Privacy Policy

Privacy Policy of PowerPen

General

Thank you for considering and choosing our Services. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns with regards to your personal information, please contact us at sageaitech@gmail.com. This document describes our privacy policy and it presents what information we may collect, how we use it and what rights you have in relation to it. Please take some time to read through it carefully.

By using our Services, you agree to the collection and use of information in accordance with this policy. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our Services.

This Privacy Policy might be updated at some point so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.

Personal Data we may collect or use

When you download the App, we receive whatever information the applicable App Marketplace shares with us.
When you contact us, we process whatever personal data you provide us, such as name, telephone number and email address, as well as the question or issue you raised (collectively, “Contact Information”).

When you use the App, some information about your device may be processed automatically. This information is generally non-personal, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. Otherwise we may not be able to provide you with all the requested services and features of the App. Examples of such information:

App usage data – we may collect anonymous app data, the sessions frequency and duration, passing levels, making purchases, failures and other events while using the Services. The purpose of these statistics is to improve the App and also improve your experience throughout the app.
Technical data we may also collect anonymous data such as IP Address, your device’s operating system, browser type, language, hardware type, mobile network
Identity data such as your unique device ID (persistent/non-persistent).

These types of data are usually anonymous and can not be associated or connected with you.

The app does use third party services that may collect information used to identify you.

Link to privacy policy of third party service providers used by the app

Firebase Analytics

How we use Personal Data

We will not use the information we collect for any purpose other than those disclosed in this Policy. We will process your Personal Data based on the legal basis. For example, we may use the Personal Data in the following ways:

To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
Research and development: We use Personal Data for internal research and development purposes and to improve and test the features and functions of our Services. We use information that is processed automatically to better understand user behaviour and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.
If applicable, send you push notifications, related information, including confirmations and reminders (if you choose to allow that function)—only for users 18 years old or older and you can independently disable this anytime.
If applicable, we may use Automatically Collected information and Cookies information to maintain and improve our Services, including to do the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed.

We do not share personal information with other third parties, except for legal reasons upon request by public authorities. We do not sell your personal information to third parties.

Data Processing

Our Services may collect non-personal data using integrated third-party services like Google Play services. Such data are stored in these third-party services. We do not store personal data on our servers. These services have their own privacy policies.

We hereby undertake not to conduct any disclosure or transfer of the User’s personal data to any third parties, except Processors, mentioned in this paragraph, without receipt of personal consent of the User.

You should know that we don’t process payments directly. Payments are processed via the Google Play Store Google Play Policy. We don’t collect or store payment data, details or payments-related personal data. Payment processing takes place through a payment system, integrated into the app store.

How Long We Keep Personal Information

We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide. In all cases, we do not retain such data for more than 12 months. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information.

Personal Data Protection

The security of your information is fundamental to us. We have implemented industry standard security measures, which include the encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties.

User’s Rights

The User is also entitled to:

request the access to and rectification or erasure of personal data;
restrict the processing of personal data concerning the User;
object to processing of personal data concerning the User;
demand for realization of the right to data portability;
exercise the right to lodge a complaint with a relevant supervisory authority;
update Personal Data provided to us;
the User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.

Our Policy Towards Children

Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission. We consider a user to be a child if they are under the age of 18, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information.

Specific Provisions Applicable Under California Privacy Law

This is additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA and any terms defined in the CCPA have the same meaning when used in this notice.

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number	YES (Device ID)
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	“A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.”	NO
C. Protected classification characteristics under California or federal law.	“Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), driver’s license number, passport number, or other similar identifiers.”	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data (Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data).	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

As a California resident, you have the rights listed below:

You can request information about how we have collected and used your personal information during the past 12 months including the categories of personal information collected, the sources from which we collected personal information, the business or commercial purpose for collecting personal information, and the third parties with whom we shared personal information.
You can ask us to delete personal information we have collected from you. We may need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.
Right to be Free from Discrimination. We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
The right to opt out of the sale of Personal Information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests.
You may exercise your California privacy rights described above by emailing us. We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights.
You can request a copy of the personal information that we have collected about you during the past 12 months.

10. Further Privacy Notice for EU Residents (“GDPR Notice”)

If you are a European user, you can also request limitations to the processing of your personal information, object to the processing of your information, or exercise your right to data portability.

You have a right to know what Personal Data we hold about you, how and why we handle your Personal Data. You can ask us for a copy of your Personal Data and in some cases to have the information communicated to you. If you would like to exercise your right of access please contact us as described below and let us know what information in particular you would like to receive.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

You have the right to withdraw your consent at any time.

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. These changes are effective immediately after they are posted on this page.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at sageaitech@gmail.com