DAILY DIARY: JOURNAL WITH LOCK
PRIVACY POLICY
Last Updated Aug 19, 2022
AppManage Group #1, LLC (“Company“, “we”, “our” or “us”), acting under the Google Play and Apple App Store alias SimpleInnovation, understands the importance of protecting your privacy. This Privacy Policy explains what information of yours will be collected when you download, install, register with, access, or use this mobile application (the “App”), and how such information will be used and shared. It also explains choices you have to control the collection, correction and/or deletion of such information.
This policy applies only to information we collect in our App and in e-mail, text and other electronic communications sent through or in connection with our App. This policy DOES NOT apply to information collected in other apps or websites (including third-party websites you may access through the App), or information collected by any third party. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Should you not wish to have your information gathered or used as described in this policy, you may uninstall the App from the device(s) on which you have downloaded it.
Membership in self-regulatory frameworks
We are members of the Digital Advertising Alliance (DAA) (http://www.aboutads.info/), European Digital Advertising Alliance (http://www.edaa.eu/) and Japan Interactive Advertising Association (JIAA) (http://www.jiaa.org/). Therefore, we adhere to the cross-industry Self-Regulatory Principles for Online Behavioral Advertising, the IAB Europe EU Framework for Online Behavioral Advertising, and JIAA Behavioral Targeting Advertising Guidelines.
The information we collect, how we use it, and the limited ways in which we share it
User Data
When you use the App, you have the option of providing us with any of the following information, which we refer to as your “User Data”:
Your first name or preferred means of address;
Your email address;
Personal notes, which could, depending on what was entered, contain information which could on its own or together with other information, be used to personally identify you (“Personally Identifiable Information” or “PII”).
By default, your User Data will only be stored locally on the device from which you access the App. We cannot access your User Data if it is only stored on your device. If you so choose, you may elect to have up back-up your User Data, in which case we will upload it to Google Drive. My Diary use and transfer to any app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Your User Data is encrypted when stored in the cloud, and a limited number of our employees are the only individuals who may access it. If you elect to store your User Data in the cloud, we will ask you to provide a password to prevent unauthorized access to your User Data, and your email address so that you may reset your password if you forget it. If you choose to provide one, your name or preferred means of address will only be used to give you a more personalized experience in-App, enabling the App to refer to you by that name or other means of address. Other than these limited uses, we do not use the User Data you provide, and it is only provided to facilitate your own use of the App.
Voluntary Application Feedback
You may provide us with feedback regarding the App, either via reviews and rating in the app store, or via email. App Store reviews and ratings are posted in a public forum on app stores, we and the public can see them. We take your feedback seriously, and often implement or incorporate user feedback. Email feedback is managed by our support staff, and neither your email nor your feedback is shared with third parties.
Analytics Data
Anonymous data, which we refer to as “Analytics Data,” regarding your use of our App is tracked and transmitted to us by our Apps themselves. Analytics Data consists of:
A device identifier enabling other issues on the same device to be located;
Crash logs, enabling application failures to be investigated; and
App interaction signals and event data, typically indicating when an application feature has been used in a certain way.
We use Analytics Data to fix and improve the App and evaluate features, including if and when users use different features, and how quickly new features are found. Analytics Data is anonymized, meaning it cannot be traced back to you. We process Analytics Data using Google Analytics, Firebase, and Microsoft App Center, but do not otherwise share it.
Advertising Data
Like many apps, our App is in part supported by advertising. Unless you opt-out, discussed more below, we may serve ads to you by transmitting to our select advertising partners a standard advertising identifier (an “Advertiser ID”) that we collect from your device. Advertising IDs are standard across the mobile advertising industry and are used to identify a particular device for advertising purposes. Advertising IDs are random identifiers that are generated by and tied to your mobile device. An example from a Google Android device looks like this: cdda802e-fb9c-46af-9846-0233d394c712.
Advertising IDs are typically generated once per device, so your device would always be associated with the same Advertising ID. Advertising IDs don’t contain any Personal Information in and of themselves. However, because they are typically static, a device will maintain the same Advertising ID over time, it is possible for third parties to use an Advertising ID in conjunction with location data they could collect from your device or from other apps you use, and other apps known to be associated with your device’s Advertising ID, to create inferences about you. Both Apple’s iOS or Google’s Android operating system provide a mechanism for users to reset or disable their device’s Advertising ID. If you elect to disable your Advertising ID, we respect that choice and will not send your device’s Advertising ID to our advertising partners.
Our Period Calendar applications transmit a device’s Advertising ID without adding any other Personal Information or other additional information. We believe this results in an excellent user experience with relevant and helpful advertising, while also protecting your privacy and safety.
