Walli Mobile Application Privacy Policy

Effective Date: April 23, 2025

This Privacy Policy details how your personal information is collected, processed, used, and shared by Smart media internet marketing ltd. (referred to as “Walli”, “the Company”, “we”, “us”, or “our”) when you use the Walli mobile application (the “Application”). Smart media internet marketing ltd. is the legal entity acting as the data controller for the personal information collected and processed through Walli.

Our designated Data Protection Officer (DPO) is Yoav Tzori, who can be contacted regarding privacy matters at [email protected]

1. What Information Does the Application Obtain and How Is It Used?

The Application obtains information you provide and collects certain information automatically.

a) User Provided Information

The Application obtains the information you provide when you download, register, and use the Application. This may include:

  • When you register with us and use the Application: your full name, email address, username, password, website, links to your social networks (Instagram, Facebook, Twitter, etc.), and your biography.
  • Transaction-related information: such as when you respond to any offers, or download or use applications from us (Note: If you make purchases, payment information is typically processed by the app store provider, e.g., Google Play or Apple App Store, subject to their privacy policies).
  • Information you provide when you contact us for help.
  • Information you enter into our system when using the Application: such as likes, downloads, artists you follow, and content you interact with.

We may use the information you provided us to contact you from time to time to provide you with important information, required notices, and, where permitted, marketing promotions.

b) Automatically Collected Information

In addition, the Application may collect the following information automatically:

  • Device Information: The type of mobile device you use, your mobile device’s unique device ID (or other identifiers), IP address, mobile operating system, device model, and manufacturer.
  • Advertising Identifier: Your mobile device’s Advertising ID (e.g., IDFA for iOS, GAID for Android).
  • Network Information: The type of mobile Internet browsers you use, the name of your mobile operator or ISP, network connection type (Wi-Fi, cellular), and network status.
  • Usage Information: Information about the way you use the Application, such as features used, content viewed, wallpapers applied, time spent in the app, interactions with advertisements, language, and time zone settings.
  • Location Information (if enabled): When you use the Application, we may use GPS technology (or other similar technology) to determine your current location (e.g., city level) to personalize content, display relevant advertisements, and improve our services. You can control location access via your device settings or within the Application settings (see Section 8 below).
  • Crash Logs and Diagnostics: Information related to crashes and performance issues, including device state information, unique device identifiers, and location information, to help diagnose and fix problems. This data is often processed via third-party services like Firebase Crashlytics.
  • Other Information from Permissions: Depending on the permissions you grant, the app may access features like storage (to save wallpapers), network state, ability to set wallpapers, receive notifications, etc., solely to enable Application functionality. We collect information related to the use of these permissions to operate and improve the Application.

We use this automatically collected information to understand user behavior, personalize the content (including ads) and features you see, improve the Application’s performance and stability, provide relevant services, and for security purposes.

c) Access to Third-Party Service Accounts

The Application may allow you to connect your account with third-party services like Facebook or Google for login or feature integration. These services require explicit authorization from you.

  • Access to Facebook account (Meta Platforms, Inc.): Allows connection with your Facebook account. Permissions asked: Email and Public Profile. Place of processing: US (and potentially other locations as per Meta’s policy).
  • Access to Google account (Google LLC): Allows connection with your Google account. Permissions asked: Email and Profile ID. Place of processing: US (and potentially other locations as per Google’s policy).

Users are responsible for any Personal Data of third parties obtained, published, or shared through this Application and confirm that they have the third party’s consent to provide the Data to us.

2. How We Use Your Information

We use information about you for the following purposes:

  • To provide, maintain, personalize, and improve the Application and its features.
  • To fulfill your requests and send you related information.
  • To send you technical notices, updates, security alerts, and support/administrative messages.
  • To communicate with you about news, updates, promotions, and other information about the Application (where permitted).
  • To monitor and analyze trends, usage, and activities in connection with the Application.
  • To personalize the Application content and features, including serving personalized advertisements based on your interests (see Section 8 for opt-out options).
  • To detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Shanga and others.
  • To diagnose and fix technical issues, such as crashes.

