PRIVACY POLICY
Last
Updated: April 03, 2023, with Effective Date April 03, 2023
IRONTECH
LIMITED (ʺweʺ,
ʺusʺ
or ʺourʺ)
respects your privacy and understands that you care about your personal
information and how it is used. This Privacy Policy (ʺPrivacy Policyʺ)
clarifies our privacy practices and describes how we collect, use, disclose and
otherwise process your personal information when you install and/or use (ʺuseʺ) "Youni: AI Art & Selfie
Editor" software application for mobile devices
(hereinafter, ʺthe ʺAppʺ or ʺour Appʺ), and explains the rights and choices
available to you concerning your personal information.
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. It is
a natural person who can be identified directly or indirectly, in particular by
reference to an identification number or one or more factors specific to your
physical, physiological, mental, economic, cultural, or social status.
And
namely personal information identifies, relates to, describes, references, is
capable of being associated with, or could reasonably be linked, directly or
indirectly, with you.
Our
Privacy Policy applies to all users, and others who access our App (ʺUsersʺ).
PLEASE
READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR
PERSONAL INFORMATION MAY BE PROCESSED, AND YOUR CHOICES REGARDING YOUR PERSONAL
DATA, CAREFULLY. WHEN YOU USE THE APP(S), YOU ACKNOWLEDGE THAT YOU HAVE READ,
UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.
Following
the EU General Data Protection Policy (EU-GDPR) and the UK General Data
Protection Regulation (UK-GDPR) we are the data controller unless otherwise
stated.
I. INFORMATION WE PROCESS AND
HOW WE DO THE PROCESSING
Depending
on the circumstances mentioned below, the following general categories of personal
information may be collected and otherwise processed:
|
|
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 on 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. |
|
E. |
Sensory data |
Visual, or similar information. |
PLEASE,
NOTE THAT:
No
audio or video information can be collected from you.
In a
nutshell, under no circumstances no of your image or face data, whether made,
edited, or not, with help of the App shall be available to us, stored, or
otherwise processed by us.
It
means that we cannot collect store or use the data contained in your camera
roll or photo library.
After
you set the relevant settings on your mobile device for technical access to
your camera (to take photos)/photo library (to save photos), all visual data
(like images, photos, and portraits) that might be edited (processed) with help
of the App is stored locally on your device and/or in your iCloud storage and
is inaccessible to us. Only you can share files with a certain party by
exporting them through the App.
However, if
you apply the “AI Avatar” feature available in our App for editing your photos,
such photos will be sent to the servers which we are used by us for processing
the photos.
The list of
the servers which we use for processing the photos is available in Section III
of this Privacy Policy (III.
INFORMATION SHARING AND DISCLOSURE).
Be aware
that Neural Network Model Stable Diffusion is used to
provide you the “AI Avatar” feature in our App.
Using “AI
Avatar” allows you to generate personalized pictures (avatars) from your
photos.
How
does it work?
1. The User uploads 10 to 20 photos using the App;
2. Using
the uploaded photos, the
Stable Diffusion model is retrained to personalize the model;
3.
After the model copy is retrained,
it generates the pictures
(avatars) from the model that is based (retrained) on the photos you uploaded;
4. As soon as the pictures (avatars) from your photos are
generated, the copy of the model, along with uploaded photos, are deleted
permanently from the
servers
we use. It means that any photos of yours and any visual data will be
permanently deleted from the servers which we use not later than 24 hours after
such photos are uploaded to these servers.
5. We do
not use your Personal Data to generally train and/or create our separate
artificial intelligence/products.
Moreover,
we do not collect any special categories of personal data about you
(this includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data). Nor
do we collect any information about criminal convictions and offenses.
Also, 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, handling your personal information, and keeping
it safe and secure. This information is processed as part of the performance of
the contract between you and us.
You
may access the applicable “in-app” purchase rules and policies directly from
the App Store.
We obtain
the categories of personal information listed above from the following
categories of sources:
1.1.
