PRIVACY POLICY

Updated: December, 2024

GENERAL INFORMATION

This PRIVACY POLICY outlines how RAWSTHORN LTD handles personal data gathered from you during your use of the Motie App, RAWSTHORN LTD data protection practices and indicates the various types of information that may be processed when you use the Motie App. It is applicable to all individuals who access and use the Motie App regardless of the locations of such individuals (except for the section " ATTENTION U.S. RESIDENTS" >>.

RAWSTHORN LTD gathers data, either individually or when combined with other information under its possession, that has the potential to identify you ("personal Information").

"Personal data" or "personal information" - any data, of any nature, concerning an individual who can be identified, either directly or indirectly, specifically through reference to that data.

RAWSTHORN LTD kindly requests that you carefully review the following PRIVACY POLICY to understand how your personal data may be processed. By utilizing the Motie App, you acknowledge that you have read, comprehended, and consent to be bound by these terms.

Unless stated otherwise, RAWSTHORN LTD assumes the role of data controller for the purposes of the General Data Protection Regulation (GDPR).

The Motie App is designed for adults, not for children. As a result, RAWSTHORN LTD does not knowingly or intentionally gather or request any personal information from children.

“Child” or “children” - terms that may be interpreted differently on the basis and in accordance with applicable data protection laws of certain countries. RAWSTHORN LTD considers as a child any person who is under 16 (sixteen) and holds this opinion until RAWSTHORN LTD has legal grounds to consider and treat such person as an adult.

Anyone who is considered a child in accordance with applicable data protection law should not provide any personal information directly to the Motie App. Parents or guardians are solely responsible for controlling the provision of their children’s personal data. It means that it is parents’ or guardians’ liability to prevent their children from providing any personal data to the Motie App without verifiable parental consent. If RAWSTHORN LTD becomes aware that RAWSTHORN LTD have collected personal information from a child without obtaining verifiable parental consent, RAWSTHORN LTD will promptly delete that information.

Safeguarding the security of your personal information is of utmost importance to RAWSTHORN LTD. RAWSTHORN LTD adheres to widely accepted industry standards to ensure the protection of personal information that is transmitted to RAWSTHORN LTD. RAWSTHORN LTD implements suitable technical and organizational measures to uphold data protection principles, such as data minimization, in an effective manner. RAWSTHORN LTD strives to encrypt your personal data using robust encryption algorithms, including hashing whenever feasible. In the event of a security breach that compromises your personal information, RAWSTHORN LTD will promptly notify you in compliance with applicable laws.

