Web E Design Digital Lab, its subsidiaries and its affiliates (“Company”, “we” or “WEDDL”) respect the privacy of the users (including children) of their mobile applications (“User” or “you”) and are committed to protect the Users’ information. We believe you have a right to know our practices regarding information we may collect and use when you use our Apps (defined below).

IMPORTANT -WEDDL operates mobile apps which are oriented for children under the age of thirteen (13) (including, without limitation, mobile applications which are distributed within Domenico Longobardi, TELDA srls as well as mobile apps which are not targeted to children under the age of thirteen (13) that are distributed within WEDDL’s developer account under the brand “Web E Design Digital Lab” and do not include an age gate,  shall collectively be referred to as “Apps”. WEDDL’s privacy practices and principles are described in Chapters A,  B below.

1. Your consent (important, please read carefully!)

BY INSTALLING THE APPS ON YOUR MOBILE DEVICE, ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE APPS, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION. PLEASE NOTE: IF YOU OR, AS APPLICABLE, YOUR LEGAL GUARDIAN, DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MUST NOT INSTALL, ACCESS AND/OR USE THE APPS AND YOU ARE REQUESTED TO PROMPTLY ERASE ALL TABTALE APPS FROM YOUR MOBILE DEVICE.

If you are under the age of eighteen (18) , please ensure that your legal guardian has reviewed and agreed to this Privacy Policy.

Chapter A: 

With respect to collecting, using and disclosing personal information regarding children under the age of thirteen (13) (“Kids”) using our Apps:

We do not knowingly collect any personal information from Kids other than as expressly specified in Sections 3.2 and 3.3 below.

We hereby prohibit Kids from actively and directly providing us with any personal information other than as specified in Section 3.3 below. If you are a legal guardian of a Kid and believe your child has provided us with any personal information, please contact us at info@weddl.it and we will delete such information from our servers.

WEDDL may collect and maintain the information described in Section 3, directly or through certain products or services, solely for providing support for WEDDL’s internal operations as permitted under applicable laws and rules (described in greater detail below).

Third party providers of certain products or services operating on our behalf, such as advertising networks, analytics services etc. (“Third Parties”) may passively collect and maintain information about Users. Such Third Parties are carefully selected by WEDDL to ensure compliance with applicable privacy laws, and we confirm that they are compliant with the US Children’s Online Privacy Protection Act of 1998, this Privacy Policy and the rules promulgated by the Federal Trade Commission (FTC) under that Act, including but not limited to the Children’s Online Privacy Protection Rule 16 C.F.R. Part 312) (“COPPA”) and the policies and guidelines of the applicable Platform Provider (such as Apple or Google) in performance of their services for WEDDL and are compliant with GDPR UE Regolamentation.

Any question about Third Parties’ privacy practices and policies should be directed to our Privacy Policy Administrator by e-mail to:info@weddl.it. We will forward your inquiry to the applicable Third Party and make an effort to provide you with such Third Party’s response within a reasonable timeframe.

We included an age-gate in certain Apps to prevent access to specific features to Users who did not pass the age gate for protection of Kids (e.g. restricting behavioral advertising, information sharing by Kids, or the option to accept push notifications).

2. Offline Use

WEDDL allows an offline use (without Internet connection and without GPS enablement) of some features of its  Apps. Offline use of Apps will preclude collection by WEDDL and/or Third Parties of any information pertaining to the User and its use of the Apps.

3. Online Use

There are three types of data and information which may be collected from Users of our Apps:

3.1 Non-personal Information:

WEDDL and Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such Kids Non-personal Information, WEDDL and the Third Parties are not aware of the identity of the User from whom Kids Non-personal Information has been collected. Kids Non-personal Information collected by either WEDDL or Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ads, sites, applications and campaigns a User came from and associated revenue), App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone, etc.), data regarding User behavior within Apps (e.g. ad impressions, User’s response to ads, including ads viewed or clicked), User’s in-app purchases including data regarding receipt validation, User’s gameplay (e.g. level reached, frequency and time spent in the App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, virtual inventory items (if any), tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), other WEDDL Apps installed, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 13), and geo-location – only at a country and city level. It is hereby clarified that no street name is collected.

