PRIVACY POLICY POPCALC
This Privacy Policy governs our data practices in connection with your use of the PopCalc app. This Privacy Policy is compliant with the General Data Protection Regulation (GDPR 2016/679).
Carrel Conseil is an app development studio that creates Apps that can be downloaded freely, functioning on the basis of an advertising model. For many of our Apps, we also create a paid version that does not contain advertising. In general, if you do not want us to use your data to tailor the ads that are displayed within the App, you can choose to use a version that does not contain advertising.
By using the App, you are consenting to our processing of data as set forth in this Privacy Policy. Our terms for the use of Apps (which can be found here http://popcalc.com/terms) apply to your use of the Apps.
1. What data do our Apps obtain?
1.1 We collect data about you and the way the Apps are used in various ways.
a. Automatically Collected Data - The Apps collect certain data automatically, such as: the type of device you use, device identifiers, such as the resettable advertising identifier assigned to your device, the IP address of your device, geographical data such as the location of your device, your operating system, Wi-Fi mac address in your area, the type of internet browsers you use, data connection status and success/failure of connection, and data about the way you use the App, installed applications on your device, and other non-personal data as reasonably required by us to enhance our services. If you activated ‘Location’ in the settings of your device and allowed the App to collect data about the precise location of your device, the App will collect such data. Furthermore, we may collect location data using network triangulation, GPS, and Wi-Fi IP address to determine your general device location. We also may collect location data and other diagnostic data through the Apps for network analytics and troubleshooting purposes.
b. User-Provided Data - The App obtains the data you provide when you download and use the App. We may ask that you provide: (a) your name, email address, age, username, password, and other registration data; (b) transaction-related data, such as when you make purchases, respond to any offers, or download or use Apps from us; (c) data you provide us when you contact us for help; and (d) data you enter into our system when using the App, such as contact data.
c. We may also get data from other sources and may combine it with data collected about you.
2. Data Sharing and Advertising
2.1 To the extent feasible, we only use your data in an anonymized, hashed or obfuscated way. We only use the personally identifiable information to the extent required to provide our services.
2.2 We may share your data with third parties in the ways that are described in this Privacy Statement. We may disclose your data (a) as required by law, such as to comply with a subpoena or similar legal process, (b) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, (c) with our trusted services providers who work on our behalf, which do not have an independent use of the data we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement, and (d) with third-party advertising networks and analytics companies as described below.
2.3 We may use and share the data, including the Automatically Collected Data and the User-Provided Data, in an anonymized, hashed or obfuscated way for purposes of advertisement by us or our partners. We do not pass any personally identifiable data to ad networks or advertisers. The data may be used for the purpose of serving users advertisements based on particular users’ presumed interests, and also to present advertisements in third-party applications or other platforms. We work with advertisers and third-party advertising companies that collect data about how you interact with advertising and content provided in the App, which helps us keep the cost of the App free. Advertisers and advertising companies use some of the data collected by the App, including the advertising identifier assigned to your device to serve advertisements that are targeted to your interests in the App. These third parties may also obtain anonymous data about other applications you’ve downloaded to your device, the websites and applications you visit, and your location in order to help analyze user behaviour and serve targeted advertising on the App and on other applications and websites. We may use and share your location data to provide you with localized data, including localized advertising, within the App. To learn how to opt-out of the use of data collected from the App for targeted advertising purposes, please see the ‘Managing Your Data’ section of this Privacy Policy.
2.4 We may work with analytics companies to help us understand how the App is being used, such as the frequency and duration of usage.
2.5 If you have allowed us to collect data about your precise location by activating ‘Location’ in the settings of your device, we may share it with our ad network partners in order to tailor the ads that are displayed within the App.
2.6 The paid versions of our Apps generally do not contain advertising and will not use your data for this purpose. In the Apps that do not contain advertising, the data collection software will still collect data but will not use it to serve you interest-based advertising.
3. Managing Your Data
3.1 You can stop all collection of data by the App easily by uninstalling the App. You may use the standard uninstall processes as may be available as part of your device or via the application marketplace or network.
3.2 You may at any time opt-out from further allowing the App to have access to your precise location data by deactivating ‘Location’ in the privacy settings on your device.
