Welcome to Tracker for DI, our iOS mobile application (our “APP”). We appreciate your interest in our APP and our handling of the data entrusted to us by you.

General Information and Mandatory Disclosure

What is personal data?

Personal Data is information by which you can be directly or indirectly identified. This generally includes information such as your name, address, email address and telephone number; however, it may also include other information such as your IP address or preferences and interests.

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.

Why do we have a privacy policy and what law applies?

In accordance with the California Consumer Protection Act (“CCPA”) and the General Data Protection Regulation (“GDPR”) we are required to inform you how we process your Personal Data. Doing so we will only use your Personal Data in accordance with the CCPA and the GDPR, and only as described in this Privacy Policy. 

Who is responsible and who can I contact?

The person responsible for processing is: 

BrutalBytes

639 Louise Dr

Tunnel Hill, GA 30755

United States of America

If you have any questions about the processing of your personal data by us or about data protection in general, you can reach us at admin@brutalbytes.com. 

The legal bases of processing

The CCPA and the GDPR specify when data processing is permitted. As such one of the following must apply when we process your Personal data:

• you have given your consent,
• the data is necessary for the fulfillment of a contract / pre-contractual measures,
• the data is necessary for the fulfillment of a legal obligation, or
• the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden. 

Your rights as a data subject

Every data subject has the following rights:

• Right to information,
• Right to correction of inaccurate data,
• Right to erasure or a right to be “forgotten”,
• Right to restrict the processing of personal data,
• right to data portability.

In addition, the data subject also has a general right to object (cf. Art. 21(1) GDPR). In this case, the objection to data processing must be justified. If data processing is based on consent, your consent can be revoked at any time with effect for the future. To exercise your data subject rights, please contact us.

In addition, you have the right to lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any Supervisory Authority.

Processing based on your consent

Insofar as you have given us consent to process personal data for specific purposes (e.g., sharing of data, evaluation of payment transaction data), the lawfulness of this processing is given on the basis of your consent. Consent given can be revoked at any time.

Accuracy and updating your information

If you believe that the personal data, 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 contact us at admin@brutalbytes.com. 

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer your requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal data, notably where such requests would not allow us to provide our service to you anymore.

About our APP

In principle, our APP is designed to have data protection-friendly default settings. This includes, for example, that only such personal data is collected that is required for the function of the APP (principle of data minimization). As such we have made sure that as little as possible information that directly identifies you is collected.

We assure you of the lawful and responsible handling of all data that you transmit to us as a user of our APP and would like to transparently present to you below which data we process, what we use it for and whether and, if so, to what extent it is stored by us and/or transmitted to third parties.

What sources and data do we use

We process personal data only to the extent authorized by you personally. In doing so, we only collect and process the data that is absolutely necessary to maintain and use the APP. Personal data may be collected in two ways, that is directly when you for example volunteer it to us or automatically for example when you install and use our APP.

How we use data?

The main reason we use your data is to deliver and improve our services as follows:

• to provide our APP to you,
• provide you with customer support and respond to your requests,
• to improve our APP and develop new features and services,
• retain data related to fraudulent activities to prevent against recurrences,
• to ensure legal compliance,
• analyze your profile, activity on the service;
• assist law enforcement, and
• enforce or exercise our rights.

Data collection, storage and use of personal data

When you contact us

If you send us feedback, or a support request, your e-mail address will only be used for correspondence with you and only to clarify your support case. Your data will not be passed on to third parties. The data of your request will be deleted after completion. In the course of the support you have requested, it may be necessary for you to provide us with some of your personal data so that we can fulfill our contractual obligations. The data transmitted in this context will be deleted after the end of the support. The legal basis for this processing is consent) and legitimate interest. 

Purchases 

When you make in app purchases, Apple may collect the following data from you to process the desired order:

• Apple user ID
• Email address
• Payment confirmation from the payment data collected by Apple; and
• Device IP and device serial number to link the story history to the device.

Collection, storage and use of non-personal data

Advertising

Our App is build using the Freemium Model. As such, the APP uses third-party advertising networks service to display ads. In order to provide personalized advertisements to our users, use device information that include personal and non-personal information, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize this advertising procedure. 

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. 

The APP uses the Google Admob service to display ads. Ads are either personalized based on the device you are using or random and you will be asked to decide upon you opening our APP for the first time. You can also opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. 

In addition, you may also choose to control targeted advertising you receive by using the settings and controls on your device and upon startup of our APP you will be promoted to grant permission for tracking.

By integrating Google services, Google may collect and process information (including personal data) for analytical purposes trough Google Analytics and Crashlytics. 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. 

Downloading the APP

The APP can be downloaded from the Apple App service “App Store” a service of  Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and  Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP.

Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

Installing the APP

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. 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. 

Starting the App

Every time you start the APP, your data is synchronized, and your device communicates with our server through a signed token. The transmission takes place automatically and is a prerequisite for the secure functioning of the APP and is therefore mandatory.

Device information

Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID) sensors such as accelerometer, gyroscope, and compass and Payment Data and Billing confirmations.

Security

We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal data. As with all online technology, we take steps to secure your data, however we do not promise, and you should not expect, that your personal data will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures. 

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. 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 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.

Data storage and transmission

Your data is stored on our device and if transmitted exclusively via SSL-encrypted connections. In the process, the certificates are checked for validity and -if technically possible, in order to prevent misuse and man-in-the-middle attacks as far as possible.

Data is only transferred to third countries if this is necessary/legally required for the execution of your orders or if you have given us your consent. We will inform you separately about details, if required by law.

Please note that Apple and Google may transfer and store your data when you are using our APP, in particular for Payment or the display of Advertising, we however have no knowledge and influence over those processes. Further information can be found in Google and Apples Privacy Policies and Data Processing Addendum’s.  

Use of third-party services

The use of third-party backup services is subject to the respective third party’s own Privacy Policies as linked above, over whose content and compliance we have no influence.

No forwarding to third parties

Data will only be passed on to third parties without your consent if we are legally obliged to do so, e.g., in the event of a corresponding court order.

Obligation to provide personal data

You are not obliged to provide us with personal data. However, depending on the individual case as described above, the provision of certain personal data may be necessary for the provision of the services. If you do not provide us with this personal data, we may not be able to provide the requested service.

Authorizations and Access

When using the app, you will receive so-called push messages from us, even if you are not currently using the 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.

We may request access or permission to certain functions from your mobile device (tracking for AdMob and Push notifications). The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can change your permissions at any time via the Settings Menu of your device.

Uninstall

You can stop the collection of information by our APP by uninstalling it using the standard uninstall procedure for your device.

Automated individual decision-making including profiling

We do not make automated decisions in individual cases, including profiling.

Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Access and Correction

The CCPA and the GDPR give you the right to access your Personal Data. Your right of access can be exercised in accordance with the CCPA and the GDPR. Any access request may be subject to a fee of an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you. 

In the event that you wish to correct and/or update your Personal Data in our records, you may inform us in writing of the same by sending us an email at admin@brutalbytes.com. 

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 CCPA and the GDPR. 

Changes

Because we’re always looking for new and innovative ways to improve our APP, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

Queries and Complaints

Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.