1. Introduction

{LIGHTEN APPS LTD} (“LIGHTEN APPS LTD”, “we”, “our”) is committed for protecting the privacy of our mobile application users visitors (the “App”, and “you”, “your” or “user”), respectively) That starts with helping you understand our privacy practices. The following information describes how LIGHTEN APPS LTD collects and processes information about you when you use our App.

This document (the “Privacy Policy”) aims to provide you with a clear understanding of what information we collect and why we collect it, how it is used and shared, how we secure your information and the choices available to you regarding the collection of such information.

We strongly encourage you to read this document in conjunction with our privacy overview, which summarizes the key aspects of our privacy practices.

The App is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.

IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE WEBSITE, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY.

1. Data Collection and Use

Through your use of our App, we collect information in the following ways:

• Automatically Collected Data: Some information is automatically gathered when you use our App. This includes non-personal information like session durations, the content you access on the App, the frequency and scope of your use, and details about your computer and internet connection, such as the operating system and browser type and Personal Information.
• Voluntarily Provided Personal Information: Information that can personally identify you may also be collected, which includes but is not limited to your full name, email address, and the location of the computer used to access the Website (the “Personal Information”). This Personal Information is collected during your interaction with our App and when you contact us.

The Personal Information collected by us include the following:

• Online Identifiers:  such as your Internet Protocol address, device ID, Google advertising ID (GAID), etc. Where we process such Online Identifiers for operational, functional, and security purposes, we process your data based on our legitimate interest. Where we use the Online Identifiers for marketing, personalized ads, and tracking it will be based on your consent provided through the Apps’ organic permissions. 
• App Permission: depending on the App used or the features you wish to enjoy, you will be asked to grant us access permissions such as: Precise location permission (ii) Installed Application Information – include the list of application installed on your device (iii) Photo Library – access to your camera roll and photo library (iv)  Phone – access to your call log and contacts; (v) Storage – we may collect through your storage permission data on your USB storage; (vi) Network – we may collect through your network permissions list of devices and networks your device “see” and connection history of your device. Prior to activating each Permission, we will provide you information regarding the data sets which are processed through such Permission and the purpose of use of such Permission. To allow Permissions, you will need to actively and explicitly enable them through an in-app permission or through your mobile device settings, depending on the Permission.  Each Permission is provided separately, and you can decide to either accept them all, accept partly, or none of them. Please note, you can disable the App Permissions at any time, however, depending on the App Permission you disable a feature or all features might not properly operate.
• Our App may include advertisements (Ads) placed via our partners’ SDKs, as detailed below, and may collect personal data such as your IP address, online activities, and demographic data. This information is used for the purpose of displaying targeted advertisements (Targeted Ads). If you prefer not to receive Targeted Ads or to prevent other interest-based advertising identifiers from being used in the App, you can adjust your App settings to reset these preferences or opt-out of such advertising through your device settings. Please be aware that opting out of Targeted Ads does not mean you will no longer see Ads in our App. However, these Ads will not be personalized based on your interests. We process this data based on your consent, as required by applicable laws. You may withdraw your consent at any time through the App settings or your device settings (e.g., opting out of advertising ID or tracking).
• Purchase Data. When you decide to make a purchase on our App, the payments are in-app payments and shall be subject to the app store terms and privacy: Google Terms of Service; Google Privacy Policy
  We do not keep any payment data, however, we process commercial transaction data such as records of purchases and prices, shipping details (if applicable), address, phone number and email address.

We may use the collected information as part of our Services and operations as follows:

• Providing the Services and App features: in order to operate our App and provide you with the App services and other features that can be accessed and used through the App we will need to access, collect and process the Personal Information.
• Improvement and Development of Services: We analyze the collected information to improve and develop our Services. This includes reviewing and enhancing the user-friendliness of our App and ensuring it aligns with your feedback and our business goals.
• Maintaining a Safe and Secure Environment: Your information is used to enhance the safety and security of our App. This includes preventing fraud, verifying identity, and taking actions against activities that violate our terms of service or applicable law.
• Personalizing Content, Advertising, and Marketing: We leverage personal information to customize our App’s content and marketing strategies including delivering of ads to better suit your interests and enhance your overall experience.