3.3 Most modern devices provide advertising identifiers. These identifiers have different names depending on the brand of your device. For example, they are called Identifier for Advertisers (IDFA) on iOS/Apple devices. These operating systems let you see your advertising identifier in the settings of your device, and you control how it is used. It includes options for you to change your identifier and opt-out of cross-app advertising. The features or functionality hereof may change at the discretion of the operating systems. To opt-out of the use of data collected by our advertising partners across different applications to serve ads that are targeted to your interests, please consult the settings available on your device (for instance ‘Limit Ad Tracking’ on your iOS/Apple device).
3.4 The NAI and the Digital Advertising Alliance (DAA) offer opt-out tools to assist you in managing your choices for participating companies. For more data about these tools please visit: https://networkadvertising.org/choices/
or https://aboutads.info
4. Business Transfers
4.1 Data about you may be disclosed as part of any merger, acquisition, or sale of company assets. In the unlikely event of an insolvency, bankruptcy or receivership, your data may also be transferred as a business asset.
5. Children
5.1 We do not use the Apps to knowingly solicit data from or market to children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with data without their consent, he or she should contact us at contact@carrelconseil.com. We will delete or anonymize such data from our files within a reasonable time.
6. Security
6.1 We are concerned about safeguarding the confidentiality of your personal data. We provide physical, electronic, and procedural safeguards to protect data we process and maintain. For example, we limit access to this data to authorized employees and contractors who need to know that data in order to operate, develop or improve our Apps. Please be aware that, although we endeavour to provide reasonable security for personal data we process and maintain, no security system can prevent all potential security breaches. As stated above, we use anonymization techniques in order to limit the use of personally identifiable information as much as possible.
7. Data Retention Policy
7.1 We will retain User-Provided Data for as long as you use the App and for a reasonable time thereafter. We will retain Automatically Collected data for up to 12 months and thereafter we may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the App, please contact us at contact@carrelconseil.com and we will respond in a reasonable time. Please note that some or all of the User-Provided Data may be required in order for the App to function properly.
8. Subscriptions
8.1 You may access parts of Carrel Conseil apps for free, and other services and products require payment of subscription fees or in-app purchases. To access the premium features of our apps, which have additional features, including (but not limited to) ad-free experience, premium support, instant updates, you will have to pay via an auto-renewing subscription from Apple’s iTunes store. You may receive ads from Carrel Conseil suggesting new features or other apps from our portfolio.
8.2 Carrel Conseil auto-renewable subscriptions are purchased via an iTunes auto-renewing subscription. This means your subscription is automatically renewed at the end of the subscription period.
8.3 You can modify or cancel your subscription at any time from within the application by signing in to your iTunes account on your computer or iOS device and changing the settings.
8.4 If you purchase a subscription with automatic renewal, you acknowledge and agree that we are authorized to charge you through your iTunes account for the renewal and you will be charged for the regular price of your subscription within 24 hours prior to the end of the current term. You can turn off automatic renewal in your iTunes account settings, but you must do so at least 24 hours before the end of the current term to avoid renewing. Refunds will not be provided for the unused portion of any term.
8.5 For more details: iOS: http://support.apple.com/kb/HT4098
8.6 Your payment is managed by Apple via iTunes and you will need to contact Apple’s customer service for refunds, as we are not able to process refunds ourselves. Please note that if you purchase a subscription through the Apple iTunes Store or our iPhone or iPad applications, the sale is final, and we can not provide a refund. Your purchase will be subject to Apple’s applicable payment policy, which also may not provide for refunds.
9. Changes
9.1 This Privacy Policy may be updated from time to time. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here: http://popcalc.com/privacy. You are advised to consult this Privacy Policy regularly for any changes.
If you have any questions, please contact us at contact@carrelconseil.com
This Privacy Policy was updated on 20th August 2019
ADDITIONAL PRIVACY POLICY CARREL CONSEIL APPS FOR CALIFORNIAN USERS
This Privacy Policy for Californian residents supplements the information contained in the Privacy Policy of Carrel Conseil (hereinafter: “Carrel Conseil”, “We”, “Us” or “Our”) and applies solely to visitors, users, and others who reside in the State of California (hereinafter: “consumers” or “you”). This privacy notice is compliant with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.