Directly from you
(Information that you submit):
Guided by the principle of
data minimization we designed our Apps in a way that doesn't require you to
sign up for an account to use the App. It means that you do not need to provide
us with any information that can be used to access the App (like full name,
username, the public username used on social media accounts, phone number(s),
e-mail address, or other similar information), however, when you decide to
contact us using the e-mail or support form (for example to inquire about the App
or to request support regarding the App usage) we may collect and use whatever contact information
(name, e-mail address, and any information that you provide, including the
contents of the messages or attachments) you send us via email or contact form
when it is necessary for the adequate performance
of the contract between you and us. We use such information to respond
effectively to your inquiry, fulfill your requests, and send you communications
that you request and perform the requested services.
We process visual data from
the photos that you submit to us via the App when you apply the “AI Avatar”
feature available in our App (such processing is necessary for the adequate performance of the contract
between you and us).
1.2.
Indirectly from you
(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 ground 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.
We use third-party automatic
data processing technologies to analyze certain information sent by your device
via our App (advertising or analytics tools). Some of them launch automated
processing of your personal data, including profiling, which means any form of
automated processing of personal data used to evaluate certain personal aspects
relating to you, in particular, to analyze or predict aspects concerning your
personal preferences, interests, behavior, location or movements (see the list
of data described below). Processing information through automatic data
processing technologies starts automatically when you launch the App.
The following are the types
of information we collect indirectly from you:
·
Device Details. When
you use a mobile device to access the App, some details about your device are
reported, including “device identifiers”. Device identifiers are small data
files or similar data structures stored on or associated with your mobile
device, which uniquely identify your mobile device (but not your personality).
Device identifier enables generalized reporting or personalized content and ads
by our partners, service providers, and/or other third parties.
The following data can be
processed:
-
Information about the device
itself: type of your mobile device, type of operating system and its version,
model and manufacturer, screen size, screen density, orientation, battery, and device
memory usage.
-
Information about the
internet connection: mobile carrier, network provider, network type, Internet
Protocol (“IP”) address, timestamp and duration of sessions, speed, browser.
-
Location-related
information: IP address, the country code/ region/ state/ city associated with
your SIM card or your device, language setting, time zone, neighboring
commercial points of interest (eg. “coffee shop”).
-
Other
device identifiers: e.g. user identifiers like Identify for Advertisers (IDFA), etc. (if they are set up by the
App’s developer).
· Information about the App. Its
name, API key (identifier for the App), version, and properties of our App can
be reported for automated processing and analysis.
· Cookies and similar technologies. When
you use the App, cookies and similar technologies may be used (pixels, web
beacons, scripts). A cookie is a text file containing small amounts of
information that are downloaded to your device when you access the App. The
text file is then sent back to the server each time you use the App. This
enables us to operate the App more effectively. For example, we will know how
many users access specific areas or features within our App and which links or
ads they clicked on. We use this aggregated information to understand and
optimize how our App is used, improve our marketing efforts, and provide
content and features that are of interest to you. We may ask advertisers or
other partners to serve ads or services to the App, which may use cookies or
similar technologies.
· Log file information. Log
file information is automatically reported each time you request to access the
App. It can also be provided when the App is installed on your device. When you
use our App, analytics tools automatically record certain log file information,
including the time and date when you start and stop using the App, and how you
interact with the App.
· Ad-related information.
The following data might be reported about the ads you can view: the date and
time a particular ad is served; a record if that ad was “clicked” or if it was
shown as a “conversation” event; what ad offer is about; what type of ad it is
(e.g., text, image, or video); which ad placement is involved (where the ad
offer is displayed within the App); whether you respond to the ad.
· In-app events. When
you use our App, analytics tools automatically record in-app information
(tutorial steps, payments, in-app purchases, custom events).
Information provided
automatically to advertising or analytics tools does not generally come under
our control, therefore we cannot be responsible for processing such
information. Please mind that some services are engaged in personal data
profiling and may obtain information related to your personality and/or your
device by using technologies that do not belong to our scope of responsibility.
We do not control, supervise or stand surety for how the third parties process
your personal data, that might be collected by their means (not through our
App). Any information request regarding the disclosure of your personal
information should be directed to such third parties (see Section III).
II. THE 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:
(a) To provide the App, maintain,
improve, test, and monitor the effectiveness of our App. We use information you provide to us directly and
information that is processed automatically to provide and deliver the App to
you as well as to better understand User behavior and trends, detect potential
outages and technical issues, support the existing functions of the App, and to
add new features and services to the App.
