SCROBLE App Privacy Policy

Privacy Policy of SCROBLE App

This Application collects some Personal Data from its Users.

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Owner and Data Controller

SCROBLE S.A.
6, Boulevard Pierre Dupong
L-1330 Luxembourg

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; Cookies; Data communicated while using the service; email address; app information; country; date of birth; device information; device logs; first name; gender; last name; phone number; username; VAT Number; company name; profession; address; fax number; state; county; ZIP/Postal code; various types of Data; city; Tax ID; field of activity; User ID; number of employees; website; Calendar permission; Contacts permission; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Microphone permission; Phone permission; Sensors permission; SMS permission; Storage permission; Reminders permission; HomeKit permission; Motion sensors permission; Bluetooth sharing permission; Social media accounts permission; Microphone permission, without recording; NFC Reader permission ; Biometric Data access permission; Media Library permission (Music); Photo Library permission; Health Data read permission; Health Data update permission ; Siri permission; Apple's speech recognition servers permission; TV Provider permission ; Google Assistant permission; Google Home permission; Call permission; Camera permission, without saving or recording; Write-only Photo Library permission; general activity data; body measurements & indexes; movement activity; food related activity ; sleeping activity; heart rate and other vital data; blood type; geographic position; password; Social Security number (SSN); picture; prefix ; profile picture; workplace; budget; academic background; Twitter handle; billing address; house number; language.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this 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 Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes 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 the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this 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 the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

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.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Interaction with external social networks and platforms, Beta Testing, Contacting the User, Content commenting, Data transfer outside the EU, Device permissions for Personal Data access, Displaying content from external platforms, Handling activity data, Hosting and backend infrastructure, Location-based interactions, Platform services and hosting, Registration and authentication, Registration and authentication provided directly by this Application, Remarketing and behavioral targeting, RSS feed management, Social features, Tag Management and Traffic optimization and distribution.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by this Application

This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me

Provides access to the 'About Me' section of the profile.

Access Friend Lists

Provides access to any friend lists the User created.

Access Page CTA

Provides the access to manage call to actions on User-managed Pages.

Access private data

Access the User's and friends' private data.

Access Requests

Provides read access to the User's friend requests.

Activities

Provides access to the User's list of activities.

Age range

Provides access to the User's age range.

App Notifications

Send notifications.

Birthday

Provides access to the birthday.

Books Actions

Shows when the User has rated, read, quoted from or has said they want to read a book with the app.

Business Management API

Read and write with Business Management API.

Chat

Provides applications that integrate with Facebook Chat the ability to log in Users.

Checkins

Provides read access to the authorized User's check-ins.

Contact email

Access the User's contact email address.

Create Events

Enables the application to create and modify events on the User's behalf.

Create notes

Add or modify notes.

Current City

Provides access to the User's current location.

Custom Friend Lists Access

Provides access to the names of custom lists the User has created to organize their friends.

Custom User Actions

Allows the app retrieve the actions published by another application as specified by the app namespace.

Deals

Read the deal activity.

Education History

Provides access to education history.

Email

Provides access to the User's primary email address.

Events

Provides access to the list of events the User is attending.

Export Posts

Export the posts and make them public. All posts will be exported, including status updates.

Family Members and Relationship Status

Provides access to the User's family and personal relationships and relationship status.

Fitness Actions

Shows the User's workout with the app.

Friend subscriptions

Provides access to the User's friends subscriptions associated with the app.

Friends' About Me

Provides access to the 'About Me' section of the friends' profile.

Friends' Activities

Provides access to the friends' list of activities.

Friends' birthdays

Provides access to the friends' birthdays.

Friends' Checkins

Provides read access to the friends' check-ins that the User can see.

Friends' Current Cities

Provides access to the friends' current locations.

Friends' Custom User Actions

Allows the app to retrieve the actions published by another application as specified by the app namespace.

Friends' Education History

Provides access to friends' education history.

Friends' Events

Provides access to the list of events the friends are attending.

