Last modified: July 16, 2022
Contact information of the data controller:
Founder: Anna Holovko
Address: Harwood Street, British Columbia, Canada
“NON-PERSONAL DATA” refers to information that does not allow the identification of a person. “PERSONAL DATA” means any information relating to an identified or identifiable individual (“data subject”), such as the data subject’s name, identification number, location data, or online identifier. Personal data is often similar to Personally Identifiable Information (PII). However, personal data is broader in scope and encompasses more data than PII.
“GDPR” stands for the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data.
CCPA stands for the California Consumer Privacy Act of 2018.
COPPA stands for the Children’s Online Privacy Protection Act of 1998.
“EEA” includes all current member states of the European Union and the European Economic Area. For the purposes of this policy, the EEA includes the United Kingdom of Great Britain and Northern Ireland.
Information we collect and how we collect it
When using Lily Mily, we may ask you to provide certain personal data. For transparency, we explain in detail what personal data we collect and have access to, the purposes for which we use it, and the legal basis on which we rely when processing your personal data. We adhere to all principles of data minimization, meaning that we only collect the minimal necessary amount of personal data for your further use of Lily Mily.
Personal data collected through the Applications
When you use the Applications, we collect your email address, name, and age. We use this data for the following purposes:
Additionally, we automatically collect certain necessary information that we use for re-engagement and re-attribution purposes. Please note that this information, such as your device identifier, may be considered personal data under certain laws. However, this technical data does not allow us to identify you as an individual, and we have no intention of doing so. We have listed in detail all types of technical information that we automatically collect through the Applications:
- Device identifier;
- Timestamps that inform us when you install or first launch the program;
- Information sent by self-reporting networks, such as Facebook, Snapchat, and Google Ads;
- URLs you click on to access the application or later;
- Information about how you use the Application;
- Advertisements you click on or view;
- Other data about your online behavior.
We use the above-mentioned technical information for detailed analysis of your usage.
We collect this information for the Applications to understand how you discover the Applications, to study the reasons behind your installations or deletions of the Applications, and to track your online behavior.
We retain this data for as long as necessary for its purposes, but no longer than 12 months.
The lawful bases on which we rely for collecting information and using your personal data are “performance of a contract with you,” “your consent” (for targeted advertising emails, quality marketing, and promotions), and “pursuing our legitimate business interests” (i.e., ensuring the security of the Applications and complying with applicable laws).
The applications downloaded from Google Play Store, when used, utilize the analytical services of our third-party provider, Firebase (https://firebase.google.com), offered by Google. Firebase automatically collects the following technical personal and non-personal data from you:
- IP address;
- Number of sessions;
- Session duration;
- Installation source;
- IDFA (Identifier for Advertising).
We use the collected data for the following purposes:
- We use the collected data for the following purposes:
- Analyzing technical aspects of your use of the applications;
- Optimizing the applications to suit your needs;
- Preventing fraud and misuse of the applications;
- Ensuring the security of the applications;
- Displaying relevant advertisements to you;
- Providing the full range of our services;
- Verifying age restrictions in compliance with the legislation of your country of residence;
- Offering the option to purchase the FULL VERSION subscription or specific individual sections within the applications;
- Personalizing your experience to offer tailored offers specific to you;
- Using promotional codes;
- Personalizing content;
- Searching for and fixing errors;
- Providing user support and assistance;
- Using data for administrative, analytical, and statistical purposes;
- Facilitating and promoting communication among users;
- Providing advertising/marketing information, including joint special offers from the Company and our partners;
- Conducting advertising/direct marketing and assessing effectiveness;
- Managing subscriptions and cancellations;
- Protecting against any malicious user actions and other security considerations for the Company;
- Safeguarding the legitimate interests of the Company;
- Complying with other legal requirements, including timely responses to requests from data subjects and supervisory/law enforcement authorities;
- Candidate selection and employment within the Company.
