Privacy Policy

Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.

This Privacy Policy (the “Policy”) serves to explain what information "SharterDev" (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.

App Privacy Policy

In this Privacy Policy we explain:

• The ways we collect personal data about you and why we do so
• How we use your personal data, and
• The choices you have about your personal data.

This Privacy Policy applies to all of apps, websites and other related services, collectively the “Services”. Please note that we may from time to time update this Privacy Policy by posting a new version on this website. If we make any material changes, we will notify you by posting a notice in the Services prior to the change becoming effective. Your continued use of the Services after the effective date will be subject to the new Privacy Policy.

The personal data we collect

Device Information

We collect your device and network connection information in order to provide you with a better experience when you use our app.

This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:

SDK/API/JS code version, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent deice identifier, the terminal manufacturer, the terminal device operating system version, the location of the language, the time zone and the network state (Wi-Fi and so on), the CPU, and the battery use, Screen resolution, Memory usage, Storage usage, sim operator, sim card country, Application release status in google play, Ad loading strategy, Ad platform and advertising placement id, anonymous web browsing behavior, hidden app(Anonymous), Download error information (url and error log).

We store the information collected through the Android ID tied to the device you are using. In this way, we can retain your advertising behavior while you are using the app. We will treat this information as personal information.

Data about your use of the Services

• Number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, number of the app opened and some viewed pages.
• Permissions status
• Number of apps installed by users
• Package name
• Users' installed apps information
• First open time timestamp
• Mobile brand
• Net status
• Firebase device id
• Mobile model
• Sim country
• System language
• Advertisers may store or read cookies
• Web domain name visited by the browser user

These data only be passed to the certified third-party statistical platform: Firebase, Facebook Analytics and our self-built data statistics system (ECS).

The above information is only used to improve the product experience and will not be sold to any third parties. We will not use this information for purposes other than improving the product experience and ad performance.

Monetization and Analytical Information from Other Sources

Third-party SDKs integrated in our app may access your information, including:

• Google Advertising ID
• Demographic data (e.g. determination of your IP address)
• Data to fight against fraud (e.g. click fraud in advertising)
• Data associated with your device (e.g. device type, technological information, country)
• Data to do advertising, marketing and analysis
• Advertisers may store or read cookies

The information collected by third-party SDKs is governed by the providers of these SDKs and we have no control over such third parties. The third-parties include monetization partners, such as Google AdMob, Facebook AudienceNetwork, MoPub, Smaato, PubNative, IronSource, ChartBoost, Pixalate, Mintegral etc., and also analytical tools partners, such as Firebase, Facebook Analytics and our self-built data statistics system (ECS) .

Android Advertising ID

We use your Android advertising identifier in order to provide you with customized advertisement experience. It is used exclusively for advertising and analytics. Please note that the advertising identifier does not contain any user sensitive information that can be used to identify you as a user or your device. It is not connected to personally-identifiable information or associated with any persistent device identifier (for example: SSAID, MAC address, IMEI, etc.).

Other Information

We may collect information that you directly and voluntarily provide to us. The information includes but is not limited to: your email address, the content of feedback, your location(for analyzing location accuracy) and the content of questionnaire answered by you. When you forget your password and send us an email to request a temporary password, we will collect your device id, send time, a random code, which is only used to generate a unique and temporary password.

Account Information

When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number and a photo, if you choose to have a photo associated with your account.

Why we collect your data

To improve and optimize the Services

To provide better Services to you, we have a legitimate interest to collect and process necessary data to:

• Update and develop the Services
• Develop and improve your experience
• Manage the relationship with you
• Customize your service experience
• Respond to your comments and questions and provide support to you
• Provide offers in the Services as well as in other websites and services
• Send related information (e.g. updates, security alerts, support messages) to you

To provide the Services

To provider the Services, we process data necessary to:

• Allow you to use the Apps and the Services
• Operate the Services
• Provide and deliver products and services that you request

To carry out activities related to advertisements and marketing

To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the Services and with other users, and so forth.

We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process necessary data to:

Track the content you access in connection with the Services and your online behavior

Deliver, target and improve our advertising and marketing materials

Pass the information collected from you to third party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.

To secure the Services

Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.

In order to keep the Service safe, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Services

Prevent cheating, crime or fraud

Take action against fraudulent or misbehaving users

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions answers, comments, submissions that you post in the forum will be publicly available.

What Information Do We Share

As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.

What Are the Important Permissions We Request?

Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we ask are listed below:

• Phone
• read phone status and identity
• Photos/Media/Files
• read the contents of your USB storage
• modify or delete the contents of your USB storage
• Storage
• read the contents of your USB storage
• modify or delete the contents of your USB storage
• Wi-Fi connection information
• view Wi-Fi connections
• Nearby Wi-Fi devices
• Device ID & call information
• read phone status and identity
• receive data from Internet
• view network connections
• expand/collapse status bar
• full network access
• run at startup
• prevent device from sleeping
• Other

For the permission of Nearby Wi-Fi devices, when we target Android 13 or higher and use Wi-Fi APIs, we request this permission to enable "File Transfer" feature when user using this feature to transfer files to others. We strongly assert that our app never derives physical location information from Wi-Fi APIs. To do so, we have set the android:usesPermissionFlags attribute to neverForLocation.

Legal Basis of Your Personal Data

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our app.

Your rights and options

Please contact us at [email protected] if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

• Where denial of access is required or authorized by law;
• When granting access would have a negative impact on other's privacy;
• To protect our rights and properties;
• Where the request is frivolous or burdensome.

Your rights regarding your personal data

You have the right to a copy of your personal information to be supplied to you in an electronic format upon request.

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and the right to restrict how we use or share your data. If certain personal data is processed based on consent given by you, such consent can also be withdrawn by you at any time, for example in the applicable app’s settings.

We will respond to all requests within a reasonable time frame. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local data protection authority within the European Economic Area for unresolved complaints.

You can contact us by using the “Contact support” feature available in some of our apps’ settings.

Opt-out of targeted advertising

You can always opt-out of directed advertising in our apps by checking the privacy settings of your device. Please review your device’s user manual on how to do so.

Cookies and similar technologies

Some of our online Services use cookies and similar technologies to provide and personalize the Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser or device’s settings, but some parts of the Services may then not function properly.

How we protect your data

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention

We retain your data for as long as your account is active or as needed to provide you the Services. We will for example periodically de-identify unused app accounts and we regularly review and anonymize unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Your personal data is deleted or anonymized automatically after two years of account inactivity. Certain data such as payment data may be stored for periods longer than this in accordance with applicable accounting laws.

Age limits

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, such as your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete such data without delay. If you believe that we might have any data from or about a child under the age of 13, please contact us.

Special Information for California Residents

For California Residents, We provide separately which addresses how we respect California's users' privacy.

Changes to the Policy

Any information that is collected is subject to the Policy in effect at the time such information is c·n made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.

Contact Us

If you have any questions or concerns about the Policy, you may contact us at email: [email protected]