TYPES OF PROCESSED INFORMATION

1. Automatically processed data Information:
With your consent, RAWSTHORN LTD utilizes third-party technologies for automatic data processing (such as advertising or analytics tools) to analyze specific information transmitted by your device through the Motie App. This includes Identity For Advertisers. Certain integrated advertising or analytics tools engage in automated processing of your personal data, which may involve profiling (any form of automated data processing utilized to assess various personal aspects concerning you to analyze or predict factors related to your personal preferences, interests, behavior, location, or movements). The automatic processing of information commences once you grant permission for the Motie App to track your activity. You have the option to withdraw your consent at any time; please refer to the section "OPT-OUT" below. RAWSTHORN LTD may process certain information regarding your device and user behavior based on RAWSTHORN LTD legitimate interests. It typically does not individually identify any specific individual, and RAWSTHORN LTD only accesses it in an aggregated format. The purpose of processing - to enhance the Motie App and provide you with the optimal experience. Please note that RAWSTHORN LTD does not have direct control over the information automatically provided to advertising or analytics tools. Therefore, RAWSTHORN LTD cannot assume responsibility for the processing of such information. If your user ID is linked to your Facebook account, Facebook may utilize your device information in conjunction with categorized data stored in their databases (such as age, gender, or other demographic details). RAWSTHORN LTD does not oversee, monitor, or guarantee the practices of third parties in handling your personal data, which they may collect through their own methods unrelated to the Motie App.	Device Information: When you utilize the Motie App on a mobile device, certain details regarding your device are recorded, which may include "device identifiers" (small data files or similar structures that are stored on or linked to your mobile device, allowing for the unique identification of your device (but not your personal identity)): 1) information connected with device: its type, operating system version, model, manufacturer, screen size etc to optimize the performance and compatibility of the Motie App on your device; 2) internet connection information: your mobile carrier, network provider, network type, IP address, timestamp, session duration, connection speed, and browser to deliver a seamless browsing experience and troubleshoot any connectivity issues; 3) location: your IP address, country code, region, state, city associated with your SIM card or device, language settings, time zone, and nearby points of interest to offer location-based features and tailor content to your geographical preferences; 4) other information: user identifiers set up to personalize your experience and provide relevant content based on your user profile. Application Information: name, API key (identifier for the application), version, and properties of the Motie App to improve the services and understanding user behavior within the Motie App. Cookies and etc: cookies and similar technologies such as pixels, web beacons, and scripts. These technologies help to enhance the functionality and effectiveness of the Motie App. For instance, to track the number of users accessing specific areas or features of the Motie App and determine which links or advertisements are clicked on. Log File Information: whenever you make a request to access the Motie App or install it on your device, log file information is automatically generated and recorded: the start and end times of your the Motie App usage of the Motie App and your interactions within the Motie App. Ad-related information: the date and time an ad is displayed, the content and nature of the ad offer, the ad format (text, image, or video), the specific placement of the ad within the Motie App, and your interaction with the ad. In-App events: tutorial progress, level advancements, payments, in-app purchases, custom events, progression milestones, and user data processing preferences.
2. Functional Information:	Contact Information (such as your name, email address, and any additional content provided in the email) that you voluntarily provide when reaching out to RAWSTHORN LTD via email or support form. RAWSTHORN LTD collects, stores, and processes this information using its cloud storage provider (Amazon.com, Inc.) to ensure efficient response to your inquiry, fulfill your requests, deliver the requested services, and send you the communications you specifically request. Activity Info that is necessary to your use of the Motie App. RAWSTHORN LTD needs to have a technical access to your mobile gallery (i.e. Photos) to be able to save widgets and other content available within the Motie App to your device. RAWSTHORN LTD does not collect, store or use the data contained in your mobile gallery unless you share this data with RAWSTHORN LTD otherwise. Motie Activity Info that is related to your use of the “Motie” function. The “Motie” function allows you to track habits, set goals and control the achievement of such goals. Motie Activity Info saves and stores on your mobile device. RAWSTHORN LTD does not collect or store the data you enter via the “Motie” function and does not use this data for purposes other than providing you with functionality of the “Motie” function. Widget Data that is related to your use of the Motie App functions which allow you to personalize and customize widgets by adding your personal data (i.e., Horoscope Widgets, Weather Widgets, Distance Widgets via “Profile and Friends” function). Widget Data related to your use of Horoscope Widgets and Weather Widgets: (i) saves and stores on your mobile devices; (ii) does not collected or stored by RAWSTHORN LTD; (iii) may be transferred to the third-party service providers (https://vedicastroapi.com/, https://openweathermap.org/ ) for the purposes of providing you with the Motie App functionality. Please refer to the section “SHARING OF THE DATA” below to get links on privacy policies of the third-party service providers mentioned herein. Widget Data related to your use of Distance Widgets via “Profile and Friends” function: (i) does collected and stored by RAWSTHORN LTD only for the purposes to provide you with the full access and functionality of the “Profile and Friends” function; (ii) may be deleted on your request at any time (with necessary provision of your User ID randomly generated during your usage of the “Profile and Friends” function).
3. Payment Information:	The billing, processing, and charging for in-app purchases are handled by RAWSTHORN LTD e-commerce provider (Apple). They are responsible for safeguarding and ensuring the security of your personal information. This information is processed to fulfill the contractual obligations between you and RAWSTHORN LTD. Please note that RAWSTHORN LTD does not have access to or utilize your credit or debit card details.

