Note:
The services provided include subscriptions that renew automatically. Please carefully review these policies, especially Section 1, before initiating a trial or finalizing a purchase for our app's auto-renewing subscription service. To prevent charges, you must actively cancel your subscription at least 24 hours before the conclusion of the free trial or the ongoing subscription period.
PRIVACY POLICY
Updated and Effective as of January 15, 2025
IMPORTANT PRIVACY INFORMATION
To use some of our Services (apps, websites, and others), we may ask you to provide specific information such as your name (or nickname), email address, date of birth, information about your feelings and mental well-being, and other onboarding details. Depending on the app or web product you choose within our ecosystem, additional data—such as your pulse, heart rate, a photo of your hand, or other information—may be required (please refer to Section 2.1 of this Policy). In some of the cases, you have the option to skip certain onboarding questions by selecting "Skip" or a similar feature.
Additionally, we may automatically collect information from your device, including language settings, IP address, time zone, device type and model, and other data points. This data enables us to provide Services (e.g., rendering product features), analyze app usage (e.g., feature popularity), and enhance specific experiences like refund processing.
To improve subscription management and engagement tracking, we integrate with Apple’s App Store Server API. This includes using the consumptionRequestReason feature, which collects data about your interactions with subscription content. Certain event data (Customer Account Age, User Account Details, Content Consumption Level, Platform Information, Total In-App Purchase Amount, App Usage Time, and Account Status) may also be shared with Apple to enhance subscription management in line with Apple’s guidelines. Apple uses and protects this data per its Privacy Policy, retaining it only as necessary to fulfill its purpose, such as improving the refund process by reviewing refund requests more effectively. For further details on how Apple protects data, see the Apple Platform Security Guide or the App Store & Privacy documentation. Apple may share this data with service providers acting on its behalf, partners, or others at your direction but will not use it for marketing purposes. You may opt out of transferring this event data to Apple by contacting us.
We encourage you to read this Privacy Policy to better understand how we handle your data (Section 2), your data privacy rights (Section 7), and the privacy control features available to you.
If you have any unanswered questions or wish to exercise your privacy rights, please contact us at support@appsella.tech.
In this privacy policy, the following definitions are used:
«Services» refers to our Apps, Websites, and any related services or properties we control;
«Apps» refers to games, applications, and other products produced by us on any and all platforms;
«Websites» refers to websites and other online properties we control;
«Personal Data» refers to data that relates to you as an identified or identifiable individual;
«Anonymous data» does not include data where the identity has been removed;
«User, consumer, you» is any third party that uses our Services.
WE HOPE YOU TAKE SOME TIME TO READ THROUGH IT CAREFULLY, AS IT IS IMPORTANT.
PLEASE DO NOT PROVIDE ANY SENSITIVE INFORMATION UNLESS YOU ARE CERTAIN ABOUT ITS NECESSITY AND HAVE GIVEN YOUR EXPLICIT CONSENT.
Thank you for choosing to be part of our community!
This privacy policy describes how our organization APPSELLA LTD is the legal entity incorporated in accordance with the laws of the Republic of Cyprus under the registration number HE 427133 with the following address of registration: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Cyprus (collectively, “we”, “us”, or “our”) collects, uses, stores, transfers and discloses personal information from our Users in connection with our Services. One way to protect your privacy is to learn how personal information will be used before you give it out. We attach great importance to your privacy rights and truthfully explaining why and how we use your information.
We hope you take some time to read through it carefully, as it is important.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), APPSELLA LTD will be the data controller responsible for any personal data we process.
In this privacy policy, the following definitions are used: за
«Services» refers to our Apps, Websites, and any related services or properties we control;
«Apps» refers to games, applications, and other products produced by us on any and all platforms; «Websites» refers to websites and other online properties we control;
«Personal Data» is used when referring to personal data that relates to you as an identified or identifiable individual;
«Anonymous data» does not include data where the identity has been removed;
«User, consumer» is any third party that uses our Services.
We have the right to update this Privacy Policy from time to time so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.