We kindly ask for your understanding regarding certain types of targeted advertisements in our mobile applications, including third-party ads, to raise funds for the development, distribution, and technical support of our programs, many of which are offered for free. For example, while using our applications, you may encounter third-party advertisements.
To send you any promotional/marketing messages via email, we require your specific consent, which can be revoked at any time (including by contacting our data protection officer).
We request that you only provide personal data that is necessary for the selected service, newsletter distribution, or response to your specific inquiry/complaint. If you decide to disclose additional personal data voluntarily, we will ensure its processing with an appropriate level of security.
We retain such data for as long as necessary for its purposes, but no longer than 12 months. The legal bases for processing the above-mentioned data are “pursuing our legitimate business interests” (i.e., analysis, expansion, and protection of our applications) and “your consent.”
Processing Personal Data Objectives
The company provides services and makes its programs available practically worldwide. We primarily use the collected information about users/clients to ensure the proper quality of our services, including improving your gaming experience and enhancing the features and capabilities of our programs in the future. We may analyze information related to program usage to tailor user tasks and better meet their needs.
Some of our programs have in-app purchase functionality (FULL VERSION plan or specific sections).
External payment systems do not share the information you provide, and we do not have access to credit card data. However, we receive summaries of all successful purchases, including the transaction amount necessary to grant access to your in-app purchase.
Ми використовуємо хмарні сервіси Google LLC (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4) для безпеки персональних даних.
We do not collect any sensitive or special categories of personal data (“confidential data”) from you unless you decide to provide such data at your discretion. This includes personal data related to your health, racial origin, sexual orientation, religion, political beliefs, or membership in a professional or trade association.
Promo Code Terms
Lily Mily Promo Codes (“Promo Codes”) are provided by Lily Mily (directly or through a partner) in accordance with the Terms of Service (“Terms and Conditions”). Each Promo Code provides access to the FULL VERSION or specific sections:
at a special price;
starting from the moment you confirm your acceptance of the Promo Code by submitting valid payment details accepted by Lily Mily (Promo Period);
Under certain circumstances, considering the overall limit of allowed redemptions for this Promo Code.
By purchasing Promo Codes, you:
- give your consent to the advertised Promo Code;
- accept and agree to these Promo Code Terms;
- acknowledge and agree to the Terms and Conditions.
To be eligible for receiving a Promo Code, users must meet all the following conditions (each referred to as “Eligible User”):
If you do not have a subscription to a previous Promo Code advertised as available to current subscribers, a valid subscriber;
Promo Codes are non-cumulative;
Purchasing the full version or individual section is possible with the use of a Promo Code but as a one-time entry;
The right to use the Promo Code remains until the next update of the mobile application, after which the Promo Code needs to be reinstalled;
Provide Lily Mily with a valid and up-to-date payment method approved by Lily Mily;
Additional qualification requirements (if any) occasionally advertised in connection with the Promo Code. Users may redeem the Promo Code once per respective requirements. Previous users cannot avail the offer again.
The promotional code must be accepted before its expiration date, if applicable. Except where prohibited by law, Lily Mily reserves the right to modify, suspend, or terminate the validity of the promotional code at any time and for any reason, and in such a case, we will not honor subsequent registrations with the promotional code.
Duration and Cancellation
Some of our applications feature in-app purchases (FULL VERSION plan or certain sections).
External payment systems do not transmit the information provided by you, and we do not have credit card data. However, we receive summaries of all successful purchases, including the transaction amount, which is necessary to grant access to your in-app purchase.
If you do not cancel your subscription before the end of the promotional period, you will automatically become a permanent subscriber, and your Lily Mily Premium subscription will automatically renew for additional periods equivalent to the subscription term unless you cancel it before the expiration of the corresponding subscription term according to the terms and conditions of Lily Mily. The payment method you specify will automatically charge the current subscription fee. If you cancel within the promotional period, you will lose access to Lily Mily Premium, and you understand and agree that you will not receive any refund or exchange of any kind, including for any unused virtual currency or other virtual item, any Content, or data associated with the use of the Service or anything else.