3.2 Kids’ Persistent Device Identifier and No Other Kids personal identifiable information:

WEDDL and Third Parties may passively collect a persistent device identifier from Kids, such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address (“Kids’ Persistent Device Identifier”). This is processed for the limited purposes of supporting the internal operations of the Apps. In the case of IP addresses, we keep these for 1 week for error logs, then delete them. WEDDL does not collect and does not permit Third Parties to collect from Kids any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about the Kids. We note that WEDDL may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.

WEDDl does not link any additional personally identifiable information to the Kids’ Persistent Device Identifier, even from other services. WEDDL does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Kids.

3.3 Information gathered through the Apps “Ask a Question” or “Support” type of a feature:

If a Kid e-mails a question to WEDDL, using the “Ask a Question” or “Support” type of a feature which may be available within the Apps, WEDDL may respond to such question by using the Kid’s e-mail address. Promptly after responding (or, at WEDDL’s discretion, not responding) to such question, WEDDL will delete the Kid’s e-mail address.

Purpose of the collection: The information described above is collected and processed solely for the purpose of supporting WEDDL’s internal operations. This means the following:

  • providing and improving Apps as well as ensuring proper functioning of the Apps and services;
  • maintaining or analyzing the functioning of the Apps and services;
  • authenticating Users (e.g. verify the User’s identity when he/she interacts with advertisements or acquires in-app purchases);
  • personalizing content and enhancing User experience;
  • performing network communications;
  • protecting the security or integrity of Users, Apps and services;
  • serving contextual advertisements;
  • capping the frequency of advertising;
  • ensuring legal or regulatory compliance;
  • fulfilling a User’s request under Section 3.3.

The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.

How is the Information about our Users of Apps being collected? The Non-personal Information and Kids’ Persistent Device Identifier are collected either by WEDDL or by Third Parties through the Users’ use of the Apps, including through Third Parties’ SDKs embedded in our Apps. Non-personal Information and the Kids’ Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Apps, such as “cookies-like technology” and local storage (see Section 19 below for further details on Cookies and Local Storage).

If Third Parties collect Non-personal Information, Kids’ Persistent Device Identifier and/or any other information directly from Kids, such collection and processing is governed by such Third Parties’ privacy policies and not by this Privacy Policy. However, all Third Parties are carefully selected to ensure compliance with applicable privacy laws, and we confirm that they are compliant with COPPA, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider in performance of services for TabTale.

3. Sharing Kids information with third parties

We may share the Kids’ Persistent Device Identifier only in limited cases, including the following:

  1. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
  2. to enforce this Privacy Policy or the Terms of Use, including investigation of potential violations thereof;
  3. to detect, prevent, or otherwise address fraud, security or technical issues;
  4. to protect the rights, property, or personal safety of WEDDL, its Users, suppliers, licensors, and/or licensees, or the general public;
  5. when WEDDL is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or
  6. pursuant to the approval of a Kid’s legal guardian, in order to supply certain services that such legal guardian or the User of the Apps may have requested from the Company.

5. Advertising

We accept ads from Third Party ad networks which may be displayed in Apps. These Third Parties ad networks are carefully selected to ensure compliance with applicable privacy laws, and we confirm that they are compliant with COPPA, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider in performance of services for WEDDL. Note that if the User of the Apps clicks on any of these ads, the User will leave our Apps and go to the advertisers’ site which the User selected, and the advertisers may use cookies and other tracking technologies to collect Non-personal Information and/or Kids personally identifiable information. We recommend that Kids and their legal guardians  review the terms of use and privacy policies of these advertisers. Their privacy policy, not ours, will apply to any of those interactions. WEDDL may also promote Apps in Third Parties’ applications and platforms.

In addition, WEDDL may advertise other WEDDL Apps within Apps. Such ads are not directed towards specific Users but are rather broadly posted onto random WEDDL Apps.

We use Google AdMob and block all sensitive content in settings as showed below:

setting advertising

 

Chapter B: Additional Terms and Conditions 

14. Third Party Providers

When you use the Apps Third Parties collect, store and/or process the information detailed in this Policy.

These Third Parties are carefully selected to ensure that they, and their related entities who may access Your information, provide Your information with equal protection to that stated in this Privacy Policy and required by applicable privacy laws and the Platform Providers’ rules, policies and guidelines. WEDDL uses commercially reasonable efforts to engage with Third Parties that post a privacy policy governing their collection, retention, processing and use of non-personal and personal information. For further information regarding the collection, processing and usage of your information by the Third Parties, please review their privacy policy practices. The following Third Parties require disclosure of their privacy policies in this Privacy Policy: Google AdMob https://policies.google.com/privacy?hl=en

15. The User’s compliance with Certain Additional Terms and Conditions

A User’s access to and use of the Apps (including use of Promotional Codes defined in TOU) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. WEDDL does not exercise control of such third parties and is not responsible for their privacy practices and their use of the Users’ personal information. You should review the privacy policies of these third parties to learn how they may collect and use your Personal Information.

