Privacy Policy (App)

Last updated: 01. January 2023


Trust today xyz Limited („Company“, „Owner“ or „We“) respects your privacy and is committed to protecting it. This Application collects some Personal Data from its users. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you. We use your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.



Navigation


  1. Summary
  2. Owner and Data Controller
  3. Mode and place of processing the Data
  4. Legal basis of processing
  5. Place
  6. Retention Time
  7. The purposes of processing
  8. Detailed information on the processing of Personal Data
  9. Further information about Personal Data
  10. Hosting and backend infrastructure
  11. The rights of Users
  12. Details about the right to object to processing
  13. How to exercise these rights
  14. Cookie Policy
  15. Additional information about User's Personal Data
  16. System logs and maintenance
  17. Links to Other Websites
  18. Information not contained in this policy
  19. Changes
  20. Contact
  21. Definitions and legal references

1. Policy Summary


Personal Data collected for the following purposes and using the following services


  1. Beta Testing with TestFlight
    Personal Data: App information; device information; email address; first name; Usage Data; username; various types of Data as specified in the privacy policy of the service
  2. Data transfer outside the EU
    Data transfer abroad based on standard contractual clauses: Personal Data: various types of Data

Hosting and backend infrastructure


  1. Firebase Cloud Storage
    Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Further information about Personal Data


  1. Unique device identification
    This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
  2. Push notifications
    This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of this Application.

2. Owner and Data Controller


Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracker; Usage Data; app information; email address; first name; username; device information

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.


3. Mode and place of processing the Data


Methods of processing: The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.


4. Legal basis of processing


The Owner may process Personal Data relating to Users if one of the following applies:

  1. Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  2. provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  3. processing is necessary for compliance with a legal obligation to which the Owner is subject;
  4. processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  5. processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


5. Place


The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.


6. Retention Time


Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

  1. Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  2. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.


7. The purposes of processing


The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Beta Testing and Device permissions for Personal Data access.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.


8. Detailed information on the processing of Personal Data


Personal Data is collected for the following purposes and using the following services:


Beta Testing: This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.

The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.

TestFlight (Apple Inc.): TestFlight is a beta testing service provided by Apple Inc.

Personal Data processed: app information; device information; email address; first name; Usage Data; username; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy ↗.

Californian consumers: Category of personal information collected according to CCPA: identifiers; internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.


9. Further information about Personal Data


Push Notifications This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of this Application.

Data transfer outside the EU The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.

Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on standard contractual clauses (this Application) If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Personal Data processed: various types of Data.

Californian consumers: Category of personal information collected according to CCPA: internet information.


10. Hosting and backend infrastructure


This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Cloud Storage: Firebase Cloud Storage is a hosting service provided by Google Ireland Limited or by Google LLC, depending on the location this Application is accessed from.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Germany – Privacy Policy ↗; Germany – Privacy Policy ↗.


11. The rights of Users


Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

12. Details about the right to object to processing


Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.


13. How to exercise these rights


Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.


14. Cookie Policy


This Application uses Trackers. To learn more, the User may consult the Cookie Policy ↗.


15. Additional information about User's Personal Data


In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.


16. System logs and maintenance


For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.


17. Links to Other Websites


This Application may contain links to other websites that are not operated by the Owner. If you click on a third party link, you will be directed to that third party's 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.


18. Information not contained in this policy


More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled: This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.


19. Changes to this privacy policy


The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Your California Privacy Rights: If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa ↗

California's "Shine the Light" law (Civil Code Section §1798.83) permits users of this Application that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to help@a-tree.app ↗

Children under the Age of 13: This Application is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at: help@a-tree.app ↗


20. Contact


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

By email: help@a-tree.app ↗


21. Definitions and legal references


Personal Data (or Data): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data: Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User: The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject: The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application. (Described as either "the Owner", "We", "Us" or "Our" in this policy, referring to Trust today xyz Limited, Im Seefeld 16, 63667 Bad Salzhausen, Germany)

This Application: The means by which the Personal Data of the User is collected and processed.

Service: The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie: Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker: Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information: This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.





Help


Why four games? 􀁌

Each game sparks something different in your mind. It's like a canvas for you to express a thought, with a friend, in a playful way.

How long lasts a game? 􀁌

Each game lasts 24h in your inbox. Always fresh, always new.

How to plant a game? 􀁌

To plant (solve) a game, you e.g. need to find out a wordplay or solve a quiz. Your folder creativeness score grows when you plant a game. A folder lists played rounds with a friend in a score.

How can I invite a friend? 􀁌

You can invite your friend, in-app.


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Four games in your pocket, to play with friends. On iPhone.


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