(A) Who we are:
We are AE Zext, a publishing company delivering apps for mobile devices. AE
Zext is the controller of your personal information, and is responsible for
your personal information. All references in this policy to "AE Zext",
"our", "us" or "we" refer to AE Zext, or our
group companies, as appropriate. All references in this policy to
"apps" are to our apps that are available to download on mobile
devices from time to time.
(B) Our values
and what this policy is for: We value your privacy and want to be
accountable and fair to you as well as transparent with you in the way that we
collect and use your personal information. We also want you to know your rights
in relation to your information which you can find here.
In line with these
values, this privacy policy tells you what to expect when we collect and use
personal information about you. We have tried to make it easy for you to
navigate so you can find the information that is most relevant to you and our
relationship with you.
We are always looking
to improve the information we provide to our customers and contacts, so if you
have any feedback on this privacy policy, please let us know using our contact
details in section 10.
(C) Who this
policy applies to: This policy applies to users of our apps and people who
contact our customer support function.
(D) What this
policy contains: This privacy policy describes the following important
topics relating to your information (you can click on the links to find out
more):
1. Collection of your personal information and how we use it:
2. Our legal basis for using your personal information;
3. How and why we share your personal information with others;
4. How long we store your personal information;
5. Your rights;
6. Children;
7. Where we may transfer your personal information;
8. Risks and how we keep your personal information secure;
9. Changes to this privacy policy; and
10.Further questions and how to make a complaint.
(E) Your
rights to object: You have various rights in respect of our use of your
personal information, as set out in section 5. Two of the fundamental rights to
be aware of are that:
1. you may ask us to stop using your personal information for direct marketing
purposes. If you exercise this right, we will stop using your personal
information for this purpose.
2. you may ask us to consider any valid objections which you have to our use of
your personal information where we process your personal information on the
basis of our, or another person's, legitimate interest.
You can find out more information in section 5.
(F) What you
need to do and your confirmation to us: Please read this privacy policy
carefully to understand how we handle your personal information. By engaging
with us in the ways set out in this privacy policy, including downloading and
using any of our apps, you confirm that you have read and understood the
entirety of this privacy policy, as it applies to you.
The detail - the key
information you should be aware of
1. Collection of your
personal information and how we use it
1.1 What personal
information we collect about you
(a) Our apps collect the following information about you (and we use the
information in the ways explained below):
(i) if you agree to receive personalized ads, data about your general location
and the Identifier for Advertising (IDFA) of the device;
(ii) if you participate in any chat activity on our apps, we will collect your
handle and any data that you share within your messages posted to that chat;
(iii) if you choose to use the Facebook connection functionality and depending
on your Facebook privacy settings, your basic Facebook profile information.
(b) If you contact our customer support function, we will collect your e-mail
address (as well as any other information you include in your correspondence
with us), including any updates to any of that information.
1.2 How we use your
personal information
We will collect, use and store the personal information listed above for the
following reasons:
(a) to help us manage advertising and provide you with advertising and
marketing via our apps that is relevant to you, both from us and from our third
party partners, as further described in the 'Third party advertising' section
below;
(b) to record your preferences in relation to advertising and marketing
communications; and
(c) to receive and respond to customer support enquiries we receive from you.
1.3 Other uses of your
personal information
(a) We also collect, use and store your personal information for the following
additional reasons:
(i) to deal with any enquiries or issues you have about how we collect, store
and use your personal information, or any requests made by you for a copy of
the information we hold about you. Even if we do not have a contract with you,
we may process your personal information for these purposes where it is in our
legitimate interests for customer services purposes;
(ii) for internal corporate reporting, business administration, ensuring
adequate insurance coverage for our business, ensuring the security of company
facilities, research and development, and to identify and implement business
efficiencies. We may process your personal information for these purposes where
it is in our legitimate interests to do so;
(iii) to comply with any procedures, laws and regulations which apply to us -
this may include where we reasonably consider it is in our legitimate interests
or the legitimate interests of others to comply, as well as where we are
legally required to do so; and
(iv) to establish, exercise or defend our legal rights - this may include where
we reasonably consider it is in our legitimate interests or the legitimate
interests of others, as well as where we are legally required to do so.
