Privacy Policy

At Let’s Clean (trading name of Clyapp Limited), “we,” “our” or “us”)) we believe that your privacy is very important. This Policy outlines the types of personally identifiable information and other data that we will collect from you through your use of our mobile application Let’s Clean ("App"), and how we will use and when we might disclose such information and data to third parties.
By downloading the App onto your device, you give your consent to this Privacy Policy and our Terms of Use. We display the link to our Privacy Policy in our website’s footer at http://clyapp.com/ and https://letsclean.clyapp.com/, within the Google Play store listing page and within the App.

In this Privacy Policy, Let’s Clean will sometimes be referred to as ‘we’, ‘us’, or ‘our’. Additionally, there are references to “you”. In these instances, “you” - a user of our App (“user”).

The data controller in respect of the App is Clyapp Limited a company registered in England and Wales (company number 13027617), with its registered office at 20-22 Wenlock Road, London, England, N1 7GU.

If you have any questions about this Privacy Policy, you can reach us on [email protected].

This Privacy Policy is effective as of January 27, 2021 and was last modified on January 27, 2021.

Definition of the types of information discussed in this Policy:

“Personal Information” is the type of information that specifically identifies you personally and/or can be used alone to contact you online or offline, such as your full name, physical address, email address, telephone number, photograph, precise geolocation information, credit card information and, in some cases, user’s name.

“Non-personal Information” is anonymous information about your mobile device, such as your unique device ID, or other persistent identifiers, and their hardware/software/firmware, as well as data regarding your use of the App, such as the actions you take within the App, the device you use, and the date and time of your use of the App.

What kind of information we collect?

Personal information

In general, we do not require nor request any Personal Information from you when you use our App. In the event we collect Personal Information from you, we will only use it to the limited extent required to provide you with the services you have requested (e.g., to send you an e-mail) or to respond to your inquiries. In no event will we ever sell, rent or transfer your Personal Information to third parties for direct marketing purposes, for monetary or other valuable consideration.

Non-personal information

Below we have listed the types of information we collect. It should not be considered as personal information, as from that information we cannot directly or indirectly identify you as an individual. Non-personal information is aggregated, in anonymous form.

When you use the App, we may collect the following information:

App usage data, the information about how you use the App, including your preferred language (geography), the date and time when you first installed the App and the date and time you last used the App.
This data will be retained for the duration of your use of our App and will be completely deleted after 30 days from the date our Аpp is deleted from your device.

Purchase history, if you choose to purchase an App subscription, the confirmation that you are a paid subscriber to the App.
This data will be retained for the duration of your use of our App and will be completely deleted after 30 days from the date our Аpp is deleted from your device.

Device data, such as your mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google Advertising ID, browser type, screen resolution, IP address (and the associated country in which you are located), and other information about the device you are using to visit the App.
This data will be retained for the duration of your use of our App and will be completely deleted after 30 days from the date our Аpp is deleted from your device.

Online activity data, such as information about your use of and actions on the App, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and certain third parties (e.g. online advertising networks) also may collect this type of information over time and across third-party websites and mobile applications. We may collect this information directly or through our use of third-party software development kits (“SDKs”) e.g. Google)). SDKs may enable third parties to collect information directly from our App.
This data will be retained for the duration of your use of our App and will be completely deleted after 30 days from the date our Аpp is deleted from your device.

How we use the non-personal information?

To get and analyze data and for advertising purposes as well, we use the trusted big platforms such as Google, Facebook, Yandex that gather the information on our behalf in order to:

1. To Perform statistical analysis about your use of the App (through the use of Google Analytics, Yandex Metrica and Facebook).

2. To display advertisements to you (through the use of Google AdMob and Facebook). If you use the free version of the App, we work with advertising partners to display advertisements within the App. These advertisements are delivered by our advertising partners and may be targeted based on your use of the App or your activity elsewhere online.

Disclosing non-personal information that we collect

We do not share non-personal information with third parties, except as necessary for our legitimate business needs, to carry out your requests, and/or as required or permitted by law. This includes:

SERVICE PROVIDERS
We transfer information only to certain third party service providers so they can process your information on our behalf to help us operate the App (such as analytics, marketing) or to handling payments through those third party service providers’ services. We only share non-personal information that allows them to provide their services to us.

