PRIVACY POLICY

Last Updated: January 14, 2025

IRONTECH LIMITED ("we", "us" or "our") values your privacy. This Privacy Policy ("Privacy Policy") explains how we collect, use, share, and otherwise process your personal information when you use the "Photo Collage - Collageable" mobile application (the "App").

When we refer to personal information (or personal data), we mean any information of any kind relating to you as an identified or identifiable natural person. This can include your name, identification number, or any information specific to your physical, economic, cultural, or social identity. 

Our Privacy Policy applies to all users of our App ("Users").

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE PROCESS YOUR PERSONAL INFORMATION AND YOUR CHOICES REGARDING IT. BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY.

In line with the EU General Data Protection Policy (EU-GDPR) and the UK General Data Protection Regulation (UK-GDPR), we are the data controller unless stated otherwise.

I. INFORMATION WE PROCESS AND HOW WE DO THE PROCESSING

Depending on the circumstances described below, we may collect and process the following categories of personal information:

PLEASE NOTE THAT:

• We do not collect audio or video information from you.
• We do not have access to or process your image or face data made or edited with the App.
• We cannot collect, store, or use data from your camera roll or photo library.
• Any visual data (such as images, photos, and portraits) edited with the App is stored locally on your device and/or in your iCloud storage and is inaccessible to us. Only you can share files by exporting them through the App.
• If you upload photos for editing using the App, the photos are sent to our server for processing and sent back directly to the App on your device. We do not store your photos or any visual data after that processing except for depersonalized demographic data as described in Subsection 1.2 below.

Additionally, we do not collect any special categories of personal data (e.g., details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic, and biometric data). We also do not collect information about criminal convictions and offenses.

Furthermore, we cannot access or use your credit card or debit card information. Our e-commerce provider (Apple) is responsible for billing, processing, and charging for in-app purchases. It handles your personal information securely. This information is processed as part of the performance of the contract between you and us. You can access the applicable in-app purchase rules and policies directly from the App Store.

We collect the following categories of personal information from the following sources:

1. Information You Provide to us Directly

Following the principle of data minimization, our App does not require you to set up an account. You do not need to provide any information to access the App (e.g., full name, username, social media usernames, phone numbers, email addresses).

However, if you contact us via email or support form (e.g., to inquire about the App or request support), we may collect and use the contact information you provide (name, email address, and message contents). This is necessary for us to respond effectively, fulfill your requests, and provide the requested services as part of the performance of the contract between you and us.

Furthermore, if you upload any photos for editing using the App, we will process visual data from the photos in order to adequately perform the contract between you and us. Additionally, if the photos you submit contain identifiable human face(s), we will further process demographic data inferred from those photos, including estimated gender, age, and skin tone, to offer you relevant tools and provide a more tailored user experience on the basis of our legitimate interest in improving and customizing our App.

2. Information Collected by Automated Means

When you use the App, some information about your mobile device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the grounds of our legitimate interest in improving our App and giving our Users the best experience. If we do not access such data, we may not be able to provide you with all the features of the App.

When you use the App, some information about your mobile device and user behavior is processed automatically. This information is generally non-personal, i.e., it does not, on its own, permit direct association with any specific individual, and is accessed in aggregated form only. We process this data based on our legitimate interest in improving the App and enhancing user experience. Without accessing this data, we may not be able to provide all App features.

We use third-party automatic data processing technologies (advertising or analytics tools) to analyze information sent by your device via our App. Some tools may process your personal data, including profiling, to analyze or predict your personal preferences, interests, behavior, location, or movements. Processing starts automatically when you launch the App.

The types of information collected by automated means include:

• Device Details. Type of mobile device, operating system and version, model and manufacturer, screen size, screen density, orientation, battery and device memory usage.
• Internet Connection Details. Mobile carrier, network provider, network type, Internet Protocol (“IP”) address, session timestamps and duration, speed, browser.
• Location-related Information. IP address, the country code/region/state/city associated with your SIM card or device, language setting, time zone, and neighboring commercial points of interest.
• Other Device Identifiers. E.g., user identifiers like Identify for Advertisers (IDFA) if set up by the App’s developer).
• App Information. App name, API key (identifier for the App), version, and properties for automated processing and analysis. 
• Cookies and Similar Technologies. Cookies, pixels, web beacons, and scripts may be used. Cookies are text files downloaded to your device when accessing the App and sent back to the server each time you use the App. This helps us operate the App more effectively, understand usage patterns, improve marketing efforts, and provide content and features of interest to you. Advertisers or partners may use cookies or similar technologies to serve ads or services in the App.
• Log File Information. Log file information is automatically reported each time you access the App, including the time and date you start and stop using the App, and your interactions with the App.
• Ad-Related Information. Date and time an ad is served, records if an ad was clicked or shown as a conversation event, ad offer details, ad type (text, image, video), ad placement, and user response to the ad.
• In-App Events. Analytics tools automatically record in-app information when you use the App (tutorial steps, payments, in-app purchases, custom events).

