The term "processing" shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Please note that WE DO NOT MONITOR AND/OR RETAIN YOUR MESSAGES AND/OR OTHER CONTENT THAT YOU SEND THROUGH OUR KEYBOARD. All messages and other content are erased and deleted from our servers immediately after they are sent to the recipient. Your messages are stored on your own device and we are not able to access them. We also encourage you to review the privacy policies and settings of the third-party chat providers and other text communication providers within which you use our keyboard.
Information you directly and voluntarily provide to us
Information about a year of your birth: When you open our App after it has been downloaded to your device, you will be required to provide us with the year of your birth, as described below. This is required in order to filter which functionalities and contents can be available/enabled to you in our App, as some of the features will be unavailable to users of whom the chosen year of birth indicates they are less than 16 years old (Please see also “Children” Section below).
Your email address: In our App we offer various raffles, sweepstakes and other promotional competitions. In order to participate and enter to such competitions, you will be required to register. In this registration process you will be asked to provide us with your valid email address. This personal information is required for user verification, to collect evidence of earned tickets ("credit points" in raffles) and to contact you in case you win the raffle, sweepstake or other promotional competition. After providing us with your email address, an email that contains a link to confirm your email address will be sent to you. By confirming your email address the registration is concluded and you become eligible to enter the raffles and other promotional competitions.
Alternatively, you can use your Google account, Facebook account or other third-party social media account to register for raffles, sweepstakes and other promotional competitions. If you decide to use such an account to register, we will only require the collection of email address associated with your account.
You can find more information about how to participate in raffles in our Help Center in "Raffles" Section.
We may also use your email address in order to send you administrative or account-related information, inform you about relevant security issues or updates and also newsletters of promotional nature, as more concisely described in “How we use your information we collect” Section below.
Further on when registering to enter the raffles, sweepstakes and other promotional competitions, you may be asked to provide us with information about your country of residence. We will gather this information with information about where you use our App - not the exact geolocation but only a country and region (Please see “Information automatically collected from you through the services” Section) and a year of your birth. As the participants earn tickets also by watching ads, as more precisely described in Raffles Terms and Conditions, this information is processed in order to serve you ads and other content that are compliant with the applicable laws in your country in which the ads and such content (e.g. lotteries, betting and other content) are served. Such ads and content will be served and only target users in the jurisdictions in which advertising of such restricted content is permitted. Please note that due to our compliance with applicable laws and regulations, we can only serve you permitted ads if you provide us with this information.
In raffles you can also earn tickets by inviting friends & family to use our App, by sending them a unique link to install the App. PLEASE NOTE THAT WE DO NOT TRACK WHO YOU SHARE THE LINK (INVITATION TO USE OUR APP) WITH. We only get the information that the App has been installed following the link you had sent.
Your gender, age, location, interests and preferences: When using our App, you may voluntarily fill out some of the questionnaires in order to provide us with relevant feedback and to increase our knowledge about you as our user that we may use in order to provide you with interest-based content, including but not limited to advertisements. By answering to those questions you can also earn tickets for raffles. Information collected through this feedback will be used for interest-based advertising, explicitly on the basis of your consent. In these questionnaires we may ask you about your hobbies and interests and also for information about your gender, age and location (only a country and city you are from). Such information shall be pseudonymized and aggregated.
Your contact information: If you are a visitor to our Website or a user of our App, we may receive classical personal information from you when you voluntarily contact us directly. We will use such information only to respond to your inquiry. When your inquiry is sorted out, we will immediately erase all the information that you provided us with regarding the inquiry in question.
We ask that you not send us, and you not disclose any sensitive personal information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) on or through the App, Website or other services. In case you send us or disclose any of the mentioned sensitive personal information, such information will be immediately and permanently erased from our servers.
Information automatically collected from you through the services
Most of the information that we collect about you comes directly from you through automatic means when you use our Service and may be your personal data. In general, we collect technical information that may uniquely identify your device through its identifiers (so called device identifiers or persistent identifiers such as IP address, IDFA, IDFV, Android Ad ID). Those identifiers identify the device you use and not you as a user personally, but are considered as personal information according to some data protection legislations e.g. EEA (European Economic Area) data protection legislation.
The information we collect about you relates to the type of device you are using, various characteristics that help us identify your device, and how you use our Service on your mobile device.
