabling or preventing sharing of the IDFA on your device by not opting in for ATT are not means to stop all advertising in WidgetPet. Our right to advertise in WidgetPet is described in the End User License Agreement. Therefore, we may always still show general and/or Contextualized Advertising as these are in our legitimate interest and necessary to support use of WidgetPet.

 

4.3 Identifier for Vendor (IDFV”) 

The identifier for vendor (IDFV) may be shared with third parties for analytics purposes and attributing stats for the App based on your use. This identifier is specific to and only identifies the apps by us (i.e. the "Vendor") that are specifically installed on your device. If youve not opted into or restricted ATT or Personalized Advertising/tracking for WidgetPet, we do not use this identifier to track your activity across any other third party apps, and the data that is linked to this ID is limited to respect your personal privacy. You can also learn more here https://developer.apple.com/app-store/user-privacy-and-data-use/.

 

5 Use of and Lawful Basis for Processing Your Information.

 

The lawful basis for us processing your Information for the uses described below will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; and/or the processing is in our legitimate interest of providing WidgetPet.

 

By using the Website and/or the App, you authorize and acknowledge the following uses of your Information:

 

Processing Purpose/Use

Information

Data Type

Lawful Basis

Contact and communicate with you in response to a communication initiated by you to us, whether through email, telephone, text message, and/or messages within the Website and/or the App;

Email Address, Name, Device Screenshots

Personal Information

 

Consent by requesting response or initiating communication with us and providing this information during such

Provide you with technical service and support, including updates;

 

Improve algorithms and fix bugs or problems; service reliability;

Email Address, Name, Device Screenshots

Consent by requesting response or initiating communication with us and providing this information during such

If available, to provide sign in or authentication capabilities in the App;

Email Address

Consent to EULA/Terms and Privacy Policy

Consent by choosing to use authentication feature

Customize and/or personalize selection and display of third-party advertisements within the Website and/or App;

 

Combine your information with other information from other third party services for Personalized Advertising and Targeted Ad serving;

IDFA, IDFV

Consent via opting-in to App Tracking Transparency (ATT)

Aggregate/Collect certain information that does not include your personal information and disclose and/or reduce it for our analysis, analytics, modeling, demographic profiling and/or Targeted Advertising;

 

Combine your information with other information from the App or other HAppile Interactive applications on your device for Contextual Advertising and Targeted Ad serving;

Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data

Non Personal Information (i.e. anonymized, contextual only, etc)

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Enable your use of the Website and/or App and its associated services;

Contextual/Device Data, User Generated Content

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Provide you with technical service and support, including updates;

 

Improve algorithms and fix bugs or problems; service reliability;

 

Develop new features;

Contextual/Device Data, Crash Data/Logs, App Data/Service Usage Data

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Customize and/or tailor the Website and/or App and your user experience;

Consent & Compliance Parameters, Contextual/Device Data, App Data/Service Usage Data

Legitimate Interest,

 

Consent to EULA/Terms and Privacy Policy,

 

Your Privacy Protection

 

COPPA/GDPR/CCPA/etc. Compliance

Advertise products and services of HAppile Interactive;

Contextual/Device Data, Service Usage Data, Ad/UA Performance Data

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Transmit and process your information and actions within the Website and/or App;

 

Measure service usage;

 

Provide you with information concerning HAppile Interactives benefits or services;

Contextual/Device Data, App Data/Service Usage Data

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Provide statistical information, and include your use in the same, where applicable;

 

Communicate and plan promotions or other offers;

Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Facilitate your use of the Website and/or App and upgrades/replacements to the Website and/or App.

