This policy was last updated on Nov 25, 2021.

Effie (“the software”, “the product”, or “the app”) and effie.pro (“the website”) are developed by 7S2P Inc. Your privacy is important to us (“effie.pro”, “Effie”, “7S2P”, “we”, “us”, or “our”). We abide by the General Data Protection Regulation (GDPR), and we have developed this Privacy Policy to demonstrate our commitment to protecting your (“you”, “your”) privacy.

This Privacy Policy describes our data privacy practices, including what types of personal information are gathered, how we use and share the information, how we safeguard the information, and how you can delete or change the information.

This Privacy Policy applies to personal information collected through our website effie.pro, our product Effie, and our interactions and communications with you. By using the Effie program, effie.pro or our services, you agree to how we use your personal information as stated in this Privacy Policy.

No matter how your personal information is collected and stored, we will deal with it in accordance with this Privacy Policy.

We hereby remind you to read and understand the terms of this agreement fully, pay extra attention to the exemption and mitigation clauses, the clauses restricting your rights, dispute resolution, and the application of laws. Among them, the restriction and exemption clauses may be bolded or underlined in bold to call for extra attention. Please read carefully and choose to accept or not accept this agreement. If you do not agree with this privacy policy, please stop accessing or using effie.pro or Effie.

When you use the software, its related services and visit the website, after your authorization, we will collect and use the following information to deliver better service:

When you visit our website, we may collect your cookies.

A cookie is a small text file that records your actions and preferences when you visit the website over a period of time, so you don’t have to set up your preferences when you return to the website or go from one page to another. For example, you don’t need to reset the language preference on the browser. We cannot see or store these cookies, so we won't get any information that can be used to identify your personal identity.

Cookies also help us understand visitor behavior. We use a third-party analysis tool, Countly, to collect information such as the number of pages they view, the average time they spent on the website, where they’re from, and what they click. The analysis tool solely collects the visitor’s IP address and cannot identify personal information (such as the name and address). The processing and sharing of your personal data by Countly is governed by Countly's privacy policy. We use your information collected through Countly to improve our website so that we can provide you with a better experience, and we will not use it for any other purposes. All cookies at our website are non-unique, non-identifiable, secured, and non-intrusive.

By clicking Close at the cookies prompt when visiting our website, you agree to how we use cookies. If you don’t want to place cookies on your device for tracking, you can clear them all and change your browser settings. For details on how to clear or manage cookies on your device, please refer to your web browser’s documentation. Please be aware that if you disable cookies, you may need to manually adjust certain options every time you visit our website and certain services or functions of the website may not work properly.

Our website may contain links to other websites whose privacy statements may differ from ours. If you visit other websites with the links provided, they may collect your personal information. When this happens, the processing of your information is governed by their privacy statements. We recommend that you carefully read the privacy statement of any website you visit.

In order to understand and respond to your request and provide you with follow-up customer support services, when you contact us by submitting a contact form on our website, or send us an email directly, we will collect and store your name and email address, and any information or attached files you send.

When you post a comment, your name, email address, IP address and any information you enter in the comment will be recorded by our system. Although we have access to your public comment and public username, we won’t collect or store such information. We don’t have access to your name (unless it’s the same as your username) or your email address. Only comments that are in compliance with the law will be published by us. And we won’t use your personal information for any other purposes.

To manage and verify your subscription on multiple devices, we will collect your digital purchase receipt and unique device identifier from Apple. The digital purchase receipt only includes information about the type and the time of purchase. We don’t see any contact or payment information. We also don’t have access to your Apple ID. We use a unique, pseudonymized identifier that is stored inside your iCloud account and only accessible to our app. In addition to basic purchase information, we also collect data about redeemed membership codes.

We also use MyCommerce as our third-party payment service provider. When you’re paying, you will need to provide related payment information. The processing of your information by the payment service provider is governed by MyCommerce’s Privacy Policy. MyCommerce won’t share all payment information with us, e.g., we cannot know your full bank card number or credit card security code.

We won’t use your personal information for any other purpose.

If you no longer use Effie and its related services, you can delete your account, and we will stop our services to you, provided that the conditions stipulated in the service agreement and the relevant national laws and regulations are met. (When you delete your account, all service information and data related to the account will be deleted as well.)

For statistical reasons and fraud protection, we collect pseudonymized data about the time and type of purchase or the redeemed membership codes, the unique user identifiers, an anonymous device identifier, the app versions and the language settings. In addition, we collect the App Store promotion campaign for Effie as well as the displayed purchase options within the app.

We may obtain relevant personal information that you have authorized to share from the administrator and third-party partners. For example, we may obtain account personal information (avatar and nickname) you have authorized to share from a third party and bind your third-party account with your Effie account after you agree to this Privacy Policy so that you can directly log in and use our products and/or services with a third-party account.

Effie won’t share your personal information with any companies, organizations and individuals other than Effie, except in the following circumstances:

1. Sharing with explicit consent: After obtaining your explicit consent, Effie may share your personal information with third parties.

2. Effie may share your personal information with relevant third parties in accordance with the requirements of laws and regulations or mandatory government requirements or judicial rulings.

3. Sharing with affiliated companies: In order to improve the products and services of affiliated companies that Effie recommends, your personal information may be shared with affiliated companies for the verification of their products, services, and customer service, etc. Effie will only share necessary personal information. If the affiliated company wants to change the purpose of processing personal information, they will ask for your authorization again.

