PRIVACY POLICY

Last Updated: May 10, 2024

This Privacy Policy applies to your use of the Evoread mobile application (“App”). This Privacy Policy explains how we collect, store, use and share your personal data and how you can exercise your privacy rights. This Privacy Policy is an integral part of our Terms of use (“Terms”).

OONA Trading Limited, a legal entity duly incorporated under the laws of Cyprus, with registered office at Kyriakou Matsi 3 & Anexartisias, ROUSSOS LIMASSOL TOWER, 4th floor, 3040, Limassol, Cyprus (“we” or “us”), is a data controller with respect to your data processed in accordance with this Privacy Policy.

We may update our Privacy Policy from time to time. When we do, we will revise the date at the top of the policy. If we make changes that are material, we will use reasonable efforts to notify you (such as via an in-app notice or a push-notification). We encourage you to check this Privacy Policy regularly for updates, so that you know our current practices.

By downloading, accessing and/or using the App, you acknowledge the collection and use of your information in accordance with this Privacy Policy, including our and our partners’ use of your data for the purposes as described below.

PLEASE, READ THE FOLLOWING CAREFULLY AND MAKE SURE YOU FULLY UNDERSTAND THIS PRIVACY POLICY. IF YOU HAVE ANY CONCERNS ABOUT PROVIDING INFORMATION TO US OR IT BEING USED AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE, DISCONTINUE AND AVOID USING THE APP.

  1. 1. DATA COLLECTED

    1. 1.1. We collect the following types of personal data about you:

      1. 1.1.1. Data provided by you
        • Data you voluntarily provide to us at your sole discretion.

      2. We do not require you to provide us with any personal data, in addition to those we get from your Apple or Google Account when you sign-in to the App using these tools (see clause 1.1.3 for more details). However, if you voluntarily choose to provide us with any data when you contact us (via the App, social media, e-mail or any other channels), we will process such data in accordance with this Privacy Policy. For example, if you decide to contact us with a request, we will process the content of your message, the date and time of your message, our response and any other personal data you provide in that context.

      3. 1.1.2. Data collected by us automatically

      4. We will automatically collect the following data of yours:

        • Data about your use of the App (e.g. the date and time you used the App, session length, reading progress, the type of content that you read, liked and saved books, etc.)

        • IP address

        • Device identifiers (such as your device ID, MAC address, IMEI)

        • Advertising identifiers (such as IDFA) (despite we do not serve ads within the App, we need the advertising identifiers to attribute your installation of the App to a particular website, platform or other source, i.e. particular marketing campaign)

        • Non-identifying data about your device, such as device name and operating system, browser type, language and other technical data like screen size or processor, or combination of this data available for a developer for checking the device compatibility with the App.

      5. 1.1.3. Data provided by third parties

      6. We may receive information relating to you and your use of the App from the following third-party providers:

        • Analytics Providers. Our analytics providers may provide us with:

          • Data about your use of the App (such as in-app events, your interaction with the App, software errors, etc.) so that we could improve the App;

          • Data about the performance of our advertising campaigns (e.g. we may be provided with information from which ad network and advertising campaign the install of the App originated from, or data on fraud traffic such as refund abuse in games or click fraud in advertising);

          • Other data mentioned in clause 1.1.2 above.

        • Advertising Partners. From time to time, we may receive non-personal information from our advertising partners concerning the performance of our advertising campaigns (e.g. we may be provided with information about impressions, clicks, installs or other advertising campaign performance indicators).

        • Sign-In Tools. As your account in the App is linked to your Apple Account or Google Account (“Sign-In Tools”), such Sign-In Tools will share with us certain bulk of your personal data. What data they will share will depend on your privacy setting within those Sign-In Tools, but it would typically include your basic profile information such as your name, user ID, email address, language preference and profile picture. If you want to limit the sharing of data with us, you need to regulate this in the privacy settings of the relevant Sign-In Tool. We do not get access to or store your logins or passwords for any of these Sign-In Tools.