Technical information: If you access our Services through a mobile device, we shall collect technical information about your mobile device that is required for your use of our Service. Such technical information enables us to maintain and analyze the functioning of our Service, to adjust the content of the Service and also to display advertisements. Information about your mobile device that we automatically collect include the following:
Device type, device ID, operating system (OS) type, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, device capabilities etc.;
Information about your usage of the App (events such as application started, view opened, landing page icon clicked, selected features, screen entered/exited, chosen club > club-themed keyboard, change of the club, raffles instructional video watched, consents given, steps skipped, registration done, emojis/GIFs/stickers searched etc. and application settings switches such as prediction activated/deactivated, swipe and type sounds activated/deactivated etc.);
Information you share on third-party websites or through social media services: The App may include connections and links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information and share the content you created within the App. Please note that while using such third-party websites and social media services, you are using sites, products and services developed and administered by people or companies not affiliated with or controlled by us and your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We do not collect, process, store and/or share those information, but we encourage you to review the privacy policies, personal data collecting, processing and sharing practices and settings of those third-party websites and social media services to make sure you understand which your personal information may be collected and processed by those third-party websites and social media services.
You are always able to limit the amount of information collected from your device by adjusting your device.
To provide our services to you and to improve our services: We require certain information from you in order to provide you with the services you requested. We use your information for constantly developing, delivering and improving our Service and contents, tailoring our products and services, providing updates, technical trouble shooting, understanding and analyzing trends in connection with usage of the Service, and administering the Service, all to make sure we provide you with the best experience.
For delivering newsletters: Furthermore we use some of your personal information such as your email address to send you newsletters that contain non-promotional content such as App related information, informations about all new raffles, sweepstakes and other promotional competitions, administrative and account-related information to keep you updated about our Service, inform you of relevant security issues or updates, etc. and also promotional content (we send up to four promotional emails per month). We will use your email address with the purpose of sending you newsletters only on the basis of your explicit consent. You can always choose to opt-out of our newsletters directly through the App settings - "Newsletter subscriptions" or by clicking the “Unsubscribe” link included in the footer of every email we send.
For participating in raffles, sweepstakes and other promotional competitions and for prize-winning activities: If you participate in a raffle, sweepstake or other promotional competition, you will first need to register. In order to register, we will ask you to provide us with your email address and your country of residence. We need your email in order to verify your entry, to collect evidence of tickets you have earned and to contact you in case you become a winning participant. Information about your country of residence is required in order to serve you appropriate and compliant ads (Please see more in “Information you directly and voluntarily provide to us“ Section above).
In case you become a prize-winning participant, we will first proceed to make an authentication of you based on the personal data you have provided to us during your registration and then we may further ask you to provide us with your name, surname, home address, country of residence and your national tax number (if required by law) in order to send you the prize and to fulfil our tax obligations. We may need to share these data with tax authorities. Providing us with your mentioned personal data is strictly voluntary and will only be processed for the sole purpose of prize-related activities (which includes the tax obligations). We may retain your personal information we need for prize-winning activities (name, surname, home address and national tax number) for one year or longer if required by tax authorities and will not use it for purposes other than those set out in this paragraph. After one year we will permanently delete this personal information from our servers. Should you decide not to provide us with such information, we will not be able to send you the prize.
The winner may be published within the App and/or on our Website with his or her nickname/username/email address, city and country of residence. Also, a number of tickets the winner has earned to win may be published. This information may be used only on a basis of your explicit consent. Should you not wish to provide us with you consent, the winner will only be announced with information about the city and a country the winner is from and his/her number of tickets.
For push notifications: We use push notifications to remind you about your activities within the App, new updates, send you news and sport (match) data and to provide you with other promotional and non-promotional content. You will be asked to accept (by giving your explicit consent) or refuse push notifications. If you do not accept push notifications, you will not receive them, but you can later change your mind and consent to receive push notifications by tapping the "Take me there" button on the "What you are missing" screen. You can also always unsubscribe from push notifications by unchecking the “Notifications” option within the App settings or by using the settings on your mobile phone.
When you decide to unsubscribe from push notifications, such push notification tokens are deleted from our database.
For tracking and fraud prevention: We use your information for tracking the performance of our ad-campaigns and for identifying and preventing fraud for our advertising campaigns. Also, we use your information for the purposes of tracking performance, ad visibility and privacy compliance of third-party advertising campaigns in our App and other services.
