1. Your acknowledgment of this policy
This Privacy Policy ("Privacy Policy") details how your Personal Information collected via the Services is used and processed by Canduo.
BY ENTERING, BROWSING, CONNECTING TO, ACCESSING OR USING THE SERVICES IN ANY WAY, OR UPON THE COMPANY’S REFERRAL TO THIS PRIVACY POLICY AND/OR BY PROVIDING PERSONAL INFORMATION TO US AFTER SUCH REFERRAL, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES AND YOU SHOULD NOT PROVIDE US WITH ANY PERSONAL INFORMATION.
YOU ALSO ACKNOWLEDGE AND CONFIRM THAT, EXCEPT AS EXPRESSLY STATED IN THIS PRIVACY POLICY, YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US. WHERE WE ARE REQUIRED TO COLLECT OR PROCESS PERSONAL INFORMATION PURSUANT TO A LEGAL OBLIGATION APPLICABLE TO US, WE WILL INFORM YOU OF SUCH OBLIGATION.
Note to non-EU or UK based Users
BY ENTERING, BROWSING, CONNECTING TO, ACCESSING OR USING THE SERVICES IN ANY WAY, OR UPON THE COMPANY’S REFERRAL TO THIS PRIVACY POLICY AND/OR BY PROVIDING PERSONAL INFORMATION TO THE COMPANY AFTER SUCH REFERRAL, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE TO CANDUO’S PRACTICES DESCRIBED HEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION UNDER THE TERMS OF THIS POLICY.
2. Who we are
In this policy, references to Canduo, or to "we", "our", or "us" are to Canduo, based in Israel. Canduo is the "data controller" of the Personal Information described in this policy. Individuals wishing to contact us about data protection issues may do so by emailing us at canduoapp@gmail.com.
3. Which information we may collect on our Users?
The App was designed so that we do not need to collect information about you. The subsections below describe what stays on your device, and the limited information we do receive.
3.1 Information that stays on your device (not collected by us)
The App processes the following information locally on your device to make the experiences work. It is not transmitted to us or to any third party, and we have no access to it:
- Hinge and motion data: the App reads how far your device is open, how fast it is folding, and the device’s motion sensors (for example, which way is down). These readings are used in real time and are not stored.
- Your photo library (Photo Album only): when you tap “Open my albums”, the App asks for access to your photo library through the standard iOS permission prompt. It reads your albums to display them, and it never edits, deletes, uploads or keeps a copy of your photos. If an original photo is stored only in iCloud, Apple’s Photos system may download it to your device so it can be shown. That transfer happens between your device and Apple under Apple’s privacy policy; we do not receive the photo. You can change or revoke this permission at any time in your device settings.
- Content you save: the paper planes you save in Urigamy, your level progress in AngleVerse, the stars you earn on each level of Foldy Flow, your best score in Penalty and the achievements you unlock (with the counts they are measured on) are stored in the App’s private storage on your device. Deleting the App deletes them. They may be included in your device backups, which are governed by Apple’s terms and your settings.
- Game state and settings (such as scores, the selected material or difficulty) are kept in memory only while you play.
3.2 Non-personal Information
The App does not collect technical or behavioral information about your use of the App, and the Website does not use analytics tools. We do not use third-party service providers to analyze your behavior on the Services.
If you have chosen, in your device settings, to share analytics with app developers, Apple may provide us with aggregated usage statistics and crash reports for the App. This information is collected by Apple, not by us, under Apple’s privacy policy. It is provided to us in a form that does not identify you, and we use it only to fix defects and improve the App’s stability. You can turn this sharing off at any time in your device settings (Settings > Privacy & Security > Analytics & Improvements).
3.3 Personal Information
Personal Information is individually identifiable information ("Personal Information"). We collect Personal Information only in the following cases:
- Communications: when you email us or send a message through the Support form on the Website, we receive the details you provide, such as your name, email address and the content of your message, and any other information you choose to include.
- Free text: any information you enter as free text in the Support form or in your communications with us is transferred to us "as is". We therefore recommend that you refrain from entering information that is of a sensitive nature or that is not required for the purpose of your inquiry.
- Website server logs: like any website, when you visit the Website our hosting provider automatically processes your IP address and basic request details (such as the page requested, the date and time, your browser type and the referring page) in order to deliver the pages to you and to protect the Website against abuse. We do not use this information to identify you or to build a profile of you.
We do not operate user accounts, and we do not collect names, email addresses, profile photos, advertising identifiers, precise location, contacts, health data, or payment information through the App.
Important note: any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information, as long as such connection or linkage exists.
To the extent you provide us with Personal Information relating to third parties (such as a family member, or other individual), you represent and warrant that you have provided such third parties with a copy of this Privacy Policy and obtained their informed consent to the provision of such information to us for purposes of our processing thereof in accordance with this Privacy Policy, and that you shall bear sole responsibility in this regard.
