When you use our app and services you’re trusting us with your personal data.
November 15, 2022
When you use our app and services you’re trusting us with your personal data.
2. WHO WE ARE AND HOW TO CONTACT US
Registered business name: ADVA Soft GmbH
Business address: Scherenbergstraße 8, 10439 Berlin Germany
Business email: firstname.lastname@example.org
“App” means the Batched - Multi Photo Editorapplications available on the Apple App Store;
“App Owner”, ADVA Soft GmbH, a company incorporated in Berlin Germanyunder company number HRB 158929 B, with address Scherenbergstraße 8, 10439 Berlin Germany;
“End User” means an individual using any of our Apps;
“Services” means any of the services we provide to Partners or individuals through our Apps and Websites.
4. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
Information related to your Device
We collect various types of information about the computer or mobile device you use to access our Services, including, operating system and version, the hardware model, screen resolution, colour and depth, device identifiers and mobile network information.
When you communicate with Us, when you fill out customer survey forms, when you subscribe to our Services or when you post information about our Services, you may disclose the following types of basic personal data:
Your name, Your surname, Your email address, Your fax number, your gender, postal address.
When You subscribe to Our services, we collect financial data such as your credit/bank card number, payment method, the CVC number and expiry date of the card used.
We use third party analytics tools to collect data about how you access and use our app. This includes the dates & times you access the app, the actions you take within the app such as subscriptions you purchase, app opening, importing photos, making edits to photos, exporting photos or pages viewed, app crashes and other system activity.
We also use third party tools to assign a randomly-generated user ID to You to analyse in-app user behaviour and to use this data to improve our product and Services.
We collect coarse location data about You and it includes ity, state, and country information.
Photos you upload may contain personal data such as your gender, your age range, you location and your race & ethnicity.
5. HOW DO WE COLLECT YOUR PERSONAL DATA?
A. Data You directly provided to Us
You voluntarily disclose Your personal data to Us when You:
When you communicate with Us,
When you fill out customer survey forms,
When you subscribe to our Services or
When you post information about our Services
B. Data we automatically collect about You, including via third party SDKs
When You access and use our App and Services we use third party SDKs(Software packages), analytics tools and cookies to collect data about You.
We use Mixpanel to collect data about your access and use of our Services
Visit the following page to learn about how Mixpanel collects your data and its further use of your data:
We use Adapty to collect data such as your purchase history and information about Your device
By using Adapty, we collect data such as Identifiers and your purchase history. Visit the following page to learn more about how Adapty processes Your data:
We use Appsflyer Service to process your personal data such as:
- “Technical Information”: This covers technical information concerning an End User’s mobile device or computer, such as browser type, device type, and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier.
- “Technical Identifiers”: TThis refers to various unique identifiers that generally only identify a computer, device, browser or Application such as IP address.
- "Engagement Information": This includes information relating to our campaigns and End User actions, such as clicks on our ads, and ad impressions viewed.
To ensure that your personal data is processed as per our instructions, we enter into a Data Processing Agreement with AppsFlyer, which can be found here:
C. Information we collect from third party sources
We may receive updated information about you, such as an most recent billing address, from the relevant financial institution issuing your credit card in connection with our billing for the Services we provide.
6. PURPOSES FOR THE COLLECTION AND USE OF YOUR DATA
To provide and maintain our services;
To provide the main functionality of our App;
Enhance the safety and security of our users and services;
To provide customer support;
To process payments and manage your subscriptions;
To respond to questions, concerns, or customer service inquiries;
To enforce the legal terms that govern our business and commercial relationships;
To comply with law and legal process and protect rights, safety and property; and
For other purposes requested or permitted by our users or other relevant individuals, such as website visitors.
7. SECURITY MEASURES WE TAKE TO PROTECT YOUR DATA
The security and confidentiality of your Information is very important to us, so we take security measures, including physical, electronic and procedural measures, to help safeguard your information from unauthorised access and disclosure.
We have implemented reasonable administrative, technical, and physical security measures to protect your Personal Data against the unauthorised access, destruction or alteration of your information.
- All data is transmitted securely using HTTPs protocol.
- Please know that, despite our efforts, no security measures are perfect or impenetrable. So, we cannot guarantee the absolute security of your transmissions to us and of your personal information that we store.
- Perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.
- We access, use and process EU Personal Data for purposes consistent with the consent obtained from the individual to whom the EU Personal Information relates.