 

Store, archive, retrieve, attribute, and make copies of your user generated content or app related data/information;

User Generated Content, Contextual/Device Data

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

Understand your needs and requests;

Contextual/Device Data, App Data/Service Usage Data, Crash Data/Logs

Legitimate Interest, Consent to EULA/Terms and Privacy Policy

 

 

6 When Your Information Is Shared.

 

HAppile Interactive shares your Information with third parties in the following cases:

 

Sharing Purpose/Use

Information

Data Type

Lawful Basis

Where sharing or disclosure of your Information is necessary and/or in the legitimate interest of supporting you through customer service communications and responses/feedback;

Name, Email Address

Personal Information

Consent by requesting response or initiating communication with us and providing this information during such

If available, to provide sign in or authentication capabilities in the App;

Email Address

Consent to EULA/Terms and Privacy Policy

Consent by choosing to use authentication feature

Where sharing or disclosure of Information is related to an advertising or social media campaign and/or for attribution of app install or purchase related to such;

 

Where HAppile Interactive has obtained your consent;

IDFA, IDFV

Consent via opting-in to App Tracking Transparency (ATT)

Where sharing or disclosure of Information is necessary to respond to requests by government authorities;

 

Where Information is demanded by a court order or subpoena;

 

Where sharing or disclosure of Information is needed to protect the employees, independent contractors, officers, directors, members, users, or owners/shareholders of HAppile Interactive;

 

Where sharing or disclosure of Information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty;

 

Where HAppile Interactive is otherwise legally obligated to share Information;

Name, Email Address, Device Screenshots, IDFA, IDFV, Consent & Compliance Parameters, Contextual/Device Data, Crash Data/Logs, App Data/Service Usage Data, User Generated Content, Ad/UA Performance Data

Personal & Non- Personal Information

Consent to EULA/Terms and Privacy Policy

 

Comply with Legal Request/Req’mt

Where sharing or disclosure of Information is necessary or in our legitimate interest to provide you with the Website and/or the App (We may share your information with trusted third-parties who assist us in operating the Website and/or the App, providing the associated services, and conducting our business);

 

Where HAppile Interactive has obtained your consent;

 

Where WidgetPet or HAppile Interactive has been purchased by a third party;

Consent & Compliance Parameters, Contextual/Device Data, App Data/Service Usage Data, Crash Data/Logs, User Generated Content, Ad/UA Performance Data

Non- Personal Information

Legitimate Interest

 

Consent to EULA/Terms and Privacy Policy

Where sharing or disclosure of Information is related to an advertising or social media campaign and/or for attribution of app install or purchase related to such;

Consent & Compliance Parameters, Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data

Legitimate Interest

 

Consent to EULA/Terms and Privacy Policy

 

 

7 Who We Share Your Information With.

 

We may use third-party service providers to store and process your Information.

 

Disclaimer: No Liability Third-Party Services and Third-Party Links.

The third-party service providers affiliated with HAppile Interactive have their own independent privacy policies governing the use of your Information pursuant to the GDPR and CCPA and we encourage you to read those privacy policies carefully. You understand that even if HAppile Interactive deletes your Information that it may still be available in a third-party service providers database. HAppile Interactive has no responsibility or liability for the Information collection, use, or storage activities of the third-party services providers used by HAppile Interactive to provide you with the services associated with WidgetPet.

 

HAppile Interactive may outsource or subcontract some of our technical support, tracking and reporting functions, database management functions, and other services to third parties. We may share information from or about you with them so that they can perform their services as long as they comply with this Privacy Policy, the GDPR, and the CCPA. You understand and agree that HAppile Interactive will not be held responsible for any third-party communications sent by entities that HAppile Interactive does not own or control. You are encouraged to review any third-party privacy policies before utilizing any such third-party service.

 

HAppile Interactive may include or offer third-party products or services on the Website and/or App and provide third-party links to the same via advertisements provided by third parties. These third-party websites have separate and independent privacy policies. HAppile Interactive has no responsibility or liability for the content and activities of such third parties or their websites. We encourage you to read carefully the privacy policies of all such third-party websites. We seek to protect the integrity of the Website and/or App and therefore always welcome any feedback about any such third-party websites, content, or ads.

