Last updated on October 16, 2019


Thank you for using my Software. I am an indie software developer, Raymond Cardillo, doing business as Cardillo's Creations (“Cardillo's Creations”, “I”, “my”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us.

When you use our Software, Sites, or Services, you are trusting us with your personal information. As such, we take your privacy very seriously. This document describes the details of the privacy policy relevant to this Software. 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. Please take some time to read through it carefully, as it is important to understand. If there are any terms in this privacy policy that you do not agree with, please immediately discontinue use of our Software.

This privacy policy applies to all information collected through this software.

Please read this entire privacy policy carefully before using this Software or our Services because it's important to understand how we may use any information that we may obtain while you are using our Software or Services. By using this Software, or by allowing it to be used, you are confirming that you have read and understand our terms and policies.


TABLE OF CONTENTS


1.  WHAT INFORMATION DO WE COLLECT?

Information automatically collected

In Short:   Some information – such as advertising ID, IP address, and/or device characteristics – may be collected automatically when you use our Software.

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


2.  HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

This software does not collect any information that can identify you personally. Our other Software, Sites, and Services are likely to have different policies and should also be read and understood before using them. You should also review the Privacy Policy of any Third Party services listed below.


3.  WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:   We only share personal information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

This software does not collect any information that can identify you personally. However, if you share it with us through other means, in general, we may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in 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.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • 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.

4.  WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short:   We only share information with third parties that we trust and support our business needs.

We may share or disclose your information with the following third parties. These providers may not actually collect any data but they are being disclosed because we use their services so they have the potential to collect your information. We have categorized each party so that you may easily understand the purpose of our use and the potential for data collection and processing. We are not in direct control of these third party providers so you should review their privacy policies carefully as well.

  • Appodeal SDK - Advertising
    An advertising SDK that is used to display ads periodically (in between page transitions). To support a wide audience of users, the Appodeal SDK is configured to request ads that are safe for children and COPPA compliant.
    https://www.appodeal.com/home/privacy-policy/
  • Corona SDK - Framework
    The cross platform framework used to create this application. They have removed all forms of data collection for better COPPA and GDPR compliance.
    https://coronalabs.com/privacy-policy/

5.  DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:   We may use cookies and other tracking technologies to collect and store your information.

We may use cookies, advertising IDs, and similar tracking technologies (like web beacons and pixels) to access or store information.

“Cookies” are electronic files created by your web browser that many websites place on a visitor’s computer to store information that makes each visit to a respective site more efficient. Our Sites may use both “session” and “persistent” cookies. Session cookies store information about you only while you are visiting our site, and is then deleted when you leave our site. Persistent cookies store information about you, your preferences, and information about other websites you visit, and remains on your computer or device after you leave our website. To remove cookies, you may configure your browser to clear all cookies, or configure it to reject cookies whenever you visit a new website. Please consult your browser’s documentation for specific instructions on removing cookies.

“Advertising ID” is a unique number assigned to your mobile device for advertising purposes. The user can change them at any time, but they can be used to track your use of Software, Sites, and Services. While we don't use them specifically, several of the third party components that we use in this Software may use them.

As discussed above, we use third party providers to improve the quality of our Software, Sites, and Services, and to give you access to more relevant information. These services may also use session and persistent cookies, tracking beacons, or other monitoring and tracking technologies. Please refer to their privacy policy or cookie policy for additional details.


6.  HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:   We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


7.  HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure, nor can we guarantee that our third parties are 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.


8.  DO WE COLLECT INFORMATION FROM MINORS?

In Short:   We do not knowingly collect data from children under 18 years of age.

While some of our content may appeal to a younger audience, we do not knowingly solicit data from children under 18 years of age. Although this application does not directly collect any data, it does use third party frameworks that have the potential to collect some data. However, this application does not allow minors to provide consent and any frameworks being used are configured according to consent selection. If you become aware of any data that we have collected from children under age 18, please contact us immediately.


9.  WHAT ARE YOUR PRIVACY RIGHTS?

In Short:   In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.   

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area 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:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Sites visit:
http://www.aboutads.info/choices/


10.  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. 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 Policy.


11.  DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:   Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.


12.  DO WE MAKE UPDATES TO THIS POLICY?

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be included in any software updates and shown on our website. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.


13.  HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may get in touch using the contact information listed below.

Raymond Cardillo (dba Cardillo's Creations)
Pasadena, Maryland, United States
e-mail:
phone: +1-443-906-3872