Last
modified: February 2024
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X Cleaner
(“we,” “us” or “our”) takes your privacy seriously. This Privacy policy
(“Privacy policy”) explains our data protection policy and describes the types
of information we may process when you install and/or use “X Cleaner”software
application for mobile devices (the “App”, “our App”).
When we refer
to personal data (or personal information) we mean any information of any kind
relating to a natural person who can be identified, directly or indirectly, in
particular by reference to such data.
It is a
natural person who can be identified directly or indirectly, in particular by
reference to an identification number or to one or more factors specific to his
or her physical, physiological, mental, economic, cultural or social status.
Our Privacy
policy applies to all users, and others who access the App (“Users”).
For the
purposes of the GDPR, we are the data controller, unless otherwise stated.
PLEASE READ
THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL
INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE
THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.
IF YOU ARE A
CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE
Under the
California Consumer Privacy Act of 2018 (CCPA) California residents shall have
the right to request:
· the categories of personal information that is processed;
· the categories of sources from which personal information
is obtained;
· the purpose for processing of user personal data;
· the categories of third parties with whom we may share
your personal information;
· the specific pieces of personal information that we might
have obtained about a particular user provided that the data given in the
request is reliable enough and allows to identify the user.
Please use
the navigation links through this Privacy policy:
PERSONAL
INFORMATION
All about the
categories of information, its sources and purposes of processing
Please mind
that according to CCPA personal information does not include de-identified or
aggregated consumer information.
SHARING
How your
information can be shared
Please note
that all third parties that are engaged in processing user data are service
providers that use such information on the basis of agreement and pursuant to
business purpose.
OPT-OUT
OPTIONS
If you don’t
want us to process your personal information any more please contact us through
the contact form. In most
cases there is no way to maintain the App’s further operating without
functional data therefore you will be advised to remove the App from your
device.
If you don’t
want us to share device identifiers and geolocation data with service providers
please check your device settings to opt out as described below
REQUESTS
To submit a
verifiable consumer request for access, portability or deletion of personal
data please contact us through the contact form. Please include in the text of your appeal the
wording "Your rights to maintain confidentiality in the state of
California”.
When
submitting a verifiable request, you should be ready to:
· Provide sufficient information that allows us to
reasonably verify you are the person about whom we collected personal
information or an authorized representative, which may include: name, address,
city, state, and zip code and email address. We may use this information to
surface a series of security questions to you to verify your identity. If you
are making a request through an authorized agent acting on your behalf, such
authorized agent must provide written authorization confirming or a power of
attorney, signed by you.
· Describe your request with sufficient detail that allows
us to properly understand, evaluate, and respond to it.
We will not
be able to respond to your request or provide you with personal information if
we cannot: (i) verify your identity or authority to make the request; or (ii)
confirm that the personal information relates to you. We may ask you for
additional information or documents to verify your identity. We may also carry
out checks, including with third party identity verification services, to
verify your identity before taking any action with your personal information.
This is regarded as a safeguard measure to prevent disclosure of your personal
information under a fake or scum request.
We ensure
that personal information provided in a verifiable consumer request will be
used only to verify the requestor’s identity or authority to make the request
and not for any other purpose. We will keep it for the adequate term reasonably
needed for the purpose described above and delete after the purpose is
fulfilled.
We try to
respond to a verifiable consumer request within forty-five (45) days of its
receipt. If we require more time, we will inform you of the reason and
extension period in writing. Please note that we are only required to respond
to two requests per customer each year.
EQUAL RIGHTS
Nothing in
the way we deal with your request shall be interpreted as discrimination, which
means that we will not set up different pricing or products, or different level
or quality of services for you, if you choose to exercise your rights. However,
in some circumstances, we may not be able to provide services if you choose to
delete your personal information from our records.
SALE OF DATA
We do not
sell any of your personal data to third parties.
There are
several categories of information that can be processed.
Functional
Information and information that you submit
We ask for
and process the following personal information when you use the App. This
information is necessary for the adequate performance of the contract between
you and us. Without such information it is impossible to provide complete
functionality of the App and perform the requested services.