 

7.1 Analytics/Attribution:

      Google Analytics (privacy policy here);

      Google Funding Choices/UMP (privacy policy here);

      Firebase (privacy policy here);

      Apple (privacy policy here);

      Facebook Pixel (privacy policy here);

      AppLovin (privacy policy here);

      AppsFlyer (privacy policy here);

 

Apple. WidgetPet is available on the Apple App Store. Apple may collect and/or we may share one or more of the following: IDFV, 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.

 

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, App Data/Service Usage Data, Ad/UA Performance 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.

 

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, App Data/Service Usage Data, Ad/UA Performance Data, and Crash Data/Logs with Google Firebase for analytics purposes. Google Firebase uses the data collected to track and monitor the use of WidgetPet to provide us with analytics monitoring and insights in our legitimate interests of maintaining and improving WidgetPet. You may review Googles 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.

 

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 2.4) 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, App Data/Service Usage Data, and Crash Data/Logs with Google for this crash reporting and understanding purposes. Google uses the data collected to track and monitor the stability of WidgetPet to provide us with crash monitoring and insights in our legitimate interests of maintaining and improving WidgetPet. You may review Googles 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 WidgetPet. Facebook may collect and/or we may share one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, and App Data/Service Usage Data, Ad/UA Performance 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 WidgetPet.

 

AppLovin is a mobile marketing platform. We use AppLovin as an advertising mediation and user acquisition platform partner to help grow and sustain WidgetPet in our legitimate interest. AppLovin may collect and/or we may share one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data, and Crash Data/Logs with AppLovin. This data is used in our legitimate interests of growing, improving, and sustaining WidgetPet by providing insights and learning to us on the use and marketing/monetization performance of WidgetPet.

 

AppsFlyer is a mobile marketing analytics and install/session attribution tracking platform. We use AppsFlyer to measure the performance/effectiveness of our advertising and user acquisition campaigns and to monitor/analyze our App’s audience, reach, user retention, and growth. AppsFlyer may collect and/or we may share one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, Ad/UA Performance Data, and App Data/Service Usage Data with AppsFlyer. This data is used in our legitimate interests of growing, improving, and sustaining WidgetPet in evaluating our user acquisition, analytics, and marketing efforts.

 

Google Funding Choices/User Messaging Platform(UMP) is a service we may use to aid in our onboarding flow and determine regionally specific consent requirements, such as for users in the EEA and subject to GDPR protections. Google Funding Choices may collect and/or we may share one or more of the following: Contextual/Device Data, with Google Funding Choices to help protect your privacy rights and manage onboarding flow.

 

7.2 Advertising:

We may show advertisements on WidgetPet to help support and maintain WidgetPet and keep it available for free. We partner with industry leading third-party advertisements services and companies, which may include the following:

 

   AdMob by Google Inc. – (Privacy Policy here);

   Vungle – (Privacy Policy here);

   AppLovin – (Privacy Policy here);

   InMobi – (Privacy Policy here);

   Fyber – (Privacy Policy here);

   Unity – (Privacy Policy here);

   Smaato – (Privacy Policy here);

   Facebook – (Privacy Policy here);

   AdColony – (Privacy Policy here);

   Mintegral – (Privacy Policy here).

 

You can also find additional contact details for the above data processors in section 20.

 

These advertising third party providers may have access to process your data as defined here for the legitimate interest of advertising in order to protect your privacy rights, serve you best, and to contextualize and personalize (if allowed) ads for you. Examples of User data that may be processed include the following:

 

   Consent & Compliance Parameters (i.e. aforementioned in section 2.2)

   Contextual/Device Data parameters (i.e. aforementioned in section 2.3)

   Ad/UA Performance Data parameters (i.e. aforementioned in section 2.7)

   Service Usage Data (i.e. aforementioned in section 2.5), 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 4.3)

   The Advertising Identifier (IDFA) of your device (if tracking is allowed for WidgetPet as discussed in 4.2)

 

7.3 Database:

Firebase by Google Inc. – WidgetPet may use third-party service provider Firebase to store and maintain content and data for our service, including IDFV, User Generated Content, App Data/Service Usage Data, Contextual/Device Data, and Consent & Compliance Parameters. The Firebase database is a secured Public Database hosted by Google that we own and control.

