Privacy Policy

We are committed to protecting and respecting your privacy.

This policy describes how personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Here below we will use the term “Our Apps” to refer all the Android apps published by Smart Launcher SRL.

As you may know, Smart Launcher SRL offers its services also through its mobile apps or other online platforms such as its partners’ websites and social media. This Privacy Policy is applicable to any data we collect about you or that you voluntarily provide to us through these platforms or other connected tools (for example e-mails sent to our Team).

This Policy is provided pursuant to the UE Regulation on data protection (General Data Protection Regulation, hereinafter “GDPR”).

By accessing our Website and using our app, you accept and consent to the practices described in this Policy. If you do not accept the provisions set forth herein, we invite you not to use our Website or app.

 

DATA CONTROLLER AND OWNER

Smart Launcher Srl – Via Scaloria 129 c/o st.D’Amico, 71043 Manfredonia (Italy),

Owner contact email:  contact@smartlauncher.net

For the purpose of the Legislative Decree of 30 June 2003 No. 196 (the Code concerning the protection of personal data) (the “Code”).

 

METHODS OF PROCESSING

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

 

1. Types of Data collected

1.1 We may collect and process the following data about you:

a) Usage activity about how you interact with our application(s) or site and which areas of our application(s) or site you visited.

b) Details of transactions you carry out through our site or the application(s) and of the fulfillment of your orders.

c) If you contact us, we may keep a record of that correspondence.

d) The list of applications for which Smart Launcher automatically requires automatic sorting, which is required to provide you a customized user experience. We may use this anonymous data for statistical purpose too.

e) Information that you provide by filling in forms on the Website or through the Application.

f) Cookies and unique device identifiers for advertising (Google Advertiser ID)

1.2 Some features like searching a contact from the search bar, require access to your Address book. This is required for the only purposes to provide to the user the ability to search a contact in the Application. No data from your Address Book is collected, shared or sent in any way on the net.

1.3 This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

 

2. IP ADDRESSES AND COOKIES

2.1 Information collected automatically from this Application (or third party services employed in this Application) can include: the IP addresses or domain names of the computers utilized by the users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

2.2 We may collect some device information, including where available your IP address, operating system, the referring URL, if any, for system administration and to report aggregate information to our advertisers. This is statistical data about and does not identify any individual.

2.3 For the same reason, on this website, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service. They enable us to estimate our audience size and usage pattern. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

 

3. PLACE OF PROCESSING

3.1 The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

3.2 The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

3.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

3.4 Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

 

4. USES MADE OF THE INFORMATION

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Hosting and backend infrastructure, Displaying content from external platforms and Contacting the User.

4.1 We use information held about you in the following ways:

a) To ensure that content from Our Apps is presented in the most effective manner for you and for your computer.

b) To provide you with information, products or services that you request from us or which we feel may interest.

c) To carry out our obligations arising from any contracts entered into between you and us.

d) To allow you to participate in interactive features of Our Apps, when you choose to do so.

e) To notify you about changes to Our Apps.

 

5. ADVERTISING

5.1 We reserve the right to deliver advertising to you in conjunction with your use of Our Apps and utilise the processor bandwidth and storage hardware on your Device for this purpose.

5.2 Advertising may be contextual, that is it may be sent to you based on your current location or use of Our Apps. Any opt out that you send us in relation to direct marketing communications does not apply to such advertising. In addition, you may receive advertising and promotional information or offers if you respond to a Our Apps prompt on radio or television or in audiovisual or interactive media.

5.3 Where Our Apps contains links to third-party content, applications, services and/or advertising, we are not responsible for the privacy policy or for any matters relating to such third party products, promotions or advertising, including responsibility for controlling any personal data that you may provide in response to such products, promotions or advertising. We encourage you to check the privacy policies of all third party sites that you visit.

5.4 We have relationships with third party companies that may serve you ads and use information about you in accordance with the terms of this policy. Some of these companies may be members of the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA) or other equivalent organizations that comply with the NAI Code of Conduct. You may access the opt out page maintained by the NAI by clicking on the following link: www.networkadvertising.org/choices/. Please note that opting out will not prevent you from seeing ads, it just means that the ads being served by those companies will no longer be targeted based on your web browsing.

 

6. PROTECTION OF MINORS

6.1 To use Our Apps you must be aged 16 or older. Additionally, if you are under 18 years old, you must obtain the permission of your parent or guardian and the person who pays your mobile phone bills (if different) and they must agree to these Terms on your behalf before you use Our Apps and before you provide any personal information to us. Also, to use some of the Services you may be asked to register with us and provide certain personal details. See the section on privacy below regarding what we do with this information.