·
Activity
Information directly related to your use of the App. After you
set the relevant settings on your device we may have technical access to your
contact list - in order to be able to find duplicate and empty contacts, match
contact details; and to Photos - to be able to search for similar photos, to
import photos the user wants to hide, to add photos to a widget. However, we
cannot collect, use or store the data contained in your contact list or Photos
on any of our servers.
·
· Payment details
If you have
purchased the subscription on App’s web page and you want to cancel it via our
support chat within the App or via our contact form we may request you to indicate one of the
following:
·
o your email address registered when you purchased the
subscription,
o receipt number identifying the payment,
o unique number identifying the invoice.
·
Contact
Information (name, e-mail address, as well as any other content
included in the email) which you may fill in by yourself when you contact us
via email, support form. We collect, store and process it by our cloud storage
provider (Amazon.com, Inc.). We use such information to respond effectively to
your inquiry, fulfill your requests, send you communications that you request
and perform the requested services.
·
Information
That Is Processed Automatically
On the basis
of your permission we use
third-party automatic data processing technologies (advertising and analytics
tools) to analyze certain information sent by your device via our App (Identity For Advertisers for iOS devices/
Advertising ID or Android ID for Android devices). Some integrated
advertising or analytics tools (check Section IV to see the list of them)
launch automated processing of your personal data, including profiling, which
means any form of automated processing of personal data used to evaluate
certain personal aspects relating to you, in particular to analyze or predict
aspects concerning your personal preferences, interests, behavior, location or
movements (see the list of data described below). Processing information
through automatic data processing technologies starts automatically once you
allow our App to track your activity. You can withdraw your permission at any
time - please check opt-out options in Section VIII below.
We may
process some information about your device and your user behaviour on the ground
of our legitimate interest. This information falls within categories of data
described above in Subsection “Information That Is Processed Automatically”, it
is generally non-personal, i.e. it does not, on its own, permit direct
association with any specific individual, and we may access it only in
aggregated form. We use this information for improving our App and giving our
users the best experience.
· Device Details. When you use a mobile device (tablet /
phone / smartwatch) to access our App, some details about your device are
reported, including “device identifiers”. Device identifiers are small data
files or similar data structures stored on or associated with your mobile
device, which uniquely identify your mobile device (but not your personality).
Device identifier enables generalized reporting or personalized content and ads
by the third parties.
What data can
be processed:
·
o Information about the device itself: type of your device,
type of operating system and its version, model and manufacturer, screen size,
screen density, orientation, audio volume and battery, device memory usage.
o Information about the internet connection: mobile
carrier, network provider, network type, IP address, timestamp and duration of
sessions, speed, browser.
o Location-related information: IP address, the country
code/ region/ state/ city associated with your SIM card or your device,
language setting, time zone, neighboring commercial points of interest (eg.
“coffee shop”).
o Other device identifiers: e.g. user identifiers (if they
are set up by the App’s developer).
· Information about the applications. Name, API key (identifier for application),
version, properties of our App can be reported for automated processing and
analysis. Some services also record the list of applications and/or processes
which are installed or run on your device.
· Cookies and similar technologies. When you use the App, cookies and similar
technologies may be used (pixels, web beacons, scripts). A cookie is a text
file containing small amounts of information which is downloaded to your device
when you access the App. The text file is then sent back to the server each
time you use the App. This enables us to operate the App more effectively. For
example, we will know how many users access specific areas or features within
our App and which links or ads they clicked on. We use this aggregated
information to understand and optimize how our App is used, improve our
marketing efforts, and provide content and features that are of interest to
you. We may ask advertisers or other partners to serve ads or services to the
App, which may use cookies or similar technologies.
· Log file information. Log file information is automatically reported each
time you make a request to access the App. It can also be provided when the App
is installed on your device. When you use our App, analytics tools
automatically record certain log file information, including time and date when
you start and stop using the App, and how you interact with the App.
· Ad-related information. The following data might be reported about the ads
you can view: the date and time a particular ad is served; a record if that ad
was “clicked” or if it was shown as a “conversion” event; what the ad offer is
about; what type of ad it is (e.g., text, image, or video); which ad placement
is involved (where the ad offer is displayed within the App); whether you
respond to the ad.
