We welcome you to PicaBook: Picture Book Creator, our website and/or our iOS and Android Mobile application. We are committed to protecting your Personal Data and to providing clear and transparent disclosures about the types of information we collect and how we use it.
For your further visits to our website and App, we would like to inform you about data collection, processing and use when visiting and using our website and App. As well as objection, revocation, and other rights to which you are entitled as a person affected by data collection and use.
In principle, we will only use your Personal Data in accordance with applicable data protection laws, in particular the General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.
General Information
a) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID.
b) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
c) Responsible for data processing
Responsible for data processing is MyFortuna, Kostiantyn Makrasnov of 708 E Sanson Ave. Spokane, WA USA (“we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using support@myfortuna.app.
d) The Legal Bases for processing Personal Data
In accordance with the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
Processing of Automatically Collected Data
a) Log data
Each time you visit our website, our system automatically records data from the visiting device and stores it in a so-called log file. Among other purely technical information, this includes both device information and IP address (identification of the user's device). The legal basis for processing is our legitimate interest.
b) Hosting
The hosting service used by us for the purpose of operating our website is Firebase Hosting by Google. In doing so Google processes all data to be processed in connection with the operation of our website, including log files on our behalf. The legal bases for processing are our legitimate interests, the provision of contractual services and the conclusion of the contract for our services.
c) Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in the Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. The legal basis for processing is our legitimate interest and your consent.
d) Cookie consent
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
e) Analytics
We use Google Analytics, a web analytics service provided by Google on our website. Google Analytics also uses cookies to enable our website to analyze how users use our website across multiple devices. The information generated by the cookies about your use of our website is transmitted to and stored by Google. The following data is processed through the use of Google Analytics: a) 3 bytes of the IP address of the called system of the website visitor (anonymised IP address), b) the website called up, c) the website from which the user reached the accessed page of my website (referrer), d) the subpages accessed from the website, e) the time spent on the website, f) the frequency with which the website is accessed. Google states that it will not associate your IP address with any other data held by Google. The use of this service is based on your consent.
f) Downloading and Installing the APP
The APP can be downloaded from the "Google Playstore" a service offered by Google, or the Apple App service "App Store" a service of Apple Inc. To install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.
As far as we are aware, Google collects and processes the following data: a) License check, b) network access, c) network connection, d) WLAN connections, and e) location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.
As far as we are aware, Apple collects and processes the following data: a) device identifiers, b) IP addresses, and c) location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.
Google and Apple may collect information from and about the device(s) you use to access the App, including hardware and software information such as a) IP address, b) device ID and type, c) device-specific and App settings and properties, d) APP crashes, advertising IDs (AAID), e) information about your wireless and mobile network connection such as your service provider and signal strength; f) information about device sensors such as accelerometer, gyroscope, and compass.
g) Authorizations and Access
We may request permission to store your App data including your Internet Connection and Network, IP Address Location, Push Notifications. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our App may not function as intended. The basis for processing is our legitimate interest and your consent.
h) Push messages
When you use our App, you will receive so-called push messages from us, even if you are not currently using our App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device. Insofar as you consent to the use of push messages, consent is the legal basis for the processing.
i) Purchases
When you make In-app purchases, we (Google and Apple on our behalf) may collect the following data from you to process the purchase: a) Apple or Google user ID, b) Email address, c) Payment confirmation from the payment data collected by Apple or Google; and d) Device IP and device serial number to link the story history to the device. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the App.
j) Advertising
Our App uses the Google Admob service to display ads. Ads are personalized based on the device you are using. You can disable this via the settings on your device. Google may use the advertising ID of your device, as well as cookies and/or similar technologies, to collect personal data for the purpose of generating and displaying personalized advertising. More detailed information about what data Google collects and how it is processed can be found here.