1. Security Measures

Our top priority is to ensure the privacy of your Personal Information that we collect and use for the purpose of providing you with our Services.

We are considering the sensitivity of data that we are storing and processing. Our security team and developers are following common security best practices integrated into each process and system, to protect them against common security threats.

Our implemented security measures combine technological, administrative, and operational security controls together to ensure optimal security of all information assets.

1. Cookies

We use “cookies” and similar tracking technologies such as software developer kits (”SDKs”) when you access or use our Services. Such tracking technologies are small text files that a website (cookie) or an application (SDK) places and stores on your device while you are viewing or using such interfaces.

Such tracking technologies are very helpful and can be used for various purposes. These purposes include: (i) allowing you to navigate between pages efficiently; (ii) enabling automatic activation of certain features; (iii) remembering your preferences; and (iv) making the interaction between you and our Services quicker and easier.

Cookie & SDK	Purpose	Privacy Policy
Google Analytics	Analytical & Measurement	www.google.com/policies/privacy/partners https://policies.google.com/technologies/managing?hl=en https://tools.google.com/dlpage/gaoptout For additional information regarding our use of Google products, click HERE.
Wix.com	Operational & Functional	https://www.wix.com/about/privacy
AppsFlyer	Attribution – Analytical & Measurement	https://www.appsflyer.com/legal/privacy-policy/ To opt out: https://www.appsflyer.com/legal/opt-out/
Adjust GmbH.	Attribution – Analytical & Measurement	https://www.adjust.com/terms/privacy-policy/
Game Analytics	Analytical & Measurement	https://gameanalytics.com/trust/legal/privacy-faq/
FireBase	Analytical & Measurement	https://firebase.google.com/support/privacy
SmartLook	User behavior – Analytical & Measurement	https://help.smartlook.com/docs/privacy-policy
Unity	Game engine	https://unity.com/legal/privacy-policy
OneSignal	Push notifications	https://onesignal.com/privacy_policy

1. Your Data Protection Rights

The law establishes specific rights that must be granted to each data subject whose data is collected and processed by an organization. As a data controller, We are responsible for informing you your rights in accordance with applicable regulations.

• The right of access: You have the right to request from us a copy of your Personal Information that we have collected from you.
• The right to rectification: You have the right to request us to correct/update any Personal Information of you that is not correct.
• The right to erasure (‘right to be forgotten’): You have the right to request us to erase your Personal Information, under certain conditions.
• The right to restrict processing: You have the right to request us to restrict the processing of your Personal Information, under certain conditions.
• The right to data portability: You have the right to request us to transfer your data that we have collected to another entities, or directly to you.
• The right to object: You have the right to object to the processing of your Personal Information by our organization.

To exercise these rights, or for any GDPR-related inquiries, please contact us at privacy@lightenapps.com.

1. Data sharing and Transfers Outside the EEA

In line with our commitment to privacy and GDPR principles, we may need to share your Personal Information under certain circumstances:

• With Third Parties: To perform our contractual and legal obligations, it may be necessary to share your Personal Information with third parties. This includes affiliates, subsidiaries, or third-party service providers who assist us with services such as marketing, data management, maintenance and including advertisers to provide you with Ads.
• For Analytics: We also share information with analytics service providers for analytics services, which helps us in compiling aggregated statistics about the effectiveness of our App and Services.

These third parties may be located in countries outside of your own. In such cases, we ensure that they comply with obligations similar to those in this Privacy Policy and adhere to our data privacy and security requirements. They are permitted to use the Personal Information only for the purposes we specify. When transferring your Personal Information internationally, we use appropriate and suitable safeguards, including a variety of legal mechanisms like contracts, to ensure your rights and protections travel with your data.

• For Business Purposes: In certain scenarios, such as corporate mergers, consolidations, sales of assets, or other fundamental corporate changes, your information may be transferred.
• For Compliance: We may release information in compliance with legal obligations, such as warrants, subpoenas, or court orders, or in special cases, such as unlawful acts using our Services, security breaches, or physical threats.

1. Data Retention

We retain Personal Information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Once the data is no longer needed, we will securely delete or anonymize it.

1. Updates to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable regulations. We encourage you to review this Policy periodically. The updated Policy will be effective upon posting on our website.

1. Ways to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us by email to: privacy@lightenapps.com