PRIVACY POLICY

Effective Date: November 29, 2018

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the “EULA”) governing the use of all Firelit Studios (“Firelit”) software applications (the “App/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the App. This Privacy Policy covers how Firelit collects, uses, discloses, transfers and stores information received about you and/or information received about your computing device through your use of the Apps.

By using Firelit Apps you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. Firelit may receive and/or you may be asked to provide your information (including personal information) any time you are in contact with Firelit or use the Applications. As described in greater detail below, Firelit may share this information (including personal information) with our affiliates and with third-party partners (as defined below) and use it in ways consistent with this Privacy Policy. Firelit may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at http://www.firelitstudios.com/monogram-it/privacy.html.

If you have questions or concerns about Firelit’s Privacy Policy or information processing, please contact us at support@firelitstudios.com.

1. Interest-Based Ads

Firelit promotes its Apps and services in ours and other publisher’s apps and also allow our partners to promote and advertise their goods and services in our Apps. Firelit may share information we collect from you to our advertising partners and they can reuse such data for targeted advertising. We or our advertising partners may display interest-based, or retargeted, ads (''IBA''), but only for the device IDs that have not opted out of IBA. By using our Apps and not choosing one of the opt-out options, you give Firelit consent to transfer your data as stated below.

Firelit may pass information we collect from you such as technical information, advertising and application usage information (for example if a device has clicked on a sports ad within our Apps; for more information please see Information And Data We Collect From You Section of this Privacy Policy) as well as age & gender information to our advertising partners and they can reuse such data for targeted advertising. Firelit allows our partners to serve targeted third-party advertisements or other content. They may attach the information gathered from our App to info gathered from other apps, websites, or via other services, and then build profiles and transfer the info to another provider. By doing so the other provider may receive or gather information about you and use the information for displaying targeted ads. Advertisers may choose their audience by location, demographics, likes, keywords, age & gender, interests, behaviors, connections and any other information received or inferred about users. We cooperate with several providers of IBA that are listed herein in subsection a) and in Opt-Out Section of this Privacy Policy (''Third Parties'').

You have an option to opt out from sharing your information and data for the purposes of interest-based advertising at all times. When you opt out, you will not stop receiving ads, they just won't be based on topics you like, your interest, behaviour, demographics, etc. You can opt out by choosing one of the following options (for more information please read the ''Opt Out'' Section of our Privacy Policy):

(a) Via third-party IBA provider:

  • Google (Adx) https://www.google.com/ads/preferences/html/mobile-about.html;
  • Google (AdMob) https://www.google.com/ads/preferences/html/mobile-about.html;
  • Apple (Search Ads) https://support.apple.com/en-us/HT202074;
  • Google (Ad Words) https://support.google.com/ads/answer/2662922?hl=en;

If you choose to opt out by following one of the third-party IBA provider’s opt out mechanism, you should stop receiving interest-based and targeted ads via the selected IBA provider, but you may continue to receive interest-based or targeted ads through other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out option b) below.

(b) Via “Do Not Track Settings” in mobile phone:

Turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your Android device.

2. Information and Data Firelit Collects from You

(a) Technical Information and Data

Firelit collects technical data necessary for you to use our App and additional technical data that enables us to maintain and analyse the functioning of the App, to personalize the content of the App, and to display advertisements.

We automatically obtain certain information about your computing device, including:

  • IP address; Country code;
  • IDFAs, IDFVs, Advertising IDs;
  • Language; Locale (specific location where a given language is spoken);
  • Time zone, session start/stop time,
  • Network status (WiFi, etc.), browser plug-in types and versions;
  • User agent string (UA), platform, SDK version, timestamp;
  • Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android ID, Android Serial No);
  • Push notifications token;

In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps.

(b) Advertising and Application Usage Information and Data

When you use our Apps, we may collect additional information by using device identifiers that permit identification of your device. Such information is used for advertising and analytics purposes.

The information collected includes:

  • Which advertisements are shown;
  • Length of time an advertisement is visible and the size of the advertisement;
  • Advertisement response (if any), including clicks on ads;
  • Angle of view;
  • Application usage information, (how often you use the app, for how long you use the app, the events that occur within the app, in-app location, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.).

