‍Privacy Policy

Contents

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0. Introduction

Welcome to Kovalee (“Kovalee”, "we", "us" and "our"). Kovalee is an international entertainment company specialized in the publishing of consumer apps.

The purpose of this policy (the “Privacy Policy”) is to provide you with all the important information and explanations about how and why some of your personal data may be collected and processed by Kovalee when you use our website www.kovalee.app (the “Website”) or one of our applications (the “Apps”). This policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. Information Collection and Use

Website Apps
Categories of personal data collected

Information you provide to us: personal information that you provide to us such as when you complete a form on our Website, including but not limited to, your name, email address, phone number, country and company (and/or the industry your work in). We may also require information on your education and work experience in connection with a job opening at Kovalee for which you wish to be considered.

Our correspondence: if you contact us, we will typically keep a record of that correspondence.

Survey information: we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey.

Websites and communication usage: details of your visits to the Website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, browser language, access time, traffic data, location data, web logs, movements on the Website, referring web site addresses and other communication data. We may also collect information about the pages you view within the Website and other actions you take while visiting us. In addition, we may also use such technologies to determine whether you’ve opened an e-mail or clicked on a link contained in an e-mail.

Information relating to your usage of the Apps, e.g. downloaded app; subscription chosen; the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics; Internet Protocol (“IP”) address Information about your device or smartphone, e.g. device name, operating system version.

Information collected when you view or click on an ad for the Apps: Ads you clicked on; Gender / age group (on Meta) ; whether it leads to downloading the App or not.

We do not collect identification data or contact details. However, the app developer may collect such data. Please refer to its own privacy policy in order to obtain further information on how they process your personal data.

Purposes of our processing activities

  • To communicate effectively with you and conduct our business, including to fulfill your requests â–ş to respond to your contact / free trial / demo requests, your registration request to events organized by Kovalee or your appointment request with one of our experts, to respond to your partnership request if you were interested in doing business with us, to respond to your job application, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us;
    • Legal basis: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you)

  • To provide you with access to restricted Websites areas â–ş to provide you with an online account and access to restricted areas such as your dashboard, where you have filled in a form to create an account on our Websites. Please note that providing certain data (marked as such) is mandatory to create an account and that without such data, we will not be able to provide you with our full services.
    • Legal basis: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you)

  • To provide you with marketing materials: to provide you with email alerts, updates, offers and invitations to Kovalee events. We may also use your information for marketing our own and our selected business partners’ products and services to you by email, and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing (see below). We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you.
    • Legal basis: consent, legitimate interest (to provide you with updated news in relation to our products and services)

  • For research and development purposes: to analyse your personal information in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services;
    • Legal basis: legitimate interests (to allow us to improve our services)

  • To personalize your experience on our Websites â–ş to collect statistics about our Websites’ usage and effectiveness with various technologies and personalize your experience while you are on our Websites, as well as tailor our interactions with you.
    • Legal basis: consent, legitimate interest (to improve our Websites’ users’ experience)

  • To run analytics and understand how users interact with our product and services in order to continuously improve themeither directly or through third party partners
    Legal basis: consent when required by law; or our legitimate interest..

  • To run marketing campaigns on the apps and understand how users respond to them.
    • Legal basis: consent when required by law; or our legitimate interest.

    We can also collect and share this data:

  • To reorganise or make changes to our business â–ş in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy
    • Legal basis: legitimate interests (in order to allow us to make changes in our business)

  • In connection with legal or regulatory obligations â–ş We may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
    • Legal basis: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)

    2. Data retention

    Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain the information you provided to us as long as necessary to provide you with the services you requested through our Website and until the time limit for claims which may arise from those services has expired, or to comply with regulatory requirements regarding the retention of such data. So if we use your personal data for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.

    When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

    Behavioural data collected through the Apps is retained for the duration of the agreement with our partner (the app publisher), and then anonymized /deleted.

    3. Data sharing

    Your personal data is shared:

    • Internally with the Kovalee teams, and
    • Externally with our service providers helping us with some of our activities such as hosting providers, backend infrastructure providers, infrastructure monitoring, CRM, Marketing communication, user database management, internal databases.
      ‍
      For the Apps specifically, and with your consent when it is required by law:
      • Apps measurement, analytics, and optimization
        - Amplitude
        - Adjust
      • Marketing campaigns and advertising:
        - Snap
        - TikTok
        - Unity Ads
        - Apple
        - Meta
        - Google Admob
        - Ironsource
        - Applovin
      • A/B testing, Design and U/X, Crash reporting and fixing
        - Firebase
        - Google Analytics
      • And generally speaking, to provide our services to our business partners.

    More information is provided in the Cookies appendix.

    We contractually require these service providers to both keep your personal data confidential and not use it for any purpose(s) other than those necessary for the performance of our agreement with them.

    4. Data transfers outside the EEA

    Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal information as set out in this Privacy Policy.

    Where we transfer personal information from inside the European Economic Area (the EEA) to outside the EEA, we may be required to take specific additional measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

    Please contact us as set out in the “Contact” section below if you would like to see a copy of the specific safeguards applied to the export of your personal information.

    5. Cookies and trackers

    Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

    The Websites use internal and third-party cookies to achieve the purposes defined above.

    The Apps do not use these “cookies” explicitly. However, they use third party trackers to collect information and achieve the purposes defined above. When required by law, we will collect your consent to use such trackers.

    Further information and the list of cookies and trackers we use are provided in the Cookies annex.

