privacy policy

The following Privacy Policy applies to all Our published Products.

Privacy Policy

Last updated: June 14, 2024

Roberto Bendinelli, sole proprietor of Strobetano (“we”, “us”, or “our”), is committed to protecting the privacy of our users (“you” or “your”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use any of our published products, including mobile applications and games (collectively, the “Products”). Please read this Privacy Policy carefully. By using our Products, you agree to the collection, use, disclosure, and procedures outlined in this Privacy Policy. If you do not agree with our policies and practices, do not download, install, or use our Products.

Information Collection and Use

We may collect information about you in a variety of ways. The information we may collect via the Products includes:

  1. Personal Data: While using our Products, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to: email address, name, and phone number.
  2. Analytics Data: We may use third-party analytics tools to collect information about your usage of the Products and your device when you use our Products. This includes information such as your device’s model, operating system, browser type, unique device identifiers, mobile network information, and the actions you take within our Products. The analytics tools we currently use include, but are not limited to: Google Analytics, Apple Analytics, Facebook Analytics, Microsoft Analytics, and Unity Analytics.
  3. In-App Purchases: Some of our Products may offer in-app purchases. If you choose to make an in-app purchase, your payment information will be processed by the respective app store (e.g., Google Play or Apple App Store), and we will not have access to your full payment details. We will only receive confirmation of the transaction and the items purchased.
  4. Sensitive Personal Data: Our Products do not directly collect any sensitive personal data, such as health information, racial or ethnic origin, political opinions, religious beliefs, etc. However, the third-party SDKs integrated into our Products, such as Facebook SDK or Yodo1 SDK, may collect such data. Please refer to the respective privacy policies of these SDKs for more information on their data collection practices.
  5. Cookies and Tracking Technologies: Our Products and website may use cookies and similar tracking technologies to enhance your user experience and collect information about your interactions with our Products and website.

Please note that SDK owners, such as Facebook and Yodo1, may store and process your data according to their own privacy policies. We encourage you to review the privacy policies of these third parties to understand how they handle your information.

Use of Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Products to:

  • Compile anonymous statistical data and analysis for use internally or with third parties.
  • Create and manage your account.
  • Email you regarding your account or order.
  • Enable user-to-user communications.
  • Increase the efficiency and operation of the Products.
  • Monitor and analyze usage and trends to improve your experience with the Products.
  • Notify you of updates to the Products.
  • Offer new products, services, and/or recommendations to you.
  • Perform other business activities as needed.
  • Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  • Process payments and refunds.
  • Request feedback and contact you about your use of the Products.
  • Resolve disputes and troubleshoot problems.
  • Respond to product and customer service requests.

Disclosure of Your Information

We may share information we have collected about you in certain situations, such as:

  • With your consent, to our subsidiaries and affiliates.
  • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • If we believe the disclosure is required or permitted by any applicable law, regulation, legal process or governmental request.
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of us or any third party.
  • With third parties to fulfill the purpose for which you provide it.
  • With third-party advertising partners to serve ads in our Products. These third parties may use cookies and similar tracking technologies to collect information about your interactions with our Products and other websites and apps over time for the purpose of serving targeted ads.
  • With SDK owners, such as Facebook and Yodo1, who may have access to your data and process it according to their own privacy policies.

Your Choices

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Products because such information may be required in order for you to register as a user, purchase products or services, participate in a contest, promotion, survey, or sweepstakes, or initiate other transactions via the Products.

You can optionally opt-out of receiving marketing or promotional communications from us by following the instructions in those emails or messages. Note that you will still receive important administrative messages even if you opt-out of marketing or promotional communications.

Children’s Privacy

Our Products are not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Products. Any transmission of personal information is at your own risk.

Please be aware that SDK owners, such as Facebook and Yodo1, may have their own security measures in place to protect your data. We encourage you to review their security practices and policies.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period may vary depending on the type of data and the purposes for which it was collected. For example, we retain account information for as long as the account is active, and for a reasonable period thereafter in case you decide to re-activate the Products. We retain information about your transactions and purchases for accounting, tax, and business purposes. When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

SDK owners, such as Facebook and Yodo1, may have their own data retention policies. Please refer to their privacy policies for more information on how long they retain your data.

