In order to use the service, we will ask you to enter your name and email. We will also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the service and to measure ads.
If you decide to make a purchase or to order a service on our website, we will ask you to provide your email. We will use this data to fulfill your order.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; (b) delete the App from your device or leave the Website and not access or use it; and (c) cancel any active subscriptions or trials.
HW Fantasy Limited, a legal entity under the laws of the Republic of Cyprus, having its registered office at 46 Lykavitou, Egkomi, 2401, Nicosia, Cyprus, and its affiliates (as may be applicable) will be the controller of your personal data.
We collect data you give us voluntarily (for example, email address). We also may receive data about you from third parties (for example, when you sign in via Facebook or Google). We also collect data automatically (for example, your IP address).
We process your personal data:
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, for example, for creating an account for you.
We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Service. As a result, you will, for example, receive a push notification that a new feature has been deployed in the Service. To opt out of receiving push notifications, you need to change the settings on your device. To opt-out of receiving emails, you should click unsubscribe link in the footer of each email.
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that users choose certain types of stories less frequently, we may focus on improving the category or decide to remove it.
We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Service. We may show you advertisements on our Service, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website or installed the App, you might see ads of our products in your Facebook’s feed.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
We process your personal data under the following legal bases:
Under this legal basis we will send you marketing communications. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails.
Under this legal basis we:
We rely on legitimate interests:
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Service easier and more enjoyable, or to introduce and test new features).
The legitimate interest we rely on for this processing is our interest to promote our Services in a measured and appropriate way.
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
To be in control of your personal data, you have the following rights:
If you are based in the EEA, you have the following rights in addition to the above:
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
This Notice is designed to supplement our Privacy Policy to ensure compliance with state-specific laws and applies to the collection, use, and sharing of your Personal Information through our websites, mobile applications, and other online or offline services (collectively, the “Services”).
For California residents, this also serves as our California Notice at Collection.
The definition of “Personal Information” may vary by state law. Generally, it refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
The table below outlines the categories of Personal Information we collect, along with purposes of such collection. For more details, refer to other sections of our Privacy Policy.
| Category | Examples of Personal Information in this Category | Purpose of collection |
|---|---|---|
| Identifiers | Email address Telephone number | To provide and maintain our Services, including account creation, authentication, and access management. To serve and measure ads To communicate with users, including customer support, service updates, and promotional offers. |
| Sensitive Information | When we process sensitive personal information (as defined by State Privacy Laws), such as account login credentials or credentials allowing access to an account, we do so only for legally permitted purposes and do not use such data to infer characteristics about you. | To provide and maintain our Services, including account creation, authentication, and access management. To secure your account. |
| Commercial Information | Purchase history Any information you may share during conversations with our support agents, including your feedback, complaints, etc. | To provide and maintain our Services, including account creation, authentication, and access management. To improve user experience through personalized content, recommendations, and service customization. To serve and measure ads. To process payments, subscriptions, and transactions. To conduct analytics and research for product development and service enhancements. |
| Geolocation | Internet protocol (IP) address, country, and/or region. | To provide and maintain our Services, including account creation, authentication, and access management. To improve user experience through personalized content, recommendations, and service customization. |
| Internet or other electronic network activity information | Information regarding a consumer's interaction with an internet website, application or advertisement (Usage Data). | To improve user experience through personalized content, recommendations, and service customization. To serve and measure ads. To process payments, subscriptions, and transactions. To conduct analytics and research for product development and service enhancements. |
| Inferences drawn from any of the above information categories | We may collect data and draw inferences based on that data; however, these inferences are used solely to determine which features you use more or less and are not used to deduce other specific personal characteristics. | To improve user experience through personalized content, recommendations, and service customization. |
We may also process de-identified data, ensuring it cannot reasonably be linked back to you. We commit to maintaining and using de-identified data responsibly and will not attempt to re-identify such data unless required to validate our de-identification measures.
