Privacy Policies

Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Trackers; Usage Data; unique device identification for advertising (Google Advertiser ID or IDFA, for example); number of Users; device information; session statistics; browser information; name; email; username; password; profile picture; social media accounts; advertising data.

Full details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanatory texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.

Unless otherwise specified, all Data requested by this Application is mandatory and failure to provide this Data may prevent this Application from providing its Services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences for the availability or functioning of the Service.

Users who have questions about which Personal Data are mandatory are invited to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Services requested by the User, in addition to any other purposes described in this document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Service (this Application).

Method and place of processing of Data

Processing method

The Owner shall take appropriate security measures to prevent unauthorized access, disclosure, alteration, or unauthorized destruction of the Data.
The processing of the Data is carried out using computers and/or IT enabled tools, following organizational procedures and means strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (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 Owner at any time.

Place

The Data is processed at the Owners’ operating offices and in any other places where the parties involved with the processing are located.

Depending on the User’s location, data transfers may involve transferring User 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 the details on the processing of Personal Data.

Conservation period

Unless otherwise specified in this document, Personal Data will be processed and stored for the time necessary for the purposes for which they were collected, and may be retained for a longer period due to any applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for: Advertising, Statistics, Registration and authentication, Contact management and messaging, Hosting and backend infrastructure, Platform and hosting services, and Remarketing and behavioral targeting.

To obtain specific information about the Personal Data used for each purpose, the User may consult the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

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

Google Analytics 4 (Google LLC)

Google may use the data collected to contextualize and personalize the ads of its own advertising network.

In Google Analytics 4, IP addresses are used at the time of collection and discarded before the Data is recorded in any data center or server. Users can obtain more information in the official Google documentation.

Personal Data processed: Usage data; session statistics; device information; browser information; number of Users; Trackers.

Google Ads Conversion Tracking

Google Ads Conversion Tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Application.

Personal Data processed: Usage Data; Trackers.

Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)

Meta Ads Conversion Tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta advertising network with actions performed on this Application. The Meta pixel tracks conversions related to the Facebook, Instagram and Audience Network platforms.

Personal Data processed: Usage Data; Trackers.

Firebase Cloud Messaging (Google LLC)

Firebase Cloud Messaging is a messaging service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to individual devices, groups of devices, specific topics, or segments of Users.

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

Firebase Notifications (Google LLC)

Firebase Notifications is a messaging service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opens and conversions.

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

Amazon Simple Email Service (SES) (Amazon)

Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

Personal Data processed: e-mail.

Firebase Authentication (Google LLC)

Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication may use third-party identity providers and save the information on its platform.

Personal Data processed: social media accounts; email; profile picture; name; username; password.

Firebase Cloud Firestore (Google LLC)

Firebase Cloud Firestore is a hosting and backend service provided by Google LLC.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Google AdSense (Google LLC)

Google AdSense is an advertising service offered by Google LLC. This service uses the “DoubleClick” Cookie, which tracks the use of this service (this Application), and the User’s behavior in relation to the advertisements, products and services offered. Users can decide to disable all DoubleClick Cookies by visiting: Ads Settings. To understand Google’s use of data, please see the Google Partner Policy.

Personal Data processed: Usage Data; Trackers.

AdMob (Google LLC)

AdMob is an advertising service provided by Google LLC. To understand how Google uses your data, please see Google’s partner policy.

Personal Data processed: Usage Data; unique device identification for advertising (Google Advertiser ID or IDFA, for example); Trackers.

Google Ad Manager (Google LLC)

Google Ad Manager is an advertising service offered by Google LLC that allows the Owner to run advertising campaigns together with external advertising networks with which the Owner, unless otherwise stated explicitly in this document, has no direct relationship.
To understand Google’s use of Data, please refer to the Google Partner Policy.

This service uses the “DoubleClick” Cookie, which tracks the use of this service (this Application), and the User’s behavior in relation to advertisements, products and services offered. Users can decide to disable all DoubleClick Cookies by visiting: Ads Settings.

Personal Data processed: Usage Data; Trackers.

Meta Audience Network (Meta Platforms, Inc.)

The User can control this in Facebook’s 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 processed: Usage Data; unique device identification for advertising (Google Advertiser ID or IDFA, for example); Trackers.

Google Play Store (Google LLC)

This Application is distributed on the Google Play Store, a platform for the distribution of mobile applications, provided by Google LLC. By being distributed through this application store, Google will collect usage and diagnostic data and share aggregated information with the Owner. Much of this information is processed on an opt-in basis. Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analytics settings can be found on this page.

Personal Data processed: Usage Data.

App Store Connect (Apple Inc.)

This Application is distributed on the Apple App Store, a platform for the distribution of mobile applications, provided by Apple Inc. App Store Connect allows the Owner to manage this Application on the Apple App Store. Depending on the configuration, App Store Connect provides the Owner with statistical data about user interaction and application discovery, marketing campaigns, sales, in-app purchases and payments in order to measure the performance of this Application.

