Privacy Policy

This privacy policy is applicable to the sPictle app (hereinafter referred to as “Application”) for mobile devices, which was developed by Ignacio Gil Alvarez (hereinafter referred to as “Service Provider”) as an Ad Supported service. This service is provided “AS IS”.

What information does the Application obtain and how is it used?

User Provided Information

The Application acquires the information you supply when you download and register the Application. This includes your email, date of birth, and username. Email and date of birth are encrypted for secure storage. Registration with the Service Provider is not mandatory. However, bear in mind that you might not be able to utilize some of the features offered by the Application unless you register with them. The Service Provider may also use the information you provided to contact you from time to time to provide you with important information, required notices, and marketing promotions.

Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device (used exclusively for security purposes to mitigate attacks and not associated with any other user data), your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

Consent and Privacy Settings

You have control over the types of personal data you choose to share with us. Our Application provides three levels of privacy settings:

  • Necessary: Only the data required for the Application to function is collected.
  • Performance: Includes data processing for performance analytics using Google Firebase to help improve app functionality.
  • Personalization: Involves using data to remember your search history and preferences to enhance your user experience.

Automated Decision-Making and Profiling

While our Application does not engage in automated decision-making or profiling that has legal or similarly significant effects, it does use third-party advertising services provided by Google AdMob, which may use your data to display personalized ads based on your interests and previous interactions. For more information on how Google processes your data and how you can manage your preferences, please visit Google’s Privacy Policy.

Feed Personalization

Our Application offers a personalized experience by displaying a feed of posts based on the people you follow. The feed is primarily organized by date and gives preference to posts from your followers to enhance user engagement and relevancy.

Push Notifications and Gallery Access

Our Application uses push notifications to keep you informed about relevant activity and updates. You must opt-in to receive these notifications, and you can adjust your preferences or opt-out at any time through the settings on your device.

Additionally, the Application requires access to your device’s gallery if you choose to upload and set a personal avatar. This access is only used for uploading and storing your chosen images within the app.

Security of Information

Encryption: We employ advanced encryption techniques to protect the sensitive data you provide, such as your email and date of birth. Additionally, the application uses a securely generated key to authenticate users. This key is encrypted and stored on the user’s device and in our database to ensure that all personal data is protected against unauthorized access.

Does the Application collect precise real-time location information of the device?

This Application uses your device’s location solely to check your proximity to specific spots and to verify if you are within the geographical boundaries of a city for mission completion purposes. If you are within a predetermined distance from a monument, the application will notify you to enable camera access to capture the monument. Additionally, location data is used to determine if you are eligible to complete missions within a particular city. This location information is used exclusively for these functionalities and is neither transmitted nor stored externally.

Do Third Parties See and/or Have Access to Information Obtained by the Application?

Aggregated and Anonymized Data: We only transmit aggregated and anonymized data to external services to aid in improving the Application and our services. This data cannot be used to identify individual users.

Sharing with Third-Party Service Providers: Specific personal information may be shared with third-party service providers, who assist us in operating our Application, conducting our business, or servicing our users. These providers are listed below along with the purposes for which we share the data:

  • Google Play Services and AdMob: These services are used for advertising and analytics purposes, helping us to understand user behavior and improve marketing strategies.
  • iOS Services: For users on iOS devices, our application utilizes various iOS services and frameworks to enhance functionality and user experience.
  • Google Analytics for Firebase and Unity: These platforms are employed to collect analytics data that enhances app functionality by providing insights into app usage and user engagement.
  • Backblaze and Bunny: Utilized for storing user data and delivering content, respectively, essential for features such as saving game progress and sharing images within the Application.

iOS Specifics: For iOS users, we ensure that all data access complies with Apple’s privacy guidelines, including obtaining user consent through the standard iOS prompts before accessing personal data.

Each provider has their own privacy policy detailing how they handle data, which you can review through the following links:

Disclosure of Information

We may disclose both user-provided and automatically collected information under certain circumstances:

  • Legal Requirements: As required by law, such as to comply with a subpoena or similar legal process.
  • Safety and Rights Protection: When we believe in good faith that disclosure is necessary to protect our rights, ensure your safety or the safety of others, investigate fraud, or respond to a government request.
  • Service Providers: With our trusted service providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

These disclosures are conducted under strict contractual terms to ensure the privacy and security of your data.

