Owner and Data Controller
GM UniverseApps Limited
Address: GREG TOWER, Floor 2, 7 FlorinisNicosia 1065Cyprus
Contact email: email@example.com
- Terms and Definitions
- "Application" means "Scanner App Pro: PDF Scan", a mobile
application, that is also the means by which the Personal Data of the User is collected and processed.
- "Cookies" means portions of code that is
transferred to a User's mobile device assisting the Owner in providing the Service according to the
- "Data Controller" (or "Owner") means the natural or legal
person, public authority, agency or other body which, alone or jointly with others, determines the purposes and
means of the processing of Personal Data, including the security measures concerning the operation and use of
the Application. The Data Controller, unless otherwise specified, is the Owner of the Application.
- "Data Processor" means the natural or legal person, public authority,
agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy
- "Data Subject" means the natural person to whom the Personal Data refers.
- "Personal Data" (or "Data") means any information that
directly, indirectly, or in connection with other information – including a personal identification
number – allows for the identification or identifiability of a natural person.
- "Usage Data" means information collected automatically through the
Application (or third-party services employed in the Application), which can include: the IP addresses or
domain names of the computers utilized by the Users who use the Application, the URI addresses (Uniform
Resource Identifier), the time of the request, the method utilized to submit the request to the server, the
size of the file received in response, the numerical code indicating the status of the server's answer
(successful outcome, error, etc.), the country of origin, the features of the browser and the operating system
utilized by the User, the various time details per visit (e.g., the time spent on each page within the
Application) and the details about the path followed within the Application with special reference to the
sequence of pages visited, and other parameters about the device operating system and/or the User's IT
- "User" means the individual using the Application who, unless otherwise
specified, coincides with the Data Subject.
- "Service" means the service provided by the Application as described in
it and in the relative terms (if available).
- Unless otherwise specified, all references made within this document to the
European Union include all current member states to the European Union and the European Economic Area.
- Types of Data collected
- Among the types of Personal Data that this Application collects, by itself or
through third parties, there are: Cookies, Usage Data, various types of Data and unique device identifiers for
advertising (IDFA, for example).
- Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using the Application.
- Unless specified otherwise, all Data requested by the Application is mandatory and
failure to provide this Data may make it impossible for the Application to provide the Service. In cases where
the Application specifically states that some Data is not mandatory, Users are free not to communicate this
Data without consequences to the availability or the functioning of the Service.
- Users who are uncertain about which Personal Data is mandatory are welcome to
contact the Owner.
by the owners of third-party services used by this Application serves the purpose of providing the Service
required by the User.
- Users are responsible for any third-party Personal Data obtained, published or
shared through the Application and confirm that they have the third party's consent to provide the Data to
- Mode of processing the Data
A. Methods of processing
- The Owner takes appropriate security measures to prevent unauthorized access,
disclosure, modification, or unauthorized destruction of the Data.
- The Data processing is carried out using computers and/or IT enabled tools,
following organizational procedures and modes strictly related to the purposes indicated. In addition to the
Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the
operation of this (administration, sales, marketing, legal, system administration) or external parties (such as
third-party technical service providers, mail carriers, hosting providers, IT companies, communications
agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be
requested from the Owner at any time.
B. Legal basis of processing
- The Owner may process Personal Data relating to Users if one of the following
- provision of Data is necessary for the performance of an agreement with the User
and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner
- processing is necessary for the purposes of the legitimate interests pursued by the
Owner or by a third party.
- In any case, the Owner will gladly help to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
C. Retention time
- Personal Data shall be processed and stored for as long as required by the purpose
they have been collected for. Therefore:
- Personal Data collected for purposes related to the performance of a contract
between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests
and compliance with a legal obligation to which the Owner is subject shall be retained as long as needed to
fulfill such purposes.
- The Owner may be obliged to retain Personal Data for a longer period whenever
required to do so for the performance of a legal obligation or upon order of an authority.
- Once the retention period expires, Personal Data shall be deleted. Therefore, the
right to access, the right to erasure, the right to rectification and the right to data portability cannot be
enforced after expiration of the retention period.
- The purposes of Personal Data processing
- The purposes of Personal Data processing are as follows:
- To provide the Service.
- For remarketing and behavioral targeting. This type of service allows the
Application and its partners to inform, optimize and serve advertising based on past use of the Application by
the User. This activity is performed by tracking Usage Data that is transferred to the partners that manage the
remarketing and behavioral targeting activity. The User may opt out of these practices by visiting the Network
Advertising Initiative opt-out page. The User may also opt out from remarketing
and behavioral targeting provided by Facebook, as provided here.
- The Owner may also provide User with information of commercial or promotional
nature concerning other Owner`s products.
- Data transfer to third parties
- The Owner may share Personal Data with service providers for analytical,
advertising and other purposes so that the Owner can better consider new features or otherwise tailor or
enhance the Service, particularly:
- Appsflyer (AppsFlyer Ltd). Appsflyer is an analytics service provided by AppsFlyer
Ltd. Personal Data collected: Cookies and Usage Data. Place of processing: Israel – Privacy
Policy – Opt
- Facebook Analytics for Apps (Facebook, Inc.) Facebook Analytics for Apps is an
analytics service provided by Facebook, Inc. Personal Data collected: Usage Data and various types of Data as
Policy. Privacy Shield participant.
