MLITE PRIVACY POLICY

Last updated11 August, 2021

This Privacy Notice explains what personal data is collected when you use our mobile applications, websites and the services provided through them (together “App” or “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or by us if you purchased it directly from our websites; and (c) delete the App from your devices.

TABLE OF CONTENTS

  1. CATEGORIES OF PERSONAL DATA WE COLLECT
  2. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
  3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
  4. WITH WHOM WE SHARE YOUR PERSONAL DATA
  5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
  6. INTERNATIONAL DATA TRANSFERS
  7. DATA RETENTION
  8. DATA SECURITY
  9. CALIFORNIA PRIVACY RIGHTS
  10. CHILDREN’S PRIVACY
  11. PERSONAL DATA CONTROLLER AND PERSONAL DATA PROCESSOR
  12. DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR
  13. CHANGES TO THIS PRIVACY NOTICE
  14. CONTACT US
  1. CATEGORIES OF PERSONAL DATA WE COLLECT

    1. Data you give us. You provide us with information about yourself when you register for and/or use the Service, namely email address.
    2. Data provided by third parties. When you use sign in with Apple or Google to register an account in the App, we get personal data from your Apple ID or Google account. This data may include, in particular, your name and verified email address.
    3. Data we collect automatically:
      1. Data about how you found us. We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
      2. Device and Location data. We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, country and address, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID.
      3. Advertising IDs. We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device).
      4. Transaction data. When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
      5. Contacts data. We may collect your contacts’ data while accessing the list of contacts via Apple consent request or Google consent request. You may refuse to provide these data without any interruptions to the Service.
    4. Third-party data. While using the Service, you may provide us with third-party personal data such as phone number, device and location data, contacts data, any personal data that can be indicated in text messages, SMS. You hereby authorize us to serve as a data processor to process these third-party personal data on your behalf. Please see Section 12 for the details.
    5. CookiesA cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising. Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.
  2. OR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

    We process your personal data:

    1. To provide our Service.This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. To host personal data and enable our App to operate and be distributed we use servers in Germany and Netherlands. Personal data, which are provided by users may be stored outside the EU. In some cases, these personal data and information may be stored in Canada. We adopted all necessary security measures for protection of your Personal Data according to the best practices of security, protection and confidentiality. If we transfer your Personal data to third party service providers, we will compel each third party service provider to adopt necessary security measures for protection of your Personal Data according to our data protection agreement.
    2. To customize your experience. We process your personal data, in particular, such as your characteristics and preferences, to adjust the content of the Service and provide content tailored to your personal preferences.
    3. To manage your account and provide you with customer support. We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms of Use or this Privacy Notice.
    4. To communicate with you regarding your use of our Service. We communicate with you, for example, by push notifications. These may include emails. To opt out of receiving push notifications, you need to change the settings on your device. To opt out of receiving emails, you need to reply to the email – opt out, we will stop sending emails.
    5. To research and analyze your use of the Service. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use data for statistical analysis purposes, to test and improve our offers.

      To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Find more in Appsflyer’s Privacy Notice.

      We use Facebook Analytics, which is a service is provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our app, how often users make purchases, and other interactions. Find more in Facebook’s Privacy Notice.

      To analyze how visitors use the Service and to measure the effectiveness of some ads we use Google Analytics, a web analysis program of Google. On Google Analytics we get, in particular, information on the data you enter on our website and users’ interactions within the website. Google allows you to influence the collection and processing of the information generated by Google, in particular, by installing a browser plug-in, available here. You can read more about how Google uses the information here.

      To analyze how visitors use the Service and to measure the effectiveness of some ads we use Amplitude Analytics, an app analysis program of Amplitude inc.. On Amplitude Analytics we get, in particular, information on the data you enter on our app and users’ interactions within the app. You can read more about Amplitude and its Privacy Policy

    6. To send you marketing communications. We may process your personal data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish legal basis for sending you marketing communications. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails. We may also show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.
    7. To process your payments. We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for our Service and we will be notified that the payment has been made and will provide you with. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
    8. To comply with legal obligations. We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
  3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users).

    In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

    We process your personal data, in particular, under the following legal bases:

    Legal Basis Purpose
    Consent To send you marketing communications
    To perform our contract with you To provide our Service (in accordance with our Terms of Use), to customize your experience, to manage your account and provide you with customer support, to communicate with you regarding your use of our Service, to process your payments
    Our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data to research and analyze your use of the Service, to communicate with you regarding your use of our Service, to enforce our Terms of Use and to prevent and combat fraud
    Legal obligation to comply with legal obligations.
  4. WITH WHOM WE SHARE YOUR PERSONAL DATA.

    We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 2 of this Privacy Notice. The types of third parties we share information with include, in particular:

    1. Service providers.We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:

      1. cloud storage providers
      2. data analytics providers
      3. independent contractors
      4. marketing and affiliate partners
      5. payment processing providers
      6. communication services providers
    2. Law enforcement agencies and other public authorities. We may use and disclose personal data to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
  5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS.

    To be in control of your personal data, you have the following rights:

    1. Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us in the profile section of the App. If you would like to receive a copy of data we process, please send us a data access request.
    2. Deleting your personal data. You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
    3. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof. Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:
    4. The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
    5. The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or other file format.

    To exercise any of the available to your privacy rights, please send a request to [email protected]

  6. INTERNATIONAL DATA TRANSFERS.

    We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Use and for purposes indicated in this Privacy Notice. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

  7. DATA RETENTION

    We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Notice (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  8. DATA SECURITY.

