Last updated: April 09, 2025
1. Overview
This Privacy Policy describes how Pronotes Limited ("Pronotes", "we", "us", "our") collects, uses, keeps, discloses, and otherwise handles personal data when someone uses our Services ("you", "your").
In this Policy, Services means the digital products and online experiences we operate or control, including:
Apps: our software applications and related digital products.
Websites: the sites and online pages we run.
Related features: customer support, community features, marketing activities, and other services linked to our Apps or Websites.
If a specific Service includes its own privacy notice, that notice will apply to that Service instead of, or in addition to, this Policy.
Our Services may include links to third-party sites or services. Third parties manage their own practices and policies. We are not responsible for how third parties collect or use data.
Please read this Policy carefully before using the Services. By accessing or using the Services, you acknowledge this Policy and our Terms and Conditions. If you do not want us to process personal data as described here, do not use the Services.
2. What We Collect
The information we collect depends on how you interact with the Services and what the law requires in your location. We may collect the categories below.
2.1 Information you provide
You may choose to give us information when you create an account, contact support, fill in forms, respond to surveys, or otherwise communicate with us. This can include:
Contact details such as an email address.
User-provided content such as text, images, video, audio, gameplay-related content, and support messages.
Activity and purchase details such as interactions with features, browsing behavior within our Services, purchase history, and advertising-related preferences.
2.2 Information collected automatically
When you use the Apps or visit our Websites, we may automatically record technical and usage information, such as:
Identifiers: user or account identifiers, device identifiers, device characteristics, customer number (if applicable), mobile advertising ID, and similar IDs.
Location information: approximate or precise location (depending on device settings and permissions).
Diagnostics: crash logs, performance information, and error reports.
Tracking data: cookies and similar technologies (described in Section 9).
Other usage data related to how the Services function and how users engage with them.
2.3 Information from other sources
We may receive information about you from third parties where permitted by law. Examples include social platforms or analytics providers. This may include (where applicable):
Social sign-in providers.
Cookie-based or similar tracking sources.
Analytics services (for example, Firebase Analytics).
3. How We Collect Information
We use our own tools and may also rely on third parties to operate and measure the Services.
3.1 Cookies and comparable technologies
Cookies are small files stored on your device or browser. We and our partners may use cookies, pixels, SDKs, and similar technologies to:
Keep Services working properly.
Remember settings and preferences.
Understand usage and improve performance.
Reduce fraud and abuse.
Support advertising measurement and personalization (where permitted).
Cookie choices and controls are explained in Section 9.
3.2 Analytics tools
We use analytics to understand how people use our Services and to maintain reliability. This can include information such as IP address, device IDs, operating system details, network information, engagement metrics, and feature usage.
Some data is stored locally when you are offline and can be transmitted once you reconnect.
3.3 Advertising technologies
We may use advertising and measurement technologies (for example, cookies, pixels, web beacons, SDKs, and APIs) to display ads in our Services and to assess how ads perform.
These tools may connect usage across devices or platforms to tailor ad content. Information collected for ad delivery and measurement can include:
Which ads were shown and where.
How long an ad was visible.
Basic device, domain, and IP-related information.
Interactions with an ad (if any).
Opting out of personalized ads generally does not remove advertising. It changes the type of ads you may see.
3.4 Safety, anti-fraud, and moderation
To protect the Services and the community, we may use technical measures to detect cheating, abuse, policy violations, or fraud. Depending on the feature, this may involve reviewing reports, monitoring activity patterns, and moderating user-generated content.
4. How We Use Personal Data
We use personal data to run the Services, improve them, meet legal duties, and protect users and our business.
4.1 Providing the Services
We may use data to:
Set up and manage accounts.
Enable core functionality.
Process payments and deliver purchases.
Send service communications (for example, updates, security messages, purchase confirmations, and support replies).
Maintain and improve Apps, Websites, and related features.
4.2 Personalization and user experience
We may use data to:
Maintain user profiles and preferences.
Improve gameplay and feature experiences.
Provide community and social functionality.
Offer customer support.
Show offers or content that may be relevant to you.
4.3 Advertising and marketing
Where allowed, we may use data to:
Deliver ads and marketing communications.
Personalize promotional content.
Measure and improve marketing effectiveness.
Your options are described in Section 10.
4.4 Security and integrity
We may process information to:
Detect and reduce fraud, cheating, and other misuse.
Enforce our Terms and policies.
Protect the Services, our users, and our rights.
Keep records required for legal, tax, or compliance reasons.
4.5 Other compatible purposes
We may analyze data for product research, reporting, and planning. Where appropriate, we may de-identify or aggregate information so it can no longer reasonably identify a person, and use that information for legitimate business purposes.
If we need to use personal data for a materially different purpose, we will provide notice when required.
5. Legal Bases (Where Required)
When privacy laws require a legal basis, we rely on one or more of the following:
Consent: when we must obtain permission (and you can withdraw consent where applicable).
Contract: when processing is needed to deliver the Services or fulfill a request.
Legal obligation: when required by law.
Legitimate interests: such as improving the Services, providing support, marketing, and preventing fraud, balanced with appropriate protections.
If local law does not recognize legitimate interests for a specific purpose, we will rely on another lawful basis as required.
