Effective Date: October 19, 2022
H’Appile Interactive (“us”, “we”, or “our”) operates the Crinkle application (hereinafter referred to as the “Service”).
H’Appile Interactive is dedicated to protecting your privacy and making transparent how we use your data and its purpose for our service.
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service.
Please note, Individuals must be able to consent to the processing of personal data to use the Service, i.e. be at least 13 years of age in the US, or greater if their respective jurisdiction requires (i.e. 16 years of age in the EEA, etc.) to be able to consent to personal data processing and use.
1 / DEFINITIONS:
–Service, Service is the iOS and/or iPadOS based Crinkle application operated by H’Appile Interactive, including all associated and/or affiliated backend services such as servers and/or data architectures/infrastructures, apis, websites, etc.
–You, You as referred to in this policy is meant to encompass the broad definition of a "user". In some instances this may mean simply yourself as an individual and may in other cases encompass an organization or group of individuals if you are representing such and advocating the use of the service in such place and/or on behalf of.
–Personal Data, Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
–Usage Data, Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit, action on a page, IP address, software version, etc).
–Cookies, Cookies are small files stored on your device (computer or mobile device).
–Data Processors (or Service Providers), Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
–Data Subject (or User), Data Subject is any living individual who is using our Service and is the subject of Personal Data.
–Children/Child for the purpose of this policy refers to individuals who are under the age of ability to consent to Personal Data processing in their jurisdiction (e.g. < 13 in the USA; < 16 in California, USA; < 16 in parts of the EEA, etc). Please refer to your state’s or jurisdiction’s specific requirements.
2 / INFORMATION COLLECTION AND USE:
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected:
2.1 / Personal Data
While using our Service, we may ask for and/or store certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
-cookies and usage data
-your legal name (only for Registered Authors, as outlined in terms of service section 2.1.6)
-region you reside in (only for Registered Authors, as outlined in terms of service section 2.1.6)
2.2 / Device, Geographic, Usage Data
When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, vendor unique device ID, the IP address of your mobile device, the geolocation of your use, the local timezone of your use, your mobile operating system version, the currently installed app version, the type of mobile Internet browser you use, the timestamp/date of your use, actions taken on the service, and other diagnostic data (“Usage Data”).
2.3 / Crash Reports
To improve and diagnose crashes of our service or application, we may collect crash logs and information when/if the platform experiences a crash during you use. This information may includes things such as operating system state (i.e. memory use, CPU use, etc), device state (like orientation, etc.) and specific "traces" or logs of activity (i.e. actions within the app like screen transitions/sequences, taps, etc.) leading up to and at the time of crash.
2.4 / Service & Tracking Data
We may collect service data. This may include the content and/or works, etc. that may be generated by your use of the service, etc. More details and depth on this type of data generation and our rights to, etc. are detailed in our Terms of Service.
We may also track things such as the frequency of and/or attributing of content you’ve recently accessed, used, modified, etc. on the service (i.e. tracking page reads). We use this service data and/or tracking metrics for the facilitation of our service. We do not share personally identifiable tracking information with other users (unless initiated by your request), however we may use these metrics for ranking works on popularity, trending stats, monetization calculations for authors, etc.
2.5 / Tracking Data
2.5.1 / Cookies
Cookies usually exist in web and browser based environments.
Cookies are small pieces of data that are stored by your browser when a site is visited to track and store information associated with your activity to help improve your browsing experience, capture analytics, perform authentication, store cache records, etc.
However, our adjacent platforms such as website (i.e.) or links from within our app that direct to and/or any other subdomains or websites associated with our service may use the following Cookies:
2.5.2 / Others
Other tracking technologies may also be used such as beacons, tags, pixels, and scripts to collect and track information and to improve and analyze our Service.
2.5.3 / Advertising Identifier (i.e. IFA)
The Advertising Identifier on your device may be shared with third party advertisers to track and target personalized advertisements based on your use and/or ad clicks. This is again mentioned later section 11.3 for Advertising.
You can limit the specific use of this by advertisers, in regard to how they serving ads based on on your device if you wish to opt out of personalized ads and limit such tracking. The setting can be modified within the "Settings" app on your iOS or IPadOS devices. You can find instructions for how to do so here .
