This Privacy Policy (the "Policy") explains how we, Reborn Studio collect, use, share, and protect information when you install, access, or use our mobile application and any related features, content, and services (collectively, the "Services").
This Policy is incorporated into, and forms part of, our Terms of Service and/or other applicable terms of use (the "Terms") that govern your use of the Services. Capitalized terms not defined in this Policy have the meanings given to them in the Terms. Where permitted by applicable law, in the event of a conflict between this Policy and the Terms, the Terms will prevail.
1. WHO WE ARE AND HOW TO CONTACT US
If you have questions, requests, or complaints regarding privacy, you may contact us at: Rebornstudios2021@gmail.com.
Where applicable law distinguishes roles (for example, "Controller" under the GDPR or "Business" under certain U.S. state privacy laws), we act as the entity determining the purposes and means of processing as described in this Policy.
2. SCOPE AND REGIONAL DISCLOSURES
This Policy applies to users worldwide. Certain jurisdictions (including the European Economic Area, the United Kingdom, and certain U.S. states such as California, Colorado, Connecticut, Virginia, and Utah) provide additional privacy rights and require additional disclosures. Where applicable, those items are addressed in the relevant sections below.
3. INFORMATION WE COLLECT
You can find here information regarding the data sets we collect, purposes for which we process your data as well as our lawful basis for processing, and how the data is technically processed. In general, we may collect two types of information from you, depending on your interaction with us:
Non-Personal Data
During your interaction with our Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, operating system type and version, language preference, time and date stamp, country location, etc.
The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information as follows:
We may disclose or share Non-Personal Information with third parties as specified below and solely if applicable.
Personal Data
We may also collect from you, during your access or interaction with the Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below.
To clarify, you can use the Services without providing us with any contact information. In addition, we collect you IP address through your use of the Product. Note that, while IP address is not considered personally identifiable information in many jurisdictions, there are jurisdictions (such as the EU), in which IP Address may be considered "Personal Information". Therefore, we treat the user's IP address as Personal Information, in accordance with applicable laws.
Nonetheless, if we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the processing of Personal Data we collect, the purpose, lawful basis, and processing operations:
DATA SETS | PURPOSE AND OPERATIONS | LAWFUL BASIS UNDER THE GDPR |
|---|---|---|
Contact Information: If you voluntarily contact us for support or other inquiries, you may be required to provide us with certain information such as your name, email address, etc. | We process such data to provide you with the support you requested or to respond to your inquiry. The correspondence with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). | We process such information based on our legitimate interest. Unless you are contacting us for support, in which providing support is part of our contractual obligations to you. |
Online Identifiers and usage data: When you access our Service, we will automatically collect certain data regarding your app usage patterns, including how you engage with the App and its features, timestamps, etc. | We use this data to ensure the functionality of our App, prevent fraudulent activities, and ensure Users’ security. | Where we collect such data for operation and security, we process your data based on our legitimate interest. |
Device Information: When use the App we will automatically collect certain data regarding your device, such as your device model, device ID, IP address, device token, cellular network details, etc. | We use this data to ensure the functionality of our App, prevent fraudulent activities, and ensure Users’ security | Where we collect such data for operation and security, we process your data based on our legitimate interest. . |
Permission Data: Certain features within the App require our access to your device permissions ("Permissions"). The Permission we will need may vary depending on the feature you wish to use and may include: (i) Software Inventory Permission – list of applications installed on your device; (ii) Telephony Permission – access to your call history and contacts; (iii) Data Storage Permission – collect information from your device storage; (iv) Network Permission – access to your network settings, including detected devices and networks, and your connection history. | We use this data to ensure the functionality of our App features. | we process your data based on your consent provided through the application permission notification and google native permissions screens. |
SDK Data Through the use of third-party software development kits (“SDK”), we may display within the App certain promotional content ("Ads"). This may allow us or our advertising partner to process different data about you, such as your IP address, browsing history, advertising ID, etc. | We will use this data in order to share it with our advertising partners, so they can deliver personalized Ads based on the user’s interests and preferences ("Personalized Ads"). We may also may also share with our advertising partner the ad ID, so they can cross track users across different apps, and the user’s usage data | We will process this data subject to your consent. |
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the “International Data Transfer” Section below, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.
4. HOW WE COLLECT YOUR INFORMATION
Depending on the nature of your interaction with the Services, we may collect information as follows:
5. COOKIES AND SIMILAR TECHNOLOGIES
We and/or our service providers and partners may use SDKs, cookies, pixels, and similar technologies ("Tracking Technologies") to:
Advertising ID Controls: You may be able to reset or limit the use of your advertising identifier via your device privacy/ad settings.
6. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
We may share information with the following categories of recipients:
Once information is shared with a third party, it may also be subject to that third party's privacy practices.
7. USER RIGHTS AND OPT-OUT OPTIONS
8. USER RIGHTS AND OPT-OUT OPTIONS
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:
Right to be informed, right to know | You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy. |
|---|---|
Right to access | You have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it. |
Right to correction | You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. |
Right to be forgotten, right to deletion | You have the right to request the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. Depending on your territory, we may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, other legitimate interests such as record keeping with regards to our engagements, completing transactions, providing a service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising free speech, ensuring the right of another consumer to exercise their free speech rights, or exercising another right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. |
Right to portability | You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. |
Right to opt out under the EU, and specifically in the US the right to opt out from: (i) selling Personal Data; (ii) right to opt out from targeted advertising; and (iii) right to opt out from profiling and automated decision making | Sale of Personal Data for targeted advertising, monetary gain or profiling, or share or sale of personal information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. You can reset your advertising ID by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select "Ads" and selecting "Reset advertising ID". |
Right to appeal or complaint | If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK. Additional information for the appeal procedure under certain state laws, please see section “Jurisdiction-specific Notices”. |
Non-discrimination | Such discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our customers or users. |
You may exercise any or your right above by sending us your request to Rebornstudios2021@gmail.com.
