We at "ColorPicker"(“we”, “us”, or “our”) have created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business. This Privacy Policy describes the practices concerning the information collected by "ColorPicker", through the use of our websites and mobile applications on which this Privacy Policy is posted. This Privacy Policy applies to our mobile applications and other online services we may provide on which this Privacy Policy is posted, and our collection of information from our corresponding social media features and pages (each a “Service” and collectively, the “Services”). In addition to describing how we collect, use, disclose and otherwise process personal information, this Privacy Policy explains the rights and choices available to individuals with respect to their personal information. We may provide additional privacy notices to you at the time we collect your data. This type of an “in-time” notice will govern how we may process the information you provide at that time. 1. Information We Collect We may obtain information about you in a variety of ways, including through your use of our Services, when you email or otherwise communicate with us (including through social media), or when you participate in events or other promotions. The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the “GDPR”). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction. Categories of personal information we collect: Category Specific Examples A. Identifiers A real name, alias, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers B. Personal Records Name, Email address and username. Some personal information included in this category may overlap with other categories. C. Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. D. Internet or other similar network activity Information on a consumer’s interaction with a website, application, or advertisement. See Information collected by Automated Means below for further details. E. Geolocation data Physical location or movements (inferred from your IP Address). F. Sensory data Audio Recordings (for translation purposes), Images (Avatars added to your account or images taken for translation purposes). 2. Sources of Information and Purposes of Use Some of this information you provide to us and some we collect when you use our Services. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others. You may choose not to provide some or all of your personal information to us but doing so may prevent us from providing our Services to you or limit our ability to provide you with the level of service that you would otherwise expect from us. Automated Information includes information such as: IP address Operating system used (for example: iOS) Device Information Time zone Identifiers associated with cookies or other technologies that may uniquely identify your device or browser Cookies on / off (See our Cookie Policy) Dates and times of access IDFA Subscription information We or our third-party service provider may assign you a unique identifier through automated means in order to match information collected from you through different means or at different times, (including both personal information and Automated Information) and to use such information as described in this Privacy Policy. This Automated Information is generally used for the following purposes: for the technical provision of our Services in order to be able to provide you with a functioning user-friendly experience. to provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks. to uncover insights about your use of our website and mobile applications in order to improve our Services and features, including developing new products and features. to facilitate your access to our website or mobile application. to customize our Services for you. to help us better understand our current and potential customers so that we may market our Services accordingly. events and usage data is captured for our internal business analytics in order to understand how our users interact with our mobile applications and use our services. For example, we may capture when a user visits a screen, taps a button, permits notifications, upgrades, or otherwise interacts with the app. Monitoring and analyzing the effectiveness of our communications (including by identifying when emails sent to you have been received and read). 3. How We May Use Your Personal Information In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following: Performing Our Services Maintaining or servicing accounts, providing customer service, operating our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments. Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions. Internal Research Understanding and evaluating how our Services and features perform with our users. Uncovering insights about usage in order to improve the Services and provide customers with enhanced features as well as inform our development of new features and products. Development of customized or personalized experiences of our Services, such as remembering your information, so you do not have to re-enter it each time you use one of our Services. Auditing Interactions with Consumers Measuring usage of our websites and mobile applications. Measuring our marketing activity (e.g., measuring how a user was acquired). Security To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks. Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide. Debugging/Repair Identification and repair of impairments to intended, existing functionality of our Services. Marketing Understanding our customer in order to more effectively market our Services. Quality and Safety Maintenance and Verification Activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services Verification or maintenance of the quality or safety of Services Tracking and responding to quality and safety matters. Protecting our rights and property. Complying with legal or regulatory requirements, judicial process, industry standards and our company policies, please see our Terms of Service. Other purposes that may be described at the time you choose to provide personal information to us. To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction. 4. How We May Share Information about You with Others We may share information about you for the purposes described in this Privacy Policy or pursuant to a specific “in-time” privacy notice we may provide at the time we collect the information. Corporate Affiliates to assist us in technical processing operations, such as data hosting and maintenance, finance, legal and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings; and for corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. Third Party Service Providers We may share information about you with the following categories of third-party providers for a variety of business purposes: Customer Communications and Insights Platforms. We may share email, app usage and interactions with our third-party customer communications platform provider for the following business purposes: performing services that allow us to communicate with you and administer your account as well as track your usage for our internal analytics. Internal Business Insights Platforms. Our third-party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features. We may share or make available unique user identifiers, IDFA, device id, IP address and app usage and events (such as when you subscribed to our services) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and (ii) better understand our customers in order to market our products more effectively. Measurement and Attribution. These service providers offer tools that allow us to measure and attribute the source of new subscription sign ups and that allow us to uncover insights about usage and app events. We may use unique user identifiers made available to us from these third party providers to help us measure the effectiveness of our ads (e.g., where and how a user is acquired) and to uncover information about how our customers are using our apps in order to improve their quality and safety. Other technology providers necessary to provide our services (including cloud storage and web hosting providers). We may make certain Automated Information and/or aggregate or non-personally identifiable information available for various purposes including monitoring network traffic to detect malicious actors and to protect against malware, fraud or other unlawful uses or activity. Marketing providers. We, or the third-party service providers we use to assist us with marketing our own products to you, may use the information we collect from you to provide advertisements and offers for our other products. We may share information about you in connection with (including during the evaluation or negotiation of) a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind-down of a business (each a “Corporate Transaction”). Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we engage in any Corporate Transaction (including, selling or transferring all or a portion of our business or assets). If we engage in such a sale or transfer, we will where feasible - direct the recipient to use the information in a manner that is consistent with this Privacy Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information. Legal, Regulatory, Compliance and Similar Reasons In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities. We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us. In addition, we may collect, use and disclose your personal information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy. 5. Do Not Track Disclosures Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our sites do not currently process or respond to "do-not-track" (DNT) settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals. Certain third parties, such as ad networks, web analytics companies and social media and networking platforms, collect information about your online activities over time and across websites. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. Information about how to opt out from your data being used by third parties can be found above under " Information collected by automated means." 6. Data Retention Except as provided below, we may retain your personal information for the longer of three (3) years after we become aware that you have ceased using our Services or for so long as necessary to fulfill any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using our services, so we encourage you to contact us at the appropriate support email in the How to Contact Us section of this Privacy Policy if you are no longer using the services. We may retain other information that is not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so. 7. How We Protect Personal Information We use various efforts intended to safeguard the security and integrity of personal information collected through our Services. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk. If you correspond with us by e-mail or using Web forms available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account. If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information. 8. Links to Websites and Third-Party Content For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that it does not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information. 9. Information Relating to Children We do not knowingly collect information from children under the age of 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 16 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 16 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account. 10. Updates to Our Privacy Policy We reserve the right to change this Privacy Policy at any time. When we update this Privacy Policy, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Policy. In some cases (for example, if we make certain material changes) and when required by applicable law, we may inform you by additional means, such as by sending you an email. In some cases, when required by applicable law, we may obtain your consent to the changes. 11. How to Contact Us You may contact us with questions, comments, or concerns about our services and this Privacy Policy or our privacy practices Our support team can be contacted [email protected].
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