8. LEGAL BASES WE RELY ON TO PROCESS YOUR DATA
[For EU & UK Users only]
We rely on following legal grounds to process your personal data in compliance with the EU & UK GDPR.
We rely on legitimate Interests ground to collect and use data about your device, your in-app activities, purchases you make and actions you take within our App. We rely on legitimate interests to process this data to provide and maintain our core Services, to improve our products based on data analytics, to provide you with customer support and to enhance our business activities.
We collect, use and retain related to financial data such as the payment method you use, amount paid and credit card details to comply with our legal obligations.
9. YOUR LEGAL RIGHTS REGARDING YOUR DATA
You can exercise some or all of the following rights depending on the law that applies to the processing of your personal data.
Right of Access:
You can make a request to find out if we process your data and obtain copies of personal data we hold about You subject to limitations described in applicable laws.
Right to Rectification:
You may ask Us to correct any inaccuracies or false information related to your personal data.
Right to Erasure of Your Data:
Subject to the limitation set forth in applicable laws, you can submit a request for deletion of your data.
Right to Restriction of processing:
You may request the restriction of processing of your data on the ground that the data is not accurate or the processing activity is not legitimate.
Right to Object:
You may raise objections to processing of your data if we are relying on legitimate interests.
Right to Data portability:
If applicable, you can ask for transfer of all personal data we hold about You to another organisation.
10. SHARING YOUR DATA WITH THIRD PARTIES
- Where our users ask us or give us permission to disclose their data to third parties,
- Where we provide personal data to third parties to carry out administrative tasks and to provide our services such as for web-hosting, customer service, data analytics, service improvement and payment processing.
- Where we are legally required to disclose personal data to legal/regulatory authorities upon a valid and lawful request.such as for anti-money laundering or fraud detection.
We disclose your personal data to third parties on the condition that they keep your personal data confidential and they take all appropriate technical organisational and contractual measures to keep your data secure and confidential. Furthermore, these third parties also warrant that they will only use personal data for the specified purposes.
11. DATA RETENTION POLICY
Data retention period
We may store your data longer than 12 months if required by a law or regulation.
12. HOW TO REQUEST DELETION OF YOUR DATA
You can exercise your right to deletion of your data by emailing Us at: email@example.com
When We receive a data deletion request from You, We will immediately delete any personal data unless:
- There is a legal or regulatory requirements that requires the retention of data for longer periods such as those due to tax law;
- For other reasons as stated in this policy.
Information in copies made for backup and business continuity may remain for longer than the original data.
13. HOW TO DELETE YOUR DATA AND REVOKE PERMISSIONS
When you delete the App from your device, all your data, including your imported photos will be deleted within the App.
We do not store your photos on our servers.
If you have given Us access to your Photos, but wish to turn this off, you can do so by the following methods:
- From Batched app — Settings, Privacy Details, ALLOW BATCHED TO ACCESS, Photos, None;
- From default Settings app — Batched, ALLOW BATCHED TO ACCESS, Photos, None.
14. INTERNATIONAL DATA TRANSFERS OUT OF EU & UK
When we transfer your data from the European Economic Area (“EEA”) or UK to countries that the European Commission has not deemed to provide an adequate level of protection, we normally do so on the basis of Standard Contractual Clauses approved by the European Commission for such purpose. You may request a copy of the Standard Contractual Clauses by contacting us as described below.
15. HOW TO EXERCISE YOUR LEGAL RIGHTS, INCLUDING RIGHT TO DELETION OF YOUR DATA
If you decide to exercise your rights we listed in Section 9, you should get in touch with Us by one of the following ways to submit your request:
- Application by post: Scherenbergstraße 8, 10439 Berlin Germany
- Application by Email: firstname.lastname@example.org
When you submit your request by one of these methods, you should include the following information within your request:
Provide us with your name & surname & contact details or other data that may help us to determine if we process Your data.
Description of your request in detail.
We reserve the right to ask for any additional information to verify your identity and authenticity of your request.
We aim to respond to your request within the time limits imposed by relevant laws.
16. HOW TO FILE A COMPLAINT WITH SUPERVISORY AUTHORITIES
For EU & UK users:
If you are located in the EU or the UK, you can file a complaint with the competent Data Protection Authority within that country.
For example, if you reside in the UK, you can contact the ICO via following ways:
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
For country specific complaint processes, please check the websites of the competent Data Protection Authorities in your country.