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Thanks for using our Wildlife Wonder App !

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Who we are
We are DFFRNT Media B.V. (“DFFRNT”). Our office is located at Fred. Roeskestraat 115, 1076 EE, Amsterdam, the Netherlands.

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We have developed the Wildlife Wonders App (hereafter: the “App”). And we are the data controller of the (personal) data that is processed through the App.

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Please visit our website for more information about us.

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For privacy related questions you may contact us as follows:
T: + (0) 20 280 2400
E: privacy@dffrntmedia.com

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Our data philosophy
At DFFRNT our business is to develop and commercially exploit app’s. App’s that are fun and safe to use. We are in the app business. We are explicitly not in the data business. We do not want your data. We do not exploit your data. Therefore, we collect as little as data as technically possible to achieve our main goal; to build app’s that are fun and safe to use.

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This means we collect and process data only insofar that is necessary to monitor the use that is made of the App. We want to know whether you like it or not. Or what parts of the App you find more interesting than other parts. Nothing more, nothing less. We can achieve this goal by collecting mainly so called ‘meta data’. That is data that cannot identify you. Nevertheless, due to the technological nature of app uses a certain minimum amount identifiable data must be processed. At DFFRNT our philosophy is to keep that to the absolute minimum. And if even that usage is too much you may simply opt out.

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Find out how we have implemented our philosophy and learn more about your privacy rights in the remainder of this Privacy Statement.

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Your rights
Our data processing activities are primarily governed by the European General Data Privacy Directive (“GDPR”). This GDPR confers basic privacy rights. You may:

  1. request access to the personal data we process about you;

  2. request that we correct inaccurate or incomplete personal data about you;

  3. request deletion of personal data about you;

  4. request restrictions, temporarily or permanently, on our processing of some or all personal data about you;

  5. request transfer of personal data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and

  6. opt-out or object to our use of personal data about you where either:

    i. our use is based on your consent or our legitimate interests, or

    ii. you do not want us to share with third parties data related to cookies and similar technologies for website functionality or advertising purposes;

  7. not to be subject to automated individual decision-making, including profiling.

 

These rights are not unrestricted. And not all rights are applicable regarding the processing of personal data through the App, simply because we do not perform processing activities that are subject to your rights. Here you find more information about your rights.
You may have additional rights under your local privacy laws.

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What (personal) information do we process and why do we do that?

We want to monitor the use of the App. To that end we use Google Analytics for Firebase. Below we explain how this works.

We want to monitor the use of the App in order to assess whether you like (all or specific parts) of the App. We gather typical meta data about:

  • the number of App downloads;

  • the number of active users;

  • the average length the App is played for;

  • how many time a section of the App is opened, and for how long.

Our ultimate goal is to improve (the user experience of) the App. Therefore, we collect meta data on typical user properties. Below you find the complete list.

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User property              Description
Age                               Identifies users by six categories: 18-24, 25-34, 35-44, 45-54, 55-64, and 65+.
App Store                    The store from which the app was downloaded and installed.
App Version                The versionName (Android) or the Bundle version (iOS).
Country                       The country the user resides in.
Device Brand             The brand name of the mobile device (e.g., Motorola, LG, or Samsung).
Device Category        The category of the mobile device (e.g., mobile or tablet).
Device Model             The mobile device model name (e.g., iPhone 5s or SM-J500M).
First Open Time         The time (in milliseconds, UTC) at which the user first opened the app, rounded up to the next hour.
Gender                        Identifies users as either male or female.
Interests                      Lists the interests of the user (e.g., "Arts & Entertainment, Games, Sports").
Language.                   The language setting of the device OS (e.g., en-us or pt-br).
New/Established       New: First opened the app within the last 7 days.
                                     Established: First opened the app more than 7 days ago.
OS Version                  The version of the device OS (e.g., 9.3.2 or 5.1.1)

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All before mentioned data is typically meta data. So what actual personal data do we use? We only process the following personal data:

 

Click on the data type to acquire more information about what the data actually is and what is does.

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Google Analytics uses this data to provide analytics and attribution information. The precise information collected can vary by the device and environment. Here you find more information on data collection by Google Analytics for Firebase.

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So in essence we only use your personal data in order to be able to acquire reliable meta data on App usage in order to improve (the user experience of) the App.

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How do we acquire your personal data ?

You (,or better: your mobile device and associated Android or Google user account) provide the personal data to Google Analytics and therefore to us. You are never obliged to provide your personal data. But if you disable data sharing options the App may not work as intended.

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On what legal grounds do we process your personal data?
We may lawfully process your legal data if at least one of the following applies:

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  1. you have given us consent to process your personal data for the above mentioned purposes; or the processing of personal data is necessary for:

  2. the performance of a contract with you;

  3. compliance with a legal obligation;

  4. in order to protect your (or someone else’s) vital interests;

  5. the performance of a task carried out in the public interest; or

  6. for the purposes of the legitimate interests pursued by us (or 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, in particular where the data subject is a child.

 

We do believe that we may process your personal data on the ground that it is necessary to pursue our legitimate interests, that is ultimately to improve the user experience of the App. And we consider that our legitimate interests are not overridden by your privacy interests due to the hardly privacy infringing nature of the personal data we collect in connection to the purpose we use it for.

 

Nevertheless, we want to offer you the highest level of control about our processing of personal data as possible. Therefore we solely process your personal data on the ground that you have given us your consent to do so. Please note that you can revoke your consent at any time. If you ‘opt out’ by revoking your consent we will stop processing your personal data.

 

How long do we keep your data?
Google Analytics retains certain advertising identifier associated data (e.g., Apple’s Identifier for Advertisers and Identifier for Vendors, Android’s Advertising ID) for 60 days, and retains aggregate reporting without automatic expiration. Retention of user-level data, including conversions, is fixed at up to 14 months. For all other event data, you may set the retention in your Analytics settings to 14 months.

You have acquired the App in a loyalty scheme of your local supermarket. We retain your personal data for 6 month after the duration of that loyalty scheme.

 

How do we secure your data?
Information security is of great importance to us. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure (personal) data collected via our App. Without having to intention to be complete we mention a couple of security measures:

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  • The App is build using Unity. Unity is PCI Compliant, leveraging industry best practices and security tools to maintain a high-level of security;

  • Communication with the host device is all done through the Unity API to ensure compatibility and security;

  • The webAPI is build using the modern .NET Core libraries. The WebAPI is read-only and stateless and contains only public information, meaning a lot of security concerns do not apply;

  • We don’t use an access token/key system since the data is static and publicly available without the need of user identification;

  • Data is transmitted over HTTPS, ensuring secure transport;

  • Data is ‘one way encrypted’ and stored on secure Microsoft Azure servers.

 

International Data Transfers
All (personal) data is processed and stored in the European Economic Area (“EEA”). No (personal) data is transferred outside the EEA.

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How do we share data about you?
First of all we would like to emphasize that we do not share personal data with third parties that use the data for purposes of their own.

We do share personal data with our data processors. They all are bound to Data Processing Agreements. That means we, and ultimately you, stay in absolute control of your personal data. Also this ensures your privacy interests are adequately safeguarded.

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We use your personal data to acquire reliable meta data on App usage. We share statistical reports of this meta data on App usage with our partners. Our partners are companies that are active in the loyalty scheme business. Our partners have licensed the App as part of a loyalty scheme to your local supermarket where you have acquired the Wildlife Wonders App-scheme. Our reports do not contain any of your personal data whatsoever.

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Changes to this Policy
We may make changes to this Privacy Statement from time to time. Changed will either be based on changes to applicable laws and regulations or changes in data processing activities that you need to know of. We will inform you about any changes we make to this Privacy Statement.

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Questions and Complaints
If you have questions, remarks or complaints about how we process your personal data, or if you want to exercise one of your rights please contact us.

If you have any complaints you may also make a contact the UK Information Commissioner’s Office (ICO) at www.ico.org.uk. If you reside outside the UK you may also contact the privacy regulator in your country. Most privacy regulators can be contacted online using the resources provided at https://globalprivacyassembly.org/participation-in-the-assembly/members-online/

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