Friends' Family Members and Relationship Status

Provides access to a friend's family and personal relationships and relationship status.

Friends' Games and App Activity

Allows the app post and retrieve game achievement activity.

Friends' Groups

Provides access to the list of groups the User's friends are a members of.

Friends' Hometown

Provides access to the friends' hometown.

Friends' Interests

Provides access to the friends' lists of interests.

Friends' Likes

Provides access to the list of all of the pages the friends have liked.

Friends' music.listens Actions

Allows the app to retrieve the actions published by all applications using the built-in music.listens action.

Friends' news.read Actions

Allows the app to retrieve the actions published by all applications using the built-in news.reads action.

Friends' Notes

Provides access to the friends' notes.

Friends' Online Presence

Provides access to the User's friend's online/offline presence.

Friends' Photos

Provides access to the photos the friends have uploaded, and photos the friends have been tagged in.

Friends' Questions

Provides access to the questions the friends have asked.

Friends' Religious and Political Views

Provides access to the friends' religious and political affiliations.

Friends' Significant Others and Relationship Details

Provides access to the friends' relationship preferences.

Friends' Statuses

Provides access to the friends' status messages and checkins.

Friends' video.watches Actions

Allows the app to retrieve the actions published by all applications using the built-in video.watches action.

Friends' Videos

Provides access to the videos the friends have uploaded and have been tagged in.

Friends' Websites

Provides access to the friends' web site URLs.

Friends' Work History

Provides access to a friend's work history.

Games and App Activity

Allows the app post and retrieve game achievement activity.

Gender

Provides access to the User's gender.

Groups

Provides access to the list of groups the User is a member of.

Groups member info

Provides access to publicly available group member information.

Hometown

Provides access to the User's hometown.

Insights

Provides read access to the Insights data for pages, applications, and domains the user owns.

Interests

Provides access to the User's list of interests.

Likes

Provides access to the list of all of the pages the User has liked.

Link

Provides access to the Facebook Profile URL of the User.

List of Friends

Provides access to the User's list of friends that also use said app.

Manage Advertisements

Provides the ability to manage ads and call the Facebook Ads API on behalf of a User.

Manage Friend Lists

Enables the app to create, delete and edit the User's friend lists.

Manage Groups

Manage the User's groups.

Manage Mailbox

Read and send messages from the User's mailbox.

Manage Notifications

Enables the app to read notifications and mark them as read.

Manage Pages

Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.

Mobile Messaging on behalf of Page

Send and receive mobile messages on behalf of a Facebook Page.

music.listen Action

Allows the app to retrieve the actions published by all applications using the built-in music.listens action.

News Feed and Wall

Provides access to all the posts in the User's News Feed and enables the application to perform searches against the User's News Feed.

news.read Actions

Allows the app to retrieve the actions published by all applications using the built-in news.reads action.

Notes

Provides access to the User's notes.

Offline Access

Access the data when the User is not using the application.

Online Presence

Provides access to the User's online/offline presence.

Page Messaging

Send and receive messages through a Facebook Page.

Photos

Provides access to the photos the User has uploaded, and photos the User has been tagged in.

Post Likes to my Wall

Publish stories about things the User Likes to the Wall.

Publish App Activity

Allows the app to publish to the Open Graph using Built-in Actions, Achievements, Scores, or Custom Actions. The app can also publish other activity which is detailed in the Facebook's Publishing Permissions document.

Publish as Page

Enables the ability to post, comment and like as any of the Pages managed by the User.

Publish Checkins

Enables the app to perform checkins on behalf of the User.

Publish content into groups

Allows posting content into a group on behalf of the User.

Publish to the Wall

Enables the app to post content, comments, and likes to a User's stream and to the streams of the User's friends.

Questions

Provides access to the questions the User has asked.

Read Group Content

Lets the app read content in a group managed by the User.

Read Mailbox

Provides the ability to read from a user's Facebook Inbox.