Please read this Policy carefully and do not hesitate to contact us if you have any questions at support@appsella.tech. Where applicable, if you do not provide us with the relevant Personal Data, you may not be able to use our Services completely. You should not use the Services if you do not agree with this Policy, our Terms of Use.
How to contact us:
Name: APPSELLA LTD
Address: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Cyprus
E-mail: support@appsella.tech
AI Feature
In our app, we feature a Personal AI-Therapist-assisted chatbot powered by OpenAI's ChatGPT. Consequently, if you choose to engage in a conversation with the AI Therapist, your conversations will be transmitted to OpenAI's servers via an API connection. However, we will not transfer any data from your conversations that would enable OpenAI to identify you unless you explicitly provide such information within your conversations. We do share your nickname with OpenAI to ensure proper addressing by the AI Therapist, which is essential for delivering the user experience we aim to provide. It's important to note that we do not permit OpenAI to utilize your information for training or enhancing its models.
Please be aware that some of the information you may disclose during your conversations could be sensitive. We kindly request that you refrain from providing such sensitive information, and we assure you that we will not process such data unless we obtain your explicit consent. When we do process such information, it will solely be for the purpose of delivering our service to you.
The data transfer between our platform and OpenAI occurs through a SOC 2 Type 2 compliant API connection, which has been independently audited by a third-party auditor in accordance with the 2017 Trust Services Criteria for Security. You can find more information about this audit from publicly available sources on OpenAI's website (https://openai.com/policies/api-data-usage-policies).
OpenAI will retain the information you send via the API for a maximum of thirty (30) days, after which it will be deleted, except when OpenAI is required to retain copies under applicable laws. In such cases, OpenAI will isolate and protect that information from any further processing except as mandated by applicable laws.
For additional details regarding OpenAI's API data usage policies, please consult https://openai.com/policies/api-data-usage-policies
1.1. The App is provided on a free basis, granting users access to its basic features upon download. However, premium features, content, or services are available through a subscription model, typically on a recurring weekly basis. Subscribers may receive benefits such as exclusive content and advanced features. Detailed subscription terms are accessible on the purchase screen prior to completing the transaction.
1.2. A free trial period of three days may be offered, allowing users to experience premium features. If not canceled at least 24 hours before the trial period ends, users will be automatically charged the specified price for the chosen subscription plan, as indicated on the payment screen.
1.3. In-app purchases are facilitated through the App. Payment will be charged to the specified payment method at the time of purchase confirmation or after the trial period expires. It is important to note that we do not collect payment data; all financial transactions are processed by our authorized agents, Google Play and Apple Store.
1.4. Prices and taxes may be subject to occasional changes, transitioning to a subscription model, which includes recurring subscription fees. We will communicate any changes in prices to you in advance. These changes will take effect at the beginning of the next subscription period following the date of the price adjustment. By continuing to use the subscription after the price change takes effect, you will be deemed to have accepted the new pricing. If you do not agree to a price change, you can reject it by unsubscribing from the applicable subscription before the new price becomes effective.
Tax rates and other fees are determined based on the rates applicable at the time of your monthly charge. These amounts may change over time due to local tax requirements in your country, state, territory, county, or city. Any change in the tax rate will be automatically applied based on the account information you provide.
1.5. CANCELLATION: Subscriptions renew automatically at the end of each period unless canceled. Deleting the app does not cancel subscriptions. Users can cancel subscriptions via their Google Play and App Store accounts or through the "Cancel Subscription" button in the app settings, which redirects to the subscriptions section in Google Play/App Store. After cancellation, access to subscription features continues until the end of the current period.
For subscriptions purchased on the App Store: you can easily cancel a free trial or subscription by disabling auto-renewal in your Apple account settings. To manage subscriptions independently, refer to Apple's support page for detailed guidance. If you wish to cancel your subscription directly on your iOS device, follow these steps:
1 - Open the standard iOS Settings app.
2 - At the top, tap your name.
3 - Navigate to "Subscriptions."
4 - Tap the subscription that you want to manage.
5 - If you wish to cancel, tap "Cancel Subscription."