Certain state privacy laws, such as those in California, require us to disclose the categories of Personal Information that we have shared with third parties for business purposes over the past 12 months. During this period, we have disclosed all categories of Personal Information outlined in the “Categories of Personal Information We Collect” section for business purposes. For example, we may share IP addresses and device identifiers with service providers that assist us with crash monitoring and reporting.
Some U.S. states grant residents the right to opt out of sharing their Personal Information with third parties in exchange for valuable consideration (which may be classified as a “sale” or “share” under state privacy laws, even if no monetary transaction occurs). If you reside in one of these states and would like to limit the disclosure of your Personal Information to third parties for advertising or marketing purposes, please refer to Section 10.4 below.
Certain U.S. state privacy laws grant residents specific rights regarding their personal information. If you reside in a state with such laws, you may have the following rights:
| Your Right | Description |
|---|---|
| Right to Know | You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for business purposes in the 12 months preceding your request. |
| Right to Access | You have the right to request access to the specific pieces of personal information we have collected about you in the 12 months preceding your request. |
| Right to Delete | You have the right to request that we delete the personal information we have collected from you. We will use commercially reasonable efforts to fulfill your request, subject to applicable laws. However, we may be required to retain certain information for legitimate business purposes or as required by law. |
| Right to Correct | You have the right to request that we correct inaccurate personal information we maintain about you. |
| Right to Opt-Out of Sales, Sharing, and Targeted Advertising | You may have the right to opt out of certain uses of your personal information, including: • The “sale” or “sharing” of your personal information as defined under state privacy laws. • The use of your personal information for targeted advertising. |
| Right to Data Portability | You can request a copy of your personal data in a structured, portable format. |
| Right to Non-Discrimination | You have the right to exercise your privacy rights without fear of discrimination. |
| Right to Withdraw Consent | Where applicable, you have the right to withdraw your consent for data collection and sharing. |
| Right to Limit the Use of Sensitive Personal Information | Certain states provide the right to restrict how businesses use sensitive personal information. In order to opt-out, please contact us at support@passionapp.co with the subject line “Limit the Use of Sensitive Personal Information.” We will process such requests in accordance with applicable laws. |
To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request, this may include your email, date of subscription purchase, date of last activity, date of account creation or some other Service use data that will reasonably identify you as an owner of the account. We may also ask you for additional proof of identity, if necessary.
If we deny your request, you may have the right to appeal our decision. To do so, please contact us and explain your concerns. If you are dissatisfied with the result of the appeal, you may escalate the matter by contacting the Attorney General’s office in your state of residence.
If you are an authorized agent acting on behalf of a consumer, you may submit an opt-out, access, deletion, or correction request by contacting us. If you are making a request on behalf of a California resident, you may be required to submit proof of authorization, such as:
• A valid power of attorney
• Written permission signed by the consumer, along with identity verification from the consumer
We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
Privacy laws in some U.S. states broadly define the term “sale” to include sharing of information via cookies, pixels, and similar tracking technologies for certain targeted advertising activities. We do not sell Personal Information for monetary compensation. However, when you visit our websites, we and our advertising partners may collect device data and behavioral insights through tracking technologies, which could be interpreted as a “sale” or “sharing” under state laws, even if no money is exchanged.
We do not knowingly engage in sales, sharing, or targeted advertising using the personal information of individuals under 18.
More information about our data-sharing practices is available in the table below.
| Category of Personal Information Disclosed | Category of Third-Party Recipient |
|---|---|
Identifiers (such as pseudonymous cookie IDs, IP address, or if you have an account, a hashed version of your email address). Internet or other electronic network activity information (such as links you click or pages you visit on our website or your interactions with the Service). Commercial information (such as whether you bought a subscription). | Advertising networks. Social networks. |
Your opt-out settings apply per device and browser. If you switch devices, clear cookies, or use a different browser, you may need to reapply your opt-out settings.
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.