This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We are Convexio Inc, a company under laws of United States, with registered address at: 1829 Nyork Street Muskogee, OK 74403 USA (“SKEI” or “we”), a developer and publisher of child support applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our mobile applications and other products (“Portal”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

1. INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes directly from your local Child Support Agency. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you use our app and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (provided that we never receive your payment or credit card information).

The information that we may collect about you through the Services broadly falls into the following categories:

(a) Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to register with our application, such as:
your date of birth, email address or other details, necessary to process your registration request;

The personal information that you are asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information.

(b) Information that we collect automatically

When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:

Data and analytics about your use of our Services (e.g. the means by which you were referred to our Services)
Your IP address and device identifiers such as your Advertising ID, Device ID numbers (for more see here Advertising IDs and Device IDs)
Your device type and the operating system that you use
Broad geographic location (e.g. country or city-level location) based on your IP address

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this information may be collected through cookies as explained further under the heading Cookies below.

(c) Information we obtain from third-party sources

We do not collect nor obtain any information about you from any third party. The information you provide to us is only used to authenticate against your child support agency in order for us to show your child support case information to you as maintained by the CSE agency.

(d) No special categories of information

We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Kindly be cautious when sharing this information about yourself (or others) in our forums.

 

2. HOW WE USE YOUR INFORMATION
2.1. In General
We use the information we collect about you/your device to deliver services and our app to you and to operate our business. We use it also for improving our services, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services. We use your information also for tracking and fraud prevention and for complying with our legal obligations.

We use your information for the following purposes:

Delivering and improving our services. We use your information for developing, delivering and improving our app and other products, services, and content, tailoring our products and services, providing updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Portal, and administering the Portal.

Displaying advertisements. We do not use your personal information for showing advertisements in other publisher’s apps.

Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Portal, gathering demographic information about our user base, data about where the Portal was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Portal and services, or to test our new Portal features and content.
Security. We use your information for enhancing the safety and security of our Portal, products and services.
Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.

2.2. In-App Purchases
Our Portal does not provide any in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.


3.HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Portal by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, conducting analysis and research and for measuring our performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

Our analytics providers. We do not use any third-party analytics for delivering our services, conducting analysis, and research. The device data we collect and use internally are encoded. We may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking feature.
Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as Amazon Cloud and Google Cloud Platform;
Our tracking and fraud prevention providers. For our Portal, we do not do any tracking.
Third-party advertising partners. We do not have any third party advertising partners.
Other third-party service providers. For our Portal, we use in-house technical teams to develop our Portal.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Portal. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.

The list of our current service providers and partners is available here.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

4.ADVERTISING
4.1. In General
We use do not use any advertising to fund our Services. We offer our Portal for free. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us authenticate with your local Child Support Agency.

If you are an European Economic Area (EEA) – based user be aware that:

(a) When you use our Portal, we do not show advertisements to you.


4.2. In-app advertising
We do not show any advertisements to you in our Portal

4.3. View of Our ads on third-party services
We do not advertise our Portal in other apps.

4.4. WHO CAN SHOW PERSONALIZED ADS TO YOU?
Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here.

4.5. HOW CAN YOU TURN OFF PERSONALIZED ADS?
Besides specific instruments available to EEA-based users via the Portal you can use your device settings.

iOS

Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.

 

Android

Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data.

 

5. THIRD-PARTY SOCIAL NETWORKS
5.1. Connecting to Third-Party Social Networks
Our Portal does not use any third-party services or social networks to access your personal information.

5.2. Information We May Receive When You Connect to Third-Party Social Networks
N/A

5.3. How You Share Your Information On Third-Party Social Networks
N/A

6. COOKIES
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options of our Service.

7. CHILDREN’S PRIVACY
Our Service does not address anyone under the age of 16 (“Children”). When we collect personal information, the individual supplying the information to us has to have a valid child support case with their local child support agency.

8. YOUR RIGHTS
If you are EEA-based user you have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests to postmaster@skei.io

Your rights include:

Right to access your data in accordance with Art. 15 GDPR (e.g. you may check what data we store about you, for this purpose please load Terms &Privacy from your Portal settings and follow instructions in section Request a Summary of Personal Data in Privacy Policy (available to EEA-based users only))
Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your email address has been changed and we should replace your old email address)
Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you have to contact your local child support agency if you want us to delete certain data that we have stored about you, please load Terms &Privacy from your Portal settings and follow instructions in section request Personal Data to be removed in Privacy Policy (available to EEA-based users only))
Right to restrict processing of your personal information in accordance with Art. 18 GDPR (e.g. you can contact us if you want to restrict processing)
Right to take your data with you in accordance with Art. 20 GDPR (Please contact your local child support agency)
Right to object how your data is handled in accordance with Art. 21 GDPR (e.g. you can contact us if you do not agree with any user analytics procedures as described within this privacy policy)
Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly).

9. GENERAL
Your information privacy and security is important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under EEA data protection laws that apply to EEA users. We have appointed data protection officer to help us ensure compliance with EEA data protection laws. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners (see the List of our current Partners here) as for the purposes described above in “How We Share Your Information” Section, which may include a transfer of your personal information outside of the European Economic Area (the “EEA”). Please check regularly for changes to our Privacy Policy.

10. LEGAL BASES
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.

The legal bases that we rely upon are the following:

Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Portal (such as in-app messaging feature), to deliver content of the in-app purchase you make.
Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Portal free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance, is to maintain records for tax purposes.

11. SECURITY
We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

 

12. INTERNATIONAL TRANSFER
Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third party service providers and partners, which require us to protect personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.

 

13. RETENTION
We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with all of our Portal has ceased.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in “Your Rights” Section.

 

14. CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://www.skei.io/privacy-policy.

For previous versions of this Privacy Policy, please contact us via postmaster@skei.io

15. CONTACT US
If you have questions or concerns about this Privacy Policy, please contact us through one of the following ways:

for privacy questions and exercising your rights via our privacy email: postmaster@skei.io ;
our data protection officer: postmaster@skei.io, 1829 Nyork Street Muskogee, OK 74403 USA;
if you have a concern or compliance regarding our treatment of your personal data you can contact the relevant data protection authority. You can find contact details of data protection authority at https://edpb.europa.eu/about-edpb/board/members_en. For more information on which authority to contact, please email us here postmaster@skei.io.
for general information, please feel free to contact us via our contact service page: https://www.skei.io.

For information collected under this Privacy Policy, the data controller is Convexio Inc, a company under laws of United States, registered at Raleigh, North Carolina.