BogorBerdaya takes user privacy very seriously. While using our products (including services), we may collect and use your relevant information in order to improve the quality of our services; we will do everything in our power to protect your privacy, as long as it is within a reasonable business scope. We recommend that you read the "Privacy Policy" in detail to get an understanding of what type of information we collect, how we collect this information and how we use it. By using our products or services, you agree to the collection, storage and use of your information as long as it follows the context dictated here and the adherence of local laws and regulations.

This "Privacy Policy" utilizes certain professional terms; we will try to explain things as concise as possible, so that you may understand completely.

The collection and use of information

We collect and store relevant personal information in order to create your Camera360 Account, and to provide the necessary support for any follow-up services. If you do not wish to provide this information, you might not be able to register an account, enjoy any or all services provided afterwards, or get the best user experience of certain services. Unregistered users may also use certain functions; we do not collect any personal information from unregistered users.

The information we collect includes：

Any names, email addresses, mailing addresses, telephone numbers, uploaded profile photos or bank cards, etc. entered or filled in when you register for an account. Bank card or credit card information is used to pay for Pinguo Technology services or products.
The information collected When using "Share Photo Stream" or "Share" services.

Other information we collect includes：

Any geographical locations, system languages, device model and type, or operating system versions while you are interacting with our services using any computers or devices. This information will help us learn more about you, in order to optimize services and provide a better user experience.
Any records, including statistical information, key operation paths, error logs, crash logs, etc. you encounter while using our products. This will help us to get a better understanding of the status of our products, in order to improve our services, further optimize user experience and provide higher quality products.
Any location information and file creation times for your photos (or similar files); any special characteristics of persons within your photos; and any content contained within your photos. We will use this information to provide "People Aggregation", "Location Aggregation", "Content Labeling", as well as a combination of other custom features using these functions as a basic foundation.
You can turn off "BogorBerdaya Cloud Services"; if you do so, we will not collect any information related to your photos (or similar files). However, you will not be able to enjoy any functions that require this information anymore.
You can turn off your device or turn off GPS location functions; by doing so, we will not obtain your current location information.

To make full use of Camera360 services, you need to create a Camera360 account using a valid email address or phone number.

We may send you notifications via email or system notifications; if you do not wish to receive these messages, you can turn them off for your device or Application by following the relevant prompts.

You may stop using our service at any time. When you delete data, a copy might remain on the servers for a period of time before complete deletion; this is due to computer system operation and continuous data backup and archiving features.

Information Disclosure

When you use Camera360 products or services, we assume that you allow and agree with these terms. Therefore, we shall not share your information with any third parties, sell or rent your information, or distribute this information to others; with the exclusion of the following situations.

We can share your information after receiving your confirmation to do so.
For mandatory reasons, such as the completion of a payment transaction to purchase Camera360 products; we might be required to share your information with associated third parties. These service providers are only authorized to use your personal information within the range required to provide said services.
In order to protect our legal rights and interests, or those of our partners and clients, we may disclose your personal information as permitted by the extent of the law.
In order to comply with local laws and regulations, for any mandatory reasons, to maintain the rights of others and to maintain public interests or other laws, we may release your personal information carefully and within the legal framework.
When there are mergers, acquisitions or other similar transactions, your personal information may be traded as a resource. If this happens, we will inform you beforehand so that you may decide if you wish to destroy or transfer your personal information.

Data Security

We use a variety of industry standard encryption methods (such as SSL, TLS) to protect you during the transmission, storage and sharing of data. But we ask that you understand that due to the limitations of the Internet, even while using the most advanced security technology available, we cannot guarantee 100% information security. Therefore, we ask that you understand and confirm the risks involved when transmitting information to us.
When you store data on our server, we will ensure the safety of your data through policies, physical means, logical means, etc. However, the data on your device or computer depends more on your equipment safety, so we recommend that you take the necessary precautions to ensure the safety of your local data.

Policy Updates

When there is an update on the Privacy Policy, we will display the update date at the top of the Policy in an obvious position. We recommend that you carefully check the updated content every time; when you continue to use our products or services, we shall always assume that you agree to the terms and conditions that are effective at the most present time.

Privacy policy for OneSignal

Most developers of apps and websites know by now that they need a privacy policy. Not only is it mandated by many regulations across the planet, but services themselves have also become quite vocal about the need for a privacy policy.