(b) To provide you with interest-based (behavioral)
advertising or other targeted content. We may use information that is processed
automatically for marketing purposes (to show ads that may be of
interest to you based on your preferences). We provide personalized content and
information to you, which can include online ads or other forms of marketing.
(c)
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 and
administrative messages. Similarly, we use your contact information to respond to you
when you contact us.
(d) To prevent fraud and spam, to enforce the law. We aimed our App to be free of spam and fraudulent
content so that you feel safe and free. We may use your information to prevent,
detect, and investigate fraud, security breaches, potentially prohibited or
illegal activities, protect our trademarks and enforce our Terms of Use.
If any new purposes for
processing your personal data arise, we will let you know we start to process the
information for that other purpose by introducing the corresponding changes to
this Privacy Policy.
III. INFORMATION SHARING
AND DISCLOSURE
We will share your
information with third parties only in the ways that are described in this
Privacy policy.
We will not rent or
sell your personal data to any third parties, but we may share your information
from tools like log files, device identifiers, and location data, with
third-party organizations that provide automatic data processing technologies
for the App. We do not control or influence these third parties tracking
technologies or how they may be used.
We may also share
certain information such as cookie data with third-party advertising partners.
This information allows third-party ad networks, inter alia, to deliver
targeted advertisements that they believe will be of most interest to you.
Please note that
while integrating external tools and services we choose legal entities that can
assure they apply all necessary technical and organizational measures to
protect personal data. However, we cannot guarantee the security of any
information transmitted from us to any such legal entity. We are not
responsible for any accidental loss or unauthorized access to your personal
data through the fault of such legal entities. These legal entities are
separately responsible for their privacy policies and practices.
The following
categories of recipients (third-party providers and advertising partners) may
be engaged by us in the processing of your information for a variety of
business purposes (namely to provide us with the necessary infrastructure for
the delivery and improvement of our App, and to perform App-related services):
|
Entity Name |
Services performed |
Entity Location |
Link to Privacy Policy |
|
Amplitude Inc. |
Analytics Service Provider |
U.S.A. |
|
|
Apple Inc. |
Cloud storage Service Provider |
U.S.A. |
|
|
AppsFlyer UK LTD |
Analytics Service Provider |
UK |
|
|
Facebook Inc. |
Analytics Service Provider |
U.S.A. |
|
|
Google LLC |
Analytics Service Provider |
U.S.A. |
https://firebase.google.com/policies/analytics/ https://firebase.google.com/terms/crashlytics-app-distribution-data-processing-terms |
|
Qonversion Inc. |
Analytics Service Provider |
U.S.A. |
|
|
Google Cloud EMEA Limited |
Cloud storage provider |
Ireland |
The above-said
legal entities provide us with automatic data processing technologies for the
App and deliver data processing, payment processing, and other services to us
concerning the App, and may be involved in the other types of services and
activities otherwise discussed in this Privacy Policy. That is why the App may
contain tracking and data collection and analytics tools and other automatic
data processing technologies for the App provided to us by such legal entities,
and that is why third-party companies may have access to and collect data and
information about you (within the categories of personal information mentioned
above), such as your device identifier, IDFA (Identifier for advertisers),
Designated Market Area (DMA), geo-location information, IP address, application
usage, access and session times, and your viewing of and interactions with
advertising, provided and delivered as described in further detail below.
Please note that
all third-party service providers, as well as advertising partners that are
engaged in processing user data, are service providers that use such
information based on agreement and according to business purposes.
In case you want to
learn more about these services and their privacy options (including an opt-out)
please consult the correspondent websites and privacy policies. We are not
responsible for any usage of your personal data by the abovementioned third
parties in violation of our instructions.
Please, note that
the App may include links to third-party websites/services, plug-ins, and
applications (for example, allowing Users to share certain content and
information on social media platforms), or you may access the App from a
third-party site. 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 the privacy practices or the content of these third-party
websites/services, plug-ins, and applications linked to or from our App,
including the information or content contained within them. We encourage you to
read the privacy notice of every website you visit/service, plug-in, and
application you use.
In addition to the
above, we may disclose your personal information if needed for objective
reasons, due to public interest, or in other unforeseen circumstances:
- as required by
law;
- when we believe
in good faith that disclosure is necessary to protect our rights, protect 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 its 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.
It means that your
personal information may also be disclosed to the following categories of recipients:
·
Government
and law enforcement officials, courts.