(b) We will not use your personal information in any way that is incompatible
with the purposes set out in this section 1. Please contact us using the
details in section 10 if you want further information on the analysis we will
undertake to establish if a new use of your personal information is compatible
with these purposes.
2. Legal basis for use
of your personal information
2.1 We consider that
the legal bases for using your personal information as set out in this privacy
policy are as follows:
(a) our use of your personal information is necessary to perform our
obligations under any contract with you (for example, to comply with the terms
of service of our apps); or
(b) you have provided us with your consent to do so. This applies in relation
to the advertising and marketing materials delivered via our apps that are
tailored to you and your preferences. You can control and withdraw your consent
at any time on our apps.
(c) where (a) or (b) does not apply, our use of your personal information is
necessary for our legitimate interests or the legitimate interests of others.
Our legitimate interests are to:
(i) run, grow and develop our business (as well as the businesses of our group
companies) including funding our business by use of advertising revenues;
(ii) and operate, maintain and improve our apps and our marketing optimisation
efforts;
If we rely on our (or
another person's) legitimate interests for using your personal information, we
will undertake a balancing test to ensure that our (or the other person's)
legitimate interests are not outweighed by your interests or fundamental rights
and freedoms which require protection of the personal information. You can ask
us for information on this balancing test by using the contact details at
section 10.
3. How and why we
share your personal information with others
Third party
advertising
3.1 We want to make
sure that our advertising and marketing is relevant and interesting to you and
our other customers. To achieve this, we use third-party advertising and
technology companies to serve advertising and/or provide aggregated data to
assist in serving advertising when you visit or use our apps. This includes
third party technology companies which collect data about you in order to build
a profile of your preferences based on your activities when you visit or use
our apps. We also use these companies to automatically collect data from you
when you use our apps in order to help us identify the advertising that are
served to you and what you do after seeing those advertising. In addition, we
share data with providers of analytics tools, such as Firebase, Google
Analytics, Tenjin which we use to analyse your use of the apps. A list of the
third party advertising and technology companies that we use is set out below.
(a) Admob (Google, Inc.)
(b) AppLovin Limited
(c) Facebook, Inc.
(d) Firebase (Google, Inc.)
(e) Google Analytics (Google, Inc.)
(f) Tenjin, Inc.
(g) Unity Ads (Unity Technologies Finland Oy)
3.2 These third party
advertising companies collect, store and use data by integrating cookies and
other tracking software on our apps. The relevant data collected by these third
parties includes:
(a) data about your device, location and use of our apps, including IP address,
a unique device ID, geo-location details and your User ID that we have assigned
to you;
(b) data which you provide to us when using our apps, including information on
your interaction with advertising and certain technical information.
3.3 These third party
advertising companies will collect and use your data to provide you with
targeted advertising that is relevant to you and your preferences with your
consent. You can control and withdraw your consent to this targeted advertising
at any time on our apps. If you do not provide or withdraw your consent to
receive targeted advertising that is relevant to you and your preferences, then
we will still serve you advertising when you visit or use our apps but this
will no longer be tailored to you or your preferences.
3.4 In some cases
these third parties will also use the data that they collect for their own
purposes, for example they may aggregate your data with other data they hold
and use this to inform advertising related services provided to other clients.
3.5 We might also
share your data with social media or other similar platforms, as well as our
advertising partners, so that you and other people can see relevant advertising
on that platform. For example, we may use the Facebook Custom Audiences service
and share your IDFA with Facebook so that we can: serve relevant advertising to
you or include you in a custom audience that we will serve relevant advertising
to you on Facebook; or create an audience of other Facebook users based on the
information in your Facebook profile. You can opt-out from Facebook Custom
Audiences in your Facebook privacy settings, for example, and other similar
platforms may have equivalent opt-out settings.