6 - If you don’t see the option to cancel, it means the subscription is already canceled and won't renew.
For subscriptions purchased on Google Play, you can easily cancel a free trial or subscription by disabling auto-renewal in your Google Play account settings. To manage subscriptions independently, refer to Google's support page for detailed guidance. If you wish to cancel your subscription directly on your Android device, follow these steps:
1 - Open the Google Play Store app on your Android phone or tablet.
2 - At the top right, tap the profile icon.
3 - Navigate to "Payments & subscriptions" and then click on "Subscriptions."
4 - Choose the specific subscription you wish to cancel.
5 - Tap "Cancel subscription."
6 - Follow the provided instructions to complete the cancellation process.
If you encounter any difficulties during this process, refer to our support resources for further assistance. We appreciate your understanding and are here to help if you have any questions or concerns.
1.6. REFUND:
Generally, if you do not meet the conditions of the Refund Policies set out above, the fees you have paid are non-refundable and/or non-exchangeable unless otherwise stated herein or as required by applicable law. In addition, our company may consider certain refund requests on a case-by-case basis and grant them at our sole discretion.
Subscription and payment management is beyond our control as Google/Apple doesn't provide access to billing information. Refund decisions are made by Google/Apple. To request a refund, use the order number found in the confirmation email received upon subscription.
To request a refund, follow these instructions from the Apple support page, Google's support page.
Our app integrates with Apple’s App Store Server API to manage in-app subscriptions and improve your experience by accurately tracking engagement with subscription content. We use the consumptionRequestReason feature, which enables us to collect specific data about your interactions with subscription content. Certain data collected may also be shared with Apple to enhance subscription management in line with Apple’s guidelines:
Apple uses and protects the data you share through the Send Consumption Information API in accordance with Apple’s Privacy Policy. For additional information about how Apple protects data, see the Apple Platform Security Guide. Apple retains the data you provide through the Send Consumption Information API for the period necessary to fulfill the purpose for which the data was collected, which is to improve the refund process by obtaining data that assists with reviewing the customer’s refund request. Apple may share the data you provide through the Send Consumption Information API with service providers who act on our behalf, our partners, or others at your direction. Apple will not share the data with third parties for their own marketing purposes. For more information, see App Store & Privacy.
We are available to guide you through the process. Please contact us at support@appsella.tech or via our website form: https://ios-support.astroline.app/ or https://android-support.astroline.app/ .
If the User made a subscription purchase but it wasn’t delivered or isn’t working correctly, the services are defective, unavailable, or don’t perform as stated and it’s been more than 48 hours since User made the purchase, we consider a refund request.
Please note that after your subscription period expires, we will not be able to refund you as the service will be deemed consumed in full unless otherwise provided for by applicable law.
Note for the EU residents. Under the law, you have an automatic statutory right of withdrawal from contracts for purchases of digital content, such as apps, games, in-app items, or other media like movies or music. The same applies when you purchase a subscription for digital content within an app. However, when you purchase or subscribe to digital content with Google Play and Apple Store, you agree that the digital content will be available to you immediately, and you acknowledge that, as a result, you waive your automatic statutory right of withdrawal. Therefore, you will not be eligible for a refund (or any alternative remedy) unless the digital content is defective, unavailable, or doesn’t perform as stated.
Note for residents of certain US states. If you reside in California or Connecticut and cancel the purchase at any time prior to midnight of the third business day after the date of such purchase, we will return the payment you have made.
1.7. Process for Filing a Complaint or Refund Request:
1 - Initiate Request: Users can file a complaint or request a refund through various channels: web site (https://android-support.fortunescope.app ), email (support@appsella.tech), and form "Contact Us" in the App
2 - Acknowledgement: Expect an acknowledgment of your request within 1 working day.
3 - Review and Investigation: Our customer support team will thoroughly review and investigate the circumstances surrounding your complaint or refund request.
4 - Communication of Decision: You will be notified of the final decision through the form you used to make the request. The notification will provide a detailed explanation of the decision and the reasoning behind it.
