Privacy Policy

We develop and publish iOS applications and we may collect, store and process some data, including personal data. This privacy policy ("Privacy Policy") sets out the main principles on which the data collected from you, or that you provide to us, will be processed by us. This Privacy Policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them.

If you have any questions related to this Privacy Policy or our practices around privacy and data protection in general, please don't hesitate to contact us.

BY USING THE PLATFORMS, YOU PROMISE US THAT YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY.

If you do not agree, or are unable to make this promise, you must not use the Platforms. In such case, you must:

• delete the App from your devices
• cancel any subscriptions using the functionality provided by Apple

I. WHAT DATA DO WE COLLECT AND PROCESS?

You will find below explanations regarding the reasons why we may collect data and the legal bases we rely on in each case.

When you visit our Platforms, you may provide us with the following types of data, and we may collect and process such data in accordance with this Privacy Policy, as follows:

Photos

• We may temporarily access the photos that you upload from your mobile device only while using our application via your camera or camera roll if you have granted us permission to access your camera or camera roll.
• You won't be able to upload content from your camera roll unless we can access your device's camera.
• We do not collect your photo albums even if you grant us your access to them.
• Please note that although we do not require or/and request any metadata attached to the photographs you upload, metadata (including, for example, geotags) may be associated with your photographs by default.
• We do not store and collect your photos in the cloud.
• We do not use the photos you provide when you use the App for any reason other than to provide you with the photo editing functionality of the App.

II. HOW DO WE USE YOUR DATA?

Whenever you choose an effect that involves face pixelation (censor filter) we use special face recognition technologies to:

• Detect a face in a photo
• And apply the effect to your photo

III. DATA RETENTION

1. By using our Platforms, you consent for us to store your personal data in line with legal, regulatory, financial and good-practice requirements.

2. The period for which we may retain your personal data will depend on the type of personal data collected, the purposes for which it was collected, applicable limitation periods for the exercise of legal rights and whether any legal or regulatory obligations require the retention of the personal data.

IV. COOKIES AND TRACKERS

1. We use cookies and other software development kits (“SDKs”) and third-party libraries. Our Platforms uses the following categories of cookies:

• Strictly necessary cookies
• Analytical/performance cookies
• Functionality cookies
• Tracking ID

2. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

3. You may block cookies by updating the relevant settings on your device or browser to allow you to refuse the setting of some or all types of cookies.

V. WHO DO WE SHARE YOUR DATA WITH?

We don't share your personal data except as consented by you or as described herein. We may need to share your personal data with selected third parties in the following circumstances:

• Third party service providers
• Third party service providers for marketing purposes
• To comply with legal or regulatory requests

VI. THIRD PARTY WEBSITES

Our Platforms may contain links to third party websites. If you follow a link to a third-party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any data to those websites.

VII. SECURITY

1. We take data security seriously. We implement and maintain appropriate technical and organizational measures including resilient security systems and protocols to protect the personal data we store.

2. We have put procedures in place to deal with any suspected data security breach and will notify you and applicable regulator of a suspected breach where the breach may cause a risk to you.

3. Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal data to you.

IX. ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you have the following legal rights:

• To access personal data we hold on you;
• To request us to make any changes to your personal data if it is inaccurate or incomplete;
• To request your personal data is erased where we do not have a compelling reason to continue to process such personal data in certain circumstances;
• To receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the personal data is based on:
• (i) your consent;
• (ii) our necessity for performance of a contract to which you are a party to;
• (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
• 5. To object to, or restrict, our processing of your personal data in certain circumstances;
• 6. If we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
• 7. To object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;
• 8. If we are processing your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us;

X. OUR POLICIES CONCERNING CHILDREN

Our Platforms are not intended for children (under the age of 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data or target interest based advertising to children and we do not knowingly allow children to register for or use the Platforms. Children should not use our Platforms or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records.