- Firebase Crash Reporting (Google Inc.) Firebase Crash Reporting is a monitoring
service provided by Google, Inc. Personal Data collected: various types of Data as specified in the privacy
policy of the service. Place of processing: United States – Privacy
- Firebase Performance Monitoring (Google Inc.) Firebase Performance Monitoring is a
monitoring service provided by Google, Inc. Personal Data collected: various types of Data as specified in the
- Firebase Realtime Database (Google Inc.) Firebase Realtime Database is a hosting
and backend service provided by Google Inc. Personal Data collected: Usage Data and various types of Data as
- Firebase Remote Config (Google Inc.) Firebase Remote Config is an A/B testing and
configuration service provided by Google Inc. Personal Data collected: various types of Data as specified in
- Google Analytics for Firebase (Google Inc.) Google Analytics for Firebase or
Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google's use of
Data, consult Google's
partner policy. This Application uses identifiers for mobile devices (including
Advertising Identifier for iOS) and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device
advertising settings for mobile phones or by following the instructions in other Firebase related sections of
(IDFA, for example) and Usage Data. Place of processing: United States – Privacy
- Data transfer outside the EU
- The Owner may transfer Personal Data to Data Processors around the world in
necessary to provide the Service to the User.
- The Owner is allowed to transfer Personal Data collected within the EU to third
countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer
is based on one of the legal bases described below:
- Data transfer abroad based on standard contractual clauses. If this is the legal
basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to
"standard contractual clauses" provided by the European Commission. This means that Data recipients
have committed to process Personal Data in compliance with the data protection standards set forth by EU data
protection legislation. For further information, Users are requested to contact the Owner through the contact
details provided in the present document.
- Data transfer abroad based on consent. If this is the legal basis, Personal Data of
Users shall be transferred from the EU to third countries only if the User has explicitly consented to such
transfer, after having been informed of the possible risks due to the absence of an adequacy decision and
appropriate safeguards. In such cases, the Owner shall inform Users appropriately and collect their explicit
consent via this Application.
- Data transfer from the EU to the U.S based on Privacy Shield. If this is the legal
basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU -
U.S. Privacy Shield. In particular, Personal Data is transferred to services that self-certify under the
Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data.
- Further information about Personal Data
- Users declare themselves to be adult according to their applicable legislation.
Minors may use the Application only with the assistance of a parent or guardian. Under no circumstance persons
under the age of 13 may use the Application.
- The Application may send push notifications to the User.
- The rights of EU Users
- Users from the European Union ("EU Users") may exercise certain rights
regarding their Data processed by the Owner. In particular, EU Users have the right to do the following:
- Object to processing of their Data. EU Users have the right to object to the
processing of their Data.
- Access their Data. EU Users have the right to learn if Data is being processed by
the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data
- Verify and seek rectification. EU Users have the right to verify the accuracy of
their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Where Personal Data is processed for
legitimate interests, f. e. for direct marketing purposes pursued by the Owner, EU Users may object to such
processing by providing a ground related to their particular situation to justify the objection.
- Have their Personal Data deleted or otherwise removed. EU Users have the right,
under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. EU Users have the
right to receive their Data in a structured, commonly used and machine readable format and, if technically
feasible, to have it transmitted to another controller without any hindrance. This provision is applicable
provided that the Data is processed by automated means and that the processing is based on a contract which the
EU User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. EU Users have the right to bring a claim before their competent
data protection authority.
- Any requests to exercise EU User rights can be
directed to the Owner through the contact details provided in this document. These requests will be addressed
by the Owner as early as possible and always within one month.
activities that are strictly necessary for the operation of this Application.
- Some of the services listed in Section 5 above collect statistics in an anonymized
and aggregated form and may not require the consent of the User or may be managed directly by the Owner –
depending on how they are described – without the help of third parties.
- With regard to Cookies installed by third parties, Users can manage their
preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the
- Notwithstanding the above, the Owner informs that Users may follow the instructions
provided on the subsequently linked initiatives by the EDAA (EU), the Network
Advertising Initiative (US), Digital
Advertising Alliance (US) and the DAAC (Canada) or other similar services.
- Since the installation of third-party Cookies and other tracking systems through
the services used within this Application cannot be technically controlled by the Owner, any specific
references to Cookies and tracking systems installed by third parties are to be considered indicative. In order
third-party services listed in this document.
- Given the objective complexity surrounding the identification of technologies based
on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on
- Additional information about Data collection and processing
A. Legal action
- The User's Personal Data may be used for legal purposes by the Owner in court
or in the stages leading to possible legal action arising from improper use of the Application or the related
- The User declares to be aware that the Owner may be required to reveal personal
data upon request of public authorities.
B. System logs and maintenance
- For operation and maintenance purposes, the Application and any third-party
services may collect files that record interaction with the Application (system logs) use other Personal Data
(such as the IP address) for this purpose.
C. How "Do Not Track" requests are handled
- The Application does not support "Do Not Track" requests. To determine
whether any of the third-party services it uses honor the “Do Not Track” requests, please read
their privacy policies.
giving notice to its Users on this page and possibly within the Application and/or – as far as
technically and legally feasible – sending a notice to Users via any contact information available to the
Owner. If a User objects to any of the changes to the policy, the User must cease using the Application and can
applies to all Personal Data the Owner has about Users.
Last updated: September 31, 2018