THE PURPOSES OF PROCESSING

1. Enabling Service Availability: RAWSTHORN LTD utilizes functional information and automatically processed information to ensure the provision of all requested services to you.
2. Enhancing, Testing, and Monitoring the Motie App Effectiveness: RAWSTHORN LTD analyzes automatically processed information to gain insights into your behavior and trends, identify potential outages and technical issues, and effectively operate, safeguard, enhance, and optimize the Motie App.
3. Communication Purposes: RAWSTHORN LTD uses the contact information you provide to communicate with you through newsletters. This includes sending marketing notifications, receiving feedback regarding your user experience, and informing you about RAWSTHORN LTD policies and terms. Additionally, RAWSTHORN LTD uses your information to respond to any inquiries or messages you send to RAWSTHORN LTD.
4. Delivering Interest-based Advertising and Targeted Content: By utilizing automatically processed information, RAWSTHORN LTD may offer marketing content tailored to your preferences, such as displaying ads that align with your interests. This enables RAWSTHORN LTD to provide personalized content and information, including online advertisements and other marketing initiatives.
5. Fraud Prevention and Law Enforcement: Ensuring a spam-free and secure environment is important to RAWSTHORN LTD. RAWSTHORN LTD employs your information to prevent, detect, and investigate instances of fraud, security breaches, potentially prohibited or illegal activities.

Please note that If any new purposes arise for processing your personal data, RAWSTHORN LTD will inform you accordingly and make appropriate changes to this PRIVACY POLICY.

SHARING OF THE DATA

RAWSTHORN LTD carefully selects third-party providers who are committed to implementing the necessary technical and organizational measures to safeguard your personal data. However, RAWSTHORN LTD cannot guarantee the security of information transmitted to such third parties. RAWSTHORN LTD are not liable for any accidental loss or unauthorized access to your personal data resulting from the actions of third parties.

RAWSTHORN LTD may share information collected through tools like cookies, log files, device identifiers, and location data with third-party organizations that provide automatic data processing technologies for the Motie App, provided that RAWSTHORN LTD does not sell your personal data to third parties.

To support the delivery and enhancement of our services, RAWSTHORN LTD may engage the following third-party service providers to provide RAWSTHORN LTD with the necessary infrastructure:

1. AdMob (Google LLC) (ad management), location: U.S.A., https://policies.google.com/privacy;
2. Amazon.com Inc. (cloud storage services), location: U.S.A., https://services.amazon.com/privacy-policy.html;
3. Amplitude Inc. (analytics), location: U.S.A., https://amplitude.com/privacy;
4. AppLovin Corporation (analytics, ad management), location: U.S.A., https://www.applovin.com/privacy/;
5. Bytedance Pte. Ltd. (Pangle) (ad management), location: Singapore, https://www.pangleglobal.com/privacy/enduser-en;
6. Digital Turbine USA, Inc. (DT Exchange) (ad management), location: U.S.A., https://www.digitalturbine.com/dt-clients-privacy-policy/;
7. Facebook (Meta Platforms, Inc.) (analytics, ad management), location: U.S.A., https://www.facebook.com/privacy/explanation;
8. Firebase (Google LLC) (user authentication, analytics and marketing services, location: U.S.A., https://policies.google.com/privacy https://firebase.google.com/support/privacy?hl=en;
9. IronSource Mobile Ltd (analytics, ad management), location: Israel, https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#step-1;
10. Liftoff group of companies (analytics, ad management), location: U.S.A., https://liftoff.io/privacy-policy/;
11. Mintegral entities (ad management), location: China, https://www.mintegral.com/en/privacy#privacy-policy-of-the-mintegral-services;
12. OpenWeather Ltd (content provider), location: United Kingdom, https://openweather.co.uk/privacy-policy;
13. Qonversion Inc. (analytics), location: U.S.A., https://qonversion.io/page/privacy;
14. UnityAds (ad management), location: U.S.A., https://unity3d.com/legal/privacy-policy;
15. VedicAstroAPI (content provider), location: India, https://vedicastroapi.com/privacy/;

You can obtain more information about the services and privacy options available, including opt-out choices, at the respective websites and privacy policies associated with those services.

There may be circumstances where RAWSTHORN LTD need to disclose your personal information for legitimate reasons, public interest, or unforeseen situations, such as: compliance with legal obligations; protection of RAWSTHORN LTD rights, your safety, or the safety of others; investigation of fraud or responding to government requests.

In the event of a merger, acquisition, or sale of all or a portion of RAWSTHORN LTD assets, RAWSTHORN LTD will notify you through a prominent notice within the Motie App regarding any change in ownership or the usage of your personal information.

RETENTION OF YOUR PERSONAL DATA

RAWSTHORN LTD typically retains your personal data for the duration necessary to fulfill the functional purpose of the Motie App and to meet RAWSTHORN LTD legal obligations. If you wish to discontinue RAWSTHORN LTD use of your personally accessible and stored information, you can request the erasure of your personal data.