International Data Transfers

The personal data we collect is stored and processed on servers located in the United States, operated by our hosting service provider, Namecheap. This includes data such as your email, date of birth, and usage data collected by the Application. Although this data is transferred outside of the European Economic Area (EEA), we ensure that Namecheap adheres to the General Data Protection Regulation (GDPR) by implementing Standard Contractual Clauses. You can view these clauses here. This arrangement ensures that your data is handled with a level of security and protection equivalent to that required by EU law.

Rights Under GDPR and CCPA

GDPR Rights: If you are a resident of the European Union, you are entitled to certain rights under the General Data Protection Regulation. These rights include the ability to request access to your data, correct errors in our records, erase your personal information, restrict the processing of your personal information, object to the processing of your personal information, and the right to download your personal information in a digital format.

CCPA Rights: If you are a resident of California, you are entitled to additional rights over your personal information under the California Consumer Privacy Act (CCPA). These rights include:

  • Right to Know: You can request information about the collection, use, and sharing of your personal data over the past 12 months, including the specific pieces of personal information we have collected about you.
  • Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions as defined by the CCPA.
  • Right to Opt-Out of Sale: Although our Application does not sell personal information, we are committed to ensuring that you have the right to opt-out of any potential future sales. If you wish to exercise this right, you can contact us directly.How to Exercise Your CCPA Rights:
    • Requests to Know and to Delete: You can make a request for disclosure or deletion of your personal information through the “Settings” menu in the Application or by contacting our Data Protection Officer at [email protected]. We will respond to your request within 45 days, with the possibility to extend this period once for an additional 45 days when reasonably necessary.
    • Opt-Out Requests: As we do not sell personal information, there is no need to opt out. However, should this policy change, we will update our privacy policy and provide you with an opt-out mechanism through our Application and website.

    Please note that we will verify your identity before processing your request to ensure the security of your personal data. For requests via the “Settings” menu, your identity will be verified through your account credentials. For email requests, we may require additional information from you to confirm that the request is valid and originates from you.

    Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you goods or services, charge you different prices or rates for goods or services, provide you with a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    Contact for More Information: If you have any questions about your CCPA rights or need further assistance regarding your rights under California law, please contact us at [email protected] or reach out to our Data Protection Officer.

What are my opt-out rights?

You can stop all collection of information by the Application by adjusting your preferences in the “Settings” section of the Application. You may also use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Data Retention and Managing Your Information

Data Retention Policy: We retain user-provided data as long as you use the Application and for a reasonable time thereafter. Automatically collected information is retained for up to 24 months and then stored in aggregate form, which is necessary for the Application to function properly.

Managing Your Data: You can directly access, modify, and manage your personal information within the Application. Through the “Edit Profile” section, adjust your email and avatar. Use the “Settings” menu to customize your privacy settings, control data collection, and manage marketing communication preferences. If you need to delete your account, this action is available in the “Settings” menu and will permanently remove all associated data from our servers, consistent with our data retention policy. For additional support or specific data deletion requests, contact us at [email protected].

Access to Your Personal Data: You have the right to access the personal data we hold about you. Request this by contacting our Data Protection Officer at [email protected], or directly through the “Settings” section of the Application. We will provide your data in a commonly used electronic format.

Your Rights Include:

  • Rectification: Correct or complete inaccurate or incomplete personal data.
  • Erasure (“Right to be Forgotten”): Request the deletion of your personal data when it is no longer necessary.
  • Restriction of Processing: Restrict the processing of your personal data under certain conditions, such as disputing data accuracy.
  • Data Portability: Receive and transmit your data to another controller in a structured, commonly used, and machine-readable format.
  • Objection: Object to the processing of your personal data based on your specific situation.

Service Termination

In the event that we decide to discontinue the Application, we commit to notifying users with reasonable advance notice via the application interface or through a push notification. This will allow users to take necessary actions regarding their personal data stored on our platform.

Data Handling upon Service Termination:

  • Data Deletion: Upon service termination, we will securely delete all personal data from our servers in accordance with our data retention policy, unless required to be retained for legal reasons.
  • Data Transfer: We will not transfer personal data to third parties without explicit user consent, unless required by law.
User Rights:
  • Access and Data Export: Users will have the option to download or export their personal data in a structured, commonly used format before the termination date.
  • Account Deletion: Users will be able to delete their accounts and all associated data before the service ceases. Detailed instructions for this will be available in the application’s settings section.

We commit to maintaining transparency and openly communicating with our users during the termination process to ensure as smooth a transition as possible.

