Caramel Mobile Application Privacy Policy

Effective date October 04 2019

Welcome to the world of Caramel!

Caramel respects the privacy rights of our online visitors and, therefore, have adopted this privacy policy to describe our privacy practices for the CARAMEL Mobile Application. CARAMEL is the operator of the Application and the controller of the information collected on it.

The Privacy Policy describes what information is collected from our users, including children, when the Application is downloaded; how such information is used and stored; in what cases such information can be disclosed to third parties; how users, parents and guardians can control the use and disclosure of collected information; and how information is protected. The Application is intended for a younger audience, including users under the age of 13. If you are under 18 years old, please review this Privacy Policy with a parent or guardian. By accessing the Application, you agree to comply with this Privacy Policy. If you do not agree with this Policy, please do not use the Application.

TABLE OF CONTENTS

If you have any questions about this policy, please contact us at the address below.

I INFORMATION AND DATA WE COLLECT
II HOW WE USE YOUR INFORMATION
III WITH WHOM WE SHARE YOUR PERSONAL INFORMATION
IV WHERE AND FOR HOW LONG WE STORE YOUR INFORMATION
V HOW WE HANDLE CHILDREN’S INFORMATION
VI YOUR CALIFORNIA PRIVACY RIGHTS
VII YOUR PRIVACY RIGHTS
VIII SECURITY
IX CHANGES TO THIS PRIVACY POLICY
X CONTACT US

I INFORMATION AND DATA WE COLLECT

We collect information you provide directly via the Application, as well as certain technical information automatically.

A. INFORMATION YOU GIVE US

The Application provides two opportunities for you to provide us with personal information: (i) to obtain customer support; and (ii) to ask characters questions.

To obtain customer support, you may utilize our website to send us an email with your questions. To utilize this function, you will be required to provide us with your first name and an email address. After we will send the answer as soon as possible. We then immediately delete your email. Your email address will not be used for any other purpose other than to respond to your support request.

You will notice that there are other opportunities for you to provide information within the Application. Specifically, you can provide your first name, birthday, gender and localisation in the profile section. Thanks to your data, we use them to develop statistics. All this information will be also used by our partners.

B. INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect technical data that you need to use the Application, as well as additional technical data that we need to maintain and analyze the functionality of the Application, and to personalize the content of the Application. This includes:

Your Internet Protocol (IP) address;
The time zone, and the start and end time of the session;
The user agent (UA) string, platform, and SDK version; and
Technical information about the device (for example, the model and name of the device, the name and version of the operating system, the name of the CPU, free disk space allocated for the application, the screen resolution, and application API-key).

II HOW WE USE YOUR INFORMATION

We use the information we collect about you and your device, including personal information, for the following legitimate business purposes:

To improve, operate, manage, and provide you with the Application;
To enable you to utilize speech-to-text functionality;
To perform services requested by you, such as to respond to your support requests; and
To perform analytics.

III WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We do not share your personal information with third parties, other than:

With third-party vendors, consultants and service providers who are working on our behalf and need access to your information to carry out their work for us. This includes FASTVPS EESTI OÜ, which provides us with a virtual server located in Estonia that hosts the Application and on which we store your information. It also includes Google, which provides a software solution to convert your speech to text after which your voice recording is immediately deleted.
When we believe it is necessary or appropriate to (i) comply with applicable law or legal process or to respond to lawful requests or legal authorities; (ii) protect the rights and property of Caramel; and (iii) protect the safety of Caramel, our users or any third party.
In connection with, or during negotiations of, any merger, sale of company assets, bankruptcy or reorganization, financing or acquisition of all or a portion of our business to another company.

We may also share aggregated information or de-identified information with third parties, at our discretion. Such information cannot be used to identify you personally.

IV WHERE AND FOR HOW LONG WE STORE YOUR INFORMATION

Your personal information is stored as long as it is necessary for the purposes for which it was collected or as otherwise set forth in this Privacy Policy.

For EU Users

Personal data collected from data subjects located in the European Economic Area (EEA) is stored in Holland. It is not transferred outside the EEA.

V HOW WE HANDLE CHILDREN’S INFORMATION

As stated above, the Application is intended for a younger audience, including users under the age of 13. We encourage parents and guardians to review this Privacy Policy with their children.

We are committed to complying with the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect users under the age of 13 online. Accordingly, we do not collection personal information from children under 13 years old, except when permitted by COPPA. Specifically, we collect the following personal information from children under 13 years old, without providing direct notice to and obtaining consent from a parent or guardian:

Email addresses: We collect a child’s email address pursuant to the one-time contact exception in COPPA, which allows us to respond to a child’s support request. After we have responded to the child’s support request, we delete the child’s email address, and it is not used for any other purpose;

We collect this information pursuant to our legitimate business interests, as permitted by the European Union’s General Data Protection Regulation.

Moreover, we do not collect more personal information than is reasonably necessary to utilize the Application.

If you have any questions about our information collection and use practices; would like to review, correct or delete your child’s personal information; or would like us to discontinue the further collection or use of your child’s personal information, please contact us using the contact details provided under the “Contact Us” heading below

VI YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, section 1798.83 of the California Civil Code allows you to request information about the disclosure of your personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their direct marketing purposes. However, you may make such a request by contacting us at:

Email addresses: We collect a child’s email address pursuant to the one-time contact exception in COPPA, which allows us to respond to a child’s support request. After we have responded to the child’s support request, we delete the child’s email address, and it is not used for any other purpose;

VII YOUR PRIVACY RIGHTS

You have the following data protection rights:

Caramel
RTL Belgium, Jacques Georginlaan, Schaerbeek
Telephone: +32479 60 46 77
Email: jmdoultremont@caramel.be

If you are a resident of the European Economic Area, you also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws and this Privacy Policy.

VIII SECURITY

We reserve the right to change, revise or otherwise modify this Privacy Policy at any time and in any way (for example, in response to changes in legal, technical or business events). When we make changes to this Privacy Policy, we will update the Effective date above. If we make any material changes in the way we collect, use or share your personal information, we will publish a new privacy policy on this page and we will make a warning in the Application when you first use the Application after such policy changes are made. If we make any material changes that retroactively impact the way in which we use or disclose personal information already collected from you, we will seek your consent before those changes become effective.

Please periodically check this page for any modifications, changes or amendments.

IX CHANGES TO THIS PRIVACY POLICY

We take reasonable steps to help protect the security and integrity of any personal information you provide to us. Nevertheless, transmission via the internet is not completely secure, and we cannot guarantee the security of your personal information through the Application. If we learn that your personal information has been compromised by a data breach, we will notify you consistent with applicable laws.

X CONTACT US

If you have any questions or wish to send us comments about this Privacy Policy, or the processing of your personal information, please contact us at:

Caramel
RTL Belgium, Jacques Georginlaan, Schaerbeek
Telephone: +32479 60 46 77
Email: jmdoultremont@caramel.be