App Store Connect collects such data only from Users who have agreed to share it with the Owner. Users can find more information on how to opt-out of data sharing via their device settings here.

Personal Data processed: Advertising data; Usage data; Trackers.

Facebook Remarketing (Meta Platforms, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Application with the Meta advertising network.

Personal Data processed: Usage Data; Trackers.

Google Ads Remarketing (Google LLC)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ads Remarketing that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie. To understand Google’s use of Data, please see the Google Partner Policy. Users may opt out of the use of Trackers for ads personalization by visiting Google’s Ads Settings.

Personal Data processed: Usage Data; Trackers.

Information about opting out of interest-based advertising

In addition to the opt-out feature provided by the services listed in this document, Users may learn more about how to generally opt out of receiving interest-based advertising within the specific section of the Cookie Policy.

Cookies Policies

This Application uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third party (so-called “third-party” Trackers). Unless otherwise specified herein, third-party providers may access Trackers managed by them.

The validity and expiration periods of Cookies and other similar Trackers may vary, depending on the term established by the Owner or respective provider. Some of them expire at the end of the User’s browsing session.

In addition to what is specified in the descriptions within each category below, Users may find more precise and up-to-date information regarding the stipulation of the term, as well as any other relevant information – such as the presence of Trackers – in the links to the privacy policies of the respective third-party providers or by contacting the Owner.

This Application uses Cookies known as “technical” Cookies and other similar Trackers to perform activities that are strictly necessary to operate or provide the Service.

Google Analytics 4 (Google LLC)

Google Analytics 4 is a web analytics service provided by Google LLC (“Google”). Google uses the Data collected to track and examine the use of this Application to prepare reports on activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and discarded before the Data is recorded in any data center or server. Users can obtain more information in the official Google documentation.

Personal Data processed: Usage data, session statistics, device information, browser information, number of Users and Trackers.

Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)

Personal Data processed: Usage Data and Trackers.

Google AdSense (Google LLC)

Personal Data processed: Usage Data and Trackers.

AdMob (Google LLC)

AdMob is an advertising service provided by Google LLC.
To understand how Google uses your data, please see Google’s partner policy.

Personal Data processed: Usage Data, unique device identification for advertising (Google Advertiser ID or IDFA, for example) and Trackers.

Google Ad Manager (Google LLC)

Meta Audience Network (Meta Platforms, Inc.)

Meta Audience Network is an advertising service provided by Meta Platforms, Inc. To understand Meta’s use of Data, please review Meta’s data policy. This Application may use mobile device identifiers (including the Android Advertising ID or the Advertising Identifier for iOS, respectively) and technologies similar to cookies to make the Meta Audience Network service work. One of the ways Audience Network serves ads is by using a User’s ad preferences. You can control this in your 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 processed: Usage Data, unique device identification for advertising (Google Advertiser ID or IDFA, for example) and Trackers.

Facebook Remarketing (Meta Platforms, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Application with the Meta advertising network.

Google Ads Remarketing (Google LLC)

Since the use of third-party Trackers through this Application cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. For complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

Due to the objective complexity of the technologies related to tracking technologies, Users are advised to contact the Owner if they wish to receive any further information on the use of such technologies by this Application.

Additional information for users

Legal basis for processing

The Owner may process Personal Data relating to the User if one of the following applies:

Users have given their consent for one or more specific purposes; Note: Under some legislations the Owner may be allowed to process Personal Data UNTIL the User objects to this (“opt-out”), without having to rely on consent or any of the other legal bases set out below. This however does not apply whenever the processing of Personal Data is subject to European data protection legislation;
the provision of the Data is necessary for the fulfillment of a contract with the User and/or any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
the processing is related to a task that is carried out in the public interest or in the exercise of an official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party;

In any case, the Owner will gladly collaborate to clarify which legal basis applies to the processing, and in particular whether the provision of Data is a mandatory requirement by law or contract, or a requirement necessary to enter into a contract.

More information about retention time

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 purposes related to the Owner’s legitimate interests shall be retained for as long as necessary to fulfill such purposes. Users may obtain 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 has not been withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever the Owner is required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, the Personal Data will be deleted. Therefore, the right to access, the right to erasure, the right to correction and the right to data portability cannot be enforced after the retention period has expired.

Users’ rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the rights to do the following, to the extent permitted by law:

Withdraw your consent at any time. Users have the right to withdraw their consent in cases where they have previously given their consent to the processing of their Personal Data.
Object to the processing of your Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access your Data. Users have the right to know if their Data is being processed by the Owner, obtain disclosures regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and request rectification. Users have the right to verify the accuracy of their Data and to request that it be updated or corrected.
Restrict the processing of your Data. Users have the right to restrict the processing of their Data for any purpose other than storage.
Have your Personal Data erased or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive your Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without hindrance.
File a complaint. Users have the right to lodge a complaint with their competent data protection authority.

