We, LeverX Poland LLC., are the data controller responsible for your information when you use our Application.
We appreciate that you trust us with your personal information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle Your Personal Data (hereinafter – the “Personal Data” or “Data”).

This Privacy Policy forms an integral part of the End User License Agreement (EULA) for LeverX mobile application “ColorBook” (hereinafter – the “Application”) which is made between the user (hereinafter – the “User” or “You”) and LeverX Poland LLC (hereinafter – “LeverX” or “we”).
By downloading the Application from the Apple App Store, you give us You consent to collect and process Your Personal Data on the terms as specified in this Privacy Policy.

What Personal Data do we collect from You?
While installing and using Application, including its Content, contacting us through the Application You will be asked to provide us with specific Personal Data.
Personal Data we collect from You includes:
• Your username;
• User ID;
• Your Device ID;
• To use certain features in our Application, you may allow us to access your camera and media library. Depending on your device, Apple system will ask for your permission before allowing us to access these features;
● We collect information about your activity on our Application, for instance how you use them (e.g., date and time you logged in, time spent in the app, features you've been using, advertising that you click on). We may collect such data only if you give us a consent to do so.
We collect Usage Data with the help of the following third-party services:

1) Firebase Analytics
We also analyse the manner in which our Application is used via an analysis tool provided by Google LLC. (1600 Amphitheatre Parkway, Mountain View, California, U.S.). A variety of user session and interaction data is gathered and collated. We need this information to improve content, to make our services more user-friendly and to optimise Application use for you. For further information about data processing at Firebase Analytics please see their privacy policy here: https://firebase.google.com/policies/analytics

2) Mixpanel
Mixpanel’s ability to use and share information collected by Mixpanel about your visits to and use of the Application is restricted by Mixpanel’s Terms of Use, available at https://mixpanel.com/terms/, and Mixpanel’s Privacy Policy, available at https://mixpanel.com/privacy/.

You have choices about the data we collect. When You are asked to provide Personal Data, You may decline. Some of the Data may be collected automatically, for example the Application Usage Data. 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 Application.
You also entitled to have the LeverX erase Your Personal Data, cease further dissemination of the data and potentially have third parties halt processing of the data. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. However, if You choose not to provide data that is necessary to provide a service or feature or to withdraw the data that is still relevant to original purposes of processing, You may not be able to use that service or feature.
The data we collect depends on the context of Your interactions with LeverX, the choices You make, including Your privacy settings, and the service and features You use.
If You are uncertain about which Personal Data is mandatory and whether the Data is collected or not You are welcome to contact LeverX.
You 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 LeverX.

Why do we collect Your Personal Data?
We collect the Data to help You to get better experience from using our Application and LeverX services.
We may use the Data we collect from You in the following ways:
• to provide the full functionality of the Application to You;
• to contact You with the information regarding our company, application, services;
• to improve our Application and services in order to better serve You.
The Data concerning the User is collected in order to realize the following functionalities of the Application and our services: User registration and authentication, analytics, social features, Content performance and features testing, advertising, device permissions for Personal Data access, infrastructure monitoring.

Do we use 'cookies'?
No. We do not use cookies in our mobile Application.

When do we collect and how we process Your Data?
We collect the Data from You when You install and use the Application.
We take 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 us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Application (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 LeverX. The updated list of these parties may be requested from us at any time.
According to our principles of the Data processing all data is:
• Fairly and lawfully processed;
• Processed for a lawful specified purpose;
• Adequate, relevant and not excessive;
• Not kept for longer than necessary;
• Accurate;
• Processed in accordance with the individual’s (data subject’s) rights;
• Secure;
• Not transferred to other countries without adequate protection.

What specific permissions do You provide to us?
Camera and Media library permission. The Application may access the camera on Your device and capture images and video from the device.
Device permission. It enables access to the unique identifier of Your device where the Application is installed. The Application would also collect the Application usage data from Your device.

What rights do You have as a Data Subject?
All Users who are the subject of Personal Data held by us are entitled to:

• ask what information we hold about them and why;
This means that you can ask LeverX what personal data of yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from LeverX your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means;

• ask how to gain access to it;

• be informed how to keep it up to date;

• have inaccurate personal data corrected or removed;
This means you can require all the inaccurate personal data concerning you being corrected. You can also complete the personal data if you feel there is a need to do so;

• prevent us from processing information or request that it is stopped if the processing of such data is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;
In some cases, prescribed by the applicable laws you can object to processing of your personal data.
You have a right to object to processing of your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process your data to pursue our or third party’s legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms.
If you make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.
Please note that when processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification. We will no longer process your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process your data for direct marketing purposes;

• require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;

• be informed what we are doing to comply with our obligations under the applicable data protection laws.

Subject to the personal data protection regulations applicable to You, You may request us to erase Your Personal Data without undue delay. The request shall be made on the legal grounds provided in the information protection regulations applicable to You, which include among other:
• the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• You withdraw Your consent on which the processing is based according to the provisions of the applicable to You information protection regulations and where there is no other legal ground for the processing;
• You object to the processing pursuant to the applicable information protection regulations and there are no overriding legitimate grounds for the processing, or the information subject objects to the processing;
• the personal information has been unlawfully processed;
• the personal information has to be erased for compliance with a legal obligation in the USA, European Union or the law to which we are subject.
You may also ask LeverX to receive Your Data and have it transferred to another Data controller. In this case You have the right to receive Your 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 the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
If You cannot access certain information and personal data collected by LeverX, You can always contact LeverX by using our contact form. We will respond to requests to access or delete Your personal data within 30 days.

How to exercise your rights as to your Personal Data?

Any requests to exercise your rights can be directed to LeverX through the contact details provided below. These requests are free of charge.

Do we provide Personal Data to the third parties?
We do not sell, trade, or otherwise transfer to outside parties Personal Data unless otherwise is provided in this Privacy Policy. This does not include website hosting partners and other parties who assist us in operating our Application, conducting our business, or serving our Users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our Application policies, or protect ours or others' rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We may share information with affiliates and partners if the information is required to provide the Application or service You have requested, or to provide You with the opportunity to participate in the products or services our affiliates offer. We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our Users. In order to ensure that these products and services meet Your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful to Yourself. The use of Your personal information is limited to the purposes identified in our relationship with the partner or affiliate.

How we protect your Personal Data?
The security of your Personal Data is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and after it is received. We process your Data using computers and/or other IT enabled tools. LeverX takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also guide and train our personnel to process your data securely according to our internal data protection policies. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at contact-leverx@leverx.com.

How long do we keep Personal Data?
LeverX retains personal data for as long as necessary to provide the services, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:
• The period of data processing needed to provide the services. This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.
• The data subject's consent for a longer retention period. If so, we will retain data in accordance with the consent.
• LeverX is subject to a legal, contractual, or similar obligation to retain the data. Mandatory data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.
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.

Changes to this Privacy Policy
From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be posted to the Application and our websites, if applicable. You agree to accept posting of a revised Privacy Policy electronically on our website as actual notice to You. Any dispute over our Privacy Policy is subject to this notice, our EULA. We encourage You to periodically check back and review this policy so that You will always know what information we collect, how we use it, and to whom we disclose it. If You have any questions that this statement does not address, please contact us via our contact form.

How can You contact us and/or complain?
All questions and complaints regarding this privacy policy, and processing Your Personal Data may be lodged using the contact details below.
LeverX Poland LLC
Address: Wołodyjowskiego 67A, 02-724 Warsaw, Poland.
Phone +48502926800
Email contact-leverx@leverx.com
Unless otherwise stated, LeverX Poland LLC is a data controller for personal data we collect through the services subject to this statement.