User Rights

You have certain rights under applicable data protection laws, which may include the right to request access to and rectification or erasure of personal data, the right to restrict or object to processing of personal data, and the right to data portability. Depending on your location and subject to applicable laws, you may have additional rights, such as the right to request disclosure of the personal information we collect about you and the right to request that we delete your personal information.

If you wish to exercise any of these rights, please contact us using the contact information provided at the end of this Privacy Policy. We will respond to your request in accordance with applicable data protection laws.

Please note that SDK owners, such as Facebook and Yodo1, may also have certain obligations regarding your rights. Please refer to their privacy policies for more information on how to exercise your rights with respect to the data they collect and process.

Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Your consent, which you can withdraw at any time.
  • The performance of a contract with you or to take steps at your request before entering into a contract.
  • Our legitimate interests, such as to improve our Products, maintain our relationship with you, and protect our business interests.
  • Compliance with a legal obligation.

International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of Switzerland, including to countries within the European Union (EU), the United Kingdom (UK), the United States, and other countries where the data protection laws may differ from those in Switzerland. If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including personal data, to Switzerland and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Whenever we transfer your personal data out of Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, the UK’s Information Commissioner’s Office, or other relevant authorities.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission, the UK’s Information Commissioner’s Office, or other relevant authorities which give personal data the same protection it has in Europe or the UK.

SDK owners, such as Facebook and Yodo1, may also transfer your data internationally. Please refer to their privacy policies for more information on how they handle international data transfers.

Third-Party Services

Our Products may contain links to other websites or services that are not operated by us. This Privacy Policy does not apply to such third-party services, and we encourage you to review the privacy policies of those third parties before using their services.

Limitation of Liability

To the fullest extent permitted by applicable law, Roberto Bendinelli shall not be liable for any indirect, incidental, special, consequential or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from: (i) your access to or use of or inability to access or use the Products; (ii) any conduct or content of any third party on the Products, including without limitation, any defamatory, offensive or illegal conduct of other users or third parties; (iii) any content obtained from the Products; or (iv) unauthorized access, use or alteration of your transmissions or content.

We are not responsible for the privacy practices or the content of the SDK owners, such as Facebook and Yodo1. We encourage you to review their privacy policies and terms of service before using their services or providing them with your personal information.

Indemnification

You agree to defend, indemnify and hold harmless Roberto Bendinelli, its affiliates, licensors and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of this Privacy Policy or your use of the Products.

Governing Law and Jurisdiction

This Privacy Policy and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of Switzerland, without giving effect to any choice or conflict of law provision or rule.

Any legal suit, action or proceeding arising out of or related to this Privacy Policy or the Products shall be instituted exclusively in the federal courts of Switzerland or the courts of the Canton of Vaud, although we retain the right to bring any suit, action or proceeding against you for breach of this Privacy Policy in your country of residence or any other relevant country. You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

Notwithstanding the foregoing, Roberto Bendinelli shall have the right to bring legal action against You in your local jurisdiction for any claims or disputes arising from your use of Our Products or your breach of this Privacy Policy.

Language

The original and legally binding version of this Privacy Policy is written in English. Any translations of this Privacy Policy are provided for convenience only. In the event of any inconsistency or discrepancy between the English version and any translated version, the English version shall prevail.

Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new Privacy Policy on this page and notify you by email to the email address specified in your account, and/or through a notice on the Products’ home screen. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically accessing the Products and this Privacy Policy to check for any changes.

Contact Information

If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us at: strobetano [at] outlook [dot] com. We have appointed Roberto Bendinelli as our Data Protection Officer (DPO), who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out above.

You have the right to lodge a complaint with a supervisory authority, in particular in Switzerland, the EU member state, or the UK where you habitually reside, work, or where the alleged infringement of data protection laws occurred. However, we would appreciate the chance to address your concerns before you approach a supervisory authority, so please feel free to contact us first.