Data Protection Officer

Our Data Protection Officer is responsible for overseeing the application’s data protection strategy and its implementation to ensure compliance with GDPR requirements. You can contact our DPO, Ignacio Gil, for all matters related to your personal data and privacy rights at [email protected].

No Sale of Personal Data

We do not sell the personal data of our users to third parties.

Use of Cookies on the Website

Our application does not use cookies; however, our website does. Details on cookie usage, including managing consent and preferences, are available in our Cookie Policy on https://spictle.com/cookies-policy.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13. The Application does not address anyone under the age of 13. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. In the case the Service Provider discovers that a child under 13 has provided personal information, the Service Provider will immediately delete this from their servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact the Service Provider at [email protected] so that necessary actions can be taken.

Security

The Service Provider is concerned about safeguarding the confidentiality of your information. We use HTTPS protocols to secure the communication between your device and our servers, which are hosted by Namecheap, known for their robust security measures. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop, or improve the Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

International Data Compliance

  • Canada (PIPEDA): We ensure that the collection, use, and disclosure of personal data from Canadian users comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), which requires explicit consent for such activities.
  • Brazil (LGPD): For users in Brazil, we adhere to the General Data Protection Law (LGPD), ensuring rights such as data access, correction, and portability are respected.
  • United Kingdom (UK GDPR): Post-Brexit, we comply with the UK GDPR and the Data Protection Act 2018, ensuring that data protection and user privacy are maintained across all processing activities.
  • Singapore and Thailand (PDPA): We comply with the Personal Data Protection Acts of Singapore and Thailand, providing transparency and rights regarding the use and management of personal data.
  • Japan (APPI): In accordance with Japan’s Act on the Protection of Personal Information (APPI), we take careful measures to handle personal data securely and provide mechanisms for users to manage their personal information. These regulations reflect our commitment to protect your privacy and ensure data security across all jurisdictions where our application is available.
  • Mexico: In compliance with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), we ensure all personal data processing activities are conducted with explicit consent and adhere to strict security measures. Mexican users can exercise their ARCO rights directly through the application settings.
  • Colombia: Under Statutory Law 1581 of 2012, we process personal data based on explicit consent. Colombian users have rights to access, update, or delete their personal information, and these can be managed directly within the app.
  • Argentina: According to the Personal Data Protection Law No. 25.326, we process personal data with clear consent and provide robust security measures. Argentine users can access, rectify, or delete their data, as well as withdraw consent through the app’s settings.

These regulations reflect our commitment to protect your privacy and ensure data security across all jurisdictions where our application is available.

Dispute Resolution

If you have any concerns or complaints about your privacy or data use, we encourage you to contact us first at [email protected] so we can address your concerns directly. If you feel that your complaint has not been adequately resolved, you have the right to contact your local data protection authority within the jurisdiction you are located.

Changes

We may update our Privacy Policy periodically to reflect changes in our practices or service offerings, or as required by law. Whenever we make significant changes, we will notify you either through the application interface or via a push notification. You are encouraged to review the Privacy Policy regularly to stay informed of any updates. Continued use of the application after any changes to the Privacy Policy have been communicated will constitute your consent to those changes.

This privacy policy is effective as of 2024-04-28

Your Consent

When you register with the Application for the first time, you will be asked to consent to our processing of your personal data as outlined in this Privacy Policy. To ensure transparency and compliance with the General Data Protection Regulation (GDPR), we employ an active consent mechanism. You will be required to explicitly check a box indicating your consent to our data practices. Only the data necessary for the application to function is processed without requiring additional consent. You have the right to adjust your data processing preferences at any time through the application’s settings.

Your consent is crucial for us to provide personalized services and enhancements to your app experience. Withdrawal of consent can be done easily within the app settings, which may affect the functionality or services available to you.

Legal Basis for Data Processing

We process your personal data based on several legal grounds:

  • Consent: By using our Application and agreeing to this Privacy Policy, you have consented to our processing of your personal data for specific purposes such as marketing and personalization. You can withdraw your consent at any time via the Application’s settings.
  • Contractual Necessity: If you create an account, the processing of your personal data is necessary to provide the services you have requested under the terms of service.
  • Legal Obligation: We may process your data when required by law, such as for tax purposes or other legal requirements.
  • Legitimate Interests: We process data for legitimate business purposes, which include fraud prevention, ensuring network and information security, or when processing is necessary for the development and enhancement of our services.

Contact Us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at [email protected].