 

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

 

iCloud by Apple Inc. – WidgetPet may use the Apple iCloud to store and maintain content and data for our service, including User Generated Content and App Data/Service Usage Data. This data may be stored associated with your Apple ID in a Private Database which is owned by you and linked with your Apple ID credentials. Under certain situations you may have the ability and choice to share data or records from your Private Database with other friends, family, etc in a Shared Database. When you engage in live play with others or shared pet functionality, etc, we may also sync data to a secured Public Database in the iCloud, maintained by us, in order to enable and facilitate such shared game play interactions with others, etc.

 

Keychain by Apple Inc. – WidgetPet may use the Keychain secure storage on your device to store and protect sensitive game data such as in-app purchases and in-app currency balances, etc. also possibly including User Generated Content, App Data/Service Usage Data, and Consent & Compliance Parameters. If your device is configured to allow, Keychain data may be sync’d across your devices and linked to your iCloud account with your Apple ID.

 

We encourage you to review all the Apple privacy and security standards https://www.apple.com/legal/privacy/en-ww/.

 

7.4 Payments:

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/.

 

7.5 Authentication:

We may utilize third party services including Apple, Facebook, Google to allow users to create profiles and save, manage user profiles and accounts. Use of these login services is completely optional and voluntary. WidgetPet does not own or manage any OAuth protocol or encryption used in these services, and has no access to your password. We cannot be responsible for 3rd party loss of and/or invalidation/corruption of your login/credentials. These services may have access to your email address for your user name and login purposes.

 

If account based authentication is offered, you may delete your profile and associated authentication credentials anytime you choose while logged in within the settings menu of the application.

 

In other cases, we may simply use anonymous authentication methods to allow secure access to backend databases and services, and in order to limit access to only those from validly authenticated WidgetPet application instances.

 

7.6 Customer Service/Communication:

We use third party services to manage our customer service forms, website, email server, and smtp protocols so we may receive and communicate with users to help or answer questions and receive feedback. These services may include:

 

WordPress by Automattic is a website creation and management platform. We rely on WordPress as our domain name server(DNS) provider, for website creation, hosting, etc. We allow users to reach out to us via a contact form on our Website, and as such WordPress may have access to your Name and/or Email Address you input to this form for contact to us. You can find WordPress’s privacy policy here https://wordpress.org/about/privacy/ and https://automattic.com/privacy/.

 

Gmail by Google is an email provider and service that we use to manage and respond to customer emails and support requests. Gmail may have access to your email address if you initiate communications with us. You can find Google’s privacy policy here https://policies.google.com/privacy?hl=en.

 

Mailgun by Pathwire is a mail forwarding and smtp routing service we use to manage our email address accounts. Mailgun may have access to your email address if you initiate communications with us. You can find Mailgun’s privacy policy here https://www.mailgun.com/privacy-policy/.

 

8 Data Aggregation and Service Statistics.

 

Information or data points/statistics obtained from your use of the Service, along with that of other users, may be combined and processed into aggregated Service metrics. These metrics are always stripped of any personal identifiers, anonymized, and never include any Personal Information. Examples of such may include, but are not limited to, derived statistics such as organic vs. inorganic install breakdowns, most successful ad campaigns or product placements in the app, revenue channel splits, retention cohorts, DAU counts, country-wide/large geo regional breakdown of such metrics, etc. These "big picture" or "aggregated" statistics may be shared and used in any way we deem fit for the Service or in our interest.

 

9 Information Transfer and Storage.

 

Through your use of the WidgetPet, you consent to the processing and storage of your Information and personally identifiable data. You understand that your Information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction. If you are located outside the United States and choose to provide Information to us, please note that we transfer your Information to the United States and process it here, and that we may store portions of your Information in the United States.

