Data Protection Notice – App Users
This data protection notice has been prepared in accordance with the UK Data Protection Act 2018 (“DPA”) and the General Data Protection Regulation (“GDPR”). This notice sets out the basis on which we collect any personal information relating to you, or that you provide to us in relation your use of our “Psychology Coach” mobile app (“the App).
Who are we?
"We", "our" or "us" means Ruby Labs Limited. Our company number is 11382334. Our registered office is at 65 Compton Street, London, United Kingdom, EC1V 0BN. We are the controller of your personal information. This means that we are responsible for deciding how we collect, store and use personal information about you.
If you have any questions about this privacy notice, please contact our User Relations Manager at URM@rubylabs.io.
Who does this privacy notice apply to?
This privacy notice applies to all users of the App. It does not form part of contract to provide services.
We may update this notice at any time.
This privacy notice answers the following questions:
- What personal information do we collect?
- Why do we use your personal information?
- What is our legal basis for collecting your personal information?
- What happens if you don’t provide the personal information we have asked for?
- Will we use your personal information for automated decision-making?
- Can we change the purpose for which we use your personal information?
- How long do we keep your personal information for?
- Do we share your personal information with any third parties?
- Sharing your personal information for advertising purposes
- Do we transfer your personal information outside the EEA?
- How do we keep your personal information secure?
- What rights do you have over your personal information?
- How will we tell you about changes to this privacy notice?
- How to contact us
We will ask you to provide the following personal information about you:
- Information you give us: If you lodge a customer query with us about the App, we collect and process your email address and any other information about yourself you choose to provide to use us when you lodge a customer query with us.
- Other than your email address, we do not collect or store the above personal information.
- Information we collect about you: We will collect a non-personally identifying device ID from Apple in order to link your use of the app for billing through iTunes.
- No Information collected through use of camera: You may grant the App access to your phone camera and gallery in order to use the App to color a photograph. Depending on your device, Apple and Android system will ask for your permission before allowing us to access these features. Photos you choose to add to and color in the App will only be stored on your device locally and iCloud account. We do not take copies of any of your art work or photos.
- Information collected by third parties: This is information collected by third party SDKs on the App and our website providers. They will collect the following data related to your usage: your IP address, cookies, unique device identifiers, URL, and the sequence of pages visited. We do not collect this information ourselves and it is collected by the relevant third parties as data controllers. This information is only shared so as to allow the app to operate. To see how they use this information please refer to their privacy policies. We have provided links to these. If you do not want to share this information you should adjust your device privacy settings to “do not track”. We have set out how to do that below.
- Analytics providers
- Unity Technologies (Unity Analytics)
- Google LLC (Firebase /BigQuery)
- Google LLC (Google play market)
- Apple Inc. (Apple Itunes Connect)
- Tracking and fraud prevention providers
- Advertising partners (ad networks)
- Tapjoy, Inc.
- ironSource Ltd.
- Unity Technologies Finland OY (Unity Ads)
- Vungle Inc.
- Facebook, Inc. (FB Analytics, FB Ads, FB Audience network)
- AppLovin Corporation
- Chartboost, Inc.
- Google LLC (AdMob) or here.
- CrossInstall Inc.
- AppGrowth Inc.
- Google LLC (Google Ads)
- Apple Inc. (Apple Search Ads)
- Tapdaq, Inc.
- Google LLC (Google AdSense)
- Twitter, Inc. (Twitter Audience Platform)
- Appodeal Inc.
- Fyber Group
- HyprMX Mobile LLC
- Liftoff Mobile, Inc.
- AdColony, Inc.
- Google LLC (DoubleClick)
- Other third-party service providers
We will use this personal information as follows:
- to provide entertainment services related to art and coloring of pictures and drawings to you;
- to confirm your valid subscription to the App; and
- to communicate with you in relation to support for the App.
We are collecting and using your personal information in order to perform our contract for these services with you.
We will collect and use your personal information to confirm your valid subscription. It is in our legitimate interests as business to ensure that you are properly subscribed to receive our services and to ensure that we are paid for those services.
