Privacy Policy - Qrafter

Qrafter collects some Personal Data from its Users.

Users may be subject to different protection standards and broader standards may therefore apply to some. Users can contact the Owner to learn more about such standards.

This document contains a section dedicated to Users in the European Union and their privacy rights.

This document contains a section dedicated to Users in the United States and their privacy rights.

This document contains a section dedicated to Brazilian Users and their privacy rights.


Owner and Data Controller

AKE Software GmbH
Grafenberger Allee 293, 40237 Düsseldorf, Germany

Owner contact email: kerem@ake.dev


Types of Data Collected

Among the types of Personal Data that Qrafter collects, by itself or through third parties, there are: Trackers, Usage Data, and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Qrafter.

Unless specified otherwise, all Data requested by Qrafter is mandatory and failure to provide this Data may make it impossible for Qrafter to provide its services. In cases where Qrafter 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.

Any use of Cookies – or of other tracking tools — by Qrafter or by the owners of third-party services used by Qrafter serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.

Users are responsible for any third-party Personal Data obtained, published or shared through Qrafter.


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.

The 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 Qrafter (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.

Place

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.

Retention Time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.


The Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Advertising, Analytics and Infrastructure monitoring.


Detailed Information on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Qrafter, 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.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User's interests and behavior, including those detected outside Qrafter.

AdMob (Google Ireland Limited)

AdMob is an advertising service provided by Google Ireland Limited.

In order to understand Google's use of Data, consult Google's partner policy.

Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: Ireland – Privacy Policy

AppLovin (AppLovin Corporation)

AppLovin is an advertising service provided by AppLovin Corporation.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy PolicyOpt out

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics for Firebase (Google LLC)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications.

Qrafter uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones.

Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United States and Ireland – Privacy Policy

Infrastructure Monitoring

This type of service allows Qrafter to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

Firebase Performance Monitoring (Google LLC)

Firebase Performance Monitoring is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States and Ireland – Privacy Policy


Information on Opting Out of Interest-Based Advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by:

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.


Further Information for Users in the European Union

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the "GDPR"), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Legal Basis of 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.
  • 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 Rights of Users Based on the GDPR

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:

  • 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.
  • 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 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 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.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law.


Further Information for Users in Brazil

This section applies to all Users in Brazil, according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

The Grounds on Which We Process Your Personal Information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

  • Your consent to the relevant processing activities
  • Compliance with a legal or regulatory obligation that lies with us
  • The carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments
  • Studies conducted by research entities, preferably carried out on anonymized personal information
  • The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract
  • The exercising of our rights in judicial, administrative or arbitration procedures
  • Protection or physical safety of yourself or a third party
  • The protection of health – in procedures carried out by health entities or professionals
  • Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests
  • Credit protection

Your Brazilian Privacy Rights

You have the right to:

  • Obtain confirmation of the existence of processing activities on your personal information
  • Access to your personal information
  • Have incomplete, inaccurate or outdated personal information rectified
  • Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information
  • Obtain information on the possibility to provide or deny your consent and the consequences thereof
  • Obtain information about the third parties with whom we share your personal information
  • Obtain, upon your express request, the portability of your personal information to another service or product provider
  • Obtain the deletion of your personal information being processed if the processing was based upon your consent
  • Revoke your consent at any time
  • Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies
  • Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law
  • Request clear and adequate information regarding the criteria and procedures used for an automated decision
  • Request the review of decisions made solely on the basis of the automated processing of your personal information

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.


Further Information for Users in the United States

This section applies to all Users who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

Categories of Personal Information Collected

Identifiers

Personal Information collected: Trackers, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service.

Purposes: Advertising, Analytics, Infrastructure monitoring

Sold or Shared: Yes

Targeted Advertising: Yes

Internet or Other Electronic Network Activity Information

Personal Information collected: Trackers, Usage Data, unique device identifiers for advertising.

Purposes: Advertising, Analytics

Sold or Shared: Yes

Targeted Advertising: Yes

Your Privacy Rights Under US State Laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

  • The right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information.
  • The right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you.
  • The right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information.
  • The right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
  • The right to opt out from the Sale of your Personal Information.
  • The right to non-discrimination. We will not discriminate against you for exercising your privacy rights.

Additional Rights for Users Residing in California

In addition to the rights listed above, as a User residing in California, you have:

  • The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising.
  • The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods.

Additional Rights for Other US States

As a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island or Montana you additionally have:

  • The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information.

How to Exercise Your Privacy Rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity.

California Consumers Under Age 16

We do not knowingly collect Personal Information of California consumers who are below the age of 16 nor do we Sell or Share it.


Additional Information About Data Collection and Processing

Legal Action

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 Qrafter 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.

System Logs and Maintenance

For operation and maintenance purposes, Qrafter and any third-party services may collect files that record interaction with Qrafter (System logs) or 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.

Changes to This Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Qrafter and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

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) / Personal Information (or Information)

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.

Usage Data

Information collected automatically through Qrafter (or third-party services employed in Qrafter), which can include: the IP addresses or domain names of the computers utilized by the Users who use Qrafter, 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, the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit and the details about the path followed within the Application.

User

The individual using Qrafter who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

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 Qrafter. The Data Controller, unless otherwise specified, is the Owner of Qrafter.

Qrafter (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Qrafter as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, as defined by the California privacy laws.

Targeted Advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User's device.


This privacy policy relates solely to Qrafter, if not stated otherwise within this document.