By using/subscribing to our apps, services, or websites, you are agreeing to this Privacy Policy and respective TERMS AND CONDITIONS.

The TopCert app (TOPCERT) has been developed by Clever Fox Online (CFO).

The purpose of this policy is to provide you with all the important information and explanations about how and why some of your data may be collected and processed by CFO when you use one of our mobile applications. This privacy policy governs and details the main principles that CFO applies to the data we collect and process to:

1. Develop and publish mobile apps (“TOPCERT”)

2. Deliver you an enhanced user experience

3. Serve advertising that are tailored to the interests of users (“CFO Ads”)

This policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them.

Should you have any questions related to this policy or our practices around privacy and data protection in general, please don’t hesitate to contact the CFO Data Protection Officer as indicated in the contact section of this policy.

Why does CFO collect data from its apps?

When you install and use CFO mobile applications, we can collect and process some of your data for different legitimate purposes.

You will find below explanations regarding the reasons why CFO may collect data and the legal bases CFO relies on in each case.

CFO collects data:

1. To provide you with the services and experience you asked for

2. Legal basis – such data processing is strictly necessary for the service(s) asked

3. To run analytics and understand how users interact with our product and services in order to continually improve our products and services

What data does CFO collect from its apps?

For all the purposes listed above the data that CFO applications collects is limited to:

1. The apps you are using

2. Your IP address

3. Your Mobile Advertising ID (Google AAID – which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)

4. Technical information about the device you use and your connection (user agent, type of connection, timestamp)

5. Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)

With whom may your data be shared?

CFO does not share your data with third parties without your prior consent.

When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:

Ad Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.

Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

1. Facebook https://www.facebook.com/about/privacy

2. Google https://policies.google.com/privacy

3. Mopub https://www.mopub.com/legal/privacy

Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:

• Google – https://policies.google.com/privacy

Authorities: only to the extent we are obliged to by applicable laws and regulations.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page, via your app subscription, or via your provided subscription email.

This policy is effective as of 01-01-2021

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at privacyofficer@cleverfox.online