Verba | Privacy Policy

 

When you use our mobile application Verba, as the case may be (the «app») and more generally, use any of our services (the «services», which include the app), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our services immediately. This privacy notice applies to all information collected through our services (which, as described above, includes our app), as well as, any related services, sales, marketing or events. Please read this privacy notice carefully as it will help you understand what we do with the information that we collect. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at verba@monicreque.com.

What information do we collect?

Personal data

The application does not collect nor uses any personal data from the users. Also, it does not provide an option to create a user account, meaning that all the information generated in the game is locally stored in your own device. This information includes your learning achievements, favorite words or played levels, for example. As a player, you have the option to connect the application with Google Play Games to have access to features such as gamer profiles, cloud saves, achievements, and social and public leaderboards. By doing so, your progress in the game will be stored and managed by Google Play Games Service according to its Terms of Service.

Usage data

We automatically collect certain information when you visit, use or navigate the app. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our app and other technical information. This information is primarily needed to maintain the security and operation of our app, and for our internal analytics and reporting purposes. The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our app and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the app (such as the date/time stamps associated with your usage, searches and other actions you take such as which features you use), device event information (such as system activity, error reports and hardware settings).
  • Device Data. We collect device data such as information about your, phone, tablet or other device you use to access the app. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, internet service provider and/or mobile carrier, operating system and system configuration information.
  • Mobile Device Permissions. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Push Notifications. We may request to send you push notifications regarding certain features of the app (for example, when you reach a new level or when you achieve a goal). If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

 

How do we use your information?

We use personal information collected via our app for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the app, such as buying coins, lives or boosters.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of the application.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

 

Will your information be shared with anyone?

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Offer Wall. Our app may display a third-party hosted «offer wall.» Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our app and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our app. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.

Is your information transferred Internationally?

Usage data and anonymized personal data described in this privacy policy are used and stored by the third-parties Google Analytics for Firebase (Google Inc.) and Firebase Crashlytics (Google Inc.) for analytics and reporting purposes, whose servers may be located in countries other than your own. Also, when you make a purchase inside the app or via Google Play, your purchase will be subject to Google’s applicable payment policy, which also may not provide for refunds.

The usage that these third-parties make of your data is governed by their privacy policy and we do not have control over this. We will, however, take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. Please check the privacy policies for the external services here addressed:

What is our stance on third-party websites?

The app may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the App. You should review the policies of such third parties and contact them directly to respond to your questions.

How long do we keep your information?

Regarding the analytics and reporting information, we will only keep it for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 14 months.

Regarding your personal information, it is locally stored in your device and will be deleted from it when you decide to uninstall the application. None of your personal information is stored in the devices of the users you communicate with, including temporary data such as chat messages.

Do we collect information from minors?

No. Our service complies with the content and target audience policies established by Google Play with a minimum target age above 13 years.  The application does not collect personal data from the users regardless of their age.

What are your privacy rights?

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track («DNT») feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Advertising

Advertising helps us to keep our app free, to maintain it and to create new features for you. The ads content is not based on your entries, since we don’t share your data with the ads providers. The free version of the Android app uses AdMob (AdMob Google Inc.) to display advertisements, such as full-screen ads or rewarded videos, which might be based on your interests. AdMob uses cookies to identify users and they may use behavioral targeting techniques, i.e. displaying ads that are in accordance with your interests and behavior, including those detected outside this app. For example, if you’ve previously visited e-shop selling jeans, you might see more ads promoting jeans or jeans shops. Google’s advertising requirements can be summed up by Google’s Advertising Principles at: https://www.google.com/policies/privacy/partners

If you don’t want to see personalized ads based on your interests you might opt-out by using this link: https://adssettings.google.com/authenticated. Please note that you will see the same amount of ads but the ads will be less relevant to you.

Changes

We may update this privacy notice from time to time. The updated version will be indicated by an updated «Revised» date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Contact

If you have questions or comments about this notice, you may email us at verba@monicreque.com.