        • Online Stores. As all the purchases within the App run via Apple Store or Google Play Store (“Online Stores”), we will get limited data on your purchases from the Online Stores, which would typically include id of operation, time, id, amount and currency of purchase. We will not get your financial data, such as your credit card number or bank account. We encourage you to review privacy policies and terms of service of the platforms for further information before making a purchase in the Online Stores.

    2. 1.2. We do not request or intend to collect any sensitive data (“special categories of information”), such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please, be cautious when sharing this information about yourself (or others) in the App.

  2. 2. PURPOSES AND BASIS FOR PROCESSING

    1. 2.1. We will process your personal data for the following purposes and on the following basis:

      2. Purpose shortly Purpose in detail Legal Basis (Data Needed for)
      2.1.1. Making the App work
      • Enabling you to use the App (facilitating, operating, providing and maintaining the App availability, operability and proper functioning, fixing the bugs)
      • Recognizing you when you return to the App
      • Verifying and confirming payments within the App monetization
      • Sending you the App-related communications (alerts, notifications)
      • Responding to your comments and questions and providing customer support
      • Protecting the security and integrity of the App
      		 Contract performance
      2.1.2. Improving the App and your in-app experience
      • Monitoring and analyzing the use of the App to improve the App operation and functionality, to identify bugs and errors in the App, to understand and analyze the usage trends and preferences of our users, and to otherwise improve and customize (personalize) the App content and your in-app experience
      • Testing the new features of the App
      		 Legitimate interest
      2.1.3. Ensuring compliance with the Terms
      • Detecting, preventing and combating potential or actual breaches of the Terms, which includes monitoring the use of the App, investigating suspicious activity within the App, taking actions against the users violating the Terms
      • Defending ourselves against any third-party claims or allegations
      		 Legitimate interest
      2.1.4. Ensuring compliance with applicable law
      • Complying with legal obligations, including if we receive an order from a court or regulatory authority
      • Detecting, preventing and combating unlawful actions of users
      		 Compliance with legal obligations
      2.1.5. Measuring performance of marketing campaigns
      • Tracking where the users come from
      • Detecting fraudulent traffic
      		 Legitimate interest

    2. 2.2. Although we do not use consent as the legal basis for processing your data, we may ask for your consent in certain cases when we are required to ask for it under the applicable terms of the Online Stores (e.g. to send you push notifications, to track your activity across other companies’ apps and websites, etc.).

    3. 2.3. We do not carry out any decision-making based solely on automated processing, including profiling.

  3. 3. SHARING OF DATA

    1. 3.1. We may share your personal data with:

      1. 3.1.1. Our service providers and partners, who perform the following functions / services:

        • Hosting / cloud storage
        • Analytics services
        • Customer support
        • Technical support
        • Software maintenance

      2. 3.1.2. State authorities and institutions (upon their requests, when otherwise required under applicable law or on our initiative in order to combat the violations of the Terms)

      3. 3.1.3. Other third parties, providing such sharing is needed for the purposes of processing listed above or upon your consent for this.

    2. 3.2. We share your personal data with these third parties only for the purposes listed in section 2 above, where we have a legal basis for this and to the extent such sharing is needed to achieve the purpose. Such third parties will provide the same or equal protection of your data as stated in this Privacy Policy and required by applicable laws and stores guidelines.

    3. 3.3. Information about you may be also disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction.

  4. 4. INTERNATIONAL DATA TRANSFERS

    1. 4.1. Our services are global by nature and your data can therefore be transferred out of the EU and your home jurisdiction and, as a result, be processed in countries other than your home jurisdiction, which sometimes may offer lower level of protection compared to the one provided in your home jurisdiction. We will always take steps to ensure adequate safeguards are in place to protect your data within such transfers. Adequate safeguards that we and our partners may use include transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection, or entering into standard contractual clauses approved by the EU Commission with the respective recipients.