4. Sharing with authorized partners: Only to achieve certain purposes stated in this policy, some of Effie’s services will be provided by third-party partners. Effie may share some of your personal information with third parties to provide better customer service and user experience. Effie will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share personal information necessary for the provision of services. Effie’s third-party partners have no right to use the shared personal information for any other purpose. You agree that Effie will share personal information with the following third parties:

If you participate in the lucky draws, competitions, or similar promotions or use credits to redeem products through the relevant website pages of Effie, our official social media accounts, etc., and Effie or the suppliers of relevant prizes and products need to send you relevant prizes and commodities, you, as the recipient, will provide your information (name, phone number and contact address) to the courier service partners or relevant suppliers.

Effie will not transfer your personal information to any company, organization or individual other than affiliated companies, except when we:

1. Have obtained your explicit authorization or consent in advance;

2. Are to meet the requirements of laws and regulations and legal procedures or mandatory government requirements or judicial rulings;

3. If Effie or Effie's affiliated companies are involved in transactions, including mergers, divisions, liquidation, asset or business acquisitions or sales, your personal information may be transferred as part of such transactions, and Effie will ensure that the confidentiality of such information being transferred at the time, and require new companies and organizations that hold your personal information to continue to be bound by the Privacy Policy, otherwise Effie will require the companies and organizations to obtain your authorization and consent again.

Effie will only publicly disclose your personal information when:

1. We have obtained your explicit consent;

2. Effie may publicly disclose and share big data analysis information without identification content after statistical processing with a third party with a cooperative relationship;

3. If Effie receives a complaint or report from a third party against you, 7S2P has the right to disclose your necessary information (including but not limited to registered name, email address, etc.) to the complaining party, and urge you to negotiate with the complaining party in order to resolve complaints and disputes in a timely manner and protect the legitimate rights and interests of all parties.

4. The collection and use of your personal information in the following situations do not require your authorization and consent:

4.1. Related to national security and national defense security;

4.2. Related to public safety, public health, and major public interests;

4.3. Related to the criminal investigation, prosecution, trial and execution of judgments;

4.4. It’s difficult to obtain your consent in order to protect the life, property and other significant legal rights of the personal information subject or other individuals;

4.5. The personal information involved is disclosed to the public by you or your guardian(s);

4.6. Collect your personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

4.7. Necessary for signing and fulfilling the contract by your requirements;

4.8. Necessary for maintaining the safe and stable operation of the products and/or services provided, such as detecting and disposing of product and/or service failures;

4.9. Necessary for legal news reports;

4.10. When it is necessary for academic research institutions to conduct statistical or academic researches based on public interests, and when they provide academic researches or described results to the outside, they de-identify the personal information contained in the results;

4.11. Other circumstances stipulated by laws and regulations.

The information you keep in Effie will be encrypted and stored on our server, but we will not use your data for profit, nor can we make any intelligent recommendation algorithms based on content analysis, nor access any advertising system, and will not do any other operations on these data.

Your personal information collected by Effie’s authorized software and services may be stored in Effie, or it may be stored and processed in subjects that Effie deems necessary to know such information. Effie will only retain your personal information for the period necessary for the purposes described in this policy and within the time limit required by laws and regulations. Effie will strictly abide by the relevant laws and regulations on the collection, use, storage, and sharing of you personal information, and use various security technologies and procedures to prevent information loss, improper use, unauthorized reading or disclosure.

Since the Internet is not an absolutely secure environment, and emails, instant communications, and online communication with other third parties may not be encrypted, Effie strongly recommends that you don’t send personal information through such methods.

Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technical limitations and various malicious attacks that may exist, even if we do our best to strengthen security measures in the Internet industry, it is also impossible to always guarantee the 100% security of the information. We will do our best to ensure the security of the personal information you provide to us. Please be aware and understand that the system and communication network you use to access our services may encounter problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of personal information, including but not limited to using complex passwords, regular change of passwords, and not disclosing personal information such as your account password to others.

In the event of an incident that endangers network security, we will take corresponding remedial measures in a timely manner in accordance with the emergency plan for network security incidents. If our physical facilities or technical protection measures are damaged, causing your personal information to be leaked, illegally provided or misused, causing damage to your legitimate rights and interests, we will assume corresponding responsibilities in strict accordance with the provisions of the law.

After we learn that your personal information has unfortunately been leaked, illegally provided or misused, we will inform you in a timely manner within [10] days at the latest in accordance with the requirements of laws and regulations: the basics of the security incident and possible impacts, the disposal measures we have taken or will take, suggestions that you can prevent and reduce risks on your own, and remedial measures for you, etc. We will inform you of the incident-related situation in the form of push notifications on the platform. When it is difficult to inform the personal information subjects one by one, we will adopt a reasonable and effective way to publish an announcement. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

If you need to check, update or correct your personal information, or have any questions, complaints or suggestions about your personal information protection, you can email Effie at help@effie.pro. Effie will handle your problem in a timely and effective manner.

If you are under 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using Effie and its related services.

We protect minors’ personal information in accordance with relevant national laws and regulations, and will only collect, use, save, share, transfer or disclose minors’ personal information when permitted by law, parents or other guardians explicitly consent, or necessary circumstances to protect minors; If we find that minors’ personal information is collected without prior verifiable parental consent, we will try to delete the relevant information as soon as possible.

If you are the guardian of a minor, when you have any questions about the personal information of the minor you guard, please contact us through the contact information disclosed in this Privacy Policy.

In order to provide you with better service and with the development of Effie, the provisions of this Privacy Policy may be revised from time to time. Effie will issue updated versions on our website, and/or with the product update. Effie hereby recommends that you check this Privacy Policy regularly, to know whether this Privacy Policy has been updated and get the updated version of the the content after modification.

The title of each clause of this policy is only listed for the convenience of users. The specific information expressed in each clause is still subject to the actual content stated in each clause.

Please feel free to leave us comments about our privacy polices. If you have any questions, or concerns, please contact us at help@effie.pro. We may update this email addressfrom time to time as part of these policies.