The advertising identifier (IFA) may also be used by third party services as a means of attribution to detect if you’ve installed the application by clicking through from another website or service, i.e. clicking on an online ad for Crinkle and then downloading the application from the app store.
3 / USE OF DATA:
Crinkle and H’Appile Interactive uses the collected data for various purposes:
-To provide and maintain our Service
-To notify you about changes to our Service
-To allow you to participate in interactive features of our Service when you choose to do so
-To provide customer support
-To gather analysis/stats or valuable information so we can improve and learn about our Service
-To monitor the usage and/or compliance of our Service and it’s features
-To detect, prevent and address technical issues
4 / LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR):
Crinkle may process your Personal Data because:
-We need to perform a contract with you
-You have given us permission to do so
-The processing is in our legitimate interests and it is not overridden by your rights
-For payment processing purposes
-To comply with the law
5 / RETENTION OF DATA:
Crinkle will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
6 / TRANSFER OF DATA:
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
7 / DISCLOSURE OF DATA:
7.1 / Business Transaction
7.2 / Disclosure for Law Enforcement
Under certain circumstances, Crinkle may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
7.3 / Legal Requirements
Crinkle may disclose your Personal Data in the good faith belief that such action is necessary to:
-To comply with a legal obligation
-To protect and defend the rights or property of Crinkle/H’Appile Interactive
-To prevent or investigate possible wrongdoing in connection with the Service
-To protect the personal safety of users of the Service or the public
-To protect against legal liability
8 / SECURITY OF DATA:
The security of your data is very important to us.
For data transmission to/from the app and our servers or any third party apis we use commercial and industry wide standard encryption protocols such as https calls (i.e. http using SSL or TLS) to protect your data.
For data storage we always design database schema and security rules with careful privacy considerations. We employ security rules on our Firebase database (see 11.2 for more on Firebase) to ensure only you have access to your personally identifiable information.
In the unforeseen event of breach or database integrity being compromised and we become aware of such that personally identifiable information is at risk or has been exposed, we will take appropriate steps to notify all users impacted.
It is important though to remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we always strive and dedicated ourselves to protecting your Personal Data, we cannot guarantee its absolute security.
9 / OUR POLICY ON "DO NOT TRACK" SIGNALS UNDER THE CALIFORNIA PROTECTION ACT (CalOPPA):
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
10 / YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR):
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Crinkle aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at .
In certain circumstances, you have the following data protection rights:
-The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
-The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
-The right to object. You have the right to object to our processing of your Personal Data.
-The right of restriction. You have the right to request that we restrict the processing of your personal information.
-The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
-The right to withdraw consent. You also have the right to withdraw your consent at any time where Crinkle relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
11 / SERVICES & THIRD PARTY PROVIDERS:
We may employ third party companies and individuals to help facilitate our Service (“Service Providers”), to provide one or more services on our behalf, perform or improve Service-related services or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
11.1 / ANALYTICS/MARKETING:
We may use third-party Service Providers to monitor and analyze the use of our Service including,
–Lumos Apps is a mobile app publisher we may work with. Lumos Apps helps us with publishing services and related. Through the course of our business interactions and to facilitate Lumos Apps’ services in the legitimate interest of growing, improving, and sustaining our apps, Lumos Apps may have access to and/or we may share one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, Ad/UA Performance Data, and App Data/Service Usage Data.
11.2 / DATABASE:
Firebase by Google Inc. – We may use third-party service provider Firebase to store and maintain content and works on our service. User information including email, user profile ID, etc may be stored in the database and/or shared with Google in order to facilitate this storage service.
We encourage you to review the Firebase privacy and security standards .
11.3 / ADVERTISING:
We may use third-party Service Providers to show advertisements to you to help support and market our products, including:
11.4 / PAYMENTS:
We may provide paid products and/or services within the Service. In this case, we use third-party services for payment processing (e.g. payment processors).
We may also issue payments to users on our service for their work as Registered Authors (i.e. independent contractors on our behalf). You can learn more about Registered Authors in our Terms of Service section 2.1.6.
Note for payments to Registered Authors we may store and share your legal name, region of residence, and email address on file with our payment processor (PayPal) to facilitate payments. We may also share your amount of revenue with PayPal so they can facilitate appropriate payment. We may also share these such details with any local or regulatory bodies in your Jurisdiction and/or any Jurisdictions which we operate for any legal/compliance basis required by law (i.e. tax collection, etc).