Non-personal information is collected for the following purposes and using the following services:

Google
All collected non-personal information is stored on the servers controlled by Google (or its wholly-owned subsidiaries).

Google Analytics
It is a mobile analysis service provided by Google LLC (USA). Google helps us to measure the App traffic and to understand how people are using your product.
This integration of Google Analytics anonymizes your IP address.
For more information on how Google Analytics uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/
Type of data processed: Device data; App usage data, Online activity data.
Legal basis for processing: your consent; our legitimate interests - meeting our contractual obligations to Google under our Google Analytics Terms of Service and allowing the Google Analytics to work on our App.
Opt-out: You can opt out from the Google Analytics by emailing us at [email protected] with a request to switch off the data collection from analytics Google servers.

Google AdMob and their partners
It is provided by Google LLC (USA) and used to display third-party advertisements in our App.
Google ad technology providers will collect data and use a unique identifier of your device to show you ads.
For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/
For more information on AdMob ad technology providers, please visit: https://support.google.com/admob/answer/9012903
Type of data processed: Device data; App usage data, Online activity data.
Legal basis for processing: your consent; our legitimate interests - meeting our contractual obligations to Google under AdSense Terms of Service (AdMob is governed by it) and allowing the Google AdMob to work on our App.
Opt-out: You can change your choice anytime for AdMob in your app settings by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en. You will still see ads, but it will not be based on your interests and info anymore.

Yandex Metrica
Yandex is an advertising service provided by Yandex LLC (Russia) and helps us to measure the App traffic and to understand how people are using your product.
This integration of Yandex Metrica anonymizes your IP address.
For more information on how Yandex Metrica uses the collected information, please visit the Privacy Policy of Yandex: https://yandex.com/legal/confidential/
Type of data processed: Device data; App usage data, Online activity data.
Legal basis for processing: your consent; our legitimate interests - meeting our contractual obligations to Yandex under our Terms of Use of Yandex.Metriсa service and AppMetrica and allowing the Yandex Metrica to work on our App.
You can opt out from the Yandex Metrica service by emailing us at [email protected] with a request to switch off the data collection from Yandex Metrica servers.

Yandex stores Personal information in the Russian Federation and in the EEA.
For users in Russia: Yandex records, systematizes, accumulates, stores, clarification (updates, changes), extracts Personal information of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.
For users in the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area, which has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, Yandex has taken appropriate measures to ensure Personal information is handled according to applicable EU data protection rules.
In particular, Yandex relies upon Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your Personal information transferred to Russia. A copy of these Standard Contractual Clauses can be obtained upon request.

Facebook
All collected non-personal information is stored on the servers controlled by Facebook (or its wholly-owned subsidiaries).

Facebook Analytics
Facebook Analytics is an analytics services provided by Facebook, Inc. (US) and Facebook Ireland Limited that helps us to measure the App traffic and to understand how people are using your product.
For more information on how Facebook uses the collected information, please visit the Privacy Policy page:https://www.facebook.com/about/privacy/
Type of data processed: Device data; App usage data, Online activity data.
Legal basis for processing: your consent; our legitimate interests - meeting our contractual obligations to Facebook under Facebook Business Tools Terms and allowing the Facebook analytics to work on our App.
Opt-out: You can opt out from the Facebook analytics by emailing us at [email protected] with a request to switch off the data collection from analytics Facebook servers.

Facebook Audience Network
It is provided by Facebook, Inc. (US) and Facebook Ireland Limited and used to display third-party advertisements in our App.
Facebook will collect data and use a unique identifier of your device to show you ads.
For more information on how Facebook uses the collected information, please visit the Privacy Policy page:https://www.facebook.com/about/privacy/
Type of data processed: Device data; App usage data, Online activity data.
Legal basis for processing: your consent; our legitimate interests - meeting our contractual obligations to Facebook under Facebook Business Tools Terms and allowing the Facebook analytics to work on our App.
Opt-out: You can change your choice anytime for Facebook ads in your app settings. You will still see ads, but it will not be based on your interests and info anymore.

When Our Privacy Policy Does Not Apply

Third party links
The App may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We and/or our third-party partners have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security, and correctly use the the information collected through the App. We take, or obligate applicable third parties to take, reasonable precautions to protect our users' information against loss, misuse, unauthorized disclosure, alteration, and destruction.