 

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and/or 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. If you would like to request specific Personal Data deleted or removed, please contact us. Note, even if HAppile Interactive deletes your Information from our servers, it may still be available in a third-party service providers database. You should consult with those third-parties in the event you would like Information deleted therefrom.

 

By design, we do not track or link personal and non-personal data sets on our servers or in any Public Databases maintained by us. We do this intentionally because it helps makes your privacy in the Service very robust and is a best practice. Therefore, we cannot reasonably begin to locate any non-personal data from your use, without you personally providing us details and specifics, for example about your pet’s profile in email form or something. Even if you were to provide us such details, we’d have no means to confirm such data truly was associated with your use and not someone one else with similar behavior or a matching widget pet, etc. and could inadvertently impact another user, etc. For such reasons and design, you understand and agree that non-Personal Information may be stored indefinitely on our servers or in Public Databases (i.e. Firebase, etc.) that we control or manage.

 

Note: Any data the service generates or stores on your device locally and/or in a Private Database (i.e. your iCloud) is still always under your own control through your device’s settings and/or AppleID/iCloud account management.

 

10 Information Security.

 

We use standard technology to store and help prevent against the unauthorized disclosure of your Information. Though we undertake commercially reasonable efforts to protect your information, no website, software, or online service is 100% completely safe. Accordingly, you provide all such information at your own risk.

 

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. Further, we always design database schema and security rules with careful privacy considerations. We employ security rules on our Firebase database to maximize data privacy and security. In the unforeseen event of breach or database integrity being compromised, and we become aware of such that Information is at risk or has been exposed, we will take appropriate steps to notify all impacted Users.

 

Certain local data generated from use and stored on device may also be encrypted using standard encryption algorithms and/or stored in the iOS Keychain, in efforts to maintain and protect the App’s data integrity, user settings, and intellectual property.

 

11 Payments.

 

We may provide paid products and/or services via the Website and App. We may use third-party payment processors for payment processing for WidgetPet.

 

We will never store or collect your payment information directly. We will also never contact you regarding such details or ask for them. If you have provided this to our third-party payment processors outside of WidgetPet, then this information is stored directly by our third-party payment processors whose use of your 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.

 

12 EU Users‘ Rights Under the GDPR.

 

The GDPR provides Users located in the EU under its protection certain rights with respect to their Personal Data collected by us on the Website and/or the App. Accordingly, HAppile Interactive recognizes and will comply with the GDPR and those rights, except as limited by applicable law. The rights under the GDPR include:

 

      Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint.

 

      Right of Rectification: This includes the right to correct inaccurate Personal Data collected and/or stored by us.

 

      Right of Erasure (Right to be Forgotten”): This includes the right to have your Personal Data deleted. However, if applicable law requires us to comply with your request to delete information, fulfilment of your request may prevent you from using our services and may result in closing your account.

 

      Right to Restriction of Processing: This includes the right to request restriction of how and why your Personal Data is used or processed by us.

 

      Right to Data Portability: This includes the right to receive your Personal Data in a structured, readable format and the right to have your Personal Data transferred.

 

      Right to Object: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.

 

      Right to not be Subject to Automated Decision-Making: This includes the right to not be subject, without your consent and notification, to a decision based solely on automated processing of your Personal Data, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.

 

To exercise any of these rights under the GDPR or request more information, you may submit a request to our Data Protection Officer(DPO) provided in section 19.

 

13 California Users’ Rights (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.

 

Under the CCPA, California Users have the following rights:

 

·         Right to Know About Personal Information Collected, Disclosed, or Sold: You have the right to request that HAppile Interactive disclose what Personal Information of yours it has collected, used, disclosed, and sold over the past 12 months.

 

·         Right to Have Personal Information Deleted: You have the right to request that HAppile Interactive delete any of your Personal Information that we collected from you.