By using the promotional code, you understand and agree that your anonymized aggregated data may be transferred to a Lily Mily partner or provider who provided you with the promotional code.
When you subscribe to the newsletter through the form available on the Website or in the Apps, we collect your email address. We use your email address to deliver the requested newsletters to you. The legal basis on which we rely for processing your email address is “your consent.” We retain such data until you unsubscribe from our mailing list.
When you leave a comment under one of our blog posts available on the Website, we collect your name, website (if provided), and any information you choose to provide in your comment. We use this information to post your comment and ensure the security of the website. The legal basis on which we rely is “pursuing our legitimate business interests” (i.e., supporting, developing, and promoting Lily Mily). We retain such data as long as your comment remains on the website.
If you need to, you can contact us, and we may keep a record of any questions, complaints, recommendations, compliments, and responses you provide. Where possible, we will delete any personal data not required for keeping such records.
There are several types of cookies, namely: (i) persistent cookies, which remain valid until you delete them yourself, (ii) cookies that remain valid until their expiration date, and (iii) session cookies, which are stored in the web browser and remain valid until the browser is closed. Cookies can also be (i) first-party cookies (set by the original website) and (ii) third-party cookies (placed by third-party websites).
By agreeing to accept our optional cookies through the cookie consent banner, you grant permission to us and the third parties we cooperate with to place, store, and access some or all cookies on your device. Below are the types of cookies described.
- Basic technical cookies that are strictly necessary for ensuring the proper and high-quality functioning of Lily Mily and providing essential services;
- Preference cookies that allow us to store your preferences for future reference and development;
- Marketing cookies, which enable us to create, implement, and analyze our marketing campaigns. These cookie files help us target the right audience, analyze the effectiveness of our marketing campaigns, and provide you with personalized advertisements;
- Statistical cookie files that allow us to generate necessary statistical reports on how you use Lily Mily.
- Identifying the Lily Mily areas you have visited.
- Personalizing the content you see on Lily Mily.
- Analyzing your usage of Lily Mily.
- Remarketing our products or services to you.
- Remembering your preferences, settings, and login data.
- Targeted advertising and displaying ads that match your interests.
- Allowing you to leave comments.
- Enabling you to share content on social media.
When we request consent for the use of optional cookies, you can choose not to provide such consent. In most web browsers, you can disable cookies at any time if needed. You can refer to the documentation of your web browser to learn how to do this. However, if you disable cookies, you may not be able to access Lily Mily’s features properly or at all.
Pixels (Web Beacons):
To collect general information about your usage of Lily Mily, we may also use a technology called web beacons (pixels).
This technology allows us to track the usage of special promotional campaigns or informational banners. Through web beacons, we receive information that allows us to statistically track the number of people who opened our emails. Web beacons also help us understand your behavior.
Pixels are used in combination with cookies to track browser activity on a specific device. We use pixels from third-party sources for tracking and statistical purposes.
Please note that the provided text is an automated translation, and it’s always advisable to review the original text for accuracy and clarity.
Refusal to provide personal data
If you do not provide us with sufficient personal data upon request, we may not be able to provide you with all our products and services. However, you can still access and use certain parts of Lily Mily without providing us with your personal data.
Sale of personal data and successors
We do not sell your personal data to third parties, and we will not do so in the future.
Transfer of personal data from the EEA
The personal data we receive from you may be stored, processed, and transferred between any countries in which we or our data processors operate. The European Union has not found the United States and certain other countries to have an adequate level of personal data protection, according to Article 45 of the GDPR. We rely on derogation for specific situations as set forth in Article 49 of the GDPR. If it becomes necessary to transfer personal data outside the European Economic Area (EEA), we will ensure that the country to which the third-party recipient belongs guarantees an adequate level of protection for your personal data, or we will enter into an agreement with the respective third party to provide such protection (e.g., data processing agreement based on pre-approved standard contractual clauses).