    6. Security and storage

    We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

    Your personal data is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards.

    7. Link to other sites

    The Website and the Apps may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

    8. Your rights

    8.1. Marketing : You have the right to ask us not to process, or to stop processing, your personal data for marketing purposes. You can exercise your right to prevent such processing by checking or not checking certain boxes on the forms we use to collect your personal data, by contacting us as set out in the “Contact” section below, or by clicking on the link made for this purpose in any marketing communication with you.

    8.2. Under certain conditions, you may also have a right to:

    1. Further information: ask us further details on the use we make of your personal data;‍
    2. Access: request a copy of the data relating to you that we process;
    3. Rectification: update of any inaccuracies in the personal data we hold;
    4. Deletion: request deletion of any personal data for which we no longer have a lawful ground to use;
    5. Consent withdrawal: where processing is based on consent, to withdraw your consent so that we stop that particular processing;
    6. Objection: object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
    7. Restriction: restrict how we use your information whilst a complaint is being investigated.

    Please be aware that certain exceptions apply to the exercise of these rights and so you will not be able to exercise them in all situations. In addition, these will vary slightly between EU Member States. For instance, in France, in addition to the rights listed above, you also have the right to define directives as to how you wish your personal data to be used after your death. If you wish to exercise any of these rights, we will check your entitlement and respond within the applicable timescale.

    If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Supervisory Authority of your usual place of residence or place where the alleged breach to the law occurred. Please click here to see the list and contact information of the EU Supervisory Authorities: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

    9. Children’s Privacy

    We design apps and services that we hope all audiences will enjoy. This Privacy Policy is scoped for our Apps targeted to general audiences. We also recognize that some of our Apps and services may be “child directed” in nature and/or have a mixed audience (e.g. may appeal to Children as a subset of the larger audience) of users. For Apps we deem to have a “child directed” component or that may appeal to children, we take extra precautions to protect child users, provide parents choices and rights, and to comply with local privacy regulations.

    10. Changes to this Privacy Policy

    We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page.

    This policy is effective as of 2023-2-15.

    11. Contact

    If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at privacy@kovalee.app.

    Cookies Annex

    This annex aims at informing you about the tracking technologies that help Kovalee to achieve the purposes described in the Privacy Policy.

    For simplicity, all tracking technologies are defined as "Trackers" within this document – unless there is a reason to differentiate. For example, while cookies can be used on both web and mobile browsers, it would be inaccurate to talk about cookies in the context of mobile apps as they are browser-based trackers. For this reason, within this document, the term cookies (Cookies) is only used where it is specifically meant to indicate that particular type of Tracker.

    Some of the purposes for which Trackers are used may require your consent, depending on the applicable law. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

    Website

    The Kovalee Website does not use any Tracker.

    If this changes in the future, we will update this policy accordingly to inform you.

    Please note that the Website may contain links to other sites. If you click on a third-party link, you will be directed to that site (for example when you apply to an open position at Kovalee). Note that these external sites may use cookies Therefore, we strongly advise you to review the Cookies Policy of these websites. We have no control over and assume no responsibility for the practices of any third-party sites or services.

    Trackers used in the Apps

    In order to achieve the purposes described in our Privacy Policy, and to provide our services to the companies publishing the Apps you use, Kovalee uses Trackers through the Apps.

    These are statistical trackers that help us and the App publisher understand how you interact with the App and allow us to perform analysis and statistics on the behavior of users. These trackers require your consent.

    Tracker name Provider Purpose Expiration
    Adjust iOS SDK Adjust To understand how users interacts with the app and to optimize mobile ad campaigns 1 year
    Adjust AND SDK Adjust To undersatnd how users interacts with the app and to optimize mobile ad campaigns 1 year
    Amplitude Analytics iOS SDK Amplitude Behavior in the app: pages consulted, clicks, time spent, etc. 1 year
    Amplitude Analytics Android SDK Amplitude Behavior in the app: pages consulted, clicks, time spent, etc. 1 year
    Amplitude React Native SDK Amplitude Behavior in the app: pages consulted, clicks, time spent, etc. 1 year

    Third-party providers

    In addition to what’s specified above, you may find more precise and updated information regarding retention periods as well as any other relevant information – such as the presence of other Trackers - in the privacy policies of the respective third-party providers.

    Adjust: https://www.adjust.com/terms/privacy-policy

    Amplitude: https://amplitude.com/privacy

    RevenueCat: https://www.revenuecat.com/privacy

    Firebase: https://firebase.google.com/support/privacy

    How to manage preferences and provide or withdraw consent

    For each App, a banner will allow you to accept or reject the use of non-strictly necessary Trackers.

    Your choices will be registered for a reasonable period and may be modified by you at any time through the App.

    It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember your initial consent. Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

    Regarding any third-party Trackers, you can manage your preferences and withdraw your consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.

    You can find information about how to manage Cookies in the most used browsers at the following addresses:

    You may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings, such as the device advertising settings for mobile devices, or tracking settings in general (you may open the device settings, view and look for the relevant setting).

    Other trackers used in the Apps

    Please note that the Apps may contain other Trackers which are not implemented by Kovalee. Please refer to the App’s privacy policy for further information.

    Contact

    Kovalee, 11 rue des Petites Ecuries, 4eme etage, 75010 Paris, privacy@kovalee.app

    Given the objective complexity surrounding tracking technologies, you are encouraged to contact Kovalee should you wish to receive any further information on the use of such technologies by the Website or the Apps.

    This Cookies Annex was last updated in March 2023.