Nevertheless, certain data may be retained for a limited period (not exceeding the necessary storage duration) if it is required to comply with legal obligations such as taxation, accounting, or auditing, or to maintain data backup and security measures, prevent fraud, or address other malicious activities.

INTERNATIONAL DATA TRANSFERS

RAWSTHORN LTD operates globally and provides the Motie App to users worldwide.

Please be aware that RAWSTHORN LTD may transfer information, including personal information, to a country or jurisdiction that does not have the same level of data protection laws as your jurisdiction. In this case, your personal information may be transferred to a third country, a specific territory within that country, or an international organization where data protection and confidentiality regulations may not offer the same level of protection as in your country.

RAWSTHORN LTD strives to ensure that any recipient of personal data provides adequate protection for the received information, in accordance with applicable data protection laws. By using the Motie App, you consent to the transfer of your personal data to any third country, specific territory, or international organization. Whenever possible, RAWSTHORN LTD encrypts your personal data before transmitting it to the hosting organizations for storage.

YOUR RIGHTS

You have the following options available for the personal information collected:

1. Data Access and Portability: You have the right to request copies of your personal information.
2. Data Modification or Correction: If you are unable to update your data through your account, you have the right to request the correction, amendment, or updating of your data.
3. Data Retention and Deletion: Your personal data is typically retained as long as you use the Motie App or as required to provide the relevant services. However, specific retention periods may vary depending on the processing context. You have the right to request the deletion of some or all of the personal data related to you.
4. Right to Know about Data Sharing: You have the right to know about sharing of your personal data with third parties. Detailed information on this issue can be found in the section “SHARING OF THE DATA”.
5. Restriction of Processing: Under certain circumstances, you may have the right to limit how your personal information is used.
6. Lodging a complaint with a supervisory authority: If you believe that your rights have been breached you have the right to lodge a complaint with a supervisory authority. Exercising this right you may be needed to provide sufficient objective evidence on infringement of data protection regulation and any other additional information about case(s) of your rights infringement.

To exercise any of the rights mentioned above, please contact RAWSTHORN LTD through the provided contact form. Kindly note that these rights apply specifically to the information RAWSTHORN LTD has physical access to and store.

In cases where your personal information is processed automatically, you may have the right to object to such processing under certain circumstances. If your personal information is processed for direct marketing purposes, you can request that your data be ceased for these purposes. To exercise this right, please contact the third-party services listed above to learn how you can object to the processing of your data.

If you are located in the European Union, you may address our team via email at [email protected] if you have any privacy-related questions.

OPT-OUT

1. If you prefer that third-party service providers do not use personalized ads based on your interests, on your iOS device navigate to Settings > Privacy & Security (in earlier iOS versions – “Privacy”) > Tracking and tap to turn off or turn on permission to track for a specific app.

   If you do not want to be asked for permission or do not want to give access to your device’s Advertising Identifier to apps, navigate to Settings > Privacy & Security (in earlier iOS versions – “Privacy”) > Tracking and turn off the “Allow Apps to Request to Track”. You can find detailed information here: https://support.apple.com/en-us/HT212025.

   If you want to disable Apple’s ad targeting, navigate to Settings > Privacy & Security (in earlier iOS versions – “Privacy”) > Apple Advertising and turn off the “Personalized Ads”. You can find detailed information here: https://support.apple.com/en-us/HT202074.

   Please note that opting out of certain interest-based advertising does not guarantee that you will no longer receive contextual ads based on non-personal information, such as ads related to the content of other digital products you use.

2. If you do not want third-party service providers to utilize your precise location data or street-level location information, on your iOS device navigate to "Settings > Privacy & Security (in earlier iOS versions – “Privacy”) > Location Services" and select status “Never” in section “Share My Location” for a specific app. You can find detailed information here: https://support.apple.com/en-us/HT203033.

ATTENTION U.S. RESIDENTS

IF YOU ARE A U.S. RESIDENT PLEASE READ THIS SECTION THAT SUPPLEMENTS THIS PRIVACY POLICY AND MAY BE APPLICABLE TO YOUR USE IN CASE YOUR STATE HAS ENACTED COMPREHENSIVE DATA PRIVACY LAWS INCLUDING BUT NOT LIMITED THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CCPA), TEXAS DATA PRIVACY AND SECURITY ACT (TDPSA), VIRGINIA CONSUMER DATA PROTECTION ACT OF 2021 (VCDPA), COLORADO PRIVACY ACT OF 2024 (CPA), CONNECTICUT DATA PRIVACY ACT OF 2022 (CTDPA) ANT OTHERS (collectively, the “Applicable U.S. Laws”).

