Privacy Policy

Our Platform, CreateApp (“Site/Application”), and its Software Applications collect some Personal Data from its Users (each, a “User”). The Data are collected and processed for the purposes set out below. This Privacy Policy governs the manner in which CreateApp collects, uses, maintains and discloses information collected from Users of the Site/Application. This Privacy Policy applies to the Site/Application and all products and services offered by CreateApp.

Kinds of Data

The Data that may be collected by this Site/Application are: Various types of Personal and Non-Personal Identification Information, Cookie and Browsing and Usage Data.

Personal Identification Information

We may collect Personal Identification Information from Users in a variety of ways, including, but not limited to, when Users visit our Site/Application, subscribe to the newsletter, fill out a form, and in connection with other activities, services, features or resources we make available on our Site/Application. The Personal Data may be freely submitted by the User or the Data Subject, or collected automatically when using the Site/Application. Users may be asked for, as appropriate, name, email address, mailing address, phone number. Users may, however, visit our Site/Application anonymously. We will collect Personal Identification Information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site/Application related activities. The Personal Data collected may regard both the User and third parties whose data the User provides. The User assumes responsibility for the Personal Data of third parties published or shared through the Site/Application and declares that (s)he has the right to communicate or broadcast them, thus relieving the Owner of all responsibility towards third parties.

Non-Personal Identification Information

We may collect Non-Personal Identification Information about Users whenever they interact with our Site/Application. Non-Personal Identification Information may include the browser name, the type of computer and technical information about Users means of connection to our Site/Application, such as the operating system and the Internet service providers utilized and other similar information.

Cookies

Our Site/Application may use “cookies” to enhance User experience. The User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Any use of Cookies by the Site/Application or the owners of third party services used by the Site/Application, unless stated otherwise, serves to identify the User and remember his/her preferences for the sole purpose of providing the service required by the User. User may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent to them. Failure to provide certain Personal Data, in particular Navigation Data, by deactivating the Site/Application’s Cookies may make it impossible to use the Site/Application or for the Site/Application to provide its services.

How We Use Collected Data and Information

We collect and use Users’ or Data Subjects’ Personal and Non-Personal Identification Information and other Data for the following purposes:

• To Personalize User Experience. We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site/Application. For such purposes Data are collected for traffic optimization and distribution, analytics, and interaction with external social networks and platforms.
• To Improve our Site/Application. We continually strive to improve our Website/Application offerings based on the information and feedback we receive from you.
• To Improve Customer Service. Your information helps us to more effectively respond to your customer service requests and support needs.
• To Administer Content, Promotions, Surveys or Other Site/Application Features. To send Users information they agreed to receive about topics we think will be of interest to them.
• To Send Periodic Emails. The email address Users provide will only be used to respond to their inquiries, and/or other requests or questions. If a User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include unsubscribe instructions at the bottom of each email, or the User may contact us via our Site/Application.

The use of Data for additional purposes by the Owner, may in some cases, and for legal purposes, require specific consent by the User or the Data Subject.

How We Protect Your Information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site/Application. In the unfortunate event of a data security breach, we will notify Users whose Personal Identification Information may have been breached.

Sharing Your Personal Information

We do not sell, trade, or rent Users’ Personal Identification Information to others. We may share generic aggregated demographic information not linked to any Personal Identification Information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site/Application or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Third Party Site/Applications

Users may find advertising or other content on our Site/Application that link to the Site/Applications and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these Site/Applications and are not responsible for the practices employed by Site/Applications linked to or from our Site/Application. In addition, these Site/Applications or services, including their content and links, may be constantly changing. These Site/Applications and services may have their own privacy policies and customer service policies. Browsing and interaction on any other Site/Application, including Site/Applications which have a link to our Site/Application, is subject to those Site/Applications’ own terms and policies.

Opt-out rights

User can stop all collection of information by the Application easily by uninstalling the Application or request to delete the account. User may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. User can also request to opt-out via email, at [email protected]

Mode and Place of Processing the Data Obtained

Method of Processing

• The Data Controller processes the Data of the Interested Parties and Users in a lawful and proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data. Processing is carried out using computers and / or telematic means, with organizational methods and logics strictly related to the stated purposes.
• In addition to the owner, in some cases, access to the Data may be available to external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). The updated list of Managers may be requested from the Owner at any time.

Place

• The Data are processed at the headquarters of the Data Controller, unless stated otherwise in the rest of this document.

Conservation Time

• The Data are kept for the time necessary to perform the service requested by the User, and the User can always ask for their suspension or removal.
• Detailed Information on the Processing of Personal Data and the Services Provided by Third Parties.

Traffic Optimization and Distribution

• These services allow the Site/Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between the Site/Application and the User’s browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.

Interaction with External Social Networks and Platforms

These services allow interaction with social networks or other external platforms directly from the Site/Application’s pages/screens. The interaction and information obtained by this Site/Application are always subject to the User’s privacy settings for each social network. If a service enabling interaction with social networks is installed it may still collect traffic data for the pages/screens where the service is installed, even when Users do not use it.