· In-app events. When
you use our App, analytics tools automatically record your activity information
(tutorial steps, levelling up, payments, in-app purchases, custom events,
progression events, method of limiting the processing of user data).
Information
provided automatically to advertising or analytics tools does not generally
come to our control, therefore we cannot be responsible for processing such
information. Please mind that some services are engaged in personal data
profiling and may obtain information related to your personality and/or your
device by using technologies that do not belong to our scope of responsibility.
In case when your user ID is linked to your Facebook account, Facebook may use
your device information in association with categorized data that were already
recorded in its databases (eg. your age, gender or other demographic
indication). We do not control, supervise or stand surety for how the third
parties process your personal data, that might be collected by their own means
(not through our App). Any information request regarding the disclosure of your
personal information should be directed to such third parties (see Section IV).
Payment
Information
Our
e-commerce provider is responsible for billing, processing and charging for
your purchases, handles your personal information and keeps it absolutely safe
and secure. This information is processed as part of the performance of the
contract between you and us. We cannot access or use your credit or debit card
information.
You may
access the applicable “in-app” purchase rules and policies directly from the
app stores.
Email
newsletters
When you
register within the App and provide your email information by choosing the
option “Sign in with Apple” (create an account for the App using your Apple ID)
we may use such email information to send you communications (“newsletters”)
regarding special subscription offers, new features and functionalities and
other news related to the App on the grounds of our legitimate interests. Sending you newsletters will allow you to
stay up to date and receive the latest news about our App, including about the
best price offers. Note that when you provide your email information by using
“Sign in with Apple” you may choose either to share your email or to keep your
personal email address private and to hide it (“Hide my email” option, if
available), in the latter case Apple will generate and provide us with a
unique, random email address that automatically forwards to your personal
inbox. You also hereby acknowledge and accept the treatment of some categories
of your personal data (i. e. the information about your name if you provide it,
date of registration within the App, subscription purchase date, geolocation
data, activity information, etc.) for market analysis activities, particularly
for the purpose of delivering you targeted newsletters that most align with
your needs and interests. The information about your email address that we’ve
received may be transferred to the email marketing tool for the purposes of
optimization and automation of the email delivery process (please check Section
IV to learn more about the tool’s privacy policies and practices). You may also
unsubscribe, opt-out of receiving newsletters to your email address at any time
by using the resignation link provided in each email you receive from us. Your
unsubscribe request shall be honored within a reasonable period of time.
Our mission
is to constantly improve our App and provide you with new experiences. As part
of this mission, we use your information for the following purposes:
(a) To
make our service available. We use functional information,
information that you submit and information that is processed automatically to
provide you with all requested services. We may process some of your payment
details if you want to cancel your subscription purchased on App’s web page.
(b) To
improve, test and monitor the effectiveness of our App. We use
the information that is processed automatically to better understand user
behavior and trends, detect potential outages and technical issues, to operate,
protect, improve, and optimize our App.
(c) To
provide you with interest-based (behavioral) advertising or other targeted
content. We may use the information that is processed
automatically for marketing purposes (to show ads that may be of interest to
you based on your preferences). We provide personalized content and information
to you, which can include online ads or other forms of marketing.
(d) To
communicate with you. We use the information we have to
communicate with you through newsletters, i.e. to send you marketing notifications,
receive your feedback about our App experience, and let you know about our
policies and terms. We also use your information to respond to you when you
contact us.
(e) To
prevent fraud and spam, to enforce the law. We really want our
App to be free of spam and fraudulent content so that you feel safe and free.
We may use your information to prevent, detect, and investigate fraud, security
breaches, potentially prohibited or illegal activities, protect our trademarks
and enforce our Terms of Use.
If any new
purposes for processing your personal data arise we will let you know we start
to process information on that other purpose by introducing the corresponding
changes to this Privacy policy.
We will share
your information with third parties only in the ways that are described in this
Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s
Self-Regulatory Principles for the Mobile Environment.
