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 to us providing astrology, palmistry, numerology, horoscope and biorhythm services.
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 our app “Astrology and Palmistry Coach”.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: This is information about you that you give us by filling in your details when using our app for the first time. The information you give us may include your: name, gender, relationship status, place of birth, date of birth, time of birth, a line/shape model of your left and right palm and, if you lodge a customer query, 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. It will only be stored on your device locally. When performing our services, other than your email address, your personal information will be reformated so that it is no longer identifiable (i.e. pseudonymised).
- 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.
- 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 astrology, palmistry, numerology, horoscopes and biorhythms to you;
- to confirm your valid subscription to our app; and
- to communicate with you in relation to app support.
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 a 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. For example if you don’t give us your date of birth we will be unable to determine your zodiac sign. 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 do use information you enter into the App to generate a general profile about you based on the information you input into the App. However, the results of that profile are to link your device to obtain content from our content engine. That content is for entertainment purposes only and should not be used by you as the basis for any important or legally significant decision.
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 apps are 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.
You can contact our support team by visiting: https://help.rubylabs.io/ or emailing: email@example.com
Facebook Remarketing and Google Ads Remarketing
Personal Data: Cookies and Usage Data
Owner and Data Controller
RUBY LABS LTD
Company number 11382334
65 Compton Street, London, United Kingdom, EC1V 0BN
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The legal basis of a processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon the order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Managing contacts and sending messages, Infrastructure monitoring, Analytics, Hosting and backend infrastructure, Advertising, Remarketing and behavioral targeting and Interaction with external social networks and platforms.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.
This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Google Ads conversion tracking (Google LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Firebase Cloud Functions (Google Inc.)
Firebase Cloud Functions is a hosting and backend service provided by Google Inc.
Firebase Cloud Storage (Google Inc.)
Firebase Cloud Storage is a hosting service provided by Google Inc.
Firebase Cloud Firestore (Google Inc.)
Firebase Cloud Firestore is a hosting and backend service provided by Google Inc.
This type of service allows this Application to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
Firebase Crash Reporting (Google Inc.)
Firebase Crash Reporting is a monitoring service provided by Google, Inc.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Firebase Cloud Messaging (Google Inc.)
Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Remarketing and behavioural targeting
This type of service allows this Application and its partners to inform, optimize and serve to advertise based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioural targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google LLC that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Personal Data collected: Cookies and Usage Data.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to the processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).