16. Links to third party sites

Certain links provided in the Apps through ads or otherwise permit Users to leave our Apps and enter non-WEDDL sites or services. These linked sites and services are not under the control of WEDDL. Most of such linked sites and services provide legal documents, including terms of use and privacy policies, governing the use of these sites. It is always advisable to read such documents carefully before using those sites and services so that you know what kind of information they are collecting.

17. Cookies & Local Storage

When you access or use the Apps, we and/or our Third Parties may use industry-wide technologies such as “cookies”, web beacons, tags and local storage (or other similar technologies), which store certain local information on your device (“Local Storage”), to identify a User’s device and ‘remember’ things about the User which may enable automatic activation of certain features (for example, if a User muted the sound within the App at a certain stage, this preference will be stored in the cache on the device and maintained the next time the User accesses the App on his device), monitoring of use of the Apps (counting Users who visit certain pages, use certain tools, viewed certain advertisements), frequency capping (for example, if we promote another App, this ensures that we do not advertise the same App more than a set number of times), to improve the quality of our services, measure ad performance, provide relevant ads etc. and making the User’s App experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User’s device. WEDDL and/or Third Parties may access such information. Third Parties may use both session cookies (which expire once you close the App) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Apps may store non-personal information (such as the different pages viewed by a User within the App) as well as User persistent identifier and geo-location data, which will be collected in accordance with the terms specified herein. It is easy to prohibit and/or delete the Local Storage, including via uninstalling the App from your mobile device and/or through the Settings option of your device. Most browsers and platforms will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the settings option of your device or according to the specific instructions provided by the technology provider and/or Third Parties privacy policies and terms of use. However, if you block or erase cookies, or change the settings of your device, your App experience may be affected and may be limited.

18. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services

A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifier or limiting ad tracking setting. If you are using a Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent that such options exist) may not cease all tracking activities by WEDDL’s Third Parties’ service providers.

If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such Third Parties and follow the instructions specified therein.

19. International Data Transfer

We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. We will take steps reasonably necessary to ensure the protection of your Personal Information (such as making transfers subject to standard contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection).  Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. You can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.

21. Deletion and Modifications of Information

You or, as applicable, your legal guardian, may request, by sending us an email to info@weddl.it the following:

  1. to receive access to, amend, and/or delete your Personal Information and/or, as applicable, Kids’ Persistent Device Identifier, that we may hold, and/or that we cease collection or use of your Personal Information; and/or
  2. that we request Third Parties who collected through the Apps the User’s Personal Information and/or, as applicable, the Kids’ Persistent Device Identifier, to do the same. WEDDL will use reasonable efforts to ensure that such Third Parties do so.

We note that some of these actions may be done directly through the settings of your Account.

After you have stopped using the Apps and/or following the termination of your Account, we will retain User’s Personal Information, and, as applicable, Kids’ Persistent Device Identifier, collected through the use of the App for a reasonable period, as is necessary to fulfill the purposes for which it was collected, as those are specified above, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, to enforce these Terms and our agreements and/or to enable Users to reinstate their Account, all as permitted under applicable privacy laws.

Personal Information that a User has shared using our Apps via any Social Network or third party Platform cannot be amended or deleted by WEDDL, where such information is in the control of that Social Network or third party Platform. We note, however, that you can modify data that a Social Network or Platform shares with us, or stop our Apps interacting with that Social Network or Platform by adjusting your settings with that third party provider. However, should you choose to block such interaction, you may not be able to enjoy all the features of our Apps. Aggregate and/or anonymous information may remain on our servers indefinitely.

22. Security

Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. TO THE FULLEST EXTENT PERMITTED BY LAW TABTALE SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.

23. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Apps and any information collected therein. WEDDL reserves the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Apps and/or our website at https://www.weddl.it Such material changes will take effect five (5) days after such notice was provided on our App and/or Site, whichever is the earlier. Otherwise, all other Changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Apps on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

24. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: info@weddl.it and we will make an effort to reply within a reasonable timeframe.