Other third parties
3.6 We will share your
personal information with the following third parties or categories of third
parties:
(a) Webair, who store all our data and may access personal data stored within
that storage solution when providing support and maintenance purposes;
(b) the OS providers of your device, or the providers of the platform from
which you downloaded our app(s), in order to verify purchases you make and
provide in-app purchase opportunities. This includes Google, Amazon and Apple;
(c) Google, Inc. (trading as Firebase), who provide analytics of bugs and
issues with our apps, so that we can fix, stabilise and improve our apps;
3.7 We may share your
personal information with our group companies where it is in our legitimate
interests to do so:
(a) to enable them to provide customer support to you; or
(b) for internal administrative and management purposes (for example, for
corporate strategy, compliance, auditing and monitoring, research and
development and quality assurance).
3.8 We will also
disclose your personal information to third parties:
(a) where it is in our legitimate interests to do so to run, grow and develop
our business:
(b) if we or any of our group companies sell or buy any business or assets (or
propose to do so), or we or any of our group companies are or may be acquired,
we or our group companies may disclose your personal information to the
prospective seller or buyer of such business or assets, and to their legal,
financial and other professional advisers, and that personal information may be
one of the transferred assets; and
(c) if we are under a duty to disclose or share your personal information in
order to comply with any legal obligation, any lawful request from government
or law enforcement officials and as may be required to meet national security
or law enforcement requirements or prevent illegal activity;
(d) in order to establish, exercise, enforce, or defend our terms of service or
any other agreement or to respond to any claims, to protect our rights or the
rights of a third party, to protect the safety of any person or to prevent any
illegal activity; or
(e) to protect the rights, property, or safety of AE Zext, our staff, our
customers or other persons.
3.9 We may also
disclose and use anonymised, aggregated reporting and statistics about users of
our apps for the purpose of internal reporting or reporting to our group or
other third parties. None of these anonymised, aggregated reports or statistics
will enable our users to be personally identified.
3.10 Save as expressly
detailed above, we will never share, sell or rent any of your personal
information to any third party without notifying you and, where necessary,
obtaining your consent. If you have given your consent for us to use your
personal information in a particular way, but later change your mind, you
should contact us and we will stop doing so.
4. How long we store
your personal information
We keep your personal
information for no longer than necessary for the purposes for which the
personal information is processed. The length of time for which we retain
personal information depends on the purposes for which we collect and use it
and/or as required to comply with applicable laws and to establish, exercise or
defend our legal rights.
5. Your rights
5.1 You have certain
rights in relation to your personal information. If you would like further
information in relation to these or would like to exercise any of them, please
contact us via email at aezext@gmail.com at any time. You have the following
rights:
(a) Right of access. You have a right of access to any personal information we
hold about you. You can ask us for a copy of your personal information;
confirmation as to whether your personal information is being used by us;
details about how and why it is being used; and details of the safeguards which
are in place if we transfer your information outside of the European Economic
Area ("EEA").
(b) Right to update your information. You have a right to request an update to
any of your personal information which is out of date or incorrect.
(c) Right to delete your information. You have a right to ask us to delete any
personal information which we are holding about you in certain specific
circumstances. You can ask us for further information on these specific
circumstances by contacting us using the details in section 10.
We will pass your
request onto other recipients of your personal information unless that is
impossible or involves disproportionate effort. You can ask us who the
recipients are, using the contact details in section 10.
(d) Right to restrict use of your information. You have a right to ask us to
restrict the way that we process your personal information in certain specific
circumstances. You can ask us for further information on these specific
circumstances by contacting us using the details in section 10.
We will pass your
request onto other recipients of your personal information unless that is
impossible or involves disproportionate effort. You can ask us who the
recipients are using the contact details in section 12.
(e) Right to data portability. You have a right to ask us to provide your
personal information to a third party provider of services.
This right only
applies where we use your personal information on the basis of your consent or
performance of a contract; and where our use of your information is carried out
by automated means.
(f) Right to object. You have a right to ask us to consider any valid
objections which you have to our use of your personal information where we
process your personal information on the basis of our or another person's
legitimate interest.