Please note
that while integrating external services we choose third parties that can
assure they apply all necessary technical and organizational measures to
protect user personal data. However, we cannot guarantee the security of any
information transmitted from us to any such third party. We are not responsible
for any accidental loss or unauthorized access to your personal data through a
fault of third parties.
We will not
rent or sell your personal data to any third parties, but we may share your
information from tools like log files, and device identifiers and location
data, with third-party organizations that provide automatic data processing
technologies for the App. We do not control or influence these third parties’
tracking technologies or how they may be used.
We may also
share certain information such as cookie data with third-party advertising
partners. This information allows third-party ad networks, inter alia, to
deliver targeted advertisements that they believe will be of most interest to
you.
We may engage
the following third-party service providers in order to provide us with
necessary infrastructure for delivery and improvement of our services:
|
Entity name |
Services performed |
Entity location |
Link to Privacy Policy |
|
Amazon.com Inc. |
Cloud storage provider |
U.S.A. |
https://services.amazon.com/privacy-policy.html |
|
Amplitude Inc. |
Analytics service provider |
U.S.A. |
https://amplitude.com/privacy |
|
Apple Inc. |
Cloud storage provider |
U.S.A. |
https://www.apple.com/lae/privacy/ |
|
AppLovin Corporation |
Ad management/ analytics service provider |
U.S.A. |
https://www.applovin.com/privacy/ |
|
AppsFlyer Inc. |
Analytics service provider |
U.S.A. |
https://www.appsflyer.com/legal/services-privacy-policy/ |
|
Facebook (Meta Platforms, Inc.) |
Analytics / ad management service provider |
U.S.A. |
https://www.facebook.com/privacy/explanation |
|
Firebase Crashlytics (Google LLC) |
Analytics service provider |
U.S.A. |
https://policies.google.com/privacy |
|
Mindbox USA LLC |
Email marketing tool |
U.S.A. |
https://mindbox.cloud/documents/privacy-policy/ |
|
Qonversion Inc. |
Analytics service provider |
U.S.A. |
https://qonversion.io/page/privacy |
In case you
want to learn more about these services and their privacy options (including
opt-out) please consult the correspondent websites and privacy policies. We are
not responsible for any usage of your personal data by the abovementioned third
parties in violation of our instructions.
Our App may
contain links to third-party websites / services or you may access the App from
a third-party site. We are not responsible for the privacy practices of these
third-party sites or services linked to or from our App, including the
information or content contained within them.
We may
disclose your personal information if it is needed for objective reasons, due
to the public interest or in other unforeseen circumstances:
· as required by law;
· when we believe, in good faith, that disclosure is
necessary to protect our rights, protect your safety or the safety of others,
investigate fraud, or respond to a government request;
· if we are involved in a merger, acquisition, or sale of
all or a portion of our assets, you will be notified via email and/or a
prominent notice in our App of any change in ownership or your personal
information usage, as well as any choices you may have regarding your personal
information.
We work in
the cross-border area and provide our App to our Users around the world.
We and
third-party organizations that provide automatic data processing technologies
for the App or our third-party advertising partners may transfer the
automatically processed information across borders and from your country or
jurisdiction to other countries or jurisdictions around the world.
If you are
located in the European Union or other regions with laws governing data
processing that may differ from U.S. law, please note that we may transfer
information, including personal information, to a country and jurisdiction that
does not have the same data protection laws as in your jurisdiction.
This means
that your personal information can be transferred to a third country, a
territory or one or more specified sectors within that third country, or to the
international organization where data protection and confidentiality
regulations may not provide the same level of protection of personal data as
your country does.
We try to
make sure that the recipient of any personal data provides a proper protection
of the personal data received, in accordance with the current legislation on
the protection of such information. By using the App, you agree that we may
transfer your personal data to any third country, a territory or one or more
specified sectors within that third country, or to the international organization.
For the
purposes of data storage, we recourse to the services of the hosting
organizations. We take your privacy seriously and, therefore, encrypt your
personal data - if possible - before sending it to the hosting organizations
for the purposes of its storage. Please note that we cooperate only with those
hosting organizations that have passed our security and reliability check.