· Authorized Agents (for example, when you
decide to designate an authorized agent to submit requests on your behalf).
· Affiliates. (for example, when
corporate audit, analysis, consolidated reporting, or compliance with
applicable laws is needed).
IV.
INTERNATIONAL DATA TRANSFERS
We
work in the cross-border area and provide our App to our Users around the
world.
We
and the legal entity that provides automatic data processing technologies for
the App or our third-party advertising partners may transfer the automatically
processed information across borders and from your country or jurisdiction to
other countries or jurisdictions around the world.
Please
note that we may transfer information, including personal data, to a country
and jurisdiction that does not have the same data protection laws as in your
jurisdiction.
This
means that your personal information can be transferred to a third country, a territory,
or one or more specified sectors within that third country, or to an
international organization where data protection and confidentiality
regulations may not provide the same level of protection of a personal data as
your country does.
We
try to make sure that the recipient of any personal data provides proper
protection of the personal data received, following the current legislation on
the protection of such information. By using the App, you agree that we may
transfer your personal data to any third country, a territory, or one or more
specified sectors within that third country, or to the international organization.
For
data storage, we recourse to the services of the hosting organizations. We take
your privacy seriously and, therefore, encrypt your personal data – if possible
- before sending it to the hosting organizations for its storage. Please note
that we cooperate only with those hosting organizations that have passed our
security and reliability check.
V.
HOW LONG DO WE USE YOUR PERSONAL DATA
We
generally retain your personal information for as long as is necessary for
performing the functional service of the App and to comply with our legal
obligations. If you no longer want us to use your information that we
physically access and store, you can request that we erase your personal
information.
However,
some data may still be stored for a certain period (but no longer than the
storage purpose requires) if the information is necessary to comply with a legal
obligation (taxation, accounting, audit) or to maintain safety and data backup
settings, prevent fraud or other malicious acts.
VI.
SECURITY
The
security of your personal information is important to us. We follow generally
accepted industry standards to protect the personal information submitted to
us, both during transmission and once we receive it.
We
take reasonable and appropriate measures to protect personal information from
loss, misuse, and unauthorized access, disclosure, alteration, and destruction,
taking into account the risks involved in the processing and the nature of the
personal information.
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.
Unfortunately,
no method of transmission over the Internet, or method of electronic storage,
is 100% secure. We do our best to protect your personal data, nevertheless, we
cannot guarantee its absolute security. If your personal information is
compromised as a breach of security, we will promptly notify you in compliance
with applicable law.
If
you have any questions about the security of our App, you can contact us
through the email displayed below.
VII.
CHILDREN’S PRIVACY
Our
App, and the services our App provides, are not directed to children under the
age of 18 (or older if required in an applicable jurisdiction to comply with
applicable laws). Therefore, we do not knowingly collect or solicit any
personal information from children under 18 (or older if required in an
applicable jurisdiction to comply with applicable laws). No one under age 18
(or older if required in an applicable jurisdiction to comply with applicable
laws) may provide any personal information to the App. If you are under 18 (or
older if required in an applicable jurisdiction to comply with applicable laws),
then DO NOT DOWNLOAD OR USE the App.
If
we learn that we have collected personal information from a child under age 18
(or older if required in an applicable jurisdiction to comply with applicable
laws), we will erase that information as quickly as possible. If you believe
that we might have any information from or about a child under 18 (or older if
required in an applicable jurisdiction to comply with applicable laws), please contact us.
VIII. YOUR RIGHTS AND CHOICES
If
you are a resident of the European Economic Area, your rights to access, edit,
and delete your information can be found in clause 8.1.
of this section.
If
you are a California resident, your rights to access, edit, and delete can be
found in clause 8.2.
of this section.
If
you are not a resident of the EEA or California, depending on your location,
you may be able to make requests to access, correct, and/or delete certain
personal information that you provide to us. For your protection, we may
require proof and verification of identity and jurisdiction of residency before
we can answer the above requests. If you wish to make such a request, you may
contact us at privacy@irontech.mobi. If we change or delete your
personal information or if you decline to actively share certain personal
information with us, we may not be able to provide you with some of the
features and functionality of the App. Once we have verified you, we will honor
such requests at our discretion and under applicable law.
8.1.