User responsibility for information provided: you represent that any Personal Information you provide to the Company is true, accurate, complete and up to date. Providing incorrect details may impair our ability to respond to you.
4. What are the purposes of the collection of information?
Personal Information we receive is used for the following purposes only:
- responding to your inquiries, support requests, complaints and requests to exercise your rights, and providing customer service;
- diagnosing and fixing defects in the App and the Website, and keeping them working properly;
- operating the Website and keeping it safe and secured, including detecting and preventing fraud, abuse, spam and security incidents;
- notifying Users of material changes to this Privacy Policy or the TOU, where we have a way to do so; and
- protecting our rights and complying with any legal obligation applicable to us, for example to resolve disputes, comply with the law and/or respond to a request from a competent authority, and to establish, exercise or defend our legal rights, or the rights of others.
We do not use your information for advertising, marketing campaigns, profiling or direct mailing, and we do not combine it with information from other sources.
Note to our Users in the EU and UK
In order for Canduo to process your Personal Information, such processing must be justified by a "lawful basis" for processing. The processing activities described in this policy are justified on the following bases:
- the processing is necessary for the performance of a contract to which you are party, or to take steps at your request before entering into one: for example, answering your support requests about the App you purchased;
- the processing is necessary to comply with a legal obligation: for example, disclosing information to authorities where required by law, or keeping records we are legally required to keep; and
- the processing is necessary for the purposes of our legitimate interests: operating a secure Website, answering general inquiries, and fixing defects in the Services. Where we rely on legitimate interests as a lawful basis, we carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
The App’s access to your photo library is based on your permission, which you grant through the iOS system prompt and may withdraw at any time in your device settings. Because the photos are processed on your device only, they are not processed by us.
Note to non-EU and non-UK Users
BY ENTERING, BROWSING, CONNECTING TO, ACCESSING OR USING THE SERVICES IN ANY WAY, OR UPON THE COMPANY’S REFERRAL TO THIS PRIVACY POLICY AND/OR BY PROVIDING PERSONAL INFORMATION TO THE COMPANY AFTER SUCH REFERRAL, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
5. Payments
The App is sold exclusively through Apple’s App Store. All payments, and any refunds, are processed by Apple Inc. ("Apple") under Apple’s own terms and privacy policy. We do not receive or store your credit card number or other billing information, and Apple does not tell us who you are when you buy the App. We receive only aggregated sales reports from Apple. The App contains no in-app purchases or subscriptions.
It is your responsibility to abide by the terms specified by Apple in its terms of use and privacy policies, including any age restrictions specified therein.
7. Data subjects’ rights
The Company acknowledges you may have the right under applicable law to access, change and delete the Personal Information we collect and process. If you wish to access, correct, amend, or delete Personal Information, please send us an email to: canduoapp@gmail.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Because the App stores your saved planes and game progress on your device only, we cannot access, export or delete that information for you. You can delete it at any time by deleting the App.
In addition, to the extent Personal Information included in our databases is used to contact you personally based on your association with a population group determined by reference to one or more characteristics of individuals whose names are included in the database ("Direct Mailing"), you have the right to demand in writing that Personal Information relating to you not be used for Direct Mailing purposes. We do not currently engage in Direct Mailing. If you wish to exercise this right, you may do so by sending an email detailing your request to: canduoapp@gmail.com.
In connection with any request to review, correct or delete your Personal Information, we may ask you to provide details that allow us to verify your identity, such as the email address you used to contact us and a description of the Personal Information concerned. If you wish to submit your request through a representative, you must also attach an explicit power of attorney for this purpose, together with a copy of the identification document of both the data subject and the authorized representative.
Note to our Users in the EU and UK
You may have the following rights (by virtue of EU and UK law) in respect of your Personal Information:
- Right to access: you may have the right to request access to your Personal Information that is held by Canduo.
- Right to rectification: if the Personal Information processed by Canduo is incorrect or incomplete, you may have the right to have your Personal Information rectified.
- Right to erasure: under certain conditions, you may be entitled to require that Canduo deletes your Personal Information.
- Right to portability: you may have the right to receive the Personal Information concerning you, or to transfer it to another controller, where processing is based on your consent or on the performance of a contract and is carried out by automated means.
- Right to object to or withdraw consent: where processing is based on "legitimate interests", you may have a right to object to such processing. Where you object, we shall no longer process your Personal Information unless (i) we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or (ii) for the establishment, exercise or defense of legal claims. Where processing is based on your consent, you may withdraw it at any time.
- Right to restrict processing: under certain circumstances, you may have the right to obtain the restriction of the processing of your Personal Information.
- Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection supervisory authority. Contact details of the EU supervisory authorities can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en. The Information Commissioner’s Office is the UK’s supervisory authority, and can be contacted at https://ico.org.uk/global/contact-us/.
