The provision of our application (hereinafter “App”), whether via websites or through various app stores, is brought to you by MGA Megaapps Limited of registered address Panagias Chrysopolitissis, 16 Ypsonas, 4181, Limassol, Cyprus postal address 6, Vasili Vryonides str. Gala Court Chambers, 5th floor, Office D, 3095 Limassol, Cyprus
(the “Data Controller” of your personal data). Consequently, “We”, “Us” and “Ours” refers to the Data Controller.
We have a designated data protection officer (DPO) to help us comply with the requirements of the General Data Protection Regulation (EU) 2016/679. You may contact the DPO directly by emailing dpo@lawgic.co.uk .
In the alternative, you may email Us with regards to queries of any nature (in particular, to exercise Your Rights) at support@anytalkapp.com
Users type their messages, which are sent via a data service to our servers, and routed to the intended recipient (who must also be a registered App User), if that recipient is online. If the recipient is not online, the undelivered message is held on our servers until it can be delivered. If the message is undelivered for thirty (30) days or more, the undelivered message is deleted from Our servers. There are different types of information we obtain, whether directly from you or automatically via your device when you use the App. Essentially, we only obtain what is strictly necessary to provide you with our services, no more, no less.
Information, relating to you or your device, is either identified automatically by Our systems, provided to Us by the operating system of your device or is input by you manually when filling out certain fields, authorizing certain actions in the Apps.
| Information you provide Us with: | Legal basis for processing |
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1. Telephone number when you log in to use the App as a registered user. Together with additional telephone numbers you wish to provide at a later stage. |
Performance of the contract with you. This is how the Service works, We cannot let you sign into the App without a valid telephone number. |
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2. Your full name, company name and avatar (an image of your choice to be shown when using the App). You can provide the same by logging in via one of the available social networks (Facebook, Twitter, Google, for instance). |
Your consent at the time of provision of the same. You can always change or replace your name and avatar within the App settings, or choose not to give any of those details (except the first name). And you do not have to give your true details, it is entirely up to you. |
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3. And if you do log in via a social network, you would do that via the “OAuth” method for secure login (read more about OAuth by following the link https://oauth.net/) Essentially, this is information from your public profile (with, for instance, Facebook) that you can control at any stage. |
Performance of the contract with you. Same as above, We could not otherwise provide you with our services as a registered user. |
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4. Messages (including encrypted and hidden chats) and attachments when communicating with support and other App users. Where you choose our end-to-end encryption, only you and the addressee may read those messages, not even Us (but that is industry standard nowadays). |
Performance of contract to respond to your queries and provide customer support. We do not use this information for anything else (for instance, we do not build your profile or target you based on your communication with us or with other users of the App). |
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5. Your contact list (whether from the device or a social network). This would allow you to link with your contacts from different areas, but not necessarily share your telephone number with them. For instance, if you have a friend with a Facebook account and you both link your Facebook accounts with the App, you will be able to communicate, but you will not see each other’s telephone numbers, until provided manually. |
Your consent when you allow access via the settings of your device (when it prompts you for access). Equally, you will have to enter your social network credentials to access contact list from that social network. You can always withdraw your consent and access to your contacts through the settings of the handset and your social network. |
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6. Email address to be used for authorization via email or confirming additional devices. We do not currently use your email for marketing purposes. If we ever decide to, it will be in Our legitimate interests to do so, but you will always have a chance to opt out of such marketing communications. |
Your consent when you provide that information to us in the settings. We will store just enough information about your email to honour your opt-out preference in the future. |
Strange, but that is it. The rest is the technical stuff that must be processed in order to provide you with our services.
| Information collected automatically or assigned by Us to you | Legal basis for processing |
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1. The server that hosts the App may record requests your device makes to the server, the details on device and browser you use, your IP address, date and time of access, city and country, operating system, browser type, mobile network information. |
Performance of the contract. The App would not operate otherwise, you need this to connect to the Internet. This data is used only for technical purposes – that is, to ensure the proper functioning and security of the App and to investigate possible security incidents. |
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2. Advertising identifiers provided by the operating system of your handheld device (such as, for instance, IDFA, GAID) |
Your consent to the provision of such identifiers given by default through the operating system of your device (Apple or Android, for instance). You are free to withdraw your consent by resetting those identifiers or opting out of interest based advertising. This may be done via the settings of your handset and/or your browser. We respect those choices you make through the settings of your device. |
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3. Various device identifiers, provided by the operating system (device ID or a vendor ID, for instance) or assigned by Us (Anytalk ID, for instance) |
Our legitimate interests in fraud prevention and potential unauthorized access from multiple devices/locations, ensuring the technical availability and security of the App. Moreover, Anytalk ID would allow you more privacy where you do not wish to share your telephone number with another User. |
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4. App version, OS version information, browser type, language used, make/model of your device |
Performance of the contract. We need to know this technical information so the App functions properly on your device. |
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5. All the events that naturally occur during your usage of the App (such as logs, events, hands played, purchase history, crashes of the App, system reports and so on). Statistical information with regards to App usage. |
Partly, performance of the contract and partly our legitimate interests in fraud prevention and potential unauthorized access, ensuring the technical availability and security of the App. Analysis of statistical information helps us to optimize the App in future updates, such usage does not affect your rights and freedoms and does not disclose any personal data of yourself or your contacts. |
We protect your data and do not treat your personal data in any way that would surprise you (unless We told you about it and you made an informed decision to consent to such usage).
