Privacy Policy of Cluify SDK

  1. Why are our activities safe for your privacy?
    1. We only collect the Google Advertising ID of a smartphone (or other device, on which the application has been installed) and the information regarding its approximate location. We do not collect any other of your data.
    2. The data that we collect does not enable us to identify you.
    3. The data that we collect is not made available to any other entities.
    4. We adhere to the highest data protection safety standards.
  2. Who collects and process the data??
    1. The data is collected and processed by the company Datarino sp. z o.o. with its registered seat in Wrocław (postal code: 53-413), ul. Gwiaździsta 62, entered in the register of entrepreneurs of the National Court Register maintained by the District Court for Wrocław-Fabryczna in Wrocław, under KRS no. 0000466917, tax identification no. (NIP) 8943047054, statistical number (REGON) 022170104, e-mail: dane@datarino.com
    2. Datarino pays particular attention to securing your privacy.
  3. How is the consent given and withdrawn? What about the access to the data?
    1. We collect and process the data based on your consent given during the application installation process. The consent is voluntary and is not a condition of using the application. The lack of the consent will result in a lower level of displayed advertisements personalization.
    2. The consent may be withdrawn at any time, which shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal of the consent shall not affect the possibility of using the application.
    3. The consent may be withdrawn by using this link. On clicking, it will be redirected to the information on the data processing, on the bottom of which you will find a spot where you may give or withdraw the consent.
    4. After the withdrawal of consent, we completely stop collecting the data.
    5. Taking into account that we do not identify you, we will not provide you with a standard access to the data, possibility of rectification or demanding of partial erasure of the data, possibility of the data portability, etc. Exercise of such rights requires a prior unequivocal identification, i.e. linking you with a smartphone Google Advertising ID. It is a complex process, depending on the particular situation. In case of questions, please contact us.
    6. At any time you may reset your Google Advertising ID (Google settings). In such case, it will also be redirected to the information on the data processing, on the bottom of which you will find a spot where you may give or withdraw the consent.
  4. How do we collect the data?
    1. The SDK code collects the Google Advertising ID and searches for wi-fi networks available at a given moment. Based on the availability of wi-fi networks, an approximate location of the smartphone is determined.
    2. The SDK code cannot collect any other data from the smartphone. We collect and process only location data and the Google Advertising ID.
    3. Collection of data is carried out in a fully automatic process. The SDK Code mechanism is safe. In particular, it is not possible that any virus or other unwanted software or malware is transmitted to the smartphone in that way.
    4. We minimize the amount of the data while collecting it, e.g. we do not collect the data from inactive devices (i.e. in case of no connections or relocation of the smartphone).
  5. For what purpose and how do we process the data?
    1. We collect and process the data for the purpose of personalization of advertisements displayed in the broadly understood Internet. It means that some of the advertisements will be linked to the location.
    2. We analyze the data collected only in terms of advertisements personalization.
    3. Other marketing surveys and analyses are carried out based on fully anonymous information (i.e. it is not even related to the Google Advertising ID).
    4. We adhere to high technical security standards, according to the current technical possibilities and existing threats. We monitor the situation in that scope and we react to arising matters on a continuous basis.
    5. Only authorized persons, liable for observing the highest security and confidentiality standards, may have access to the data.
  6. What about sensitive data?
    1. Location data of the smartphone may suggest a health condition (e.g. when being at the hospital), religious beliefs (e.g. when being at the church), political views (e.g. when being at the demonstration) or other sensitive issues.
    2. It is not possible to fully avoid collection of the data containing such suggestions.
    3. We foresee an automatic minimization of part of the data of this kind (collection blocking or automatic erasure). However, a complete erasure of the data containing suggestions of this kind would require detailed analyses, which might result in increasing the risk for your privacy, instead in decreasing it.
    4. We guarantee that your data will never be searched and analyzed for the purpose of obtaining information or suggestions regarding: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well concerning health, sex life or sexual orientation.
  7. What data do we transfer to other entities?
    1. We do not transfer any of your data to our clients. We only make available to our clients statistical reports that do not contain any individual information. In that way we completely eliminate the risk of an identification attempt by other entities.
    2. Entities providing advertisement display services are provided only with orders regarding the display a specific advertisement with a given Google Advertising ID.
  8. When will the data be erased?
    1. Any data regarding the location will be erased not later than within 12 months from the date of its collection.
    2. In specific situations, that period may be prolonged for the purpose of a given marketing campaign. In such case, the data will be erased not later than after the end of the campaign, however not later than within 16 months from the date of its collection.
    3. Instead of erasing the data, the data may be subject to a complete and irreversible anonymization.
  9. Can this Privacy Policy be changed?
    1. This Privacy Policy may be changed, however any changes hereto will be announced in at least 14 days advance.
    2. Any major changes regarding data collection and processing, in particular the change of data processing purpose, will require asking you for a new consent.
  10. Questions and complaints
    1. Any questions and doubts regarding the data processing or this privacy policy should be forwarded to our e-mail address.
    2. You may file a complaint for the collection and processing of the data to the Personal Data Protection Authority.