We may refuse to comply with a request if it is manifestly unfounded, excessive or repetitive in nature. To exercise these rights, please contact us at: canduoapp@gmail.com.
Note to our Users in the United States
If you live in a state with a comprehensive consumer privacy law (such as California), you may have the right to know what Personal Information we have collected about you, to request its deletion or correction, and to opt out of the "sale" or "sharing" of Personal Information for cross-context behavioral advertising. We do not sell or share Personal Information as those terms are defined under these laws. We will not discriminate against you for exercising any privacy right.
8. Minors
The App is designed to be enjoyed by people of all ages. It does not collect Personal Information from any User, including children, and it contains no advertising, chat, social or sharing features.
The Website’s Support form and our email address are intended for Users over the age of sixteen (16). The Company does not knowingly collect Personal Information from minors under the age of sixteen (16) (or under the age of thirteen (13) in the United States). A minor who needs help with the App should ask a parent or legal guardian to contact us. If we learn that we have collected Personal Information from such a minor, we will delete that information as quickly as possible. If you have reasons to suspect that the Company has collected Personal Information from such a minor, please notify us through the means indicated in the "Contact us" section below.
9. How we protect information
We implement technological and organizational security procedures, policies and measures as required by applicable law, in order to protect Personal Information, prevent unauthorized access, use, disclosure, alteration or destruction thereof, and reduce the risks associated therewith. The best protection is not to hold information at all, which is why the App is designed not to send any information to us. Nonetheless, there are inherent risks in the transmission of information over the Internet and in electronic storage, and despite our efforts we cannot guarantee that Personal Information we hold will never be exposed, leaked, stolen or otherwise damaged, or that our information systems will never be subject to unauthorized intrusion.
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA.
Information that the App stores on your device is protected by your device’s own security. You should protect your device with a passcode or biometric identification and keep its software up to date.
Canduo will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information, and will inform you of such breach as required by applicable law.
10. Third-party service providers
We use the third-party service providers listed in Section 6 to host, store and/or process the limited information detailed herein, for the purposes specified herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. The Company engages with third parties that post a privacy policy governing their collection, processing and use of information and that are bound to process Personal Information on our behalf only in accordance with our instructions and applicable law.
12. International data transfer
The Company may transfer Personal Information outside of your jurisdiction, to the extent required for the operation of the Services, to our external service providers (as detailed in this Privacy Policy). Such service providers may be located, and may process and store information, in countries including Israel, the United States, the United Kingdom and member states of the European Union.
In connection with any transfer of Personal Information outside of your jurisdiction, the Company will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, such as entering into appropriate data transfer agreements with service providers.
Note to non-EU or UK based Users
BY ACCEPTING THIS PRIVACY POLICY AND/OR BY ACCESSING OR USING THE SERVICES, OR BY THE COMPANY OTHERWISE DIRECTING YOU TO THIS PRIVACY POLICY, YOU EXPRESS YOUR CONSENT TO THE TRANSFER OF PERSONAL INFORMATION ABOUT YOU TO COUNTRIES OUTSIDE OF YOUR JURISDICTION. IF YOU HAVE ANY QUESTIONS REGARDING SUCH CROSS-BORDER TRANSFERS OF INFORMATION, YOU ARE WELCOME TO CONTACT US.
Note to our Users in the EU and UK
If you are located in the EU or UK, you have a right to further information regarding the appropriate safeguards used by us when transferring your Personal Information outside of the EU or UK. Such safeguards may include: (i) transferring your Personal Information to countries approved by the European Commission or UK government as having adequate data protection laws, such as Israel, or to organizations certified under an approved cross-border transfer mechanism, such as the EU-U.S. Data Privacy Framework; and (ii) entering into standard contractual clauses approved by the European Commission or UK government.
13. Data retention
The Company will retain your Personal Information only for as long as it is necessary for the purposes for which it was collected, and to the extent permitted or required under applicable law. In particular: support correspondence is kept for as long as needed to handle your request and any follow-up, after which it is deleted unless we are required to keep it by law or to establish, exercise or defend legal claims; and Website server logs are kept by our hosting provider for a limited period for security purposes.
Information stored by the App on your device stays there until you delete it or the App.
Anonymous or aggregate information that does not identify you may be retained without time limitation.
14. Changes to the Privacy Policy
The Company reserves the right to change this policy at any time, so please revisit this page from time to time. In case of any material change, we will make reasonable efforts to post a clear notice on the Website and, where possible, in the App or by email to Users who have provided us with an email address. Such material changes will take effect seven (7) days after such notice was provided. All other changes to this Privacy Policy are effective as of the stated "Last updated" date, and your continued use of the Services after that date will constitute acceptance of those changes. Where required by law, we will ask for your consent to material changes. Changes required to comply with legal requirements may take effect immediately. Changes to this Privacy Policy will not be applied retroactively.
15. Contact us
If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email at canduoapp@gmail.com and we will make an effort to reply within a reasonable timeframe.