3. Legal Basis for Processing (GDPR)

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

  • Performance of a Contract (Article 6(1)(b) GDPR): We process personal data necessary to provide the Application service, fulfill your requests, maintain the app experience, and send essential communications (technical notices, support messages).
  • Legitimate Interests (Article 6(1)(f) GDPR): We process certain data based on our legitimate interests, provided these are not overridden by your data protection interests or fundamental rights and freedoms. This includes:
    • Monitoring and analyzing usage to improve the Application.
    • Providing non-personalized or contextual advertising.
    • Personalizing content (excluding sensitive data processing requiring consent).
    • Detecting and preventing fraud and ensuring security.
  • Consent (Article 6(1)(a) GDPR): We rely on your consent for certain processing activities, such as:
    • Sharing your Advertising ID with ad network partners for personalized advertising.
    • Collecting precise location data for location-based features or ads.
    • Sending marketing communications (where opt-in consent is required).

    You have the right to withdraw your consent at any time (see Section 9).

  • Legal Obligation (Article 6(1)(c) GDPR): We may process data if required to comply with a legal obligation.

4. How Is Your Information Shared?

We may disclose information about you to the following categories of third parties:

The use of information shared with third parties is governed by their respective privacy policies. We encourage you to review the privacy policies of these third parties.

Under certain laws like the CCPA, sharing data for personalized advertising may be considered a “sale” or “sharing”. Please see Section 7 and Section 8 for information on your rights and opt-out choices related to this.

5. International Data Transfers

Your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

Specifically, our servers may be located in various regions, and our third-party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. For transfers of personal information from the European Economic Area (EEA), UK, and Switzerland, we rely on mechanisms like the European Commission’s Standard Contractual Clauses (SCCs), adequacy decisions, or other legally valid transfer mechanisms.

6. Data Retention

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter as necessary to fulfill the purposes outlined in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements.

We will retain Automatically Collected information for up to 24 months in an identifiable form, and thereafter may store it in aggregate or anonymized form for analytical purposes.

If you delete your account, we will delete personally identifiable information associated with your account within a reasonable timeframe, subject to legal retention requirements or legitimate interests (e.g., fraud prevention).

If you’d like us to delete specific User Provided Data, please contact us at [email protected] , and we will respond within a reasonable time, subject to verifying your identity and legal constraints. Note that some data may be essential for the Application to function properly.

7. Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information. These may include:

  • Right to Access: The right to request access to the personal information we hold about you.
  • Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
  • Right to Erasure (Deletion): The right to request deletion of your personal information under certain conditions.
  • Right to Restrict Processing: The right to request the restriction of processing of your personal information under certain conditions.
  • Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another controller (where technically feasible).
  • Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes.
  • Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time (see Section 9).
  • Right to Know (Specific to certain jurisdictions like California): The right to know what personal information is collected, used, shared, or sold.
  • Right to Opt-Out of Sale / Sharing / Targeted Advertising (Specific to certain jurisdictions like California & Virginia): The right to opt-out of the “sale” or “sharing” of your personal information, including for targeted advertising or certain types of profiling (see Section 8).
  • Right to Non-Discrimination: The right not to be discriminated against for exercising your privacy rights.
  • Right to Lodge a Complaint (GDPR/UK GDPR): You have the right to lodge a complaint with a data protection supervisory authority in your country of residence if you believe our processing of your personal information infringes applicable data protection laws. We encourage you to contact us first to resolve any issues.

To exercise any of these rights (subject to verification and legal limitations), please contact us at [email protected]. We will respond to your request within the timeframe required by applicable law (typically within one month for GDPR, 45 days for CCPA/VCDPA, potentially extendable).

8. Opt-Out Rights & Choices

You have several options to control or limit the collection and use of your information:

  • Uninstall the Application: You can stop all information collection by the Application easily by uninstalling it using the standard uninstall process for your device.
  • Location Services: You can disable the collection of precise location data by turning off location services for the Walli application in your mobile device settings.
  • Opt-Out of Personalized Advertising / Sale / Sharing:
    • Device Settings: You can limit ad tracking and opt-out of interest-based advertising through your mobile device’s settings.
      • For Android: Go to Settings > Google > Ads > Opt out of Ads Personalization (or Delete Advertising ID). Path may vary by device/OS version.
      • For iOS: Go to Settings > Privacy & Security > Tracking > Turn off “Allow Apps to Request to Track”. Also, go to Settings > Privacy & Security > Apple Advertising > Turn off “Personalized Ads”. Path may vary by OS version.