1. Information we collect, use & share
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We may disclose this to service providers or other third parties for business purposes. We may have collected and/or shared the following categories of personal information from consumers within the last twelve (12) months:
| Contact Information | Identifiers |
| Categories | Identifiers |
| Description | Personal information possibly shared by you when contacting support. (Eg.:email addres / Name) |
| Source | You |
| Our purposes for collecting | Providing support |
| Shared with | Third parties* |
| Data | Mobile Ad Identifier |
| Categories | Identifiers |
| Description | An identifier linked to your device used for advertising, frequency capping, etc. This identifier cans be reset by the user |
| Source | Automatically Collected |
| Our purposes for collecting | Analytics/Statistics, ad personalization |
| Shared with | Ad partners |
| Data | Device Information** |
| Categories | Internet or other electronic information |
| Description | Information about the device you are using (phone or tablet, model, operating system, etc.) |
| Source | Automatically Collected |
| Our purposes for collecting | Analytics/Statistics, ad personalization, Debugging and fixing errors |
| Shared with | Ad partners |
| Data | App Category* |
| Categories | Internet or other electronic information |
| Description | The 'type' of app (eg.: A music player could have "music") |
| Source | Automatically Collected |
| Our purposes for collecting | Ad personalization |
| Shared with | Ad partners |
| Data | Location |
| Categories | Geolocation information |
| Description | If available, latitude and longitude. |
| Source | Automatically Collected |
| Our purposes for collecting | Ad personalization, Analytics/Statistics |
| Shared with | Ad partners |
| Data | App Information |
| Categories | Internet or other electronic information |
| Description | Where you installed the app from, and what version of the app you are using. |
| Source | Automatically Collected |
| Our purposes for collecting | Ad personalization, Analytics/Statistics |
| Shared with | Ad partners |
*: This information will only be shared in very specific cases, such as when making use of certain rights under the CCPA for which we have to inform our partners as well. (Such as the right to access, correct or delete information)
**: This type of information may not always be considered personal information, but we decided to keep it in to be as transparent as possible to you.
Personal information does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Any other information excluded from the CCPA's scope.
Purposes are defined as follows:
• Providing support:
You may fill out the support form on our website or use the support links in our apps. In these cases you may voluntarily share contact information with us (such as your email address), which we use to aid in the support process.
• Analytics/Statistics:
We may utilize technical solutions that capture some of your interaction with our apps to measure the efficiency and performance of our services. This includes finding out about how you use our services, and using that information to improve our services.
• Debugging and fixing errors:
We may utilize device information that is reported upon an error, or when the user contacts us through support, to help diagnose and fix issues affecting our services.
• Ad Personalization:
We may utilize device information and location data to offer more relevant advertisements to you. Without this, you would get less relevant advertisements.
2. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
This section describes your CCPA rights and explains how to exercise those rights.
2.1 Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose; two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
2.2 Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
To complete the transaction for which we collected the personal information, providing a good or service that you requested, taking action reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities.
• To debug products to identify and repair errors that impair existing intended functionality.
• Exercise of free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Engage 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
2.3 Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
• E-mailing us at contact@carrelconseil.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
2.4 Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, based on your preference. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
3. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
4. Do Not Sell My Personal Information
We and our advertising partners collect certain information, including advertising identifiers on your mobile devices, and/or the IP address of your devices when you use our apps. We and our partners use that information to tailor and deliver ads to you on your devices. Such sharing may be considered a “Sale” under California law.
If you wish to opt out of the sharing of your information in connection with tailored advertising in our apps, please visit the privacy section of the app and check the “Do Not Sell My Info” menu. Alternatively, you may use your device’s “Limit Ad Tracking” or similar settings or download and use the AppChoices app at http://www.aboutads.info/appchoices. Please note that opting out does not mean that you will stop seeing all ads.
5. Changes to Our Privacy Policy
We reserve the right to amend this privacy notice at our discretion at any time. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here: http://popcalc.com/privacy.html. You are advised to consult this Privacy Policy regularly for any changes.
6. Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: contact@carrelconseil.com
This Privacy Policy was updated on 15th January 2021