Google has recently made sure that any apps requesting specific permissions have a privacy policy by mass emailing developers with the new rules (and removing non-compliant apps).

OneSignal is a push notification service provider that offers its base service for free. Free usually means that data is sold in one way or another. From a data protection perspective that usually has at least the alarm bells go off.

Not unsurprisingly OneSignal also offers some insights into what it considers minimum requirements for your privacy policy (if you use OneSignal).

Let’s take a look at the various documents and its contents (highlights by iubenda):

From the OneSignal terms:

Privacy Compliance. The Parties agree to comply with all applicable privacy laws, and each respective party agrees to perform the following obligations:

Licensee is responsible for obtaining all applicable consents required to enable OneSignal to collect information from End User’s device or browser. Licensee shall publish privacy policies and disclosures for the Properties that comply with applicable law and the terms of this EULA, including, but not limited to, clearly disclosing that the SDK Information will be collected and how it may be used, as set forth in Section 5 above.

Each Party shall at all times comply with its respective published privacy policies and disclosures, and each party shall at all times post a privacy policy on its website that describes how it collects, uses and shares information, and that provides information about how an End User can opt out of interest-based advertising (e.g., online behavioral or mobile cross-app advertising).

Where Licensee provides data (such as IDFAs, Android Ad IDs, or location data) in a manner other than through Company’s proprietary SDK, including without limitation through an API or an SDK proprietary to the Licensee, Licensee shall be responsible for ensuring ensure that any collection and transfer of data is done in compliance with user’s stated preferences, including without limitation devices settings to “Limit Ad Tracking” and “Opt Out of interest-based ads.”

Licensee shall notify Company in writing of any further data usage or governance requirements, restrictions or limitations, to the extent they apply, in which case the Parties may execute a further, paid subscription plan setting out such limitations and licensing payments to supplement the terms herein.

First of all you’re required to collect the necessary consents. You need a privacy policy that outlines the data processed by OneSignal and your app and how this data is used. This privacy policy goes into detail about how you collect, use and share information, plus it provides information about how your user can opt-out of interest-based advertising.

From the OneSignal privacy policy:

Consumer Control & Opt-Out Options.

In most cases, consumers have control over whether or not they would like to receive relevant advertisements and marketing email from our Clients.

Opting Out of OneSignal Push Notifications
You may in most cases opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for some or all of the apps on your device. (Different device configurations, or updates to devices, may affect or change how these settings work.)
Your choice to opt out of “Notifications” from the OneSignal platform will not affect ads placed by any other organization.

Opting Out of Online Interest-Based Advertising You can opt out of many of the platforms and service providers that facilitate online interest-based advertising by visiting the Digital Advertising Alliance’s consumer education and opt-out page, at http://www.aboutads.info/. This type of opt out is cookie based, which means that if you replace or upgrade your browser, or delete your cookies, you will need to opt out again. Opting out in this way will not prevent you from receiving ads – it will just make the ads you see less customized to you.

Opting Out of “Cross-App” Advertising on Mobile Devices
You can opt out of having your mobile advertising identifiers used for certain types of interest-based (also called “cross-app”) mobile behavioral advertising, by accessing the “settings” on your Apple or Android mobile device, as follows:

Apple Devices: If you have an Apple device, you can opt out of most app-based tracking for interest-based advertising by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON.’ You can do this by clicking on Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON.’

Android Devices: If you have an Android device, you can opt out of most app-based tracking for interest-based advertising by opening the Google Settings app on your device, selecting Ads, and then selecting the option to opt-out of interest-based ads.

Please note that these platforms control how these settings work, so the above may change. Likewise, if your device uses other platforms not described above, you should check the settings for those devices.

Additional Choices
Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for retailers, applications and websites to learn more about their privacy practices.
You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.

The above gives you a good overview of how you can help your users to opt-out of various features applied by OneSignal.

How to write that privacy policy section for OneSignal

This should give you a good idea of what you might want to put into your privacy policy document. If you’d rather have someone else take care of many of the headaches caused by managing privacy policies, you may want to take a look at iubenda and our privacy policy generator for mobile apps or web site privacy policy generator.

We have added a OneSignal section that you can add to your privacy policy via the dashboard of your account.

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