Last update: September 26, 2022
This policy covers M&N Scala, also referred to as:
This app was developed by Nelson Mimura Gonzalez, also referred to as:
We refer as “you”, “your”, to the individual, company, or other legal entity using our app.
We define as actively collected any data that you disclose to us while using our app or when you contact us.
Specifically, our app collects, by direct input from you, user-generated content such as profile-related information. Note however, as specified in the next section, that none of these data is visible outside the group (also referred to as org) you are sharing your data with. Information shared with one group is not visible by members from other groups – including groups you also are part of. Also, we implement full encryption of data so that no one, including us, outside group members you deliberately decide to share with, can read your data.
We define as passively collected any data that is automatically collected as part of third-party libraries and services used by our app.
Specifically, our app collects data from your device to provide features such as targeted advertising and improved user experience. By using our app you agree and consent with the collection of this data.
- coarse location, such as your IP address
- device identification, such as the device advertising identifier
- usage data, such as product interaction and advertising data
- diagnostics, such as crash data and performance data
None of these data are used to identify you or for tracking purposes.
The actively collected information is strictly used to create a user profile that is unique to each group (org) you are part of. By providing your information, whether personal or not, to each group you participate, you consent with sharing this information with whoever the group administrators define that should be able to see this information. Do not join and/or do not provide your information to groups you do not know the owners and/or participants.
This informaton is used by third-party services such as Google AdMob, to deliver targeted ads to you, and Google Analytics, to gather usage information to improve our app. These are the relevant links to the privacy policies and other useful information on potential third-party services being used by our app:
From “behavioral policies”, under “AdMob & AdSense” program policies:
To complement personalized advertising (formerly known as interest-based advertising), Ads Settings lets users view and edit their interests and demographics. Some users may choose to opt out of personalized ads.
Last updated: September 30, 2021
The personal information you provide in the context of creating a group profile, which is specific to each group you participate, is shared with other users from that group, or a subset of users from that group. Information shared with one group is not visible by other groups. Moreover, group administrators may limit visibility even further to only specific members of a group.
We do not share your personal information beyond this context, and we cannot decrypt and read your personal information.
Passively collected data is shared with third-party services such as Google AdMob and Google Analytics, including whatever resources and components these services may use to implement their features.
Personal information is stored in our database so that other group members may see whatever information you may share with them. We implement full encryption of personal data using three separate sets of keys – user keys, public-private keys, and organization (group) keys. These are used to encrypt user profiles and user-generated content, including group-specific profiles. We do not have any visibility to user content, except for email addresses – which are used for sign up and sign in.
We do not keep any passively collected data. Third-party services that make use of this data to provide their features may keep this data stored in some form for a specific time.
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We only process your personal information when we believe it is necessary and when we have a valid legal reason (i.e., legal basis) to do so under the applicable law.
Specifically, our app collects and processes your personal data, either actively or passively, with your consent – i.e., only if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time – click here to learn more. For actively collected information you consent with providing your information as part of the core functionalities offered by our app. For passively collected information we ask for your consent before using your data. Your consent can then be reset, reconfigured, and revoked.
We will also collect and process your personal information:
when necessary for complying with legal obligations, such as cooperating with law enforcement bodies or regulatory agencies, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved; and
when we believe it is necessary to protect your vital interests or vital interests of a third party, such as situations involving potential threats to the safety of any person.
In some regions, such as the European Economica Area (EEA), United Kingdom (UK), and Canada, you have rights that allow greater access and control over your personal information.
If you are located in the EEA, UK, or Canada, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us – please refer to section “Contact us”. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
You can withdraw your consent to us collecting and processing your personal information at any time. Actively collected data is part of the core functionality offered by our app. If you do not consent to actively collected data, you must not use our app anymore. If you consent with activelt collected data but not with passively collected data, these data will only be collected after obtaining your consent. You may deny when first questioned about it or you may reset and revoke your consent using the appropriate options in our app. Specifically, our app provides specific options to reset consent options and to show the consent form, through which the user may accept or deny the passive collection of data.
If you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information – see section “Contact us”.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents”. If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
We have collected the following categories of personal information in the past twelve (12) months:
(F) Internet or other similar network activity (e.g., browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements);
(G) Geolocation data (e.g., device location); and
(K) Inferences drawn from other personal information (e.g., inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics).
We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We collect and share your personal information through:
- Targeting cookies/Marketing cookies
More information about our data collection and sharing practices can be found in this privacy notice. If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
We have not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. In the preceding twelve (12) months we have disclosed data in the categories described in the prior section on “What categories of personal information do we collect?”.
Right to request deletion of the data — Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know. Depending on the circumstances, you have a right to know: whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information is used; whether we sell your personal information to third parties; the categories of personal information that we sold or disclosed for a business purpose; the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. We will not discriminate against you if you exercise your privacy rights.
Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights. You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
Please contact us to exercise these rights – see section “Contact us”.
We do not knowingly collect or store any personal information about children under the age of 13.
We may update this privacy notice from time to time. The updated version will be indicated with the latest date and the updated version will be effective as soon as it is accessible.
If you have any questions or comments, please use our GitHub Issues system.