Social Media permissions

• Site/Application may ask for some Social Media permissions allowing it to perform actions with the User’s Social Media account and to retrieve information, including Personal Data, from it.
• For more information about the following permissions, refer to the respective Social Media permissions documentation and to the privacy policy.

Additional Information About Data Processing

Microphone Access

• Application created by CreateApp Platform use device microphone to record audio as this is the only way to record audio. This application not send any audio to us or any other third party. If user use email client to share the recorded audio then it will be transferred to the recipient’s email client.

Camera Access

• Application created by CreateApp Platform use device’s camera to capture images in camera module. Application not capture any picture secretly or send it to server or to any third party application. If user share the captured image, then only it will be transferred to email client using for sharing.

Location

• When application is opened, we may collect location information of device. In application, we require location to show device’s current location or get location for proximity notification purpose. Except this, application do not send the location of the device to us or any other third party services. We are also using different methods to fetch the location of device via GPS or Wifi.

Payment Details

• Payment processing are done by the payment gateway directly. We never store or process any account detail in any mean. We also not sharing this information with any other third party services.

Photos/Media details

• In some module of application where application access camera or SD card for photo/media file. We never use that information in any mean and do not share with any third party service. If user share this information using any social media account, then information will be shared on that social media account.

Legal Protection

• The User’s Personal Data may be used for legal purposes by the Owner of the Site/Application in court or in the stages leading to possible legal action arising from its improper use of related services by the User.

Additional Information

• Specific information may be shown on the pages of the Site/Application concerning particular services or the processing of Data provided by the User or by the Data Subject.

Maintenance

• The User’s Personal Data may be further used in ways and for purposes required for Site/Application maintenance.

System Logs

• For operation and maintenance purposes, this Site/Application and any third party services it uses may collect system logs, i.e., files that record interaction – including navigation. They may also contain personal data, such as IP addresses.

Data Retention Policy, Managing Your Information

• We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 12 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at [email protected] we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

Information Not Contained in this Policy

• More information on processing Personal Information may be requested from the Owner at any time.

The Rights of Data Subjects

Those persons to whom the Data refer have the right, at any time, to know whether their data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Owner of the Processing System.

Legal Information

In compliance with the Childrens’ Online Privacy Protection Act (COPPA) we do not collect Personal Identification Information from any individual under age 13 without parental consent. We do not solicit or want Personal Identification Information from any minor children under age 18. Notice to European Users: This privacy statement has been prepared in fulfilment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy statement applies solely and exclusively to the Site/Application and is not meant to refer to other Site/Applications whose links are possibly contained therein.

Notwithstanding anything else in this policy, we may work with partners who use mobile SDKs to passively collect information (collectively, “SDK Information”), which generally helps us deliver personalized notifications. This data may also be used to identify you in a unique manner across other devices or browsers for the purposes of customizing ads or content. Depending on the permissions granted to this application, this information may include personally identifiable information (PII) including your email address. This information may also include precise location (i.e. GPS-level data) or WiFi information, apps you have installed and enabled, and your mobile identifier (e.g., Android Advertising ID).

Consumer Control & Opt-Out Options

Opting-out of Push Notifications

• You may in most cases opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for some or all of the apps on your device. (Different device configurations, or updates to devices, may affect or change how these settings work.)

Opting Out of “Cross-App” Advertising on Mobile Devices

• You can opt out of having your mobile advertising identifiers used for certain types of interest-based (also called “cross-app”) mobile behavioural advertising, by accessing the “settings” on your Apple or Android mobile device, as follows: By opening the Google Settings app on your device, selecting Ads, and then selecting the option to opt-out of interest-based ads. (Different device configurations, or updates to devices, may affect or change how these settings work.)

Contacting Us

If you have any questions about this Privacy Policy, the practices of this Site/Application, or your dealings with this Site/Application, please contact us at [email protected]

Changes to this Privacy Policy

The Site/Application reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page, and by ensuring analogous protection of the Personal Information in all cases. It is strongly recommended that Site/Application Users review this page often, referring to the date of the last modification listed at the bottom. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

Your Acceptance of These Terms

By using this Site/Application, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site/Application. Your continued use of the Site/Application following the posting of changes to this policy will be deemed your acceptance of those changes.

Definitions and Legal References

Personal Information or Data

• Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Browsing and Usage Data

• Information collected automatically from the Site/Application, including the IP addresses or domain names of the computers utilized by the users who connect to the Site/Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the visitor, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within the Site/Application with special reference to the sequence of pages via Site/Application, and other parameters about the operating system and the user’s IT environment.

User

• An individual using the Site/Application’s services or products.

Data Subject

• The legal or natural person to whom the Personal Data refer.

Data Processor

• The natural person, legal person, public administration or any other organization, association or organization designated by the Data Controller for the Personal Data processing system.

Data Controller

• The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Site/Application.

Last updated: November 28, 2018