6. Sharing and Disclosure
We may disclose personal data to third parties in the following situations.
Other users: if you use social or community features, certain profile or activity details may be visible to other users.
Service providers: vendors that help us operate the Services (for example, hosting, analytics, advertising, payment processing, support, and fraud prevention). They may process data on our instructions.
Marketing partners: when we run joint campaigns or promotions (where permitted).
Platforms, SDKs, and ad/analytics partners: some features depend on third-party tools, and these partners may collect information through their integrations. They operate under their own policies.
A non-exhaustive list of partners and their privacy policies is provided below (this list may change over time):
Partner Privacy policy
Apple Search Ads https://www.apple.com/legal/privacy/
Facebook Ads Manager https://www.facebook.com/privacy/explanation
Google Analytics https://policies.google.com/privacy
Tapjoy https://www.tapjoy.com/legal/players/privacy-policy/
Twitter Ads https://twitter.com/en/privacy
BIGO https://www.bigo.tv/privacyPolicy.html
Maticoo https://www.zmaticoo.com/privacy
Adsyield https://web.adsyield.com/privacy-policy/
PremiumAds https://premiumads.net/privacy
Appbroda https://www.appbroda.com/privacy-policy
Google AdMob https://policies.google.com/privacy
BidMachine https://bidmachine.io/privacy-policy/
Kidoz https://kidoz.net/website-and-kidoz-sdk-privacy-policy/
PubMatic https://pubmatic.com/legal/privacy-policy/
Gameloft https://www.gameloft.com/en/privacy-notice
AppLovin https://www.applovin.com/privacy/
InMobi https://advertising.inmobi.com/privacy-policy
Unity / ironSource / Unity Ads https://unity.com/legal/privacy-policy
Meta https://www.facebook.com/privacy/policy/
We may also disclose information to government authorities or other third parties when we believe disclosure is required by law or is necessary to protect rights, safety, and security.
7. International Transfers
Pronotes operates across regions. Your data may be processed in countries different from where you live.
When we transfer data internationally, we use safeguards required by applicable law, such as standard contractual clauses or other approved mechanisms.
8. Retention and Security
8.1 How long we keep data
We keep personal data only as long as needed for the purposes described in this Policy, unless a longer period is required or allowed by law. Retention can vary based on:
Whether the information is needed to provide the Services.
Legal, accounting, or audit requirements.
Dispute resolution or enforcement needs.
When data is no longer needed, we take steps to delete it, anonymize it, or otherwise make it unavailable for active use.
8.2 How we protect data
We use administrative, technical, and physical safeguards intended to protect personal data, including encryption in transit (for example, HTTPS/TLS) and access controls.
No method of transmission or storage is perfectly secure. While we work to protect data, we cannot guarantee absolute security.
8.3 Where data is stored
We may store and process information on cloud infrastructure. If you have questions about storage locations, contact us using the details in Section 13.
9. Cookies and Tracking Choices
9.1 What these tools do
Cookies and similar technologies can:
Enable basic site and app functionality.
Remember settings.
Support analytics.
Help reduce fraud.
Support advertising and measurement (where permitted).
9.2 Managing cookies
You can control cookies and similar technologies through:
Browser controls and privacy settings.
Our cookie banner or consent tools on supported Websites.
Disabling some cookies may affect Service functionality. Some cookies are essential and cannot be turned off through standard preferences.
9.3 Mobile advertising controls
You can limit ad tracking on mobile devices using device settings:
iOS: Settings → Privacy & Security → Tracking (and related advertising settings).
Android: Settings → Google → Ads (and related advertising ID controls).
9.4 Retention periods
Some cookies expire when you close your browser (session cookies). Others remain until they expire or you delete them (persistent cookies). Your browser settings may show details.
10. Your Rights and Options
Depending on where you live, you may have rights such as:
Accessing your data.
Requesting correction.
Requesting deletion.
Withdrawing consent (where applicable).
Objecting to, or opting out of, certain processing (including targeted advertising in some jurisdictions).
Requesting data portability.
Requesting restriction of processing.
Non-discrimination for exercising rights.
Verification
To protect you and others, we may ask for information to confirm identity before processing certain requests.
How to exercise rights
Contact us using the details in Section 13. We may have statutory timelines for responding based on applicable law.
11. Children
Our Services are not generally intended for children under 13 (or the minimum age required by local law). We do not knowingly collect personal data from children without appropriate consent. If we learn that we have collected data from a child in a way that is not allowed, we will take steps to delete it and restrict access as needed.
Parents or guardians who want to request review, modification, or deletion of a child’s information can contact us using Section 13.
12. Regional Disclosures
Some jurisdictions require additional disclosures and offer specific rights. Where required, we provide supplemental information and processes consistent with local law, including certain US state privacy laws and GDPR/UK GDPR.
13. Contact Us
If you have questions about this Policy, or want to exercise privacy rights:
Data Controller
Pronotes Limited
Customer Support: pronotes.fin@gmail.com
Data Protection: pronotes.fin@gmail.com
Mailing address
UNIT 506, 5/F., NEW WORLD TOWER 1, 18 QUEEN'S RD CENTRAL, CENTRAL HONG KONG
Phone
+84 773096123
