PRIVACY
POLICY
Last Updated: April 9, 2025
IRONTECH
LIMITED (ʺweʺ, ʺusʺ or ʺourʺ) values your privacy. This Privacy
Policy (ʺPrivacy Policyʺ) explains
how we collect, use, share, and otherwise process your personal information
when you use the "Photo Collage - Collageable"
mobile application (the ʺAppʺ).
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 (ʺUsersʺ).
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:
|
|
Category |
General Examples |
|
A. |
Identifiers |
A
real name, postal code, unique personal identifier, online identifier,
Internet Protocol address, email address, or other similar identifiers. |
|
B. |
Geolocation
Data |
Physical
location or movements. |
|
C. |
Internet
or other similar network activity |
Information
about your interaction with an application, or advertisement. |
|
D. |
Commercial
Information |
Records
of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies. |
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:
1.1.
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.
1.2.
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:
(i)
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.
(ii) 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.
(iii)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.
(iv) 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.
3.1.
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.
3.2.
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 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 Delete. You have the right to
request deletion of personal information, subject to CCPA exceptions.
● 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):
|
Recipient |
Type |
Location |
Recipient’s Privacy Policy |
|
Amplitude Inc. |
Analytics Service Provider |
USA |
|
|
Apple Inc. |
Cloud storage Service
Provider |
USA |
|
|
Appodeal Inc. |
Analytics and Ad Management
Service Provider |
USA |
|
|
AppsFlyer LTD |
Analytics Service Provider |
Israel |
|
|
Google LLC |
Analytics Service Provider |
USA |
|
|
Meta Platforms, Inc. (Facebook Inc.) |
Analytics Service Provider |
USA |
|
|
Microsoft Corp. |
Analytics Service Provider |
USA |
|
|
OneSignal Inc. |
Mobile push notification solutions
Provider |
USA |
|
|
Qonversion Inc. |
Analytics Service Provider |
USA |
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.
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.
Copyright
© 2025 IRONTECH LIMITED