Information
for Individuals in the European Economic Area (EEA) and the UK
If you reside in
the European Economic Area ("EEA") or the UK, applicable privacy laws
(in particular EU-GDPR and UK-GDPR respectively) give you certain rights
regarding your personal data.
According to both EU-GDPR and
UK-GDPR, you have the following options concerning your personal data that was
collected:
To exercise any of
the rights described above, you can contact us through the [contact form]. Please bear in mind that we ensure
the above-mentioned rights only concerning the information that we physically
access and store.
When your personal
information is processed automatically you may object to such processing in
some circumstances. Where your personal information is processed for direct
marketing purposes, you may ask to cease processing your data for these direct
marketing purposes. To exercise your right please contact the recipients listed
in Section III of this Privacy Policy to learn how you can object to processing
your data. Most of them have clear instructions on their privacy pages,
functional API, or other options.
If you don’t want
us to share device identifiers and geolocation data with service providers,
please check your device settings to opt out as described below >>
If you are located
in the European Union, you may address us when you have questions on privacy
issues by sending an email to privacy@irontech.mobi.
If you are located
in the UK, you may address our representative in the UK when you have questions
on privacy issues by sending an email to ukrep@irontech.mobi.
8.2.
Information
for Residents of California: Your California Privacy Rights
The California
Consumer Privacy Act of 2018 (CCPA) provides those who reside in the State of
California with specific rights regarding their personal information. This
section describes your CCPA rights and explains how to exercise those rights.
The
CCPA provides consumers (California residents) with the following rights
regarding their personal information:
·
Right to Access.
You have the right to request that we disclose, no more than twice in twelve
months, any of the following for the period that is twelve months before the
date the request is made:
-
The categories of
personal information we have collected about you.
-
The categories of sources
for the personal information we have collected about you.
-
The business or
commercial purpose for our collecting or selling your personal information.
-
The categories of third
parties to whom we share your personal information.
-
The specific pieces of
personal information we have collected about you.
-
Whether
we have sold or disclosed your Personal Information for a business purpose, and
if so, two separate lists disclosing:
o sales, identifying the
categories of personal information that we have sold about you in the prior 12
months as well as the categories of third parties to whom we sold that personal
information, by category or categories of personal information for each
category of third parties to whom your personal information was sold; and
o disclosures for a
business purpose, identifying the categories of personal information that we
have disclosed about you in the prior 12 months as well as the categories of
third parties to whom we disclosed your personal information, by category or categories
of personal information for each category of third parties to whom your
personal information was disclosed.
Once we receive and confirm your verifiable consumer
request, the data outlined in this section above (Right to Access) will be
disclosed to you.
· Deletion
rights. You have the right to request that we delete any
of your personal information that we collected from you and retained, subject
to certain exceptions outlined in the CCPA. Once we receive and confirm your
verifiable consumer request, we will delete (and direct our service providers
to delete) your personal information from our records, unless an exception
applies.
·
Right to Opt-Out (“Do Not
Sell”). You have the right to tell us not to disclose or
transfer your personal information to a third party in exchange for something
of value. The
CCPA refers to this as your right to say “Do Not Sell” my personal information.
We do not sell personal
information, as noted herein. If
we decide to sell personal information in the future, we will post an
appropriate notice and opt-out method, and we will not sell any personal
information previously collected.
However, if you don’t want
us to process your personal information any further, please contact us through
the [contact
form]. In most cases, there is no way to
maintain the App’s further operating without functional data therefore you will
be advised to remove the App from your device.
If you don’t want us to
share device identifiers and geolocation data with third-party service providers,
please check your device settings as described below >>
·
Non-discrimination. You
are entitled to exercise the rights described in this section free from
discrimination. This means that we will not discriminate against you in a
manner prohibited by the CCPA because you exercise your CCPA rights.
Unless permitted by the
CCPA, we will not:
-
Deny you goods or
services.
-
Charge you different
prices or rates for goods or services, including through granting discounts or
other benefits, or imposing penalties.
-
Provide you with a
different level or quality of goods or services.
-
Suggest that you may
receive a different price or rate for goods or services or a different level or
quality of goods or services.
Now,
when you are aware of your California privacy rights, please note, the
following:
· All
the categories of personal information listed in Section I of this Privacy
Policy ʺI.
INFORMATION WE PROCESSʺ has been collected by us from Users within the last
twelve (12) months.