2.1. When you use our Services, we can collect, use, receive, process, transfer, and share some of your Personal Data for different legitimate purposes. You will find below explanations regarding what personal data we may collect, the reasons why we may collect this data, and the legal bases we will rely on in each case. Please be aware that the types of information that we may collect depend on how you use the Services and interact with us.
Category | Personal Data |
User-provided information (In some instances, we may require certain Registration Information, in other cases, we may ask you to provide such data voluntarily.) | |
Contact Data – when the User registers for the Service and enters the contract | email; Name/Surname/Nickname; address, postal code, phone number, password or passcode; last 4 digits of the card number; comment. |
Location Data - we do not collect the User’s precise location | country, state, or coarse location such as Approximate Location Services (general - non-precise location). |
Quiz Data - during the onboarding questionnaire, the User may provide different quiz personal data. We do not collect, store, share, or transfer this quiz data or use this data for identification, marketing, or advertising purposes. We are not collecting biometric information. | date and place of birth, birth time, gender, weight, age, photo (arm, face, Etc.), relationship status, future goals, source of stress, answers to the questions, data on physical characteristics (including height, weight, areas for improvement), Etc. |
Automatically collected information. When you use the Service, some information about your device and user behavior may be processed automatically. Examples of such information: | |
Device Info – technical data | device type and model, two-character country code, a subdivision of country (e.g., state), city, two-character language code, operating system, and version number (ex.: ios 7.1.3, android), hardware type, connection type (for example, WiFi, 3G, 4G), network service provider, device motion parameters and carrier. |
Identity Data - identify a computer, device, browser, or product | IP Address; ID for advertisers (IDFA) (iOS only); Google Advertising ID, or GPS ADID (ID Device) if Google Advertising ID is empty; API level (Android only); Firebase ID and other similar unique identifiers. |
Usage Data (Events) - indicates if the activity happened on mobile or web | length of the User's last session in seconds; Length of the User's current session in seconds; Number of sessions recorded; Push notification token, i.e., registration token (Android), device token (iOS); clicks on User's ads; the type of ads and the webpage or Application from which such ads were displayed; downloads and installations of applications. |
Diagnostic information | logs, error reports, events, and the type, number, date, and page relating to this information. |
Cookies and Other Tracking Technologies | cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods, and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or information received from third parties. |
Please note that we may ask your permission to connect to Apple HealthKit (please see more information here: http://www.apple.com/ios/health/) and Google Fit (please see more details here:https://www.google.com/fit/) to enable us to import Personal Data about your health and activities into the Service. This imported data may include calories burned, heart rate, and other data about your health. When you choose to have this data imported, you are subject to the Google Fit and Apple HealthKit privacy policies and practices.
We collect personal data to ensure the Service provided, analyze your behavior during the usage of our Service, add new features to our Service, and provide our third-party service providers with information crucial to their services.
Providing Service includes enabling you to use the Service seamlessly and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, for example, to send you the purchased product or to render services ordered through our Website. To host personal data and enable our Website to operate and be distributed, we use Amazon Web Services, a hosting and backend service provided by Amazon. We use Stripe and PayPal, payment processing providers, to allow the purchase and process your payments. We use Firebase Performance Monitoring, a monitoring Service provided by Google. Please visit Google’s Privacy Policy and Privacy and Security in Firebase to learn more. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
2.2. The app requires your permission to access your microphone recordings and your photo and video library when you use the app to activate voice command and to enable you to share your achievements on your social media accounts. However, we do not collect or have access to such data.
2.3. We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.
The purpose of this Privacy Policy is the fulfillment of the provisions of the Terms of Service (“Contract”) concluded between the User and Appsella LTD. We collect user’s personal data when user starts using our Services. Our main aim is to perform our contractual obligation towards the User and make our Service available to the User. We use information that you submit and information that is processed automatically to provide you with all requested services.
We generally process your personal data on the following legal bases:
Contract. You have entered a contract with us and we need to use some of your personal data to provide services you have requested or take steps that you request prior to providing services. For example, we cannot create an account for you if you do not provide the required information like your email address. If you do not provide information indicated as required or mandatory within our service, it will not be available to you.