If you wish to lodge a complaint about how we process your personal data, we kindly ask you to contact us first and express your concerns. After you have contacted us through any convenient means, we will examine your requests and complaints and prepare a response for you within 30 days. If you are dissatisfied with the outcome of your complaint, you have the right to lodge a complaint with the local data protection authority.
Information exchange with affiliated entities and other third parties
We do not sell or lease your personal data to third parties for marketing and advertising purposes. We may provide personal data only to our third-party service providers, specifically our data processors, whom we hire to process data on our behalf. These third-party service providers include:
Amazon, Snapchat, Pinterest, Amplitude, TikTok (push notifications delivery services).
Facebook, Google, Snapchat, TikTok, Pinterest (analytics services, advertising networks).
Unity Technologies, Google Firebase, AppsFlyer (analytics and remote configuration tools).
Disclosure of your personal data
Disclosure of your personal data is limited to situations where it is necessary for the following purposes:
- Ensuring the proper functioning of Lily Mily.
- Providing services to you.
- Responding to requests.
- Pursuing our legitimate interests.
- Protecting our rights, preventing fraud, and ensuring security.
- Performing our contractual obligations.
- Legal purposes.
- Or if you give prior consent to such disclosure.
Your non-personal data may be disclosed to third parties for any purposes as they do not identify you as a physical person. For example, to improve Lily Mily, we may share it with potential clients or business partners for commercial or research purposes.
Provision of Information Required by Law
By law, we may be obligated to disclose your personal data if such disclosure is required by a court subpoena, law, or other legal proceedings;
- necessary to provide assistance to law enforcement officers or government law enforcement agencies;
- necessary for investigating violations or ensuring compliance with our terms;
- necessary to protect us from legal claims or demands from third parties, including you and/or other users; or
- necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliated parties.
Retention and Destruction of Your Personal Data
We only retain collected information (including personal and non-personal data) for as long as necessary and no longer than required. This means until its intended purposes or other legal or business objectives are fulfilled (if we have a legal basis for its retention). Your information may be stored electronically, on paper, or in both forms. It will be retained during the period necessary for verifying our activities, fulfilling our contractual obligations, pursuing our legitimate interests, and conducting audits. After this period, the information will be deleted.
Protection of the Privacy Rights of Third Parties
If any of your postings on Lily Mily contain information about third parties, you agree to ensure that you have permission to include such information. While we are not legally responsible for the actions of our users, we will remove any notified messages that violate the privacy rights of others.
Do Not Track Settings
Some web browsers have settings that allow you to prevent us from tracking your activities on Lily Mily. Lily Mily does not respond to such “Do Not Track” signals. You can disable these tracking features and other security settings in your browser by referring to your browser’s user guide.
Links to Other Websites
Rights of Data Subjects
Rights of data subjects according to Ukrainian law
We inform you about your rights regarding the protection and processing of personal data in accordance with Ukrainian law:
To know the sources of collection and the location of your personal data, the purposes of processing, the location or place of residence of the owner or controller of personal data, or to authorize your authorized representatives to receive this information, unless otherwise provided by law;
To obtain information about access to your personal data, including information about any third parties who have received your personal data;
To access your personal data;
Within thirty days from the relevant request, unless otherwise provided by law, to receive a response about whether your personal data is being processed and to receive the content of such personal data;
To provide a reasoned objection to the processing of personal data to the subject of personal data;
To submit a justified request to change or delete your personal data by any owner or controller of personal data if such personal data is processed illegally or is inaccurate;
To protect your personal data from any unlawful processing and accidental loss, destruction, or damage caused by intentional concealment, non-disclosure, or untimely disclosure, as well as protection against the disclosure of any information that is inaccurate or damaging to the honor, dignity, and business reputation of a natural person;
To lodge complaints about the processing of your personal data to the authorized administrative body for personal data protection in Ukraine – the Department of Personal Data Protection of the Secretariat of the Verkhovna Rada Human Rights Commissioner or to a court;
- To apply legal remedies in case of any violations of data protection rules;
- To make statements regarding the restriction of data processing with consent for such processing;
- To withdraw your consent to data processing;
- To know the mechanism of automated data processing;
- To protection from automated decision-making with legal consequences.