    We have adopted technical and organizational measures to preserve and protect your personal data from unauthorized use or access and from being altered, lost or misused, taking into account the technological state of art, the features of the information stored and the risks to which information is exposed. Although we have exercised high levels of care in providing secure transmission of information between the Application and our servers and in storing that information on our systems, no method of transmission over the Internet, or of electronic storage, is 100% secure. As such, we cannot ensure or otherwise guarantee the security of information transmitted to us over the Internet.

  9. CALIFORNIA PRIVACY RIGHTS.

    This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

    For more details about the personal information we have collected, including the categories of sources, please see Section 1 above. We collect this information for purposes described in Section 2 of this Privacy Notice. We may also share your information with certain categories of third parties as indicated in Section 4. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

    California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected] We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

    Access rights under California’s Shine the Light. California also provides its residents with additional access rights. Under Shine the Light law, the residents may ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute. To obtain this information from us, please send an email message to [email protected], which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

  10. CHILDREN’S PRIVACY.

    The Children's Online Privacy Protection Act ("COPPA") requires us to inform parents and legal guardians about how we collect, use, and disclose personal information from children under the age of 13, which is described in this Privacy Notice as well. We do not knowingly sell any products to children; however, we may collect children’s personal data on your behalf as a parent and legal guardian. We encourage parents and legal guardians to monitor their children’s Internet usage. You are solely responsible for the tracked information accessed by you or any third party you have permitted to use the Application and you agree to the Disclaimer of Warranties of the Terms of Use governing the use of the Website and the Application.

  11. PERSONAL DATA CONTROLLER AND PERSONAL DATA PROCESSOR.

    Data protection laws in certain jurisdictions differentiate between “controller” and “processor” of Personal Data. If you are visiting our Website, using the App and the Services, the Data Controller is the Fortunex Limited. In situations in which Personal Data is processed by Fortunex Limited. on behalf of You, in particular when you provide us with the personal data of third parties while connecting the device, or using location feature via SMS, etc., Data Controller is You and Fortunex Limited is the Data Processor.

  12. DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR

    1. Target Device Data.We start collecting data from a target device associated with the account, which may include personal data relating to you, to a target device user(s) or to third parties (“Target Device Data”, including information about a target device, phone number, contacts, messages and SMS, geolocation, sound around the child's device). In accordance with applicable privacy law, to the extent that it applies to us, you are the Data Controller of this Target Device Data and you appoint us as a Data Processor of such data for the purpose of providing the Service.

      Sound around the child's device. You as a parent can choose to listen live to your child's device's surroundings or choose to record these surroundings for 15 seconds. You can save it in the App and download from the App to any data storage.

      For users from USA: Please note, that this feature is available only in US states, where the one-party consent for surroundings recording is applied. In other US states the Sound around the child’s device feature is prohibited due to local laws and requirements.

      For users from other countries: It is your responsibility to comply with the laws of your country due to Sound around the child’s device features usage. In some countries you have to get a consent from third-party (individual, which is staying near your kid) for recording surroundings with such individual’s participation (conversation, talks, etc.). Please, get an advice of your lawyer, how you can legally use the Sound around the child’s device feature in the country of your designation.

    2. Your use of Target Device Data. As Data Controller, you warrant that you have the appropriate authority, or have obtained a valid consent from third party as may be required by data privacy laws, to collect and process the Target Device Data and you agree to process and use the Target Device Data in accordance with this Privacy Notice, the Terms and applicable law, and only for the explicit purposes of the Service. You will protect the confidentiality of any accessible Target Device Data and prevent access by or disclosure to any unauthorized third person. You will inform us within 24 hours about any problem arising in relation with management of your account and/or Target Device Data
    3. Data Processor Obligations. To the extent that we are Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any Target Device Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to Target Device Data only to those employees who need to know it to enable the Processor to perform the Services; (c) only process the Target Device Data as specified by this Notice and in accordance with your instructions, and (d) will not use the Target Device Data for any purposes other than those related to the performance of the Service or pursuant to your written instructions. Upon the expiry or termination of this agreement by way of de-registration, or upon your request, we will cease any and all use of the Target Device Data and will destroy or return it to you except as provided above with respect to backed-up data and termination. We will not disclose Target Device Data to any third party without your prior written consent or pursuant to court or administrative order.
    4. Warranties. You are solely responsible for use of the account and the processing of personal data associated with your account, which includes, among others, collecting, storing and analyzing personal data from a target device. You warrant, as the one responsible for Target Device Data that we process on your behalf as Data Processor, that (a) you have informed any user(s) that are 13 years old or more regarding your usage of the Service, and have obtained consent from such user(s) for this kind of activity, as provided in our Privacy Notice, and (b) you comply with all applicable legislation with respect to data privacy, including children’s data privacy. You agree to fully comply with this Privacy Notice.
    5. Indemnity. You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of Target Device Data and other third-party personal data submitted to our systems during the course of use and provision of the Service.
  13. CHANGES TO THIS PRIVACY NOTICE.

    We may modify this Privacy Notice from time to time. If we decide to make material changes to this Privacy Notice, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Notice. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Notice.

  14. CONTACT US

    If you have any questions about this Privacy Notice, please contact us in one of the following ways:

    E-mail us at: [email protected]

    Send mails to: IPL Group PTY LTD, Level 3 845 Pacific Highway, Chatswood NSW 2067, AUSTRALIA