      Opting out through device settings limits the use of your Advertising ID for personalized advertising across apps on that device.

    • “Do Not Sell or Share My Personal Information” (California & Virginia Residents): As required by the CCPA and VCDPA, you have the right to opt-out of the “sale” or “sharing” of your personal information (as defined under those laws, which can include sharing for targeted advertising). To exercise this right, please contact us at [email protected] with the subject line “Do Not Sell/Share My Info” or manage your preferences within the Application’s settings if such an option becomes available.
    • Third-Party Opt-Out Tools: Some advertising industry groups offer tools to opt-out of interest-based advertising from participating companies, such as the NAI (http://optout.networkadvertising.org/) and DAA (http://optout.aboutads.info/).
  • Marketing Communications: If you receive marketing emails from us, you can opt-out by following the unsubscribe link in the email. You can manage push notification preferences within your device settings or the Application settings.

9. Right to Withdraw Consent

Where we rely on your consent to process your personal information (e.g., for personalized advertising, precise location data), you have the right to withdraw your consent at any time. You can do this by:

  • Adjusting your device settings (for location and ad tracking).
  • Contacting us at [email protected].
  • Using specific controls within the Application settings, if available.

Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

10. Children’s Privacy

We do not use the Application to knowingly solicit data from or market to children under the age of 13 (or a higher age threshold where applicable by law, e.g., 16 for CCPA “sale” opt-in). If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact us at [email protected]. We will delete such information from our files within a reasonable time.

11. Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect the information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information to operate, develop, or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

12. Specific State Disclosures

a) California Residents (CCPA/CPRA)

This section supplements the information above and applies solely to California residents.

  • Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collecting, selling, or sharing, and the categories of third parties to whom we disclose information.
  • Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
  • Right to Correct: You have the right to request the correction of inaccurate personal information.
  • Right to Opt-Out of Sale/Sharing: You have the right to opt-out of the “sale” or “sharing” of your personal information. As noted in Section 8, you can exercise this right via device settings or by contacting us at [email protected] with the subject line “Do Not Sell/Share My Info”. We do not knowingly sell or share the personal information of minors under 16 without appropriate consent.
  • Right to Limit Use of Sensitive Personal Information: If we collect sensitive personal information (as defined by CCPA), you may have the right to limit its use. We primarily use precise location data (if enabled) for relevant ads/content, which you can control via device settings.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
  • Categories of Personal Information Collected/Disclosed: In the preceding 12 months, we may have collected and disclosed for a business purpose (and potentially “sold” or “shared” for advertising purposes) the categories of personal information listed in Section 1 (Identifiers like name, email, device ID, IP address, Advertising ID; Internet or other electronic network activity information like usage data; Geolocation data; Commercial information like transaction history if applicable; Profile data like preferences).
  • Categories of Sources: Directly from you, automatically from your device, from third-party services you connect.
  • Business/Commercial Purposes: As described in Section 2.
  • Categories of Third Parties: As described in Section 4 (Service Providers, Advertising Partners, Analytics Providers, etc.).

To exercise your CCPA rights, please contact us as described in Section 7.

b) Virginia Residents (VCDPA)

This section supplements the information above and applies solely to Virginia residents.

  • Rights: You have the right to (1) confirm whether we are processing your personal data and access it, (2) correct inaccuracies, (3) delete your personal data, (4) obtain a copy of your data (data portability), and (5) opt-out of processing for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
  • Exercising Rights: To exercise these rights, please contact us as described in Section 7.
  • Opt-Out: To opt-out of targeted advertising or the “sale” of data, please follow the instructions in Section 8.
  • Appeals: If we decline to take action on your request, we will inform you of the reason and provide instructions on how to appeal the decision within a reasonable period. You can appeal by contacting us at [email protected] with the subject line “VCDPA Appeal”.

13. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and may inform you via email or in-app notification if the changes are material. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

14. Contact Us / Data Controller Information

If you have any questions regarding privacy while using the Application, have questions about our practices, or wish to exercise any of your rights, please contact us:

Data Controller:
Smart media internet marketing ltd.
Attn: Legal – Privacy
Sderot Hahaskala 11,
Beer Sheva,
Israel

Email (including for DPO inquiries): [email protected]