Rights of Data Subjects according to GDPR
Please note that when you contact us, you must go through an identification process and provide specific requests so that we can process your inquiry and respond on lawful grounds. The list of data we must provide to you is contained in Articles 13 and 14 of the GDPR.
Please be aware that if we cannot identify you through messages or your support request, or if we have reasonable suspicions about your identity, we may ask you to provide your identifier. Only in this way can we avoid disclosing your personal data to someone pretending to be you.
We process requests as quickly as possible, but please remember that providing a complete and lawful response regarding personal data is a complex process that can take up to a month or even longer. If we need more time to prepare a complete response, we will inform you.
GDPR has established the following additional rights for data subjects to protect their personal data:
Right to Information
We are prepared to provide data subjects with information about the personal data we process. If you want to know what personal data we process, you can request this information at any time, including by contacting the Company’s data protection officer.
Right to Rectification
If you find that some of your personal data we process is incorrect or outdated, please inform us about it, including through the Company’s data protection officer.
In some cases, we may not be able to change your personal data. For example, when your personal data has already been used in a contract of offer and acceptance and/or is contained in any written document submitted to any government authority or otherwise in accordance with applicable law.
Right to Data Portability
In some cases, you may receive or request that we provide your personal data to any third party in a structured, widely used, and machine-readable format.
Right to Restriction of Processing
You may request the restriction of data processing so that we can only retain them. This means that we must stop any processing of your data, except for storage under certain circumstances.
Withdrawal of Consent to Data Processing and Right to Erasure
If we process your personal data based on your consent (e.g., for marketing communications), any further processing can be stopped at any time. Simply withdrawing your consent for such processing is sufficient.
You can also exercise your right to erasure. In cases specified in Article 14 of the GDPR, the Company will erase the processed personal data, except for data that we are required to retain in accordance with applicable law.
If you are the parent of a child aged under 13 (or any other age set by applicable law) and believe that your child has disclosed any information to us without your consent, please notify us immediately, and we will delete this information.
Rights Concerning Automated Decision-Making and Profiling
Data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, that has legal effects on them or similarly significantly affects them.
We do not use personal information for marketing and online profiling.
Our users residing in the EU have the right to lodge a complaint with the European Data Protection Supervisor.
Protection of Children’s Privacy
We consciously do not collect, store, or use personal information of children under the age of 16 without the consent of their parents/legal guardians. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com.
Our Security Policy
We have implemented standard security measures and authentication tools to protect personal data in Lily Mily. We and third-party service providers also ensure technical and physical security measures to safeguard your personal data. Our security measures include secure networks, SSL protocols, strong passwords, limited access of our employees to your personal data, and the anonymization of personal data when possible.
Unfortunately, we cannot guarantee the prevention of loss or unauthorized use of your personal data or the secure transmission of data over the Internet due to its inherent nature. We strongly recommend that you protect any password you use for Lily Mily and refrain from disclosing it to anyone else.
All media files on the website lilymily.com and in the mobile applications Lily Mily Coloring book-game for Toddlers and Lily Mily Drawing for Kids (“Applications”) (collectively referred to as “Lily Mily”) are protected by law. If any other source uses any media files that are already presented on our website, you may potentially be infringing on copyright laws and may face copyright infringement lawsuits. The idea and development stages of the mobile application “Lily Mily” are legally protected, and a Certificate and Decision on copyright registration have been obtained. Copying the style of the mobile application “Lily Mily” or game logic would constitute a copyright violation and may lead to copyright infringement lawsuits.
Address: Anna Holovko, British Columbia, Canada.
Email address: firstname.lastname@example.org