For instance, We encrypt the password created by you at the sign up stage and then store your personal data on secure servers that would prevent unauthorized access or destruction of your personal data.
We use the advertising identifiers in strict compliance with the requirements of the operating systems (for otherwise We would be in breach of their usage terms). Thus, We only use those advertising identifiers to meet our contractual obligations towards the parties that brought you to Us (whether by you clicking on an advertising banner in our partners’ apps, watching the ad or otherwise).
Whenever We contact you, We would always give you the right to opt out prior to the first communication and at any time thereafter (see the section “Your Rights” below).
The purposes for processing the data provided by you include:
Depending on the type, your personal data is stored either until you delete that data, the App or after six months of inactivity. Some data (such as IP addresses or blacklisted email addresses used for fraud) may be held for longer in our legitimate interests to protect our business from losses and also to respect your choice of opt-outs from marketing emails.
Your data is stored on one of the secure servers that we rent and We use the recommended industry practices to keep your data secure. We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.
Amazon (the “Hosting providers”) are contracted to store your personal data. Those Hosting providers are in possession of various international security certificates that ensure safety of your data with them. You can read more onthe security measures of Hosting providers by following the links:
https://d1.awsstatic.com/certifications/iso_27001_global_certification.pdf ISO 27001 certificate
accessed on December 11, 2019
Thus, having the appropriate security with the Hosting providers when storing your data, We have to ensure that access to such data is provided on a need-to-know basis. Access to the Hosting providers is controlled via various technical and organizational measures that include:
We do not share your personal data with any third parties, except where We have to comply with Our legal obligation. Some of the data of our users is aggregated for statistical purposes and processed in the legitimate interests as stated in section 2 above.
This does not mean that We blindly follow disclosure orders. We will check each request to ensure it satisfies the relevant safeguards, contains a court order or is issued under a legislative measure for the prevention, investigation, detection or prosecution of criminal offences.
As stated above, We share your advertising identifiers with third parties to meet our contractual obligations and pay their dues or protect ourselves against claims for payment.
While your data may be accessed from different parts of the world on our behalf, We do not actually transfer your personal data outside the EEA. To any extent that data is accessed from abroad, We follow set contractual safeguards and protections to ensure that your data is as safe abroad as it is within the EEA.
Where a third party accesses your data on our behalf or upon our instructions (be it inside or outside the EEA), We use the relevant legal basis to comply with the data protection legislation. In cases where there is no finding of an adequacy decision by the European Commission, we use model contracts to safeguard your rights and data.
When you log in to use any of Our Apps via an SNS (such as Facebook) you provide Us with certain information from you profile for that site. The information provided via SNS varies and depends on a particular SNS (for instance, Facebook provides information on your name, age range, picture, gender, friends list and email address). You can untick the boxes for information you prefer not to share with us during the sign up process (except the minimum required for the purposes).
You can find out more about these settings at the SNS where you play Our App (for instance, you can edit the privacy and settings of your apps with Facebook by following the link https://www.facebook.com/help/218345114850283?helpref=about_content - last accessed December 11, 2019).
Your activity when using the App via an SNS will also be subject to the SNS’ privacy policy for their part of data processing (if any), but App does not post anything to your SNS without your permission.
You are entitled to the full spectrum of the rights under the General Data Protection Regulation and We will go out of our way to accommodate any valid request. You can either exercise your rights by deleting certain features through your device or by emailing us at support@anytalkapp.com to exercise all the other rights.
You have a wide array of rights that we respect. Among those the right to:
You may be required to provide certain proof of identify so that We do not disclose personal data to those that are not entitled to it.
If your personal data is erased at your request or in accordance with our data retention policy, We only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.
Please note, all requests should be emailed to Us at support@anytalkapp.com or sent to us by post. Due to the sheer volume of messages, in-App customer support messages cannot be regarded as an effective method of notice to Us.
For the purposes of paragraph (5), section 1798.130 California Consumer Privacy Act of 2018:
There is no consensus on how mobile application companies should interpret the DNT signals. For the purposes of the CalOPPA, We do not currently respond to DNT signals whether that signal has been received on a computer or a mobile device.
We use certain cookies when you visit our website, but We give you an opportunity to choose which of those optional, non-essential cookies you would want to keep. Check the relevant cookie policy for the website you are visiting.
We never knowingly collect or solicit any information from anyone of 13 years and younger. The App and its content are not directed at nor made look to appeal to such persons. Parents or guardians that believe that We hold information about their children aged 13 and under may contact Us at support@anytalkapp.com
Feel free to contact us at any time should you have any questions in relation to this privacy policy, either via email, by post or within App.
MGA Megaapps LimitedAttention: Data Protection
6, Vasili Vryonides str. Gala Court Chambers, 5th floor, Office D, 3095 Limassol, Cyprus
Support Team:
support@anytalkapp.com
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