5.2 We will consider
all such requests and provide our response within a reasonable period (and in
any event within one month of your request unless we tell you we are entitled
to a longer period under applicable law). Please note, however, that certain
personal information may be exempt from such requests in certain circumstances,
for example if we need to keep using the information to comply with our own
legal obligations or to establish, exercise or defend legal claims.
5.3 If an exception
applies, we will tell you this when responding to your request. We may request
you provide us with information necessary to confirm your identity before
responding to any request you make.
6. Children
6.1 You must be aged
16 or over to purchase products or services from us. Our website and services
are not directed at children younger than this and we do not knowingly collect
any personal information from children younger than this.
6.2 If you are aged
below the age of 16 and we learn that we have inadvertently obtained personal
information from you from our websites, or from any other source, then we will
delete that information as soon as possible.
6.3 Please contact us
at aezext@gmail.com if you are aware that we may have inadvertently collected
personal information from a child below the age of 16.
7. Where we may transfer
your personal information
7.1. Your personal
information will be used, stored and/or accessed by staff operating outside the
EEA working for us, other members of our group or suppliers, including those
located in the United States of America. Further details on to whom your
personal information may be disclosed are set out in section 3.
7.2 When we provide
any personal information about you to any such non-EEA members of our group or
suppliers, we will take appropriate measures to ensure that the recipient
protects your personal information adequately. These measures may include the
following, as permitted in Articles 45 and 46 of the General Data Protection
Regulation:
(a) in the case of US based entities, entering into European Commission
approved standard contractual arrangements with them, or ensuring they have
signed up to the EU-US Privacy Shield (see
https://www.privacyshield.gov/welcome); or
(b) entering into European Commission approved standard contractual
arrangements with them.
7.3 Further details on
the steps we take to protect your personal information, in these cases is
available from us on request by contacting us via the e-mail address set out in
section 10.
8. Risks and how we
keep your personal information secure
8.1 The main risk of our
processing of your personal information is if it is lost, stolen or misused.
This could lead to your personal information being in the hands of someone else
who may use it fraudulently or make public, information that you would prefer
to keep private.
8.2 For this reason,
we are committed to protecting your personal information from loss, theft and
misuse. We take reasonable precautions to safeguard the confidentiality of your
personal information, including through use of appropriate organisational and
technical measures. We use industry-standard practices such as encryption,
firewalls and password protection systems to safeguard the confidentiality of
any personal information that we might collect from you. For example, your
email address will be encrypted, which will make it extra hard for someone to
discover and use them without our authorisation. We also strive to limit access
to your data to employees performing a legitimate business function which
requires them to access and use your data in order to supply you with our apps.
We review our security procedures periodically to consider appropriate new
technology and updated methods to ensure we continue to protect your data.
8.3 Although we make
every effort to protect the personal information which you provide to us, the
transmission of information over the internet is not completely secure. As
such, you acknowledge and accept that we cannot guarantee the security of your
personal information transmitted to our apps or customer services function and
that any such transmission is at your own risk. Once we have received your
personal information, we will use strict procedures and security features to
prevent unauthorised access to it.
9. Changes to our
privacy policy
We may update our
privacy policy from time to time. Any changes we make to our privacy policy in
the future will be made available to you via the privacy policy, accessible in
our app. Please check back frequently to see any updates or changes to our
privacy policy.
10. Further questions
and how to make a complaint
10.1 If you have any
queries or complaints about our collection, use or storage of your personal
information, or if you wish to exercise any of your rights in relation to your
personal information, please contact aezext@gmail.com. We will investigate and
attempt to resolve any such complaint or dispute regarding the use or
disclosure of your personal information.
10.2 In accordance
with Article 77 of the General Data Protection Regulation, you may also make a
complaint to the Information Commissioner's Office, or the data protection
regulator in the country where you usually live or work, or where an alleged
infringement of the General Data Protection Regulation has taken place.
Alternatively, you may seek a remedy through the courts if you believe your
rights have been breached.
The practices
described in this privacy policy statement are current as of 15 Jan 2025.