6.2 You represent and warrant that you are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in these Terms, and to abide by and comply with these Terms and have obtained all necessary third-party consents, licences and permissions necessary to enter into and fully perform your obligations under these Terms.

6.3 If you are reading these terms to provide permission to a minor to use Our Apps, you represent and warrant that you have the full authority to act on behalf of the service user and that you are either more than 18 years of age and contracting for yourself or are the parent or guardian of the person who will use the Services and are entering into this contract to cover their usage. In any case, you affirm that you are, or the person who will use Our Apps (where you are the parent or guardian of that person) is, over the age of 16.

6.4 The Services are not intended for children under 16. If you are under 16 years of age, then please do not use Our Apps. If you are the parent or guardian of a person under the age of 16, then please do not permit that person use Our Apps.

6.5 Your access to the Services may be deleted or blocked without warning if it is found that you are misrepresenting your age or the age of the person using Our Apps. In this case, your membership account and all related data may be deleted without warning. Your access to the Services is solely for your personal use, and you must not authorize others to use your account.

 

7. DISCLOSURE OF YOUR INFORMATION

7.1 We may disclose your personal information to third parties:

a) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

b) If Smart Launcher SRL or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use  and other agreements; or to protect the rights, property, or safety of Smart Launcher SRL, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and the infringement of any intellectual property rights.

 

8. DETAILED INFORMATION OF THE PROCESSING OF PERSONAL DATA

Personal Data is collected for the following purposes and using the following services:

CONTENT PERFORMANCE AND FEATURES TESTING (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.

Firebase Remote Config (Google Inc.)

Firebase Remote Config is an A/B testing and configuration service provided by Google Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

INFRASTRUCTURE MONITORING

This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

Firebase Crash Reporting (Google Inc.)

Firebase Crash Reporting is a monitoring service provided by Google, Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

CONTACTING THE USER

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address.

ADVERTISING

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

In order to understand Google’s use of Data, consult Google’s partner policy.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

AppLovin (AppLovin Corporation)

AppLovin is an advertising service provided by AppLovin Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Facebook Audience Network (Facebook, Inc.)

Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.

This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.

Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

ANALYTICS

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics for Firebase (Google Inc.)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google’s use of Data, consult Google’s partner policy.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

This Application uses identifiers for mobile devices (including Android Advertising ID) and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: United States – Privacy Policy.

HOSTING AND BACKEND INFRASTRUCTURE THE USER

This type of services has the purpose of hosting data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

DigitalOcean (DigitalOcean Inc.)

DigitalOcean is a hosting service provided by DigitalOcean Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

System logs and maintenance

For operation and maintenance purposes, Smart Launcher and any third-party services may collect files that record interaction with Smart Launcher (System logs) use other Personal Data (such as the IP Address) for this purpose.

WEATHER CONDITIONS

This type of services allows you to visualize on your device current weather conditions. In order to provide this service the Application needs to retrieve your current position and transmit it to our weather providers partner services.

Awareness API (Google Inc.)

Awareness API is a service provided by Google Inc. that allows to get info about the user’s environment.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Open Weather Map

Open Weather Map is a service that provides

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: Various countries as specified in the privacy policy of the service – Privacy Policy.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

These services allow you to view and interact with content hosted on external platforms directly from the Application or from the pages of this website.

If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this website to incorporate content of this kind on its pages.

Place of processing: USA – Privacy Policy

Bing Search (Microsoft Inc.)

Bing Search is a web search engine owned by Microsoft that allows Smart Launcher users to search for information on the World Wide Web.

Place of processing: USA – Privacy Policy

Branch Discovery (Branch Metrics, Inc.)

Branch Discovery is a service that enables Smart Launcher to provide contextual results and intent-based links, which gives our users simplified access to completing an action (for example, to identify nearby restaurants).

Place of processing: USA – Privacy Policy

9. RETENTION TIME

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 

10. YOUR RIGHTS

10.1 The user can exercise at any moment the rights set out in article 7 of the Privacy Code and in articles 15 and following of the GDPR, including the right to receive confirmation of the existence of personal data that concern him, to assess their content, accuracy, location (also with reference to any third Country), to ask for a copy of such data, to ask for the integration, update, correction and, when allowed by the applicable law, the restriction, cancellation, transformation in anonymous form or block for law infringement. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.

To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

10.2 Our Apps may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

11. CHANGES TO OUR PRIVACY POLICY

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Smart Launcher and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

 

12. CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to contact@smartlauncher.net

 

Effective [June 2012]

Last Update November 2018