NaissusWorks (identified as the Controller) relies on a number of technical and organizational measures to keep your personal data secure; however, we are unable to provide a full guarantee that your information will be absolutely protected due to the generally insecure nature of Internet connections.
Controller’s contact information
If you would like to contact NaissusWorks with a question regarding our application of the General Data Protection Regulation (GDPR), any other data protection law or provision in European Union, our designated data privacy controller is Ivan Jankovic, and can be reached via this site’s Contact form.
Collection and distribution of personal information
Automated collection of information
Collection of real-time location information
NaissusWorks does not collect precise real-time location information of your device.
Distribution of personal information to third parties
NaissusWorks may share the information automatically collected while you use our products and services with third-party companies and institutions, but only under following conditions:
- When required by representatives of law enforcement so as to comply with a subpoena or another legal process;
- When we reason to believe that the disclosure would result in the protection of our and your rights and safety, as well as rights and safety of others – as to assist in fraud investigations and respond to government requests;
- When the recipients of the information are trusted service providers who work on our behalf, yet who have agreed to adhere to this privacy statement and have no ability to independently use the information in question;
- If NaissusWorks – or any of its assets – is involved in a process of corporate acquisition, merger or sale, the new owner (or partner) will receive access to any information acquired under the conditions listed within this policy.
- If our products or services include third-party advertising or analytics software modules, in which case, data is collected as described in the section that follows.
Advertising and Automatic Data Collection
Our products and services may require that you enter non-personally-identifiable information such as your gender, age range or year of birth. This information is only required from the users who identify themselves as being above the age of 13, and is used to personalize the content provided by the product or service. If such users have decided not to opt out of behavioral advertising, we may use this information to display targeted ads via our advertising partners. You can choose to opt out of receiving targeted ads at any time by following the instructions in the “Opt Out” section of this Policy. We may work with analytics companies to help us understand how our apps and games are being used, such as the frequency and duration of usage. We work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in our services which help us keep the applications free. Advertisers and advertising networks use some of the information collected by the our services, including, but not limited to, the unique identification ID of your mobile device and your mobile telephone number. To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties can’t identify you personally. These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non-precise location information in order to help analyze and serve anonymous targeted advertising in our apps and elsewhere. We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising related use.
We will pass the device-level data (e.g. if a device has clicked on a sports ad within our apps) and we may pass age & gender information to our advertising partners who may reuse such data for targeted advertising. We allow our partners to serve targeted third party advertisements or other content. They may attach the information gathered from your application to info gathered from other apps, websites, or via other services, and then build profiles and transfer the info to another provider. For instance, we may pass advertising IDs to Facebook and they match it with your Facebook ID, aggregate it and delete the initial identifier. By doing so, the other provider may receive or gather information about you and use the information for displaying targeted ads. Advertisers may choose their audience by location, demographics, likes, keywords, age & gender, interests, behaviors, connections and any other information Facebook receives or infers about users. We cooperate with several providers of IBA that are listed herein in the subsection “Advertising Companies”.
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
Rights of the data subject
NaissusWorks may collect only anonymous information for the purposes of targeted advertising and tracking of user behavior within the product or service. Should the user wish to eliminate the right to access to this automatically collected information, he or she can turn off individual device tracking on his or her device.
This section lists the advertising and analytics companies with which NaissusWorks shares anonymized personal data. If you’d like to opt-out from third party use of this type of information and stop receiving targeted advertising, please visit the section entitled “Opt-out” below.
The easiest way to opt out of all information collection is to uninstall or stop using all of our products and services. Uninstalling our products can be done using the standard methods available in the operating system on your device – most often via the home screen, Settings or Store apps. You can also request opt-out via this site’s Contact form. If you are solely interested in opting out from targeted advertising, use the third-party instructions directly (Google AdMob Opt Out).
Your device may provide a “Do Not Track”, “Limit Ad Tracking” or “Opt Out of Interest-Based Advertising” setting. Turning this setting on binds our partners not to use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests. Opting out does not imply that you will see fewer advertisements; advertising services will still be able to use the content of the product or service you are using to show relevant ads. Do note that NaissusWorks cannot guarantee that our partners are respective of your opt-out choices nor can guarantee that there are no additional opt-out mechanisms implemented.
Targeted advertising is tied to a unique, anonymous code called Advertising Identifier. The reason for switching from device IDs to Advertising Identifier is that parties participating in advertising are obligated to follow users’ choice for opting out of tracking according to the app store guidelines, allow the user to delete aggregate data about their interests, and can use this identifier only for advertising and for no other purpose.
You can find the settings for interest-based ads on your mobile device by following the directions below, or contacting your device provider. Note that you can always disable the opt-out settings and receive targeted advertisement again.
- ANDROID DEVICE: For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up, open your Google Settings app > Ads > Enable “Opt Out of Interest-Based Advertising”.
- IOS DEVICE: For iOS 6, go to your Settings > Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting. For iOS 7 or Higher, go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting. More information about the iOS setting can be found here.
Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Whether Picturesque Apps is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, is to be based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Data Retention Policy, Managing Your Information
We will retain Automatically Collected information. If you’d like us to delete User Provided Data that you have provided via any of our services, please contact us via our Contact form and we will respond in a reasonable time.
We do not use our products to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact via our Contact form.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
If you have any questions regarding privacy while using our products and services, or have questions about our practices, please contact us via our Contact form.