  5. 5. YOUR RIGHTS

    1. 5.1. You will generally have the following rights with regard to our processing of your personal data (the full set of rights you have will always depend on your home jurisdiction and the particular circumstances of processing; some of the rights have their particular execution conditions, i.e. can be exercised providing certain conditions are met):

      1. 5.1.1. to access the personal data we hold about you and certain information about processing of such data (e.g. categories of data collected, purposes of processing, data recipients, retention period, the sources of collected data, etc.);

      2. 5.1.2. to request us to rectify your personal data (if they are inaccurate or incomplete);

      3. 5.1.3. to request the erasure of your personal data (where we do not have a legal basis to continue to process such personal data or in other particular circumstances);

      4. 5.1.4. to receive the personal data you have provided us with, in a structured, commonly used and machine-readable format, as well as to request us to transfer your personal data to another controller, where this is technically feasible (in certain circumstances and under certain conditions);

      5. 5.1.5. to withdraw your consent (where you have previously given your consent to the processing of your personal data). Note that withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent.

      6. 5.1.6. not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects or could significantly affect you;

      7. 5.1.7. to object to or restrict how we process your data (in certain circumstances). Please note in case of such a request we may not be always able to provide you with all the App functionalities and / or the App performance may suffer;

      8. 5.1.8. to lodge a complaint with a data protection supervisory authority (if you think that any of your rights have been violated by us).

    2. 5.2. If you wish to exercise any of the above rights, please contact us using the contact details in section 8 below. Please, note that your request for exercising any of your rights must:

      1. 5.2.1. provide sufficient information necessary to verify you as our user about whom we collected and processed personal data or to verify you as an authorized representative of such a user;

      2. 5.2.2. contain sufficient details describing your request to allow us to properly understand, review and respond to it.

    3. 5.3. We reserve the right not to respond to your request or provide you with personal data, in case we are unable to verify your identity or authority to make such a request.

    4. 5.4. Permissible number of requests, whether they are free of charge or not, and other conditions of requests shall fully depend on your home jurisdiction requirements.

  6. 6. AGE RESTRICTIONS

    1. 6.1. The App is not directed at anyone under the age of 17 and we do not knowingly collect personal data from anyone under the age of 17 or knowingly allow such persons to use the App.

    2. 6.2. If we learn that personal data has been collected via the App from persons under 17 years of age, then we will take the appropriate steps to delete this personal data.

    3. 6.3. If you are a parent or guardian and discover that your child under 17 years of age has obtained an account on the App or that we may have collected information from that child through the App, then you may alert us at legal@oona-trading.com and we will delete that child’s personal data from our systems as soon as possible.

  7. 7. SECURITY SAFEGUARDS

    1. 7.1. We are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. In addition, we limit access to personal data by our personnel and partners on a need-to-know basis only. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Please feel free to contact us at legal@oona-trading.com for additional information about these measures.

    2. 7.2. Although we use commercially reasonable efforts to assure that your data remain secure when maintained by us, please, be aware that no security measures are perfect or impenetrable. Unfortunately, the transmission of data via the internet is not completely secure and we cannot guarantee the security of your data transmitted via the App; any transmission is at your own risk. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

  8. 8. DATA RETENTION

    1. 8.1. We store the collected personal data of yours for as long as necessary to fulfil the purposes we collected it for, including for complying with our legal obligations. We may retain your personal data for a longer period in the event of any existing, upcoming or possible complaint, dispute or litigation.

    2. 8.2. To determine appropriate retention period with respect to your personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as applicable legal requirements.

    3. 8.3. In some circumstances we can anonymise your personal data (so that it can no longer be associated with you, even if combined with other data) for analytical or statistical purposes, in which case we may use this data indefinitely (i.e. also after deletion of your Account) without further notice to you.

  9. 9. CONTACT US

    1. 9.1. If you have questions about this Privacy Policy, or if you have any requests for exercising any of your privacy rights, you can contact us through the in-app support feature or via e-mail at legal@oona-trading.com. However, please note that we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond.