(A) Who we are: We are Semantic Labs Limited, a publishing company delivering apps for mobile devices. Semantic Labs Limited is the controller of your personal information, and is responsible for your personal information. All references in this policy to "Semantic Labs", "our", "us" or "we" refer to Semantic Labs Limited, or our group companies, as appropriate. All references in this policy to "apps" are to our apps that are available to download on mobile devices from time to time.
(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.
In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.
We are always looking to improve the information we provide to our customers and contacts, so if you have any feedback on this privacy policy, please let us know using our contact details in section 10.
(C) Who this policy applies to: This policy applies to users of our apps and people who contact our customer support function.
(D) What this policy contains: This privacy policy describes
the following important topics relating to your information (you can
click on the links to find out more):
1. Collection of your personal information
and how we use it:
2. Our legal basis for using your personal
information;
3. How and why we share your personal
information with others;
4. Your rights;
5. Children;
6. Risks and how we keep your personal
information secure;
7. Changes to this privacy policy; and
8.Further questions and how to make a
complaint.
(E) Your rights to object: You have various rights in respect
of our use of your personal information, as set out in section 5.
Two of the fundamental rights to be aware of are that:
1. you may ask us to stop using your
personal information for direct marketing purposes. If you exercise
this right, we will stop using your personal information for this
purpose.
2. you may ask us to consider any valid
objections which you have to our use of your personal information
where we process your personal information on the basis of our, or
another person's, legitimate interest.
You can find out more information in section 5.
(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, including downloading and using any of our apps, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.
The detail – the key information you should be aware of
1. Collection of your personal information and how we use it
1.1 What personal information we collect about you
(a) Our apps collect the following
information about you (and we use the information in the ways
explained below):
(i) if you agree
to receive personalized ads, data about your general location and
the Identifier for Advertising (IDFA) of the device.
1.2 How we use your personal information
We will share the personal information listed above for the
following reasons:
(a) to help manage advertising and provide
you with advertising and marketing via our apps that is relevant to
you, both from us and from our third party partners, as further
described in the 'Third party advertising' section below;
(b) to record your preferences in relation
to advertising and marketing communications.
2. Legal basis for use of your personal information
2.1 We consider that the legal bases for using your personal
information as set out in this privacy policy are as follows:
(a) our use of your personal information is
necessary to perform our obligations under any contract with you
(for example, to comply with the terms of service of our apps);
or
(b) you have provided us with your consent
to do so. This applies in relation to the advertising and marketing
materials delivered via our apps that are tailored to you and your
preferences. You can control and withdraw your consent at any time
on our apps.
(c) where (a) or (b) does not apply, our
use of your personal information is necessary for our legitimate
interests or the legitimate interests of others. Our legitimate
interests are to:
(i) run, grow and
develop our business (as well as the businesses of our group
companies) including funding our business by use of advertising
revenues;
(ii) and operate,
maintain and improve our apps and our marketing optimisation
efforts;
3. How and why we share your personal information with others
Third party advertising
3.1 We want to make sure that our advertising and marketing is
relevant and interesting to you and our other customers. To achieve
this, we use third-party advertising and technology companies to
serve advertising and/or provide aggregated data to assist in
serving advertising when you visit or use our apps. This includes
third party technology companies which collect data about you in
order to build a profile of your preferences based on your
activities when you visit or use our apps. We also use these
companies to automatically collect data from you when you use our
apps in order to help us identify the advertising that are served to
you and what you do after seeing those advertising. In addition, we
share data with providers of analytics tools, such as Firebase,
IronSource which we use to analyse your use of the apps. A list of
the third party advertising and technology companies that we use is
set out below.
(a) Google Admob
3.2 These third party advertising companies collect, store and use
data by integrating cookies and other tracking software on our apps.
The relevant data collected by these third parties includes:
(a) data about location, IP address, a
unique device ID, geo-location details;
(b) data which you provide to us when using
our apps, including information on your interaction with advertising
and certain technical information.
3.3 These third party advertising companies will collect and use your data to provide you with targeted advertising that is relevant to you and your preferences with your consent. You can control and withdraw your consent to this targeted advertising at any time on our apps. If you do not provide or withdraw your consent to receive targeted advertising that is relevant to you and your preferences, then we will still serve you advertising when you visit or use our apps but this will no longer be tailored to you or your preferences.
3.4 In some cases these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
4. Your rights
5.1 You have certain rights in relation to your personal
information. If you would like further information in relation to
these or would like to exercise any of them, please contact us via
email at
developer.sm007@gmail.com
at any time. You have the following rights:
(a) Right of access. You have a right of
access to any personal information we hold about you. You can ask us
for a copy of your personal information; confirmation as to whether
your personal information is being used by us; details about how and
why it is being used; and details of the safeguards which are in
place if we transfer your information outside of the European
Economic Area ("EEA").
(b) Right to update your information. You
have a right to request an update to any of your personal
information which is out of date or incorrect.
(c) Right to delete your information. You
have a right to ask us to delete any personal information which we
are holding about you in certain specific circumstances. You can ask
us for further information on these specific circumstances by
contacting us using the details in section 10.
We will pass your request onto other recipients of your personal
information unless that is impossible or involves disproportionate
effort. You can ask us who the recipients are, using the contact
details in section 10.
(d) Right to restrict use of your
information. You have a right to ask us to restrict the way that we
process your personal information in certain specific circumstances.
You can ask us for further information on these specific
circumstances by contacting us using the details in section 10.
We will pass your request onto other recipients of your personal
information unless that is impossible or involves disproportionate
effort. You can ask us who the recipients are using the contact
details in section 12.
(e) Right to data portability. You have a
right to ask us to provide your personal information to a third
party provider of services.
This right only applies where we use your personal information on
the basis of your consent or performance of a contract; and where
our use of your information is carried out by automated means.
(f) Right to object. You have a right to
ask us to consider any valid objections which you have to our use of
your personal information where we process your personal information
on the basis of our or another person's legitimate interest.
4.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
4.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
5. Children
5.1 You must be aged 16 or over to purchase products or services from us. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.
5.2 If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
5.3 Please contact us at developer.sm007@gmail.com if you are aware that we may have inadvertently collected personal information from a child below the age of 16.
6. Risks and how we keep your personal information secure
6.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
6.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our apps. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.
6.3 Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our apps or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
7. Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be made available to you via the privacy policy, accessible in our app. Please check back frequently to see any updates or changes to our privacy policy.
8. Further questions and how to make a complaint
8.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact developer.sm007@gmail.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
8.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
The practices described in this privacy policy statement are current as of 24 July 2022.