Information provided automatically to advertising or analytics tools is generally not under our control. We cannot be responsible for processing such information. Some services may profile personal data and obtain information related to your personality or device using technologies beyond our scope. We do not control, supervise, or guarantee how third parties process your personal data. Any information requests regarding your personal information should be directed to such third parties (see Section IV).

II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

1. To provide and improve the App. We use the information you provide directly and the information processed automatically to deliver, maintain, improve, test, and monitor the effectiveness of our App. This helps us understand user behavior and trends, detect potential outages and technical issues, support existing functions, and add new features and services.
2. To provide interest-based (behavioral) advertising. We may use information processed automatically for marketing purposes to show ads that may interest you based on your preferences. This includes personalized content and information, such as online ads or other marketing forms.
3. To communicate with you. We may use information that is processed automatically to send you push notifications with technical notices, updates, security alerts, and support messages. Similarly, we use your contact information to respond to you when you contact us.
4. To prevent fraud and enforce the law. We aim to keep our App free of spam and fraudulent content. We may use your information to prevent, detect, and investigate fraud, security breaches, and illegal activities, protect our trademarks, and enforce our Terms of Use. 

If new purposes for processing your personal data arise, we will notify you by updating this Privacy Policy.

III. YOUR PRIVACY RIGHTS

If you are a resident of the European Economic Area (EEA) or the UK, or California, specific rights to access, edit, and delete your information apply. These rights can be found in Subsections 3.1 (EEA and the UK) and 3.2 (California) of this Privacy Policy respectively.

For those not residing in the EEA, UK, or California, you may still request to access, correct, or delete certain personal information. Verification of identity and residency may be required before processing these requests. Contact us at privacy@irontech.mobi for such requests. Note that changes or deletions may impact the App’s features and functionality.

1. Information for Residents of the EEA and the UK

If you reside in the EEA or the UK, applicable privacy laws (in particular EU-GDPR and UK-GDPR respectively) grant you specific rights concerning your personal data:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. You have the right to request corrections or updates to your personal data.
• Data Retention and Deletion. You have the right to request deletion of all or some of the personal data.
• Restriction of Processing. Under certain circumstances, you may have the right to limit how your personal information is used.
• Lodge a complaint. You can File a complaint with a supervisory authority if your privacy rights are violated.

To exercise these rights, contact us through the [contact form]. Please note that these rights apply to information we physically access and store. You may also object to automated data processing for direct marketing by contacting the recipients listed in Section IV.

For privacy inquiries in the EEA, contact us at privacy@irontech.mobi.

For privacy inquiries in the UK, contact our regional representative at ukrep@irontech.mobi.

2. Information for Residents of California

The California Consumer Privacy Act of 2018 (CCPA) provides California residents with specific rights regarding their personal information:

• Right to Delete. You have the right to request deletion of personal information, subject to CCPA exceptions.
• Right to Know. You have the right to request information about the personal data we collect, sources, purposes, third-party sharing, and specific data collected in the past 12 months.
• Right to Opt-Out (“Do Not Sell”). You have the right to request that we stop sharing your personal information with a third party in exchange for something of value. As noted herein, we do not sell your personal information.
• Right to Non-Discrimination. You are entitled to exercise the rights described in this Section free from discrimination. We will not discriminate against you because you exercise your CCPA rights.
• Right to Correct. You have the right to request correction of personal information.
• Right to Limit. You have the right to request that we only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

How to Exercise Your California Privacy Rights. To exercise these rights, contact us via the [contact form] or email privacy@irontech.mobi. Verification of identity and residency is required for these requests. Authorized agents may also submit requests on behalf of consumers. Please include the wording “Consumer rights to maintain confidentiality in the state of California” in the text of your request.

We will respond to verified consumer requests within 45 days, with possible extensions as needed. 