Purchase Data
When you purchase a subscription or other in-app item from the Apple App Store or Google Play store, that transaction is processed by the relevant app store, and not by our Company. We have no access to your payment instruments and can see only the very limited view of the transaction shared with us by the app store. The limited data we receive consists of an order ID generated by the app store, price information, the date and time of the purchase, and may in some cases contain your ZIP code of the purchaser. This limited purchase data is only used by our support staff to request refunds for you when appropriate, and is not shared with any third party.
The uses above enumerate the limited ways in which we use the information provided by or collected from you and your mobile device when you use our App. If we are required to, we may also use your Personal Information to respond to a valid and enforceable court order, law, or legal process.
If we are involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of our assets or business, that could involve your Personal Information and User Data being transferred to the buyer or surviving entity. We value your privacy, and we will, if allowed, use reasonable efforts to notify you when your Personal Information is transferred, by posting such notice on our website or the App, and/or by contacting you if you have provided us with an email address. In the event of a transfer of Personal Information, we will instruct the buyer, surviving entity, or other third party recipient that absent your permission to do otherwise it may only use your Personal Information covered by this Privacy Policy in accordance with this Privacy Policy, even after the transfer. However, following such transfer we cannot guarantee or enforce that any such third-party will abide by our instruction. Any new information you provide after any such transfer will likely be subject to a new policy, and you should review that policy.
Third party advertising partners
As mentioned, we may provide the Advertising ID associated with your the Apple or Android mobile device to the third-party ad servers or ad networks listed below (“Advertisers”). While we do not share any other data with your Advertising ID, it is possible for Advertisers to independently collect information about your online activities over time and across different websites, apps, and other online services websites by tracking your Advertising ID elsewhere. Advertisers may use this information (including the information we provide to them) to provide interest-based (behavioral) advertising or other targeted content to your mobile device.
The App includes the use of the following services:
Service | Contractual partner | Services | Privacy Policy |
Google LLC, USA | • Google Analytics • Google Analytics for Firebase • Google Tag Manager • Google AdMob |
GA – https://policies.google.com/technologies/partner-sites Firebase – https://firebase.google.com/support/privacy |
|
Amazon | A9.com, Inc., USA and Amazon Europe Core S.a r.l., Luxembourg and Affiliates | Amazon APS | https://aps.amazon.com/aps/privacy-policy/ |
Facebook, Inc. USA and Facebook Ireland Limited | Facebook Audience Network | https://www.facebook.com/about/privacy/update/ | |
AppLovin | Applovin Corporation | Measurement / personalization of ads | https://www.applovin.com/privacy/ |
Fyber | Fyber (acquired by Digital Turbine, Inc.) | Measurement / personalization of ads | https://www.digitalturbine.com/privacy-policy/ |
InMobi | InMobi (f/k/a mKhoj) | Measurement / personalization of ads | https://www.inmobi.com/privacy-policy/ |
IronSource | ironSource Ltd. | Measurement/ personalization of ads | https://www.is.com/privacy-policy/ |
Unity | Unity Software Inc. (d/b/a Unity Technologies) | Measurement / personalization of ads | https://unity3d.com/legal/privacy-policy/ |
Vungle | Vungle, Inc. | Measurement / personalization of ads | https://vungle.com/privacy/ |
Pangle | Pangle | Measurement / personalization of ads | https://www.pangleglobal.com/privacy |
We do not control all of the Advertisers’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should consult the respective privacy policies of the Advertisers. This Company privacy policy does not apply to the Advertisers further mentioned. For information about how you can opt out of receiving targeted advertising, see Choices About Your Information below.
How we protect your information
The Company uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your data. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Choices about your information
We strive to provide you with choices regarding the information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
Advertising IDs. You may object to the transfer of your Advertising ID at any given time with immediate, future effect by adjusting the settings on your mobile device to, depending on your operating system, disable the Apple-Ad-Tracking via IFDA or to opt out of interest-based ads via the Google advertising ID. The mechanism for opting of out of interest-based ads is different for each device, so please consult the user manual for your device’s operating system for specific instructions. Additionally or alternatively, you can reset your Advertising ID at any time (and as frequently as you would like), which causes Google’s or Apple’s system to build your device’s profile for advertising purposes anew, so that advertisers cannot link your activities taking place prior to the reset to your device.
Other Tracking Technologies. Depending on your device, you may be able to adjust the settings of your device to disable or refuse app cookies and/or other tracking technologies. Please note that we do not access your device’s do-not-track settings, and we therefore do not respond to such settings. Third party advertisers, ad networks, and ad servers that display ads in our App may, however, access and respond to your device’s and browsers’ do-not-track signals; if you would like to know how a third party advertiser responds to do-not-track signals sent by your device or browser, please consult their privacy policy.
