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
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.
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
No matter how your personal information is collected and stored, we will
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.
using effie.pro or Effie.
1. What information do we collect and why do we collect it?
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
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
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
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.
Links to other websites
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.
When you submit a form from the website or send us an email
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 leave a comment
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.
Basic subscription information
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
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.
Personal information collected indirectly
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
you can directly log in and use our products and/or services with a
2. How do we use the information?
Effie won’t share your personal information with any companies,
organizations and individuals other than Effie, except in the following
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
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
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
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
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.
3. How do we protect and save your information?
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
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
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  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.
4. How you can check and correct information?
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
email@example.com. Effie will handle
your problem in a timely and effective manner.
5. How do we protect minors’ personal information?
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
In order to provide you with better service and with the development of
time. Effie will issue updated versions on our website, and/or with the
product update. Effie hereby recommends that you check this Privacy
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.
8. Contact Us
Please feel free to leave us comments about our privacy polices. If you
have any questions, or concerns, please contact us at
firstname.lastname@example.org. We may update this
email addressfrom time to time as part of these policies.