(c) Classical Personal Information

We do not collect any personal information about you through our Apps, with the sole exception of persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address). Persistent identifiers are identifiers that do not identify you personally, but may uniquely identify your device. Some legislation (such as US) may treat such information that uniquely identifies your device as personal information.

When you voluntarily contact us directly, we may collect information about you that you provide us (such as your name and surname, email address). We will use such contact information only for the purpose for which you provided it to us. We will not share this information with third parties. If you wish to delete your contact information that we received from you when you contacted us, please send an e-mail to support@firelitstudios.com and your contact information will be deleted from our database.

3. How Firelit Uses Your Information

a) In General

Firelit uses the information we collect about you/your device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

  • Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analysing trends in connection with usage of the Apps, administering the Apps, and customer communications.
  • Displaying advertisements: displaying third-party advertisements in our Apps and showing advertisements for our Apps in other publisher’s apps. Please see more in Advertising Section of this Privacy Policy.
  • Tracking and fraud prevention for advertising purposes: for some of our Apps we use third-party services for tracking and fraud prevention for advertising purposes. Please see more in Tracking Section of this Privacy Policy.
  • Analytics and research: understanding and analysing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test new features and content.

(b) Push Notifications

Firelit uses push notifications to remind you about your activities within the App. You will receive push notifications only if you are subscribed to push notifications in the App. To unsubscribe, please use the instructions provided below:

  • For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option by sliding it OFF or ON.
  • For Android and Windows: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the App.

We collect push notification tokens in order for us to be able to determine whether you are subscribed to push notifications. When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

4. How Firelit May Share Your Information with Third Parties

Firelit cannot provide all services necessary for the successful operation of the Apps by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking providers, third-party advertising providers and other third-party service providers that support the Apps (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’s advertising campaign performance. We may share such information to:

  • Our analytics providers: For some Apps we use third-party analytics such as Flurry for the purposes of delivering our services, conducting analysis and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to you. Third-party analytics providers have the right to process the data in accordance with their privacy policies (https://policies.oath.com/us/en/oath/privacy/index.html).
  • Our tracking and fraud prevention providers: for some of our Apps we use third-party services for tracking of our advertising campaigns and fraud prevention purposes. Please see more in Tracking Section of this Privacy Policy.
  • Third-party advertising partners:  We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Apps for free or at low cost. Third-party advertising partners are listed in the Interest-Based Ads Section of this Privacy Policy.
  • Advertising partner’s third-party tracking provider: For some Apps we may allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. Please see more in Tracking Section of this Privacy Policy.

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third-party.

For any additional questions about third-party information collection please refer to support@firelitstudios.com.

5. How Firelit Partners May Use Your Information

Firelit strives to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us. They adhere to this Privacy Policy, but in some cases we must use their privacy policies.

Firelit strives to commit our Partners to using the information solely for the purposes as stated in this Privacy Policy. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices. While we strive to protect the information provided to our Partners, we have no direct control over their use of the collected information and therefore you acknowledge that we are not liable for any third-party privacy breach and that our liability for our Partner breaches is limited to the amount we are able to receive as indemnification from our Partners (legal costs exempted).

Some Firelit Apps allow you to submit content generated in or by the Apps to third-party sites such as Facebook and Instagram. These submissions follow the information transfer protocols of such third parties, which are designed to enable content sharing with such third parties.

6. Advertising

When you use our Apps we may display contextual advertisements to you. In order to enable advertising, we allow our advertising partners to collect online identifiers (such as Advertising ID on Android and IDFA on iOS) that might be considered personal information under some legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on anonymized and aggregated basis.

For some territories, we may use and share with our advertising partners technical and advertising and application usage information we collect from you (please see Information and Data We Collect From You Section of this Privacy Policy) in order to enable our advertising partner to deliver, target and optimize third-party advertising in our Apps, so that the advertisements you see are more relevant to you and are based on your app and device usage, online behaviour and interests (this is commonly referred to as online behavioural or interest based advertising, i.e. IBA). In addition, we may use and share such information with our advertising partners in order to target and optimize our advertising and promotions in our and other publisher’s apps.