Read page mailbox

Lets the app read from the page inboxes of the pages managed by the User.

Religious and Political Views

Provides access to the User's religious and political affiliations.

RSVP to Events

Enables the application to RSVP to events on the User's behalf.

Share items on the User's behalf.

Show List of Managed Pages

Provides the access to show the list of the Pages that the User manages.

Significant Other and Relationship Details

Provides access to the User's relationship preferences.

Status

Provides access to the User's status messages and checkins.

Status Updates

Update the User's status.

Tagged Places

Provides access to the places the User has been tagged at in photos, videos, statuses and links.

Text Messaging

Send SMS messages to the User's phone.

Upload Photos

Add or modify user's photos.

User subscriptions

Provides access to the User's subscriptions associated with the app.

User Timeline Posts Access

Provides access to the posts on a Users's timeline.

Video upload

Add or modify User's videos.

video.watches Action

Allows the app to retrieve the actions published by all applications using the built-in video.watches action.

Videos

Provides access to the videos the User has uploaded and videos the User has been tagged in.

Website

Provides access to the User's web site URL.

Work History

Provides access to work history.

Device permissions for Personal Data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Apple's speech recognition servers permission

Used for sending the User's Data to Apple's speech recognition servers.

Approximate location permission (continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

Biometric Data access permission

Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.

Bluetooth sharing permission

Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.

Calendar permission

Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.

Call permission

Used for accessing a host of typical features associated with telephony.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Camera permission, without saving or recording

Used for accessing the camera or capturing images and video from the device.
This Application does not save or record the camera output.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Google Assistant permission

Used for sending the User's Data to Google Assistant (an artificial intelligence-powered virtual assistant).

Google Home permission

Used for accessing the Google Home and Chromecast devices and enabling this Application to interact with physical accessories in the User's surrounding environment.

Health Data read permission

Allows reading the User’s health Data.

Health Data update permission

Allows the updating of the User’s health Data.

HomeKit permission

Used for accessing the HomeKit framework and enabling this app to interact with physical accessories in the User's surrounding environment.

Media Library permission (Music)

Allows accessing the User's Media Library audio Data.

Microphone permission

Allows accessing and recording microphone audio from the User's device.

Microphone permission, without recording

Allows accessing and recording microphone audio from the User's device. The recording feature is not used on this Application.

Motion sensors permission

Used for accessing the User's device motion sensors to measure the User's activity such as step counts, stairs climbed, and movement type (walking, cycling, etc.).

NFC Reader permission

Allows this Application to read contact-less tags.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Photo Library permission

Allows access to the User's Photo Library.

Precise location permission (continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

Reminders permission

Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

Siri permission

Used for sending the User's Data to Siri (an artificial intelligence-powered virtual assistant).

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

TV Provider permission

Allows accessing the User’s TV provider account.

Write-only Photo Library permission

Allows write-only access to the User's photo library.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts
Analytics
Beta Testing
Contacting the User
Content commenting
Data transfer outside the EU
Device permissions for Personal Data access
Displaying content from external platforms
Handling activity data
Hosting and backend infrastructure
Interaction with external social networks and platforms
Location-based interactions
Platform services and hosting
Registration and authentication
Registration and authentication provided directly by this Application
Remarketing and behavioral targeting
RSS feed management
Social features
Tag Management
Traffic optimization and distribution

Further information about Personal Data

Access the address book
Analysis and predictions based on the User’s Data (“profiling”)
Automated decision-making
CCPA: Collection of personal information about consumers aged 13 to 16
CCPA: Collection of personal information about consumers below the age of 13
CCPA: Collection of personal information about minors
Personal Data collected through sources other than the User
Pseudonymous use
Push notifications
Push notifications based on the User's geographic location
Push notifications for direct marketing
Selling goods and services online
The Service is directed to children under the age of 13
The Service is not directed to children under the age of 13
Unique device identification
User identification via a universally unique identifier (UUID)

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their 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.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Latest update: January 11, 2020