9. DATA RETENTION
We retain Personal Data for as long as reasonably necessary to:
We may delete, de-identify, or anonymize information when it is no longer needed, unless we are required to retain it by law.
10. SECURITY MEASURES
We implement physical, technical, and organizational measures designed to reduce risks of unauthorized access, use, alteration, disclosure, or loss of Personal Data. However, no security measure is perfect, and we cannot guarantee absolute security.
Please contact us at Rebornstudios2021@gmail.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
We may adopt what we believe is appropriate data collection, storage and processing practices and security.
11. INTERNATIONAL DATA TRANSFER
In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.
12. LINKS TO THIRD-PARTY SERVICES
The Services may include links to third-party websites, apps, or online services. We do not control third-party practices and are not responsible for their policies or activities. We encourage you to review third-party privacy policies before engaging with those services.
13. ELIGIBILITY AND CHILDREN PRIVACY
The Services are not intended for, and may not be used by, children under the age of 16. We do not knowingly collect or otherwise process Personal Data from children under 16. We generally do not process children's Personal Data on the basis of consent. If we become aware that we have collected or otherwise processed Personal Data from a child under 16, we will take reasonable steps to delete such Personal Data, or, where required by applicable law, promptly seek verifiable parental (or legal guardian) consent for its collection and processing. If you believe that a child under 16 has provided us with Personal Data, please contact us at Rebornstudios2021@gmail.com.
14. JURISDICTION SPECIFIC NOTICES
This section applies only to California residents, pursuant to the California Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the California Privacy Rights Act, effective January 1, 2023.
This section does not address or apply to publicly available or to Personal Information that is otherwise exempt under the CCPA.
Categories of Personal Information Collected and Disclosed. While our processing of Personal Information varies based upon our relationship and interactions with you, the below identifies the categories of Personal Information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories third parties to whom we disclosed Personal Information for a business or commercial purpose
Categories of personal information | Do we collect this data? | Third-Party |
|---|---|---|
Identifiers | Yes: Online Identifier; Internet Protocol address | Affiliates Advisors and agents Advertising networks Data Analytics providers Social networks Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
F. Internet or other similar network activity. | Yes: information on a consumer’s interaction with a website | Affiliates Advisors and agents Advertising networks Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
G. Geolocation Data | Yes: approximate location derived from IP address | Affiliates Advisors and agents Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
Sources of Personal Information. We generally collect Personal Information from the following categories of sources: directly and indirectly from you; affiliates; business partners; vendors and service providers; operations systems and platforms, and marketing and data analytics providers.
Purposes of Collection, Use, and Disclosure. As described above, we may collect, use, disclose and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
Sales and Sharing of Personal Information. CCPA defines a "sale" as disclosing or making Personal Information available to a third party in exchange for monetary or other valuable consideration. CCPA also defines “sharing” as disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising.
While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” (as such terms are defined under the CCPA) the following categories of Personal Information in the following limited circumstances:
California Consumer Rights
California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
You may have the right to opt-out of the “sale” or “sharing” of your Personal Information. You can opt out of the sale/sharing of your personal information by email us at Rebornstudios2021@gmail.com
Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see "Submitting Requests" for instructions on how to exercise your rights.
Incentives and Discrimination
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information.
Discrimination: if consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.
California’s Shine-The-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to Rebornstudios2021@gmail.com. In your request, please attest to the fact that you are a California resident. Your right to obtain information regarding any of your personal information we have shared with third parties for their own marketing use was included here solely in order to satisfy legal and regulatory notice requirements, we do not share any of your personal information with third parties for their own marketing use.
ADDITIONAL NOTICE FOR US RESIDENTS
Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws and be entitled to additional disclosures.
"Personal Data" under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)
“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data.
We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.
Categories of Personal Data & Categories of third parties with whom Personal Data is shared:
Under the paragraph “Data We Collect and Purpose of Collection and Use” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used.
Additionally, under the paragraph “Sharing Data with Third Parties” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent.
“Sale” of Personal Data:
Under US privacy laws, in principal, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment however, subject to the definition of the term “Sale” under US privacy laws, we may “sell” the following categories of Personal Data when we use cookies or other third-party advertising services:
Identifiers – online identifiers such as IP and Cookie ID;
Internet and electronic network activity information – such as your engagement with our Website and ads.
Geolocation data - derived from IP (country level).
Consumer Rights:
Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
The paragraph “Your Rights Under Privacy Protection Laws” provides additional information regarding your principal rights.
Exercising Your Privacy Rights:
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: Rebornstudios2021@gmail.com
When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.
To exercise your right to opt-out of the “sale”, you may use the cookies preference management tool on our Website to change your preferences and opt-out of cookies.
Authorized agents may initiate a request on behalf of another individual by contacting us at Rebornstudios2021@gmail.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
If we decline to take action on your request, we shall so inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction (including - Colorado AG at https://coag.gov/file-complaint/; Connecticut Attorney General at: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318; Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform).
15. CHANGES TO THIS POLICY
We may update this Policy from time to time. The updated version will be posted with a revised "Last Updated" date. If changes are material, we will take reasonable steps to notify you and, where required, obtain your consent. Changes become effective upon posting or as otherwise stated in the notice.