Targeted Advertising by Third Parties. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In general, to find out more about how to opt out of receiving targeted ads from a particular advertiser click on the AdChoices icon or link (or similar icon or link) appearing in or near the ad. You can also opt out of receiving targeted ads from members of certain ad networks as follows:
If the Advertiser is a member of or advertises through: | To Opt Out |
Digital Advertising Alliance | Install and use the AppChoices App |
European Interactive Digital Advertising Alliance | Opt out at http://www.youronlinechoices.eu/ |
Google Ads | Learn how to opt out at Google Ads Help - Opt Out. |
You can stop all collection of information by the App by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the App’s marketplace or network.
Accessing, correcting and updating your information; your rights regarding your information
Access, Review, and Modification of Information; Deleting Information
Users may request to access, update, change, or delete their Personal Information via the Contact page on https://www.simpleinnovation.us/contact or by email at diary@simpleinnovation.us.
We will attempt to respond to your requests within one month and free of charge. Please note that with regard to all these rights, we reserve the right to:
Verify your identity in order to process the request, or request further information for this purpose;
Refuse your request based on the exemptions set out in any applicable data protection laws; and
Charge you a reasonable administrative fee for any repetitive, manifestly unfounded, or excessive requests.
Your California Privacy Rights
As noted above, we do not sell or share any User Data. We may, however, provide Advertising IDs from your device to Advertisers. Under certain laws, including California law, the provision of Advertising IDs may constitute a sale of Person Information. As discussed above, you may at any given time with immediate, future effect by adjusting the settings on your mobile device to, depending on your operating system, disable the Apple-Ad-Tracking via IFDA or to opt out of interest-based ads via the Google advertising ID. Please see the Choices About Your Information section above for more information.
In addition, if you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third parties. Specifically, California law provides you the right to submit a request to us at the designated address in the Contact Us section below, or via the Contact page on https://www.simpleinnovation.us/contact or by email at diary@simpleinnovation.us, to request that we:
Disclose to you the following information covering the 12-month period prior to your request:
The categories of Personal Information we collected about you and the categories of sources from which we collected the Personal Information;
The business or commercial purpose for collecting Personal Information about you;
The categories of third parties to whom we disclosed Personal Information about you, and the categories of Personal Information disclosed;
The specific pieces of Personal Information we collected about you;
Delete the Personal Information we collected from you; and
Correct Personal Information we collected from you.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. In addition, you have the right to be free from discrimination by a business for exercising these rights.
Under California law, you also have a right to know that, as described in The Information We Collect, How We Use It, And The Limited Ways In Which We Share It section above:
In the last 12-month we have collected the following categories of Personal Information:
Personal unique identifiers, when you provide us with a name or other preferred means of address;
Personal information, when you provide us with an email address, if we receive a zip code from an app store, or if you upload personal health information such as information about your cycle or sexual activity; and
Biometric information, when you provide us with information about medicines taken, temperatures, or measurements;
In the last 12 months we have shared Personal Information for a business purpose when:
users elect to have their User Data stored in the cloud and we send such data to Google Cloud; and
we provide anonymized Analytics Data to Google Analytics; and
In the last 12 months, unless you have opted-out, as described above, we have provided your device’s Advertising ID to our Advertisers, which may be considered a “sale” or Personal Information.
Data subjects in the EU
If you are located in the EU when using our services, the following information is relevant for you:
To contact our Data Protection Officer, you may send an email to diary@simpleinnovation.us with the subject ATTN: DPO. Through the use of SDKs, we allow our advertising partners in the US to collect non-PII data, which they store and use for targeting. The data recipients are regularly self-certified under the EU/US Privacy Shield (if located in the US) or may have agreed with us to apply the EU Model Clauses Controller to Controller or Controller to Processor. All three measures have been accepted by the European Commission under an Adequacy Decision as ensuring a sufficient level of data protection. The legal basis of the processing of the information is Art. 6 para 1 lit a) GDPR, your consent. You may withdraw your consent at any given time with future effect by following the withdrawal mechanisms described in the Privacy Policies of our partners, the Opt-Out procedures provided by the DAA, EIDAA and Google Adds described above, modifying the Settings in the app(s) you use or by uninstalling the app. You are not obliged to provide your information to us, neither by operation of law nor contract. If you do not provide consent to us, we will not be able to personalize your ads or measure your use of our services. You have the right to request access to and rectification or erasure of personal data and restriction of processing as well as a right to data portability and you may always lodge a complaint with a supervisory authority.
Changes to our Privacy Policy
We reserve the right to modify this Privacy Policy in our sole discretion. If we change our Privacy Policy, we will make the updated privacy policy available from within the App. Changes to this Privacy Policy are effective when they are posted. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.
Contact us
If you have any questions or concerns about our Privacy Policy, please contact us at diary@simpleinnovation.us.
AppManage Group #1, LLC : 15127 NE 24th Street
Ste 132
Redmond, WA 98052