 

·         Right to Opt-Out of the Sale of Personal Information: 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 (if authorized/allowed as discussed previously in section 4.2). Under some definitions this could be interpreted as a "sale" since we use these ads to help monetize and support WidgetPet. 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". If you choose to opt out, we will also limit Personalized Advertising and sharing of your device’s IDFA to protect your privacy.

 

·         Right to Non-Discrimination: HAppile Interactive shall not discriminate against California Users for exercising their rights under the CCPA.

 

To exercise your rights under the CCPA, you may submit a request to HAppile Interactive by contacting HAppile Interactive at privacy@happileinteractive.com.

Under Californias Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that HAppile Interactive has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting HAppile Interactive at privacy@happileinteractive.com and at the address below in section 19.

 

14 Our Policy on DNT 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.

 

15 Purchase or Sale of the App and/or Other Assets.

 

HAppile Interactive may purchase other businesses or sell components of its business, including, but not limited to, the Website and/or App. In the event HAppile Interactive purchases another business or sells any component of its business, your Information will continue to be used consistent with the terms of this Privacy Policy, unless otherwise notified by us or a new Data Controller.

 

16 How to Stop Us from collecting your Personal Information.

 

You can stop us from collecting Personal Information in the App by one or more of the following:

 

(1) Configuring your device settings to not allow App Tracking and/or the use of the IDFA in WidgetPet (section 4.2 of the policy).

(2) If you are a California Resident, by requesting "Do Not Sell My Personal Information" by tapping on the button described in section 12 and following any instructions therefrom.

(3) Stopping use of WidgetPet and removing the App from your Device(s).

 

and/or on our Website by:

 

(1) Turning off advertising/targeting cookies in your browser (section 4.1 of this policy).

 

For more details or help on any of the above, please contact us at privacy@happileinteractive.com.

 

17 Your Obligations.

 

Among other factors, we may rely upon information you provide to configure and make WidgetPet available for you. When using the Website and/or App, you are obligated to inform HAppile Interactive of any material changes to your Consent and Compliance Parameters (as detailed in section 2.2). You understand this is necessary for use of WidgetPet and may be actively relied upon under this policy and/or our End User License Agreement/Terms of Service for you. For instance, the items such as your age and state/country of residence may be necessary and being relied upon to protect your privacy rights and configure or update the App properly for you. Unless otherwise updated from you in writing to us, or until we learn/gain knowledge otherwise of, we will reserve the right to rely on any previously provided or obtained information as true and accurate.

 

18 Childrens Online Privacy Protection (COPPA).

 

The Website and App are intended for a general audience, and are not primarily directed to Children. However, HAppile Interactive also recognizes that in some cases the App may attract a mixed audience of users and age demographics. We therefore take additional steps to determine ages of users (via age gate) and configure WidgetPet appropriately to protect Children’s privacy when we gain knowledge of a Child user (via age gate). For clarity and emphasis, these steps are detailed at the beginning of this document in the outlined block titled "Children’s Privacy".

 

HAppile Interactive does not knowingly or intentionally collect Personal Information from children 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). If you are concerned that Personal Information of a Child may have been inadvertently provided to or collected by HAppile Interactive, please contact us immediately so appropriate steps may be taken to remove such information from HAppile Interactives servers. Also, if you are a parent or guardian and you are concerned that your child has somehow provided us Personal Information, please contact us so we may remove it and address any concerns.

 

19 Contact and Notices.

 

All questions and concerns regarding this Privacy Policy may be submitted to HAppile Interactive at:

 

Data Protection Officer

H’Appile Interactive, LLC

2711 Legion Rd

PO Box 8184

Erie,  PA  16506

privacy@happileinteractive.com

 

20 Third Party Data Processors.

 

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/

 

AppsFlyer

100 1st Street, 25th floor

San Francisco, California 94105

https://www.appsflyer.com/contact/

 

Mailgun

San Antonio, TX 78205

112 E Pecan St #1135

https://www.mailgun.com/contact/support

 

WordPress

Automattic Inc.

60 29th Street #343

San Francisco, CA 94110

https://wordpress.com/help/contact

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