IV. HOW WE SHARE YOUR INFORMATION

We share your information with third parties only as described in this Privacy Policy. 

We do not rent or sell your personal data to any third parties.

We may share your information (such as log files, device identifiers, and location data) with third-party organizations that provide automatic data processing technologies for the App. We do not control these third parties’ tracking technologies or how they may be used.

We may share certain information, such as cookie data, with third-party advertising partners. This allows ad networks to deliver targeted advertisements that they believe will be of most interest to you.

While we choose third-party service providers who apply necessary technical and organizational measures to protect personal data, we cannot guarantee the security of any information transmitted to such entities. We are not responsible for any accidental loss or unauthorized access to your personal data through the fault of these entities. These entities are separately responsible for their privacy policies and practices.

Categories of Recipients. The following third-party providers and advertising partners may be engaged by us to process your information for various business purposes (inter alia, to provide us with the necessary infrastructure for the delivery and improvement of our App, and to perform App-related services):

All third-party service providers and advertising partners engaged in processing user data use such information based on an agreement and according to the stated business purposes. For more information about these services and their privacy options, including opt-out options, consult their websites and privacy policies. We are not responsible for any misuse of your personal data by these third parties in violation of our instructions.

The App may include links to third-party websites, services, plug-ins, and applications, e.g., allowing users to share content on social media platforms or access the App from third-party sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites/services, plug-ins, and applications, and are not responsible for their privacy practices or content. We encourage you to read the privacy notice of every website, service, plug-in, or application you use.

Disclosure for legal and other reasons. In addition, we may disclose your personal information:

• As required by law;
• When we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets. You will be notified via email and/or a prominent notice in our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

V. INTERNATIONAL DATA TRANSFERS

We operate globally and provide our App to users worldwide. We, along with our data processing partners and third-party advertising partners, may transfer your data across borders, from your country to other countries or jurisdictions around the world.

Please note that these transfers may include personal data to countries that may not offer the same level of data protection as your home country. We strive to ensure that any recipient of personal data provides adequate protection, complying with current data protection legislation. By using the App, you consent to the transfer of your personal data to any third country or international organization.

For data storage, we use hosting services and encrypt your personal data, if possible, before transferring it for storage. We collaborate only with hosting organizations that have passed our security and reliability checks.

VI. DATA RETENTION

We retain your personal information as long as necessary to provide the App’s services and comply with legal obligations. If you no longer want us to use or store your data, you can request its deletion.

However, some data may still be retained for a specific period to comply with legal obligations (such as taxation, accounting, or audit) or to ensure safety, data backup, prevent fraud, or other malicious acts.

VII. SECURITY

We prioritize the security of your personal information and follow industry standards to protect it during transmission and once received.

We take reasonable and appropriate measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include implementing technical and organizational safeguards and using strong encryption algorithms, including hashing where possible.

We implement appropriate technical and organizational measures, which are designed to implement data protection principles, such as data minimization, effectively and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

While we strive to protect your data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we will promptly notify you of any data breach as required by law.

If you have any questions about our App's security, please contact us via the email provided below.

VIII. CHILDREN’S PRIVACY

Our App and its services are not intended for children. We do not knowingly collect personal information from children. No one under the age of 18 (or older if required by applicable law) may use the App.

If we discover that we have collected personal information from a child, we will delete it promptly. If you believe we might have information from or about a child, please contact us immediately.

IX. HOW TO OPT-OUT

Opt-out of Marketing Tracking

• For iOS: Go to Settings > Privacy > Advertising and enable "Limit Ad Tracking" (https://support.apple.com/en-us/HT202074).
• For general options: Visit https://youradchoices.com. Please note that we have no control over this website and any options it provides.

Please mind that when you opt out of certain interest-based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing

• For iOS: Go to Settings > Privacy > Location Services, select the App, and set "Share My Location" to "Never" (https://support.apple.com/en-us/HT203033).

To stop receiving push notifications, adjust your settings on your mobile device. Uninstalling the App will stop all information collection except for some information concerning you that may still be stored as described in Section VI above.

X. CHANGES TO THE PRIVACY POLICY

We recognize that information privacy is an ongoing responsibility. Therefore, we will update this Privacy Policy as needed. Changes will be posted on this Privacy Policy and other relevant places. Additional notifications may be provided as appropriate.

XI. HOW TO CONTACT US

For questions about this Privacy Policy, contact us via the [contact form] or email privacy@irontech.mobi.

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