Advertisers and third parties also may collect information about your activity on our App, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our App and on third-party sites and applications. If you do not wish to participate in our advertising personalisation or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative or AdChoices. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices and/or use the checkbox function displayed when you launch our App. The basis for processing is our legitimate interest.
k) Firebase
We use the Google Firebase developer App and related features and services provided by Google. We use the following Google Firebase services in our Platform: a) Firebase Analytics, b) Firebase Crashlytics, c) Firebase Firestore, and d) Firebase Cloud Messaging for Push Notifications. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy The legal basis is the implementation of the user contract for the use of the App.
l) Google Analytics for Firebase
Our App uses the web analytics service Google Analytics for Firebase, which uses tracking technologies to track your use of our App. In this respect, information is generated about, among other things, the number of users and their sessions, the session duration, the operating system used by the users, their device model, the region from which our App is accessed, the first start of our App, our App execution and any updates.
In order to provide the relevant data for analysis, Firebase Analytics uses your a) device's advertising ID, b) an App instance ID (a randomly generated number that identifies a single app installation), c) and the IP address, which is shortened (IP masking) before being processed on Google's servers (which may be located outside the EU/EEA) to generate the usage analysis. You can object to the use of Firebase Analytics at any time by disabling the sending of usage statistics in your device settings (Reset Advertising ID). We have no influence on these data processing operations.The basis for processing is our legitimate interest and your consent.
Data processing by us
a) Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest in processing your request.
b) Account Registration
If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form (Full Name, Email Address, and chosen Password). The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is our legitimate interest and to fulfill our contractual obligations.
Alternatively, you are able to sign up using the convenience login and sign up from Google and Apple. For Google or Apple log in and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture) linked to your account. When registering via Google`s or Apple`s connect function, you agree to the relevant terms and conditions and consent to certain data from your respective profile being transferred to us.
c) When using our services
We process the data of our registered users in order to be able to provide our services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you and to backup your books and to sync your books across devices. You may also share your books through in-app codes, website links or inside the book hub. Each book may include images, audio recordings, drawings, text or other content with personal information. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations. Additionally, some of the data you choose to provide may be considered non-Personal Data and/or “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, and religious beliefs. By choosing to provide any of this data, you consent to our processing of that data. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your or parental consent.
General Principles
a) Minors
In accordance with Art. 8 of the GDPR, the processing of Personal Data relating to a person younger than 16 years requires the consent of a parent or legal guardian. Further and in line with the US Children's Online Privacy Protection Act of 1998 (COPPA) operators of websites and online services are required to protect the privacy of children under the age of 13 years. Specifically, both the GDPR and COPPA stipulate that a) we must seek and require verifiable parental consent; b) we must provide an appropriate privacy policy, and c) clearly set out our responsibilities regarding children's privacy and safety online.
We allow users of all ages to use the app, however, we do not collect any personal information from users under the age of 13 (US only) or 16 (EU only) unless we are given verifiable parental consent. If you suspect that a user is a minor, please report it to us as soon as possible.
b) Data storage
In general, your data and content of your books is saved and stored on our Firebase server. We store your data and content of your books in encrypted format and it can only be accessed when you have the account access or you have permitted the sharing. The data you enter into your books is not accessible by us nor any other third party. You can export and delete your book at any time by using the relevant functions in our App. The legal basis is consent and of course, the contract for the use of our services.
c) Automated decision-making
Automated decision-making including profiling does not take place.
d) Do Not Sell
We do not sell your Personal Data.
e) Sharing
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; or if we have reason to believe that disclosure is necessary to protect us and our App.
f) International Transfer
We usually do not transfer Personal Data, however, if we do we ensure that processing is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.
g) Data Security
Our data processing is subject to the principle that we only process the Personal Data that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Data are always guaranteed.
Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Your Rights and Privileges
a) Privacy rights
You can exercise the following rights:
● Right to information
● Right to rectification
● Right to object to processing
● Right to deletion
● Right to data portability
● Right of objection
● Right to withdraw consent
● Right to complain to a supervisory authority
● Right not to be subject to a decision based solely on automated processing.
If you wish to exercise any of your rights, please contact us.
b) Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).
Updates
We may update this policy from time to time. If we make changes, we will revise the effective date at the end of this section. If you have any questions or if you wish to exercise your rights, please contact us using support@myfortuna.app. We encourage you to periodically review this policy to be informed of how we use and protect your Personal Data. This policy was last updated on Monday, 23rd of October, 2023.