Last updated August 4th 2023.
Photo Roulette AS (“company”, “we”, “us”, or “our”) are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected].
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT AND WHY?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- WHO WILL YOUR INFORMATION BE SHARED WITH?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT AND WHY?
Personal information you disclose to us
In Short: We collect personal information that you provide to us, such as username and photos.
We collect personal information that you voluntarily provide to us when using the app, or when contacting us via email or other support channels.
The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect include the following:
- Your name. We collect the name you enter in order to play the game. It is optional if you want to enter your full and real name. The reason we need this information is in order for other players to identify you in the game.
- Your messages. We collect all the messages that you send via the app’s chat feature. The reason we store this informations is for the chat to function and for improving the experience for all players.
- Your photos. For each round you play we collect at set of random photos from your photo library. The reason we collect and temporarily store this information is in order for the game to function.
- Your photo metadata. We collect metadata from your photos such as year, location, size and any other metadata included from the device. The reason is to make the game function, and also display some of this information to you in the App.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our App.
We automatically collect certain information when you use the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language, preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.
Information collected through our App
In Short: We may collect information regarding your mobile device when you use our App.
If you use our Apps, we may also collect the following information:
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s photos, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our App for a variety of purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the photos and videos we collect or receive to:
- Make the App work: We will use your photos and videos to make the App work. This includes sharing these with other users.
- For other Business Purposes. We may use your photos and videos for other Business Purposes, such as data analysis and to evaluate and improve our App, products, services and your experience.
We use other information we collect or receive to:
- Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Request Feedback. We may use your information to request feedback and to contact you about your use of our App.
- To protect our Sites. We may use your information as part of our efforts to keep our App safe and secure (for example, for fraud monitoring and prevention).
- To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, services, marketing and your experience.
Our use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with third parties to improve and develop the game. We also share your photos and videos with other users in order for the game to function.
In order for the game to function, we share your photos and videos with the other players in your game room. After the game is finished, the photos will be removed from their devices. Keep in mind that the users you share photos, videos and any other content with can always save that content or copy it outside the app. Don’t send messages or share content that you wouldn’t want someone to save or share.
We also share and disclose your information with the following third parties:
- Advertising, Direct Marketing, and Lead Generation: Google AdSense, AdMob and Facebook Audience Network
- Functionality and Infrastructure Optimisation: Firebase Realtime Database and Cloud Functions for Firebase
- Social Media Sharing and Advertising: Facebook social plugins
- Web and Mobile Analytics: Amplitude
- Website Performance Monitoring: Firebase Crash Reporting
- Website Testing: Firebase Remote Config
5. WHAT IS OUR STANCE ON THIRD PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third party providers who advertise, but are not affiliated with, our websites.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
Your photos are removed from our servers maximum 24 hours after being uploaded.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the services within a secure environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data protection/bodies/authorities/index_en.htm
9. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at [email protected] or by post to:
Photo Roulette AS Grottenveien 20, 1177 Oslo, Norway