11.5 / AUTHENTICATION:
Facebook, Google, Apple Sign In – We may utilize third party services by Facebook, Google, and Apple to allow users to create profiles and save, manage user profiles and accounts. Use of these login services is completely optional and voluntary. Crinkle does not own or manage any OAuth and/or other protocols/encryption used in these services, and has no access to your password. Thus Crinkle cannot be responsible for any loss of and/or invalidation/corruption of your login/credentials.
You may delete your profile and associated authentication credentials anytime you choose while logged in within the settings menu of the application.
11.6 / PUSH NOTIFICATIONS:
Apple Push Notifications – Crinkle may send push notifications if enabled and authorized on devices where users allow. These notifications are sent using Apple Push Notifications service and framework and using a device token issued by Apple. We may send information, stats, and/or reminders about the state(s), properties, or attributes of works/contents you are authoring or reading and/or actions pending your attention in the Crinkle application. We’ll never send any private personally identifiable information in our push notifications.
11.7 / COVER PHOTOS AND IMAGES:
11.8 / EMAIL SERVICE:
If you’ve provided us with your email and/or given us authorization to, or have made a request for response from us (i.e. support inquiry, signup verification, etc.), we may send you email(s). Email(s) may be sent for a variety of reasons including administrative (i.e. transactional/relationship driven emails) such as verified author email validation or support/service related inquiries/notifications, and also for commercial (i.e promotional/news based) updates like informing of new app features or promotions of such, etc. If you wish to opt out of or revoke your authorization for receipt of commercial based emails, you may do so in the settings menu of the app and/or by clicking the unsubscribe link at the bottom of any email you receive from us. Note this opting out does not apply to solely administrative driven content and emails, i.e. email validation when signing up as a registered author, payment/documentation related needs or updates, etc. that are required to facilitate our service/compliance.
To facilitate the above such email(s):
As such outlined in the above 1, 2, 3 , we may provide and/or store your email address, and associated correspondences received from, to and on the above service(s) for the sole purpose of sending you email(s) on our behalf and related tasks(i.e. address books, lists, etc) and/or log histories of such.
11.9 / LINKS TO OTHER SITES:
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
12 / DATA AGGREGATION AND SERVICE STATISTICS:
Information or data points/statistics obtained from your use of the Service, along with that of other users, may be combined and processed into aggregated Service metrics. These metrics are always stripped of any personal identifiers, anonymized, and never include any Personal Information. Examples of such may include, but are not limited to, derived statistics such as organic vs. inorganic install breakdowns, most successful ad campaigns or product placements in the app, revenue channel splits, retention cohorts, DAU counts, country-wide/large geo regional breakdown of such metrics, etc. These “big picture” or “aggregated” statistics may be shared and used in any way we deem fit for the Service or in our interest.
13 / YOUR CRINKLE ALIAS(ES):
Your Crinkle alias is considered public and may be shared or shown in the service, on adjacent platforms or screenshots in promotions and advertisements, in invites you send from Crinkle to others on your behalf to join works, etc. You understand and agree/grant permission that your alias may be shown or shared via, but not necessarily limited to, the above stated means without any additional notification.
For more definition of and details on your Crinkle Alias please refer to Terms of Service section 4.
14 / CHILDREN’S PRIVACY:
We take Children’s privacy very seriously. Crinkle is not directed towards use by Children.
Crinkle requires users to be of the age and ability to consent to personal data processing and acceptance of the terms and privacy policies by an adult of 18 years or older, who affirms responsibility/oversight for all users on their device(s). If however, we become aware that we have collected Personal Data unintentionally somehow from Children without verification of parental or guardian consent, we take steps to remove that information from our servers.
If you are a parent or guardian and you are concerned that your Child has provided us with Personal Data without your consent, please contact us.
16 / CONTACT US:
Data Protection Officer
H’Appile Interactive, LLC
2711 Legion Rd
PO Box 8184
Erie, PA 16506
Representation for data subjects in the EU and the UK:
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights,
EU Headquarters Schellinggasse 3
UK Office 20 Mortlake Mortlake High Street
London, SW14 8JN