Privacy Policy (Draft)

This is a draft version of our updated privacy policy and is subject to changes before becoming final and effective. The current effective privacy policy can be viewed at https://www.smartlauncher.net/privacy-policy. We will inform our users once the revised privacy policy is officially adopted and provide ample notice before any changes take effect. In the meantime, we welcome any feedback or questions.

At Smart Launcher SRL, we respect your privacy and are committed to protecting your personal information. This policy explains what data we collect, how we use it, your rights, and how we ensure compliance with global data protection regulations, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Lei Geral de Proteção de Dados (LGPD), and other international privacy laws. By using our apps or website, you agree to this Privacy Policy. If you disagree, please stop using our services.

1. Apps and Website Covered

This Privacy Policy applies to our apps, including but not limited to Smart Launcher and Icon Pack Studio, as well as our websites.

2. Who We Are

The data controller for all apps provided by Smart Launcher SRL is:
‍
Smart Launcher SRL, Via Scaloria 129, 71043 Manfredonia (Italy)
Email: contact@smartlauncher.net
‍We operate primarily in Europe, and your data is stored on servers located in the European Union.

3. How We Handle Your Data

We take precautions to ensure your data is safe from unauthorized access, sharing, or changes. We process your data using secure systems in compliance with GDPR’s principles of lawfulness, fairness, and transparency.

In the event of a data breach that compromises the security of your personal information, we will take immediate steps to mitigate the breach and notify affected individuals and authorities as required by law. We will inform you of the nature of the breach, the data involved, and steps taken to address it. Where required, notification will be made within 72 hours of discovering the breach, in compliance with GDPR and other applicable regulations.

4. What Information We Collect

1. 4.1 App and Website Usage: We collect data on how you interact with our app or website, such as which features you use and which pages you visit. However, we do not collect usage data about other apps on your device or websites that are not our own.
2. 4.2 App List: In some cases, like using Smart Launcher’s app sorting feature, we collect information about the apps on your device. This data is transmitted to us separately from any other data that could personally identify you, ensuring it remains anonymous. We only use this data to improve your experience, and it is not shared with any third parties.
   
3. 4.3 Transaction Details: If you purchase any of our products or services, we collect details about your transactions.
4. 4.4 Authentication Data: If you log in to our services using third-party authentication providers (e.g., Google Login), we may collect personal information such as your email address and other information shared by the third-party provider based on your consent. This information is used solely for authentication purposes.
5. 4.5 Voluntary Information: We collect personal information (e.g., name, email) that you voluntarily provide when you contact us for assistance or fill in forms on our website or apps. This information is collected to provide you with support, respond to inquiries, and fulfill any requests you submit.
6. 4.6 Cookies & Identifiers: We only use technical cookies to ensure the proper functioning of our website and apps. These cookies do not track your activity for advertising purposes.

5. Legal Basis for Data Processing

We collect and process your personal data under the following lawful bases as outlined in Article 6 of the GDPR:

1. 5.1 Performance of a Contract: When processing is necessary to deliver the services you request, such as when you use our apps.
2. 5.2 Legitimate Interests: We process data to improve our services and to ensure security, provided that this does not override your rights and freedoms.
   
3. 5.3 Consent: When required, we will obtain your explicit consent for certain types of processing, such as sending marketing communications.

6. Device Permissions

1. 6.1 Access to Address Book: Some features, like searching contacts, require access to your Address Book. We do not collect or share this data.This permission is optional and can be enabled or disabled at any time.
2. 6.2 Access to Location: The app may require access to your location, for example, to display the weather forecast. In such cases, we share your approximate location (city level) with the weather forecast provider to enable the service. This permission is optional and can be granted or revoked at any time.
   
3. 6.3 Access to Storage: The app may need access to your storage, for instance, to allow you to search for a specific picture or file, or to access the wallpaper in use. We do not collect or share this data. This permission is optional and can be granted or revoked at any time.

7. IP Addresses & Cookies

We automatically collect technical data, including your IP address, browser type, and operating system, as these are transmitted whenever you connect to our servers.