Legal obligations. We may have to process or share your personal data to comply with legal obligations, such as to comply with a subpoena or legal process.
Legitimate interests. We process your personal data for purposes that constitute our legitimate interests, such as fraud prevention and safety; protecting our, your, or others’ property rights; exercising or defending legal claims; investigating violations of and enforcing our Terms of Use; and analyzing and improving our services.
Consent. In some cases, we may process your personal data based on your consent, such as when we request access to data on your mobile device through the prompts in your device’s operating system. You have the right to withdraw your consent anytime in the manner indicated at the time consent is requested with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.
PURPOSES | PERSONAL DATA CATEGORY | LEGAL BASIS |
To provide the Services according to our policies with you. For example, we use your Personal Data to: help you with the onboarding process and personalize your results, provide the app when you download it onto your device. | Contact Data; Quiz Data; Location Data; Usage Data | Contract |
Research and development: We use Personal Data for internal research and development purposes and to improve and test the features and functions of our Services. We use information processed automatically to understand better user behavior and trends, detect potential outages and technical issues, and operate, protect, improve, and optimize our Service. | Automatically collected information | Legitimate interest |
To diagnose and fix issues with the Service. | Usage Data | Legitimate interest |
To help the User to choose a subscription plan, provide entertainment services, to send analysis reports, and go through the quiz to customize the User experience. | Quiz Data | Contract |
To communicate with you. When you contact us (for example, to inquire about our Services), we want to communicate with the User to provide support. | Contact Data | Contract |
To allow us to track the performance of our marketing campaign to help us optimize our Service features and events for each user. | User ID, in-Apps activity data, advertising ID, IP address, location | Consent Legitimate interest |
An alternative way to register (only for voluntary users’ desires). | If you sign into the Services with Facebook Connect (Instagram) or Google Connect, or Apple, we will collect information that is visible via your Facebook or Google account, such as (1) your first and last name, (2) Facebook ID/Google ID/Apple ID (3) Profile Picture/URL, city-level location. | Contract |
If applicable, billing (invoicing), account management, and other administrative purposes. If you pay for Services directly through our website, you authorize us to have our payment processor collect this information. | Contact Data. If the User purchases products or Services directly from us, we or a third party on our behalf may collect the billing information the User provides us, as well as the payment card and other payment information, solely as required to process payments or send User invoices for such purchase. | Contract |
To send you marketing communications. | Contact Data | Consent |
To personalize ads. | Automatically collected information, Location data | Consent |
To prevent fraud or harm to us or any third party and ensure the security of our network and services. | Automatically collected information | Legitimate interest |
Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. For example, when we use your date of birth when required for age verification purposes. | Contact Data | The legal obligation |
To fulfill contractual obligations with third parties. For example, when we provide pseudonymized data to our partners in analytics matters or process your payment. | Automatically collected information. Contact Data | Legitimate Interest |
To improve content accessibility, manage subscriptions effectively, and ensure compliance with Apple’s App Store policies. By analyzing engagement metrics, we aim to deliver a customized and seamless in-app experience. | Automatically collected information. | Legitimate Interest |
We may share your information with third-party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, and customer service, and to assist us in our marketing efforts. We share your Personal Data with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service in an optimal way, such as serving you personalized, relevant advertisements within the Service. We hereby undertake not to conduct any disclosure or transfer of the User’s personal data to any third parties, except Processors, mentioned in this paragraph, without receipt of personal consent of the User. The following companies are the Processors of the Personal Data of the Services of APPSELLA LTD (In case you want to learn more about the services and privacy options, please consult their websites and privacy policies):
PROCESSOR | PURPOSE | POLICY AND OPT-OUT |
Customer support: help us to communicate with you simple and fast | ||
HelpDesk (Text, Inc.) | Customer support (Email address Content of the emails) | https://www.helpdesk.com/legal/privacy-policy/ |
Ad Partners: usually collect data via their own tools (Software Development Kits or “SDK”), help us to find new users | ||