Users also have the right to be informed about the legal basis of Data transfers abroad, including to any international organization governed by public international law or formed by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details on the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users should be aware, however, that if their Personal Data is processed for direct marketing purposes, they may object to such processing at any time free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for these purposes. To find out whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise Users’ rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be addressed by the Owner as quickly as possible and in any case within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate burden. Upon Users’ request, the Owner will inform them of such recipients.

Additional Information for Users in Brazil

This section of the document integrates and supplements the information contained in the rest of this privacy policy and is provided by the entity that operates this Application and, as the case may be, its parents, subsidiaries and affiliates (for the purposes of this section, hereinafter collectively referred to as “we”, “us”, “our” and “us”).

This section applies to all Users from Brazil (Users are referred to below simply as “you”, “your”, “yours”), in accordance with the “General Data Protection Law” (the “LGPD”), and, for these Users, replaces any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal information” as defined in the LGPD.

What we rely on to process your personal information

We may process your personal information only if we have a legal basis for such processing. The legal bases are as follows:

your consent to the respective processing activities;
compliance with a legal or regulatory obligation imposed on us;
compliance with public policies set out in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymous personal information;
the performance of a contract and its preliminary procedures, in cases where you are a party to the contract;
the exercise of our rights in judicial, administrative or arbitration proceedings;
physical protection or security of you or a third party;
health protection – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and freedoms do not override such interests; and
credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out which categories of your personal information are processed, you can read the section entitled “Detailed information on the processing of Personal Data” in this document.

Why we process your personal information

To find out why we process your personal information, you can read about the sections entitled “Detailed information on the processing of Personal Data” and “The purposes of processing” in this document.

Your privacy rights as a Brazilian

You have the right to:

obtain confirmation about the existence of processing activities of your personal information;
access to your personal information;
have your incomplete, inaccurate or out-of-date personal information corrected;
obtain anonymity, blocking or deletion of your unnecessary or excessive personal information, or information that is not being processed in accordance with the LGPD;
obtain information about the possibility of providing or refusing your consent and the respective consequences;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except anonymous information) to another supplier of products or services, provided that our commercial and industrial secrets continue to be protected;
obtain the deletion of your processed personal information, if the processing was based on your consent, unless one or more exceptions from those set out in art. 16 of the LGPD apply;
withdraw your consent at any time;
file a complaint regarding your personal information with the ANPD (National Data Protection Authority) or consumer protection agencies;
object to a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request a review of decisions taken exclusively based on the automated processing of your personal information, which affect your interests. This includes decisions to define your personal, professional, consumer and credit profile or aspects of your personality.

You will never be discriminated against or suffer any kind of harm if you exercise your rights.

How to register your request

You may register your express request to exercise your rights free of charge, at any time, using the contact details provided in this document or through your legal representative.

How and when we will respond to your request

We will do our best to respond promptly to your requests. In any event, if this is impossible, we will make sure to communicate to you the factual or legal reasons that prevent us from responding immediately, or otherwise complying with, your requests. Where we are not processing your personal information, we will indicate the natural or legal person to whom you should direct your requests, if we are in a position to do so.

If you file a request for access or confirmation of processing of personal information, please be sure to specify whether you want your personal information to be delivered in electronic or printed format.

You will also need to let us know whether you want us to respond to your request immediately, in which case we will respond in a simplified manner, or whether you require a full response.

In the latter case, we will respond within 15 days from the time of your request, providing all information about the origin of your personal information, confirmation of the existence or not of records, any criteria used for processing and the purposes of the processing, keeping our commercial and industrial secrets protected.

If you request rectification, deletion, anonymization or blocking of personal information, we will immediately communicate your request to other parties with whom we have shared your personal information in order to enable these third parties to also comply with your request – except in cases where such communication proves impossible or involves a disproportionate effort on our part.

Transfer of personal information outside of Brazil permitted by law

We are permitted to transfer your personal information outside of Brazilian territory in the following cases:

when the transfer is necessary for the purposes of international legal cooperation between public intelligence, investigation and public prosecution bodies, in accordance with the legal means provided for in international law;
when the transfer is necessary to protect your life or physical safety or that of third parties;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment made in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal assignment of a public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the execution of a contract or preliminary procedures related to a contract or the regular exercise of rights in judicial, administrative or arbitration proceedings.

Additional information on Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner, in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to disclose Personal Data upon request of government authorities.

Additional information about the User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

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

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this 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 this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. We strongly recommend checking this page regularly, referring to the date of the last modification stated at the bottom.

If the changes affect processing activities carried out on the basis of the User’s consent, the Owner will collect new consent from the User, where required.

Owner and Data Controller

CuttNews (FluDroid-OU), Harju maakond, Tallinn, Lasnamäe linnaosa, Sepapaja tn 6, 15551

Owner Contact Email: [email protected]