For analytics and research: We use your information for understanding and analyzing trends in relation to the usage of the App, gathering demographic information about our user base, data about where the App was downloaded from, etc. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our App and services, or to test our new game features and content.
For security measures, authentication/verification and registration: We use your information to enhance the safety and security of our App, products and services - combat spam, malware, malicious activities or security risks. We require and use some of your personal information also to provide you with the confirmation of your registration for raffles, sweepstakes and other, and to monitor and verify your identity so that unauthorised users do not access your account with us.
For customer support: We use your personal information when you contact us to help you with any questions, concerns, disputes issues, inquiries or to provide us with your feedback. Without your personal information, we cannot respond to you to ensure your continued use of the Service.
To fulfil legal obligations and requirements: We use your information when we are required to do so by law. We process your personal information to fulfil our business obligations and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes.
In-App purchases: Our App also enables in-app purchases. For the purposes of in-app purchases we may require your email address and/or password. This information is required to keep you in our records of users who have made in-app purchase(s), so that purchased items will be available to you even in case of a change of your mobile device or in other cases that could potentially result in losing the purchased items.
Please note that we do not process payments for in-App purchases nor have access to your credit card data. In-App purchases are made through third-parties (Google Play Store and Apple App Store) that are behind billing, processing and charging for the in-App purchases and are therefore governed by their terms and conditions and privacy policies. We encourage you to review applicable terms and policies of the app store from which you originally downloaded the App, prior to make any in-app purchases.
Providing you with our services may in certain cases also require and take place through contracted partners that ensure smooth functioning of our services:
If you choose to use our Service or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Please note that not all of the countries have the same data protection laws as your own country, but we will always take appropriate steps to protect the privacy of your personal information. Where we transfer your personal data outside the European Union (EU) / European Economic Area (EEA) to which GDPR (General Data Protection Regulation) applies, we will ensure that your personal data will be protected in a manner consistent with the legal requirements, applicable to the personal data, such as:
In other circumstances, the law may permit us to otherwise transfer your personal data outside the European Economic Area. In all cases, however, any transfer of your personal data will be compliant with the applicable data protection legislation.
PLEASE NOTE THAT WE DO NOT AND WILL NOT SELL PERSONAL INFORMATION OF OUR USERS TO THIRD PARTIES. We have also not sold any personal information to third parties in the preceding twelve (12) months.
In our App, we also allow advertising. We collect the abovementioned information from you and based on such information we build filtered audiences. Such audiences may be used in order to target and optimize advertising and promotions in our App, and based on such profiles we are able to show you a tailored selection of ads that better match your interests (interest-based ads), but only if you give us your explicit consent to do so.
We also engage third-party ad providers and share some personal information with them. For the purpose of interest-based advertising we only use and share information you provide us voluntarily through different questionnaires, information about your age (based on a chosen birth year), your country of residence and information that is collected from you automatically through your device (including the persistent identifiers) with our advertising partners, based on your explicit consent. We will ask you for your consent before sharing any of the abovementioned personal information.
We show interest-based ads and we allow our advertising partners to show such ads to you if you are not less than 16 years old and you have provided us with an explicit consent for your personal information to be collected and processed for the purposes of interest-based advertising.
You have an option to withdraw your consent to show you interest-based ads at any time. You can choose to withdraw your consent via the App by going to the App settings and clicking the "Interest-based ads" button where you can turn off interest-based ads or choose to which advertising partner you allow to share your personal information for the purposes of interest-based advertising. In the latter case we will only share your personal information with those advertising partners you have not opted-out, if any.
You can also opt-out from receiving interest-based ads or targeted ads via your mobile device settings. In such case we advise you to contact your device provider or simply turn on:
Please note that when you choose to do the opt-out, you will not stop receiving ads. The number of advertisements we show to you may remain the same, however they won’t be interest-based, which means based on the topics you like, your interests, behavior, demographic etc. Please also note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
The App is aimed at general audiences. Although there is nothing inappropriate in our App and/or in our other contents we display, we pay a special attention to children’s privacy. We require from our users to provide us with information about their year of birth. If a chosen year of birth indicates the user is less than 16 years old, some restrictions will apply to him/her. Although some jurisdictions allow providers to collect and process personal data from younger users, our age gate is at 16 years of age.