AppLovin Corp | Advertising service. Personal Data collected: Cookies and Usage Data. You may opt out of certain features through your mobile device settings, such as your device advertising settings, or by following the instructions provided in their Privacy Policy. You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. Personal data is collected to find you and people like you and share our services with them. Ads Services show relevant information to potential users. | https://www.applovin.com/privacy/ |
AdColony, Inc | https://www.adcolony.com/privacy-policy/ | |
TikTok (Bytedance, Ltd) | https://www.tiktok.com/legal/page/row/privacy-policy/en | |
Сhartboost | https://answers.chartboost.com/en-us/articles/200780269 | |
IronSource Mobile Ltd. | https://ironsource.mobi/privacypolicy.html | |
Unity Technologies | https://unity3d.com/legal/privacy-policy | |
https://policy.pinterest.com/en/privacy-policy | ||
Snap Inc. | https://www.snap.com/en-US/privacy/privacy-policy/ | |
Analytic companies: provide us with tools and technologies that allow us to better understand how users interact with our services, usually collect data via their own SDKs | ||
Adjust, Ltd. | Mobile attribution and analytics. Personal Data collected: Cookies and Usage Data. AppsFlyer, a mobile marketing platform, helps App-Developers, Brands and Ad-Agencies attribute installs to campaigns and optimize their users’ acquisition funnel. Personal Data collected: Device Info, Identity Data. | https://www.adjust.com/terms/privacy-policy/ |
Other partners | ||
Apple, Inc. | To collect and process payments for subscription to the App. Personal Data collected: Payment and banking information and Usage Data. To manage in-app subscriptions, certain user interaction data, as outlined above, is shared with Apple through the consumptionRequestReason feature to facilitate accurate and secure subscription management. | https://support.apple.com/en-us/HT210584 |
Amazon Web Services, Inc. | Hosting and backend service Personal Data collected: various types of Data as specified in the privacy policy of the service. | https://aws.amazon.com/privacy/ |
BunnyWay d.o.o. | CDN Personal Data collected: various types of Data as specified in the privacy policy of the service. | https://bunnycdn.com/privacy |
Hetzner Online GmbH | Internet hosting. Personal Data collected: Cookies and Usage Data | https://www.hetzner.com/rechtliches/datenschutz/ |
Facebook Ireland Ltd. | Our Services measure conversions using visitor action pixels from Facebook. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization. Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our Services. You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data. | https://www.facebook.com/policy.php |
Google Inc. | To collect and process payments for subscriptions to the App; AdMob Google Inc. is an advertising service. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), and Usage Data. | https://policies.google.com/terms?hl=ru , https://firebase.google.com/terms/analytics/ |
Solid | To collect and process payments for subscriptions to the App and certain web services (Payment and Banking information) | https://solidgate.com/privacypolicy |
OpenAI, L.L.C. | AI-generated content provider | |
Competent Authorities | To comply with a legal obligation, process, or request. If we are bound to disclose your personal data by a judicial order or by a governmental or regulatory authority, we will comply and share the personal data with that body. |
We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy unless a longer retention period is required or permitted by law. Afterward, we will delete all aforementioned data from our possession within a reasonable timeframe. We do not verify the correctness of the personal data that we collect or that you provide. In all cases, APPSELLA LTD does not retain such data for more than 5 years. If you no longer want us to use the information that we physically access and store, you can request that we erase your personal information and close your account. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the processed personal data will be deleted or anonymized.
6.1. Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service provider’s servers. We understand that, unfortunately, the transmission of Information via the Internet is not completely secure. We do all our best to maintain the privacy and integrity of your Information. We have implemented industry-standard security measures, which include encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk. We will also not use information received through your use of the HealthKit and Google Fit framework for advertising or similar services, nor will we sell it. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password, and preventing others from using your mobile device.
6.2. We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. You acknowledge and agree that the locations of servers for the services include:
(1) Cyprus and Germany (The European Union) - the servers located in the European Union that automatically process your personal data and obtain access to your personal data for the purposes of manual processing;
Your data will be processed on our servers, which may not be located in your country of residence and can be accessed by our support and engineering around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does. Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.