We generally
retain your personal information for as long as is necessary for performing the
functional service of the App and to comply with our legal obligations. If you
no longer want us to use your information that we physically access and store,
you can request that we erase your personal information and close your account.
However, some
data may still be stored for a certain time period (but no longer than the
storage purpose requires) if information is necessary to comply with legal
obligation (taxation, accounting, audit) or in order to maintain safety and
data backup settings, prevent fraud or other malicious acts.
Applicable
data protection laws give you certain rights regarding your personal
information. You have the following options in relation to your personal
information that was collected:
· Data Access and Portability. You can request copies of your personal
information.
· Change or Correct Data. Where you cannot update data by yourself through
your account, you have the right to ask to correct, change, update or rectify
your data.
· Data Retention and Deletion. The user data is generally retained for as long as
your user profile is in existence or as it is needed to provide the relevant
services. However, specific retention times can vary based on context of the
processing performed. You have the right to ask to delete all or some of the
personal data that is held about you.
· Restriction of Processing. Under certain circumstances, you may have the right
to limit the ways in which your personal information is used.
To exercise
any of the rights described above, you can contact us through contact form. Please bear in mind that
we ensure the above mentioned rights only with respect to the information that
we physically access and store.
When your
personal information is processed automatically you may object to such
processing in some circumstances. Where your personal information is processed
for direct marketing purposes, you may ask to cease processing your data for
these direct marketing purposes. In order to exercise your right please contact
the third party services listed in the Section IV of this Privacy policy to
learn how you can object to processing your data. Most of them have clear
instructions on their privacy pages, functional API or other options.
Opt-out of
marketing tracking
If you don’t
want third-party service providers to use the personalized ads on the basis of
your interests please follow the instructions below:
· Choose option "Limit Ad Tracking" on your iOS
device in Settings/ Privacy/ Advertising, please find additional information
here: https://support.apple.com/en-us/HT202074;
You can also
visit https://youradchoices.com for
the same purpose.
Please mind
when you opt out of certain interest based advertising, you may still continue
to receive contextual ads based on other non-personal information, such as ads
related to the content of other digital products you are using.
Opt-out of
Location Data Processing
If you don’t
want third-party service providers to use your precise location data, or
street-level location information about you please follow the instructions
below:
· iOS 11 or later: turn Location Services off for the
applicable Product via the menu “Settings > Privacy > Location Services”.
Then select the applicable App and set the “Share My Location” status to “Never”.
Please see additional information here:
https://support.apple.com/en-us/HT203033.
The security
of your personal information is highly important to us. We follow generally
accepted industry standards to protect the personal information submitted to
us, both during transmission and once we receive it.
We take
reasonable and appropriate measures to protect personal information from loss,
misuse and unauthorized access, disclosure, alteration and destruction, taking
into account the risks involved in the processing and the nature of the
personal information.
We implement
appropriate technical and organizational measures, which are designed to
implement data-protection principles, such as data minimization, in an
effective manner and to integrate the necessary safeguards into the processing.
We seek your personal data to be encrypted with proper and strong encryption
algorithms, including hashing where possible.
Unfortunately,
no method of transmission over the Internet, or method of electronic storage,
is 100% secure. We do our best to protect your personal data, nevertheless, we
cannot guarantee its absolute security. In the event that your personal
information is compromised as a breach of security, we will promptly notify you
in compliance with applicable law.
If you have
any questions about the security of our App, you can contact us through the
email or contact form displayed below.
Our App is
not intended for children under the age of 18. Therefore, we do not knowingly
collect or solicit any personal information from children under 18. No one
under age 18 may provide any personal information to the App. If you are under
18, do not use or provide any information on this App or through any of its
features. Do not provide any information about yourself, including your email
address. If we learn that we have collected personal information from a child
under age 18 without verification of parental consent, we will erase that
information as quickly as possible. If you believe that we might have any
information from or about a child under 18, please contact us.
This Privacy
policy is updated regularly.
Whenever we
change this Privacy policy, we will post those changes to this Privacy policy
and other places that we consider appropriate. Additional forms of notice of
modifications or updates as appropriate under the circumstances may be provided
to you.
If you have
any questions about this Privacy policy, please feel free to contact us
via support form.