Where we allow third parties to collect and use your personal information in respect of analytics and advertising, we will only do so if permitted in your device system settings. You can change this setting as detailed above.
Where we have stated that your personal information is used in order to carry out a contract with you, to take steps to enter into that contract we will need you to provide the personal information requested. If you don’t provide that personal information when we ask for it, we may not be able to respond to you, enter into a contract with you or meet our obligations to you under that contract. If you have any concerns about whether you need to provide your personal information please contact our User Relations Manager at URM@rubylabs.io.
We do not use your personal information to make automated decisions about you.
We will only use your personal information for the purposes set out above or for a new reason that is compatible with those original purposes. If we change the purpose for which we use your personal information and you would like an explanation as to how the new purpose is compatible with the original purpose please contact our User Relations Manager at URM@rubylabs.io.
If we would like to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this and, where we are required to do so, ask for your consent.
We will only keep this information for as long as is permitted by law.
Information you enter into the app will be retained for so long as the App is installed on your devices. Once you delete the App, your personal information will be deleted as it is only stored locally on your device.
We retain information relating to your contract with us and your use of the app for 6 years after you unsubscribe from the App and we retain information relating to support queries for 1 year after we close the relevant support query.
We share your personal information with trusted third parties who support our app (such as designing our app infrastructure and customer support service). If we do this, we will put in place a contract with them which controls how your personal information may be used and which requires that your personal information is treated in accordance with data protection laws.
We do not share information that could identify you personally with our third party advertising partners (as listed above) for the purposes of advertising, remarketing and behavioural advertising based on your use of the App. We do share information that can help those partners to deliver personalised advertisements to you – this information will not identify you personally. If you would like to prevent this sharing then please change your settings.
- You can Opt Out on an Apple iOS Device, such as iPhones, iPads or iPods by switching Limit Ad Tracking to “On”. For iOS 6.0 devices and higher, this setting can be changed using the following path: Settings, General, Privacy, Advertising and toggling "Limit Ad Tracking" to 'ON'.
- You can Opt Out on an Android Device of interest-based advertising, you may do this as follows: Open the Settings app on your device, Go to "Google", Select Ads, Opt out of interest-based ads
We may transfer your personal information outside the European Economic Area where the level of data protection may not be equivalent to that in the United Kingdom. By submitting the personal information, you agree to this transfer and we will take steps reasonably necessary to ensure that your personal information is treated securely. Any such transfer will be on the basis that each third party will always keep control of the personal information within the terms of this notice.
We take appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties (see above) who have a business need-to-know.
We have put procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal information to you.
If you are a citizen in an EEA country, you have the right to make a complaint at any time to your national data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the national data protection authority and so, if you are happy to do so, please contact our User Relations Manager at URM@rubylabs.io.
You also have a number of other rights over your personal information, which are:
- the right to ask us what personal information we have about you and to have a copy of your personal information from us;
- the right to ask us to correct any errors in your personal information;
- the right to object to our legitimate interests, profiling activities and marketing communications;
- the right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit that personal information to another entity where:
(i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and
(ii) the use we are making of your personal information is carried out by automated means;
- the right to ask us to delete your personal information where:
(i) we don’t need your personal information anymore;
(ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information;
(iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing;
(iv) our use of your personal information is illegal;
(v) we have to delete your personal information to comply with our legal obligations;
- the right to ask us to restrict the use that we are making of your personal information where:
(i) you don’t think the personal information we have about you is correct, so that we can check if it is correct;
(ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it;
(iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and
(iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
- where our use of your personal information is based on your consent, the right to withdraw your consent at any time by contacting our User Relations Manager at URM@rubylabs.io.
Our Policy Toward Children
Our App is not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we discover that we have collected any personal information about a child under 13, we will take steps to delete it from our systems as soon as possible.
If you are under the age of 18, you must have your parent’s permission to download and use our Apps.
If you have any questions about this privacy notice or about the ways we use your personal information, please contact our User Relations Manager at URM@rubylabs.ioor 65 Compton Street, London, United Kingdom, EC1V 0BN.