Privacy Policy

This Privacy Policy explains how D2 INTERNESHNL INVESTMIENT YUKREIN TOV (“we”, “us”, “our”) collects, uses and protects information when you use our mobile applications for Android published on Google Play under the developer name “D2 interneshnl investmient yukrein apps” (the “Apps”) and this website, d2invest.online.

Data controller

Information we collect

The Apps do not require an account. We do not collect your name, email address, precise location, contacts or payment information in the Apps.

When you use the Apps, the following information is collected automatically by the Apps and the third-party services listed below:

• Advertising ID (Google Advertising ID, GAID);
• Device model and operating system version;
• IP address;
• App install data and in-app event data (for example, app opens, sessions and gameplay progress events);
• Crash and diagnostic data (for example, crash logs and stack traces).

Third-party services

The Apps use the following third-party SDKs, which may collect the information described above under their own privacy policies:

• AppsFlyer: install attribution and marketing analytics. AppsFlyer Privacy Policy
• Google Firebase Analytics: usage analytics. Firebase Privacy and Security, Google Privacy Policy
• Firebase Crashlytics: crash reporting. Firebase Privacy and Security
• Google AdMob: in-app advertising. How Google uses information from apps that use its services
• OneSignal: push notifications. OneSignal Privacy Policy

How we use information

• To provide and maintain the functionality of the Apps;
• To understand how the Apps are used and to improve them (analytics);
• To attribute app installs to marketing campaigns and measure their effectiveness;
• To detect, diagnose and fix crashes and technical problems;
• To show in-app advertising and send push notifications, which you can turn off in your device settings.

Legal basis (GDPR)

Where the EU/EEA or UK General Data Protection Regulation applies, we process data on the basis of our legitimate interests in operating, analysing, improving and promoting the Apps. Where applicable law requires consent (for example, for certain tracking or advertising purposes), we rely on your consent, which you can withdraw at any time.

Your rights and choices

Depending on your location, you may have the right to access, rectify or delete your personal data, and to object to or restrict its processing. You can also:

• Opt out of advertising tracking: reset or delete your advertising ID in your Android device settings (Settings → Google → Ads, or Settings → Privacy → Ads, depending on your device);
• Request access or deletion: email us at info@d2invest.online or use our contact form and choose “Privacy / Data Request”. Please include your device’s advertising ID if available so we can locate the data. We handle requests within 30 days.

Uninstalling the Apps stops all further data collection by the Apps.

Data retention

We keep data only as long as necessary for the purposes described in this policy. Analytics, attribution and crash data are retained according to the retention settings of the respective service providers, after which they are deleted or anonymised. Contact requests are kept only as long as needed to handle them.

International data transfers

Our third-party service providers may process data on servers located outside Ukraine and the EU/EEA, including in the United States. Where required, such transfers are protected by appropriate safeguards, such as the European Commission’s Standard Contractual Clauses.

Security

We use reasonable technical and organisational measures to protect information against unauthorised access, loss or misuse. However, no method of transmission or storage is completely secure.

Children’s privacy

The Apps are not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us and we will delete it.

California privacy rights (CCPA)

We do not sell personal information. California residents may request information about the categories of personal information we collect and may request its deletion by emailing info@d2invest.online. We will not discriminate against you for exercising these rights.

Website contact form

The contact form on this website does not send data to any server. It opens your own email app with a pre-filled message to info@d2invest.online. If you send that email, we process your name, email address and message solely to respond to your request. The website does not use analytics or advertising cookies.

Changes to this policy

We may update this Privacy Policy from time to time. Changes take effect when the updated policy is published on this page with a new effective date.

Governing law

This Privacy Policy is governed by the laws of Ukraine.

Contact

If you have any questions about this Privacy Policy, please contact us: