Fitsnap-AI
Gizlilik Politikası
Last updated November 4, 2024
This privacy policy (the “Privacy Policy”) describes the privacy practices of Fitsnap in connection with the Fitsnap mobile applications (each, an “App” and collectively, the “Apps”) and the Fitsnap.com website (the “Site”).
Welcome to FitSnap’s Privacy Policy!
If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about Fitsnap’s privacy practices:
-
The Apps are photo or video editors that allow users to control of body body fat ratio.
-
We do not use photographs or videos you provide when you use the Apps for any reason other than to provide you with the controling body body fat ratio functionality of the Apps.
-
We use third-party cloud providers - specifically, Google Cloud Platform to process and control photographs and videos.
-
You only send to the cloud the photographs or videos that you specifically select for body fat ratio control.
-
Photographs or videos are temporarily cached on the cloud servers during the body fat ratio control process and encrypted using a key stored locally on your mobile device.
-
Photographs or videos may remain in the cloud for a maximum limited period of 24 to 48 hours, for improved performance and lower bandwidth allowing additional changes to recently selected photos or videos in an optimal manner.
Here’s more on our privacy practices.
1. Information We Collect
1.1. When you use the Apps and select photographs or videos for body fat ratio control, we cache them for processing to render the requested body fat ratio control service:
-
Photographs or videos you select when you use the Apps, via your camera or camera roll (if you have granted the Apps the permission to access your camera or camera roll), or via the in-App internet search functionality. We process only specific photos and videos you choose to modify using the Apps; and we do not collect your photo or video albums even if you grant us access to them. We safeguard each photograph or video that you select using an encryption key stored locally on your device. This means that the only device that can view the photo or video is the device from which the photograph or video was submitted using the Apps - the user’s device. Please note that while we do not require or request any metadata attached to the photographs or videos you select for body fat ratio control, metadata (including, for example, geotags) may be associated with your photographs or videos by default. We take steps to delete any metadata that may be associated with a photograph or video you provide when you use the Apps. Photographs or videos may remain cached in the cloud for a limited period between 24 to 48 hours after your last body fat ratio control, so that you can return to it and make additional changes if you so choose.
1.2. When you use the Apps and the Site, we may collect some information, including:
-
Apps usage information and online activity data, such as information about 1) how you use the Apps and interact with them, including the features you use, your preferred language, the date and time when you first installed the Apps and the date and time when you launch the Apps; 2) sources of referrals to the Site.
-
App-related purchase history, if you choose to purchase an Apps subscription, we will not receive such information as billing address, credit card etc. (as we don’t distribute subscriptions directly), we will only receive confirmation from the relevant application store that you are a paid subscriber to the Apps so we can provide Pro services.
-
Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, push tokens, browser type, screen resolution, IP address (and the associated city/country in which you are located), and the website you visited before visiting our Site.
Generally, all data are associated only with an App Instance ID (assigned to an instance of the Apps installed on your mobile device). Online identifiers such as an IP address and App Instance ID are generally considered as personal data. However, we are not in a position to identify you specifically by name or address on the basis of such identifiers.
This information may be collected through our Site and Apps using cookies, and similar technologies. We may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from the App. For more information, please see our Cookie Policy.
1.3. When you contact us by email, we may also collect:
-
Contact information, such as your name and email address, and information relating to your communication.
2. How We Use Your Information
2.1. We do not use photographs or videos you provide when you use the Apps for any reason other than to provide you with the controling body fat ratio functionality of the Apps.
2.2. We may use information other than photographs and videos for the following purposes:
To operate and improve the Apps and the Site. We use your personal information to operate, maintain, and provide you with the Apps and the Site. In particular, we will use your personal information to perform our contractual obligations under our Terms of Use, such as to:
-
Enable you to use the Apps’ features and to visit the Site.
-
Communicate with you about the Apps, and the Site, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your email requests, questions, and feedback.
-
Provide technical support and maintenance for the Apps.
To improve, monitor, and protect our Apps and the Site. It is in our legitimate business interests to improve and keep our services safe and secure for our users. We do this by:
-
Performing statistical analysis on aggregated data relating to the use of the Apps and Site (including through the use of third-party services).
-
Troubleshooting, testing, and researching.
To market and to promote our Services. We may use your personal information to understand where our App and Site traffic comes from to improve our marketing strategies and our promotional companies. It helps us to personalize our promotion offers and understand broader our Service audience behavior, offering a tailored experience. Where required under applicable law, we process your personal information based on your consent for these purposes, which you may withdraw at any time. Otherwise, we process your personal information for marketing and promotional purposes where it is in our legitimate interests to do so.
For compliance, fraud prevention, and safety. We may use and disclose the information we collect (such as device data and Apps usage information) where it is in our legitimate business interests to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Apps and Site; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity. We may disclose this information to government authorities and other third parties as required by applicable law. We cannot disclose the photos and videos that have been cached for processing as we do not store the encryption keys.
To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data where it is in our legitimate business interests, and use and share it with third parties.
2.3. We will only process personal information on the basis of our legitimate interests where such interests are not overridden by your interests or your fundamental rights and freedoms.
2.4. We use cookies that are essential for Fitsnap to function. We would also like to use cookies and similar technologies to store, access and process your information for analytics, troubleshooting, and marketing. With your consent, we and our third-party partners may use additional tracking technologies to enhance your user experience.
3. How We Share Your Information
3.1. We do not disclose user photographs or videos to third parties (with the exception of temporarily caching an encrypted version with our cloud providers, Google Cloud Platform and Amazon Web Services, to provide the photo and video body fat ratio control features of the Apps). We cannot disclose the photos and videos cached for processing as we do not store the encryption keys.
3.2. We do not sell personal information. We may share your non-photograph and non-video information in the following circumstances:
Affiliates. We may share information we collect from you with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We may share your information with service providers that perform services on our behalf or help us operate the Apps (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
Third-party platforms and social media networks. You may select to post the controled photograph or controled video to your social media account. We do not control any third-party platform’s use of your information, which is governed by that third party’s privacy policy and terms and conditions.
Professional advisors. We may disclose your information to professional advisors, such as lawyers and auditors, where necessary in the course of the professional services that they render to us.
Business transfers. We may also transfer or assign your personal data in the course of corporate divestitures, consolidations, mergers, acquisition, reorganization or other transfers of assets, or in the event of bankruptcy or dissolution.
Compliance with law. We may be required to disclose your information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, or for the compliance, fraud prevention, and safety reasons described above. We do not have any access to your photos or videos as they are cached in encrypted format, and the key resides on the user’s device so we cannot disclose such content.
4. Your Choices
Opt out of push notifications. You may opt out of the push notifications we may send you by changing the settings on your mobile device.
Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera, camera roll, or microphone through the settings on your mobile device.
Cloud processing. You may request that we remove your information, including the photographs and videos that are temporarily cached on Google Cloud Platform or Amazon Web Services, prior to the automatic 24 to 48 hours post-control deletion time by clicking the “Request cloud data removal” button in the “Support” section of the Apps settings.
Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your jurisdiction, you may request the following in relation to your personal information:
-
Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
-
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
-
Correction of personal information that is inaccurate or out of date.
-
Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
-
Additional rights, such as to object to and request that we restrict our use of your personal information.
To make a request, please email us at privacy@Fitsnap.com. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. If you are in Europe, you can find your data protection regulator here. If you are in the ISTANBUL, the Information Commissioner’s Office is the competent authority.
Choosing not to share your information. Where we need your information in order to provide the services to you or where we are required by law to collect your information, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.
Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Please note that we may require additional information in order to verify your identity and process your request.
5. Other Sites, Mobile Applications, and Services
The Apps may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites, mobile applications, and online services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.
6. Security Practices
We use commercially reasonable security practices to help keep the information collected through our services secure. However, Fitsnap cannot guarantee the security of any information you provide, as bad actors, for example, may try to access, disclose, alter, or destroy your information.
Please do your part to help us. You are responsible for maintaining the confidentiality of your information, and for controlling access to communications between you and Fitsnap, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.
7. Retention
We configure Google Cloud Platform and Amazon Web Services to delete photographs and videos, and the information associated with those photographs and videos, within 24 to 48 hours after the photograph or video was last control using the Apps. This allows you to revisit photographs or videos to make additional modifications during that time.
With respect to non-photograph and non-video information that we may collect, we will retain such information only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy unless a different retention period is permitted or required by applicable law. You may also ask that we delete your information using the “Request cloud data removal” option in the “Support” section of the Apps settings.
8. Cross-Border Data Transfers
If we transfer your personal information internationally, these countries may not provide the same protections as the data protection laws where you are based. Where we transfer information internationally, we:
-
Make sure the data transfer complies with applicable law; and
-
Make sure that the relevant safeguards are in place to afford adequate protection for your personal information.
We do this using a variety of protections, as appropriate for each data transfer. For example, we use:
-
Standard Contractual Clauses (or an alternative legal tool, such as the UK Government-approved International Data Transfer Agreement or Addendum) to require the third party to protect your data and to provide you with EU- and UK-level rights and protections;
-
Technical protections, such as automated deletion, encryption, and pseudonymization; and
-
Policies and processes to challenge disproportionate or unlawful government authority requests.
Note, our technical support team may also access your information, such as Apps usage information, in locations outside of your state, province, or country.
9. Children
We have a minimum ‘Age Limit.’ Our Apps and Site are not directed at children under the age of 13 years or whose age:
-
Makes it illegal to process their personal data; or
-
Requires parental consent to process their personal data.
We do not consciously collect data from subjects under the Age Limit. Please do not upload photos or videos of children under the Age Limit, unless you are their parent or guardian. If you are under the Age Limit, do not use our Apps or Site. If you are a parent or the guardian of a person under the Age Limit, please do not allow such person to use our Apps or Site.
If you believe that we have received personal data from a child under the Age Limit, please contact us at privacy@Fitsnap.com.
10. Changes to the Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Apps and Site. We may, and if required by law will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the Apps.
Any modifications to this Privacy Policy will be effective upon our posting the new terms to the Site and/or upon implementation of the new changes on the Apps and Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) by Fitsnap AI (“we” or “us”), the parent company of Splice Video Editor S.r.l., when you use the Remini mobile application (“app”) or otherwise interact with us and this Privacy Policy is presented to you, in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).
11. Data Controller and Data Protection Officer
Fitsnap Technology Limited is the entity responsible for the processing of your personal information, and is the data controller in respect of such processing.
If you have any questions about Fitsnap, or any concerns regarding your privacy, you can contact us at: privacy@Fitsnap.com.
Our Data Protection Officer can be contacted by sending an email to dpo@Fitsnap.com for any requests relating to the processing of your personal data or this Privacy Policy.
12. Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing
We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.
13. Data Storage and Protection
Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.
Personal data processed for the purposes referred to in Sections 2.a), 2.e), 2.f) and 2.g) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 10 years from the termination of the agreement.
Personal data processed for the purposes referred to in Sections 2.b), 2.d), 2.h) and 2.i) (as to Soft Opt-In) will be kept until you object to such processing. However, should you not exercise your right to object, personal data will be kept for such purposes for no more than 2 years from the termination of the agreement.
Personal data processed for the purposes referred to in Sections 2.c), 2.i), 2.j) and 2.k) will be kept until you withdraw your consent to such processing. However, should you not withdraw your consent, personal data will be kept:
-
for the purposes referred to in Section 2.c), for no more than 3 years from the upload of the images, and
-
for the purposes referred to in Section 2.i), for no more than 2 years from the termination of the agreement, and
-
for the purposes referred to in Sections 2.j) and 2.k), for no more than 10 years from the termination of the agreement.
Except for any legal obligation that sets a longer data retention period, at the end of these periods, the personal data processed will be deleted or anonymized.
14. Your Choices with Regard to the Use of Your Personal Data
It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.e), and 2.f). If you do not provide the personal data, you will not be able to enjoy the app’s services and features or participate in our contests, sweepstakes or other promotions that we offer.
Where we rely on your consent for the purposes referred to in Sections 2.c), 2.i) 2. j) and 2.k), your provision of personal data is optional, and you have the right to withdraw your consent at any time. If you do not provide the personal data, you will still be able to enjoy the app’s services and features.
Where we rely on our legitimate interest for the purpose referred to in Sections 2.b), 2.d), 2.g), 2.h) and 2.i), you may, at any time, exercise your right to object to such processing as explained in Section 7 (Your Rights) below.
You can also manage how you share certain information with us by adjusting the privacy and security settings on your mobile device (such as Limit Ad Tracking or Allow Apps to Request to Track on iOS and iPadOS, or Opt out of Interest-Based Ads or Opt out of Ads Personalization on Android devices). You should refer to the instructions provided by your device’s operating system or its manufacturer to learn how to adjust your settings.
15. Sharing Your Personal Data
We may share or disclose your personal data to the following categories of recipients:
-
Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners, suppliers of mobile marketing services, and advertising networks and platforms such as Google AdMob).
-
If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers, and may be one of the assets that is transferred to another owner.
-
If you choose to participate in a contest, sweepstakes or promotion we offer, information and content you submit in connection with the contest or promotion may be shared publicly as part of our marketing and advertising efforts (for example, your video submission in a contest and your social handle could be shared in our social channels).
-
Public, judicial or police authorities, within the limits established by applicable laws.
Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.
16. Transfers of Personal Data Outside the European Economic Area
We may transfer personal data from the European Economic Area (“EEA”), the UK or Switzerland to other countries outside the EEA. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Laws, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission; or (c) binding corporate rules.
More information on the appropriate warranties are available for consultation by sending an email to privacy@Fitsnap.com.
17. Your Rights
At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Applicable Privacy Laws:
-
Right of access. You have the right to obtain information about the processing of your personal data and to access it.
-
Right to rectification. You have the right to ask for the updating, rectification or integration of your personal data.
-
Right to erasure. You have the right to request the deletion of your personal data.
-
Right to restriction of processing. You have the right to request the restriction of the processing of your personal data.
-
Right to data portability. You have the right to obtain a portable electronic copy of your personal data.
-
Right to object. Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation. In particular, you are entitled to object to the processing of your personal data for direct marketing purposes, including profiling.
-
Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent, although the processing carried out before your withdrawal of consent will remain valid.
You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
To exercise your rights, or if you have any other questions about privacy or data protection at Fitsnap AI, you can contact us by sending an email to privacy@Fitsnap.com. We may take reasonable steps to verify your identity prior to responding to your request.
18. Children’s Personal Data
The app is not intended for anyone under the age of 16. We do not knowingly collect personal data from children. If you believe we have received personal data from children under the age of 16, please email us at privacy@Fitsnap.com. If we learn that a user is under the age of 16, we will take reasonable steps to delete any processed data and close such user’s account.
19. Third-party Websites and Services
The app may include links to other websites or services operated by third parties. The activities described in this Privacy Policy do not apply to data processed by such third-party websites and services. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.
20. Changes to this Privacy Policy
We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws. If we make modifications, we will notify you by revising the date at the bottom of this Privacy Policy and, under certain circumstances, we may also notify you by additional means such as pop-up or push notifications within the app or our website, or email.
21. Additional Information for California Consumers
This section provides additional disclosures required by the California Consumer Privacy Act (“CCPA”).
a) Additional Information Related to Collection, Use, and Disclosure of Personal Information
We collect personal information from several sources: directly from you (for example, when you make purchases within the app or participate in a survey or contest); automatically when you use the app (for example, device information); and from other sources (for example, mobile measurement partners). We also generate inferences about you based on your use of the app and other information we collect.
In the preceding 12 months, we have collected the following categories of personal information: identifiers; internet or other electronic network activity information; characteristics of protected classifications under California or U.S. federal law (such as gender if you participate in a survey); commercial information (such as purchases you make in the app); approximate geolocation information (such as country); audio and visual information (such as videos you share with us if you participate in a contest); inferences; and other information that relates to or is reasonably capable of being associated with you. For details about the personal information we collect, please see Section 12(Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing) above. We collect personal information for the business and commercial purposes listed in the chart in Section 12 above.
We may share your personal information with the categories of third parties as described in Section 15 above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes: identifiers, internet and electronic network activity information, characteristics of protected classifications under California or U.S. federal law; commercial information; approximate geolocation information; and other information that we have inferred about you or that relates to or is reasonably capable of being associated with you.
We do not sell your personal information. We do allow our advertising partners to collect certain device identifiers and electronic network activity via our app to show ads that are based on your interests. If you prefer to limit this activity, your device may include a feature (such as “Limit Ad Tracking” on iOS, or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for interest-based advertising purposes.
b) Rights of California Consumers
Subject to certain limitations, the CCPA provides California consumers the right to:
-
Request more details about the categories and specific pieces of personal information that we process.
-
Request the deletion of their personal information.
-
Opt out of “sales” of personal information that may be occurring.
-
Not to be discriminated against for exercising these rights.
21. How to Contact Us
Fitsnap Technology Limited is the entity responsible for the processing of your personal information, and is the data controller in respect of such processing.
If you have any questions about Fitsnap, or any concerns regarding your privacy, you can contact us at: privacy@Fitsnap.com.
If you have any questions regarding this Privacy Policy, or if you wish to make a complaint about how your personal data is being processed by Fitsnap, you can contact our Data Protection Officer (“DPO”) at dpo@Fitsnap.com.
You may also write to us via postal mail at:
Fitsnap Technology Limited
Attn: Privacy Manager
28th October Ave 319a
8th Floor - Office 801A
Limassol, 3105
Cyprus
22. TR Representative Contact Information
For users in the ISTANBUL, VeraSafe has been appointed as Fitsnap’s representative in the ISTANBUL for data protection matters, pursuant to Article 27 of the TR General Data Protection Regulation. VeraSafe can be contacted only on matters related to the processing of personal data or data protection.
To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.
Please do not contact VeraSafe for customer service inquiries or issues unrelated to data protection.