This collection follows industry best practices to help manage server security, troubleshoot issues, and optimize performance.

For instance, monitoring IP addresses allows us to detect unusual patterns of activity, such as repeated requests from the same IP address, which may indicate a potential security threat (e.g., a DoS attack). We also use technical cookies to enhance your experience and ensure smooth functionality. For more details, please refer to our Cookie Policy.

8. Where Your Data is Processed

Your data is processed at Smart Launcher SRL’s offices in the EU and other locations where our service providers operate within the EU. We do not transfer your personal data outside of the European Economic Area (EEA). If any transfer occurs, we ensure that the receiving party provides an adequate level of data protection as required by GDPR.

9. Detailed Information of the Processing of Personal Data

We collect personal data for the following purposes and use the following services:

10. Advertising

On apps that include ads, we may show you ads based on your location or how you use our apps. You might also receive promotional content if you respond to certain prompts. If ads are provided by third-party companies, their privacy policies will apply.

11. For Users Under 18

1. 11.1 You must be at least 16 to use our apps. If you are under 18, you need permission from a parent or guardian.
2. 11.2 We do not knowingly collect data from users under 16. If we find out that we’ve unintentionally collected such data, we will delete it immediately.
   

12. Sharing Your Information

We may share your data with third parties in the following situations:

1. 12.1 Mergers and Acquisitions: In the event that Smart Launcher SRL is involved in a merger, acquisition, or sale of assets, the data we collect may be transferred to the acquiring/acquired company.
2. 12.2 Compliance with Legal Requirements: We may share your data to comply with legal obligations, such as responding to a court order or legal request.

13. Your Rights (Global Data Privacy Rights)

We are committed to providing you with comprehensive privacy rights, regardless of your location. Under GDPR, CCPA, LGPD, and other privacy regulations, you have the following rights:

1. 13.1 Right to Access: You have the right to request access to the personal data we hold about you.
2. 13.2 Right to Rectification: You can ask us to correct any inaccurate or incomplete personal data.
3. 13.3 Right to Erasure ("Right to be Forgotten"): You can request that we delete your personal data, subject to certain conditions, such as when the data is no longer necessary for the purposes for which it was collected.
4. 13.4 Right to Restriction: You have the right to request the restriction of processing of your personal data under certain conditions, such as if you contest the accuracy of the data or object to its processing.
5. 13.5 Right to Data Portability: You can request a copy of your personal data in a machine-readable format, which can be transferred to another service provider if desired.
6. 13.6 Right to Object: You can object to the processing of your personal data for certain purposes, including direct marketing.
7. 13.7 Right to Withdraw Consent: If we are processing your data based on your consent, you have the right to withdraw your consent at any time.
8. 13.8 Right to Non-Discrimination (CCPA Specific): We will not discriminate against you for exercising any of your privacy rights.

Please note, since most of the data we collect is aggregated or associated with anonymous identifiers, we may be technically unable to provide or delete specific personal data. However, if you send us a request, we will do our best to fulfill it. Requests can be sent to contact@smartlauncher.net, we will respond to your request within 30 days in compliance with applicable privacy laws.

Under the California Consumer Privacy Act (CCPA), you have the right to know about the data we collect and how it is used. However, we do not sell any personal data.

14. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. The retention period depends on the specific type of data and the context in which it was collected. For example:

1. Data related to transactions: Retained for as long as required by tax and accounting laws
2. Data for marketing purposes: Retained until you withdraw your consent.
   
3. Anonymous and aggregated data: May be retained indefinitely for analytics and statistical purposes.

Once the retention period expires, we will securely delete or anonymize your personal data. You have the right to request the deletion of your data at any time in accordance with GDPR, and we will honor such requests unless we are legally obligated to retain the data.

15. Changes to This Policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within the app and/or using our official communication channels. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

16. Contact Us

If you have any questions or concerns about this policy or your data rights, feel free to reach out to us at contact@smartlauncher.net.

Effective Date: Not yet
Last Updated: September 2024