If you believe your information is being improperly used by us or any third party, please immediately contact us using “Security Concern” in the subject line.

Storage of information

We will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.

Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes.

Access by our contractors
We or our contractors undertake regular maintenance of your data. All third parties must agree to observe the privacy of our users, and to protect the confidentiality of their information. This means your data cannot be shared with others, and there must be no direct marketing by the third parties.

Changes to this Privacy Policy

We reserve the right, at our sole discretion, to change, modify or otherwise alter this Privacy Policy at any time. You can always check the latest version of our Privacy Policy on the App. If you do not agree to any modifications to this Privacy Policy, you can stop to use the App. Your continued use of the App following the posting of any modifications to this Privacy Policy will constitute your acceptance of the revised Privacy Policy.

International Users

Your information may be stored and processed in any country where we and/or our third-party partners have facilities, and by using the App you consent to the transfer of your information to countries, including the United States, which may be outside of your country of residence and may provide for different and less stringent data protection rules than in your country.

If you object to your information being transferred or used as described in this Privacy Policy, please do not use the App and immediately delete it from your device.

The rights of Users

EU and UK residents

The United Kingdom Data Protection Act 2018 (UK GDPR) and The EU General Data Protection Regulation (EU GDPR) provides the following rights for individuals:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

How to exercise these rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and at the latest within one month.

Californian users

This part of the document uses the term «personal information» as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold
• Identifiers:
See section «Personal Information»

• Commercial information
See section «Non-personal information»: Your Purchase history

• Internet or other electronic network activity information
See section «Non-personal information»: App Usage Data, Device Data. Additionally, this category contains record types that are maintained to comply with (or to demonstrate compliance with) law. Records of user rights requests, including opt-ins, opt-outs; records maintained in connection with legal matters, litigation or subject to legal holds.

Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever the App runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like. It is not a sale if a consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party.
We do not share your personal information for money or other valuable consideration. We do share personal information with certain third parties, which may be considered a “sale” under California law even if we don’t receive money in exchange for the information.
You have the right to instruct us to stop the kind of sharing that the CCPA treats as "sales" and not to engage in that kind of sharing in the future unless you choose to allow it (by emailing to us). Please be aware there may be circumstances where we can share information with others even if you instruct us to stop "selling" your personal information, as permitted under the CCPA. For example, we may still be able to share information with our service providers so that they can provide services to us. In addition, your instruction to stop "selling" your personal information will not affect sharing that occurred before you gave us the instruction.

The rights
The CCPA provides the following rights for individuals:

1. Right of Disclosure or Access
2. Right of Data Portability
3. Right to Deletion / Erasure (The Right to be Forgotten)
4. Right to prohibit the sale of their information
5. Freedom from Discrimination
You have the right to not be discriminated against by us if you exercise any of your rights under the CCPA. This means we cannot do any of the following on the basis of your exercise of these rights: deny our App to you; charge different prices or rates for App, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of App to you; or suggest that you will receive a different price or rate for App or a different level or quality of App.
6. Right to opt out of the sale of personal information You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data for money, we will abide by your request.

How to exercise these rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and at the latest within one month.

Sources of Personal Information
• Directly from you. For example, you directly provide your personal information when you submit requests via email.
• Indirectly from you. For example, from observing your actions in our App.
• From third parties. For example, service providers that work with us in connection with the App or with the functioning of App and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter in a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our App, for example to make payment via Google Pay.
To find out more about the purposes of processing, please refer to the section «Service Providers» of this document.

What are the purposes for which we use your personal information?
We use your personal information to allow the operational functioning of our App and features thereof (“business purposes”).
We also use your personal information for commercial purposes (as indicated within the section «Service Providers» of this document) and you have the right to opt out of the sale of your personal information (as indicated within the section «Service Providers» of this document).

Children’s Online Privacy Protection Act
Our App is not directed to children under the age of 13. We do not knowingly solicit data from persons under the age of 13 and we do not knowingly market to persons under the age of 13.

Contact us

Clyapp Limited
20-22 Wenlock Road, London, England, N1 7GU
e-mail [email protected]