We do not store the chosen year of birth of users who have identified themselves as below the age of 16 in our App, but only the information that their device ID did not pass the age gate.
The features enabling potential collection and processing of personally identifiable information, with the exception of technical information automatically collected from the users through their use of our services are disabled for users who have identified themselves as below the age of 16. When collecting and processing the mentioned technical information (described in “Information automatically collected from you through the services” Section) we will not contact users under the age of 16 (no push notifications, no newsletters, no other e-mails, etc.), display interest-based advertising to them, nor do any user tracking. The underage users will not be able to participate in raffles, prize draws, sweepstakes or other promotional activities. The only personal information we collect from users who have identified themselves as below the age of 16 for the purposes of offering our services are device identifiers or persistent identifiers such as IP address, IDFA, IDFV, Android Ad ID.
Please note that ads may be displayed also to users of less than 16 years of age, but these ads will not be interest-based and will be served only from ad networks which are in compliance with The Children’s Online Privacy Protection Act (COPPA) and with Google Play’s ad network requirements.
If we discover that we collected personal information from a child under 16 years of age, other than the technical information automatically collected from the users through their use of our services, we will take reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com.
Even so, no security measure is perfect and we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.
We may store non-personal information (device information, information about application usage etc.) for an unlimited period of time. Some non-personal information is combined with personal information, but only until the personal data is not deleted. When your personal data is deleted, non-personal information related to your usage of application is anonymized.
Right of access: You may have the right to confirm that we are processing and gain access to your personal data. Should you have any questions regarding the processing, or would you like to have more insight in the personal data about you that we process, you are always welcome to contact us, and we will provide you with further information. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may limit your access if such access would adversely affect the right and freedoms of other individuals. We will try to respond to any request for a right of access without undue delay and free of charge, except where we are permitted by law to charge a fee.
Right to object: You have the right to object to the processing of your personal information. If you choose to object to our processing activities, you might not be able to use all of our services. However, we reserve the right to continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law. You are always free to opt-out from the future collection of your personal information by us and our partners by uninstalling all the App from each of your computing devices.
Right to rectification: We try to keep the information that we hold about you accurate and up to date. In case you realize that any of the information that we hold about you is incorrect, please contact us and we will correct it without undue delay. You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Please note that we may limit your access if such access would adversely affect the rights and freedoms of other individuals.
Right to withdraw consent: Where our processing of your personal data is based on your consent, you have the right to withdraw such consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right to erasure (right to be forgotten): You may have the right to request from us to permanently delete your personal data. You can make such a request if you, for example, believe that the personal data is no longer necessary in relation to the purpose for which your personal data was collected or otherwise processed. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in a pseudonymized form.
Right to restrict the processing activities: You have the right to request a restriction of the processing of your personal information, but please note that if you choose to restrict our processing activities as it relates to providing the Service, you might not be able to use them.
Right to data portability: You have the right to request that we provide you with the personal information which you have provided to us in a structured, commonly used and machine-readable format, so you can transfer this information to another data controller.
Right to lodge a complaint: If you are unsatisfied with the way we treat your personal data and you believe we have infringed or violated your privacy rights, please contact us so that we can work to resolve your concerns. You also have a right to lodge a complaint and to do so, contact the supervisory authority in your country of residence. In accordance with the GDPR's jurisdictional provisions, individuals whose personal data is being processed may lodge a complaint with the supervisory authority competent in the individual Member State of the individual. The contact details of the supervisory authorities in each Member State can be found at the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
The legal bases on which we rely on to process your personal information include:
Your consent (article 6(a) GDPR): We ask for your consent to use your data for a particular purpose, especially but not only for interest-based advertising, sending newsletters and push notifications. Where we ask for your consent, we will make this clear at the point of collection of your personal data.
Necessity for the purposes of the legitimate interests (article 6(f) GDPR): This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue legitimate interests in order to ensure you have the best experience when using our Service, to make sure your information is secure and to provide our Service free of charge or at a low cost. We pay special attention to your data protection rights, making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications and advertising purposes.
Necessity of compliance with a legal obligation (article 6(c) GDPR): This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.
Data Protection Officer - firstname.lastname@example.org
or our local Data Protection Authority by writing to:
Dunajska cesta 22
or by calling to
+386 1 230 97 30