6.3. We implement technical and organizational measures in an effort to protect Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect. These measures include Pseudonymization and tokenization of certain categories of your Personal Data.
We attach great importance to user privacy and would like to explain your data protection rights.
(i) The right to withdrawal. It’s important to remember that if we process your data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of the APPSELLA LTD via its Support service, i.e., by sending an e-mail to the address support@appsella.tech with the topic «Consent withdrawal» or in the Settings menu of the application.
(ii) The right to know what Personal Data we hold and how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access, please contact us as described below and let us know what information you would like to receive.
(iii) The right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt out, you will still receive advertising, but not direct or target interest. On Apple, you can opt out of this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android, you can opt out by going to Settings > Google Services> Ads and turning on “Opt out of Ads Personalization”.
(iv) The right to request an update or correction (rectify) to any of your Personal Data that is out of date, incomplete, or incorrect (according to Article 16 of the GDPR). In certain specific circumstances, you have the right to ask us to delete the personal data which we hold about you.
(v) The right to delete your personal data. (Right to be forgotten). You have the right to request that we delete certain of your personal data.
(vi) The right to object. You have the right to object to our processing of your personal data under certain conditions. Object to us processing your personal data at any time, on grounds relating to your particular situation. Object to your personal data being processed for direct marketing purposes.
(vii) The right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.
(viii) The right to portability of your personal data. In some circumstances, you may have the right to request that the data that you have provided to us be provided to you so you can transfer this to another data controller.
(ix) The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
(x) The right to Data portability. You have the right to Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.
(xi) The right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. You have the right to request us for copies of your personal data. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.
You may send the request aimed at exercising your rights provided herein to our email or to our business address: 28 Oktovriou 367, MEDITERRANEAN COURT, 1st Floor, Flat/Office A5, 3107, Cyprus. If you make a request, we have one month to respond to you.
Our services usually have a minimum age requirement for users and are not directed to children. We do not knowingly collect personal data relating to children. Children should never disclose their name, address or phone number, or any personal information without their parents’ prior permission. We consider a user to be a child if they are under the age of 13 unless more stringent regulation applies in their country of residence. The residents of EEA or the UK countries, users under the age of 16, are considered children unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us, and we will take the required steps to delete such information.
This is additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA, and any terms defined in the CCPA have the same meaning when used in this notice.
California law requires us to disclose information about the categories of personal information we collect and how we use it, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:
Category | Examples | Collected | We sell | Sources of Collection | Categories of Third Parties with Whom We Share Personal Information |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and Social Security number. | YES | NO | User, their Devices | Advertisers, Analytics Providers, and Third Parties as Legally required |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal data in this category may overlap with those from other categories. | NO | NO | N/A | N/A |
C. Protected classification characteristics under California or federal law. | Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), driver’s license number, passport number, or other similar identifiers. | NO | NO | N/A | N/A |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | NO | User | Payment Service Providers |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data (Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data). | NO | NO | N/A | N/A |
F. Internet or other similar network activity. | Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. | YES | NO | User, their Devices | Advertisers, Analytics Providers, and Third Parties as Legally required |
G. Geolocation data. | Physical location or movements. | NO | NO | N/A | N/A |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO | N/A | N/A |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO | NO | N/A | N/A |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | NO | N/A | N/A |
K. Inferences are drawn from other personal information. | The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES | NO | Users, their Devices, Partners | Advertisers, Analytics Providers, and Third Parties as Legally required |
We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission. We do share personal information with the Processors of the Personal Data of the Services of APPSELLA LTD mentioned in paragraph 4.
As a California resident, you have the rights listed below:
You may exercise your California privacy rights described above by emailing us. We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
If you have any questions or comments about this policy, you may contact us:
via email at: support@appsella.tech.
via post to:
The Company name: APPSELLA LTD
Address: Office 4, 6 Ioannou Karageorgiadi Mesologgioy, Agias Trias, 3032, Limassol, Cyprus