This section may apply to you if: (a) you are a resident of the relevant U.S. state and a user of the Motie App; AND (b) processing of your personal information falls within the scope of the relevant Applicable U.S. Law.

Please be aware that under this section, personal information excludes de-identified, aggregated or publicly available consumer information.

If you want to learn more about the categories of personal information that RAWSTHORN LTD processes, please click here

If you want to learn more about the purposes for which RAWSTHORN LTD processes your personal information, please click here

If you want to learn more about the list and categories of third parties with whom RAWSTHORN LTD may share your personal information, please click here

Note that your rights may vary depending on which U.S. state you reside in. To make it clear, in addition to the rights specified in the section YOUR RIGHTS you may also have additional rights established by the relevant Applicable U.S. Law. In particular, you may have the right: (a) to opt out of the targeted advertising (also referred as “cross-contextual behavioral advertising” or “interest-based advertising”); (b) to opt out of profiling; (c) to appeal on RAWSTHORN LTD actions.

To exercise your rights that cannot be fulfilled without RAWSTHORN LTD assistance you need to submit a verifiable consumer privacy request via contact form. In the body of your request, please include the phrase "Your rights to maintain confidentiality in the state of [Your State]". After receiving your verifiable consumer request RAWSTHORN LTD uses all necessary measures to authenticate that you are a user of the Motie App and a resident of the relevant U.S. state that has enacted comprehensive data privacy law.

When submitting a verifiable consumer request, please be prepared to:

• Provide adequate information that enables us to reasonably verify your identity or the authority of your representative. This may include your name, address, city, state, zip code, and email address.
• Describe your request in sufficient detail to understand, evaluate, and respond appropriately.

Please note that if RAWSTHORN LTD is unable to verify your identity or confirm that the personal information pertains to you, RAWSTHORN LTD will be unable to fulfill your request or provide you with personal information. As a precautionary measure against fraudulent or false requests, RAWSTHORN LTD may also conduct checks, including using third-party identity verification services.

Any personal information provided in a verifiable consumer request will be used solely for the purpose of verifying the requester's identity or authority and not for any other purpose.

RAWSTHORN LTD strives to respond to verifiable consumer requests within forty-five (45) days of receipt. If more time is required, RAWSTHORN LTD will notify you in writing of the reason and the extended timeframe. Please note that RAWSTHORN LTD is only obligated to respond to two requests per customer per year. In certain circumstances, if you choose to delete your personal information from RAWSTHORN LTD records, RAWSTHORN LTD may be unable to provide certain services.
You can manage some of your rights without RAWSTHORN LTD assistance through the usage of technical capabilities and settings of your mobile device. In particular, you can exercise your right to opt-out of the targeted advertising via your mobile device setting. If you want to learn more about this capability, please click here.

RAWSTHORN LTD shall not discriminate against you in your right to request. That means that RAWSTHORN LTD shall not deny you services, set up different price rates and/or scope of products, or different quantity or quality of services for you, if you choose to exercise any of your rights. However, note that RAWSTHORN LTD shall not be prohibited from charging you a different price rate or offering you a different quantity or quality of services, including but not limited to offering services for no charge or at a discount, if that difference is reasonably related to the value provided to RAWSTHORN LTD by your personal information.

RAWSTHORN LTD does not sell any of your personal data to third parties.

If you reasonably believe that clauses of the section “ATTENTION U.S. RESIDENTS” are applicable to you or any additional rights that shall be provided to you in accordance with the relevant Applicable U.S. Law are not outlined or referred to in this section, please feel free to contact RAWSTHORN LTD via contact form.

MISCELLANEOUS

RAWSTHORN LTD maintains a regular practice of updating this PRIVACY POLICY. Any changes made to this PRIVACY POLICY will be posted here and in other suitable locations.

If you have any inquiries or concerns regarding this PRIVACY POLICY, please do not hesitate to reach out using the [support form]. RAWSTHORN LTD is here to assist you.