· In
the preceding twelve (12) months, we have disclosed your personal information
included in each of the categories of personal information A, B, C, and D listed
in Section I of this Privacy Policy ʺI. INFORMATION WE PROCESSʺ for each business purpose
described above depending on your use of the App described herein.
· We
are not in the business of selling information about you to anybody, which
indicates that no personal information of yours has been sold ever.
How
to Exercise Your California Privacy Rights
To
request access to your personal information or request deletion, please submit
a verifiable consumer request to us by either:
-
[contact form];
-
e-mail: privacy@irontech.mobi
Consumers
may exercise these rights via an authorized agent who meets the agency
requirements of the CCPA. Only you or a person registered with the California
Secretary of State that you authorize to act on your behalf may make a
verifiable consumer request related to your personal information. You may also
make a verifiable consumer request on behalf of your minor child.
Please,
include the wording “Consumer rights to maintain confidentiality in the state
of California” in the text of your request.
Any request you submit to us is subject to an
identification and residency verification process, so when submitting a
verifiable request, you should be ready to:
·
Provide
sufficient information that allows us to reasonably verify you are the person
about whom we collected personal information or an authorized representative,
which may include: name, address, city, state, zip code, and email address. We
may use this information to surface a series of security questions to you to
verify your identity. If you are requesting an authorized agent acting on your
behalf, the such authorized agent must provide written authorization confirming
or a power of attorney, signed by you.
·
Describe
your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We
will not be able to respond to your request or provide you with personal
information if we cannot: (i) verify your identity or authority to make the
request, or (ii) confirm the personal information that relates to you. We may
ask you for additional information or documents to verify your identity. We may
also carry out checks, including with third-party identity verification
services, to verify your identity before taking any action with your personal
information. This is regarded as a safeguard measure to prevent disclosure of
your personal information under a fake or scum request.
We ensure that personal
information provided in a verifiable consumer request will be used only to
verify the requestor’s identity or authority to make the request and not for
any other purpose. We will keep it for the adequate term reasonably needed for
the purpose described above and delete it after the purpose is fulfilled.
We
try to respond to a verifiable consumer request within forty-five (45) days of
its receipt. If we require more time, we will inform you of the reason and
extension period in writing. Please note that we are only required to respond
to two requests per customer each year.
Opt-out of marketing tracking
If you don’t want third-party
service providers to use data concerning you to personalize ads on the basis of
your interests you should choose the option "Limit Ad Tracking" on
your iOS device in Settings/ Privacy/ Advertising, please find additional information
here: https://support.apple.com/en-us/HT202074;
You can also visit https://youradchoices.com for the same purpose. (Please, bear in mind that we
have no control over this website and any decisions it provides).
Please mind 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
If you don’t want third-party
service providers to use your precise location data, or street-level location
information about you, you should turn Location Services off for the applicable
Product via the menu “Settings > Privacy > Location Services”. Then select
the applicable App and set the “Share My Location” status to “Never”. Please
see additional information here: https://support.apple.com/en-us/HT203033.
Also, as mentioned above, we
may occasionally send you push notifications or alerts to inform you about
certain offers, news, and tips concerning the App even if our App is not
currently open or in use. If you want to opt-out from receiving these types of
communications, you can manage your push notification preferences or disable
these notifications by turning off the notification settings in the settings of
your mobile device at any time. Bear in mind that if you do that, the App may
lose full functionality or we will not be able to provide you with any
important notifications like privacy notices.
It should be noted that you can
stop all information collection regarding your App usage by uninstalling the
App using the standard uninstall process for your device. If you uninstall the
App from your mobile device, some information concerning you may still be
stored as described in Section V above.
X.
CHANGES TO THE PRIVACY POLICY
We
recognize that information privacy is an ongoing responsibility, and so we will
from time to time update this Privacy Policy as we undertake new personal data
practices or adopt new privacy policies.
Whenever
we change this Privacy policy, we will post those changes to this Privacy Policy
and other places that we consider appropriate. Additional forms of notice of
modifications or updates as appropriate under the circumstances may be provided
to you.
XI.
HOW TO CONTACT US
If
you have any questions about this Privacy Policy, please feel free to contact
us via [contact
form] or send your message to privacy@irontech.mobi.
Copyright © 2023 IRONTECH
LIMITED.