We will always follow applicable legislation and accepted market practices, and thus we will not use and share information for the purposes of behavioural advertising for users who have opted-out of IBA. For more information on behavioural advertising and our IBA providers please see Interest-Based Ads Section of this Privacy Policy. For opting out of sharing your information and data for the purposes of behavioural advertising please refer to the Opt-Out Section of this Privacy Policy.

7. Tracking

When you use the App, Firelit or third parties operating the advertisement serving technology may use information logged from your device using cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the App and to calculate the number of unique and repeat views of advertising.

Firelit uses third-party tracking and data collection tools from our service providers, such as Google Analytics, for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such tools may use cookies, APIs, and SDKs in our Apps to enable them to collect and analyse user and device related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events.

In addition, our Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, local shared objects and other technologies) in order to track impressions, clicks, installs or other advertising campaign performance indicators for the purposes of measuring third-party advertising campaign performance.

8. Third-Party Terms and Conditions

Please note that your access to and ability to use and interact with the Apps may be subject to certain third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, statistics services providers and payment providers. You recognize and agree that Firelit is not liable for any such third-party terms and conditions and their use of your personal information.

Our Apps may contain links to third-party websites, products, or services. For example, the Apps may feature offers from third-party advertisers or the ability to engage in transactions with such entities. Please note that while using such third-party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We are not responsible for the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third-party’s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. These other websites or services may place their own cookies or other files on your computing device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.

We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.

9. Opt-Out

You are always free to opt out from the future collection of your personal information by Firelit in accordance with this Privacy Policy by uninstalling all the Apps from each of your computing devices.

Instructions for opting-out of IBA:

(a) Via third-party IBA providers

For Google (Adx) please visit https://www.google.com/ads/preferences/html/mobile-about.html;

For Google (AdMob) please visit https://www.google.com/ads/preferences/html/mobile-about.html;

For Apple (Search Ads) please visit https://support.apple.com/en-us/HT202074;

For Google (Ad Words) please visit https://support.google.com/ads/answer/2662922?hl=en;

If you choose to opt out by following one of the third-party IBA provider’s opt-out mechanisms, you should stop receiving ads based on your interest via the selected third-party IBA provider, but you may continue to receive interest-based or targeted ads via other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options 2. and 3. below.

(b) Via “Do Not Track Settings” in mobile phone

If you choose to opt out via “Do Not Track Settings” in your mobile phone all providers of advertising services are bound to comply with such “Do Not Track” setting, but we cannot provide any guarantees on their behalf. If you choose the opt-out option available via our Apps, we will not share your advertising ID with advertisers for the purposes of IBA. We provide no guarantees regarding the information provided prior to opting out. Some providers may have additional opt-out mechanisms implemented.

If you turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your Android device, you can restore interest-based ads by turning the settings off. When you opt out, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on your interests. Our advertising partners may continue to serve you ads based on other non-personal information, such as ads related to the content of the application you are using.

Your iOS or Android mobile device may provide a “Limit Ad Tracking” or “Opt Out of Interest-Based Advertising” setting. When you have opted out using this setting on a device, our partners will not use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests.

You can find the settings for your mobile device by following the directions below, or contact your device provider.

iOS Devices:

  • iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
  • iOS 6: Go to your Settings > Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting
  • More information about iOS settings can be found here: https://support.apple.com/en-us/HT202074

Android Devices:

  • For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up, open your Google Settings app > Ads > Enable “Opt Out of Interest-Based Advertising”

10. In-App Purchases

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store.

11. Protection of Personal Information

We have implemented: reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

12. International Transfer

We operate globally, thus we may for the purposes described in this Privacy Policy transfer your information to our affiliated entities and/or to other third-party service providers across border and from your country or jurisdiction to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

13. Storage of Information

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services.

We will retain collected information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

Storage might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.

14. Deletion of Information

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

15. EEA Users

Firelit Apps are designed predominantly for a US audience. For users in the European Economic Area and Switzerland, Firelit Apps do not collect, store or share any personal information whatsoever, including analytics data, device identifiers, online identifiers for the purpose of advertising, or any other persistent identifier. Firelit Apps may use third-party analytics tools for the purpose of fraud prevention but no personal information whatsoever is collected.