When you access and interact with our Website and iOS mobile App and use our services, we collect and process your personal data.

This Privacy Policy contains important information about how and why we collect and use your data when you access and interact with our website, mobile apps, and services.

Registered business name: ADVA Soft GmbH
Business address: Scherenbergstraße 8, 10439 Berlin, Germany
Business email: support@adva-soft.com

For any matter or questions relating to the processing of your personal data, you can contact us either via post or by email at:

Business address: Scherenbergstraße 8, 10439 Berlin, Germany
Business email: support@adva-soft.com

Data you voluntarily provide to us

You voluntarily provide us with your personal data when you do the following:

• When you enter your financial data such as your card details and your billing address to make a purchase.
• When you provide your basic personal information such as your email address to fill out customer surveys on our website and within the app.

Data we automatically collect about you

In addition to personal data you directly disclose to us, we also use various third-party tools to automatically collect personal data about you:

• When you visit our website, we place cookies on your device to collect personal data about you. Visit our Cookies Policy to learn about how we use cookies.
• When you download and use our mobile app, we automatically collect information about how you interact with it via the following third-party tools:
  https://firebase.google.com/docs/analytics

• When you download and use our mobile app, we automatically collect information about how you interact with it via the following third-party tools:
  https://mixpanel.com/legal/app-store-privacy-details/

• When you make purchases within the app, we collect data about your purchases and your purchase tendencies and use this data for analytics purposes by using the following tool:

https://www.revenuecat.com/

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:
https://www.appsflyer.com/gdpr/dpa.pdf

For more information about how Appsflyer processes personal data, visit their Services Privacy Policy here:
https://www.appsflyer.com/legal/services-privacy-policy/

Through the methods described in Section 4, we may collect the following categories of personal data about you:

• Basic personal details such as your name and email address,
• Financial data such as your bank details, card information, and billing address,
• Information about your devices such as device&hardware model, device identifier, and IP address,
• Data related to how you access, use and interact with our website, mobile app, and services. For instance, we collect data about actions you take within our apps such as making a purchase or clicks.
• Data related to individual purchases you make and your purchase habits and tendencies
• Data about the specific actions you take on the photos you edit via our app such as the removal of certain objects inside the photos you upload and the place and the type of object you remove

In addition, we may collect data related to your use of our mobile app such as:

Number of sessions
Session duration
Operating systems
Device model
Geography
App opens
App updates
In-app purchases

We only process your personal data for specific purposes such as:

• To enable you to access and use our services and features;
• To contact you to provide information and updates about our App;
• To carry out research and analytics about how you use and interact with the App/Sites;
• To improve our app, website, and services by collecting data about your usage of our services;
• To resolve disputes in relation to the relationship between you and us;
• To investigate fraud, to protect and enforce our legal rights;
• To send you promotional materials about our services;
• To deliver a series of advertisement products such as real time bidding from third party advertisers(Website data).
• To analyze the type, place, and form of objects you remove from the photos you upload so that we can better understand which objects our users want to remove more frequently. This will help us fine-tune our algorithm so that we can offer our users better auto-selection and object removal functionality.

Purpose for the processing of data	Categories of data	Source of data	Legal basis
To enable you to access and use our services and features	Financial data such as your bank details, card information, and billing address	You voluntarily disclose your financial data to us when you make a purchase to access and use our services	Contractual necessity
To carry out research and analytics about how you use and interact with the App/Sites; To improve our app, website, and services by collecting data about your usage of our services. To analyze the type, place, and form of objects you remove from the photos you upload so that we can better understand which objects our users want to remove more frequently. This will help us fine-tune our algorithm so that we can offer our users better auto-selection and object removal functionality.	Data related to how you access, use and interact with our website, mobile app, and services. For instance, we collect data about actions you take within our apps such as making a purchase or clicks. In addition, we may collect data related to your use of our mobile app such as: Number of sessions Session duration Operating systems Device model Geography App opens App updates Purchases you make, and your purchase tendencies	We automatically collect such personal data when you access and use our services	Legitimate ınterests
To resolve disputes in relation to the relationship between you and us. To investigate fraud, to protect and enforce our legal rights	Any data relevant to the issue at hand	Depends on the way in which data is collected	Legitimate interests
To send you promotional materials about our services	Your email address	Provided directly by you	Consent
To deliver a series of advertisement products such as real-time bidding from third-party advertisers	Information about your device, IP address, online identifiers, actions you take such as app installs and clicks	Automatically collected via cookies and other third-party tools as described in our cookies policy	Consent

Reason for disclosure	Who may access your data	What categories of data are disclosed
To process payments such as when you subscribe to our services	Payment service provider: Apple Pay, Google Play, Paypal	Cardholder name, cardholder address, card number, payment amount, transaction date/time. For more detailed information, please refer to section 12.
Service providers	To provide you with our services and to carry out certain business operations as described above, we disclose your personal data to third parties such as analytics service providers	Data related to how you access, use and interact with our Website, our mobile app, and services. For instance, we collect data about actions you take within our mobile apps such as making a purchase or clicks In addition, we may collect data related to your use of our mobile app such as: Number of sessions Session duration Operating systems Device model Geography App opens App updates In-app purchases
Affiliates	We may share our mobile app usage data with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy	Data related to how you access, use and interact with our Website, our mobile app, and services. For instance, we collect data about actions you take within our mobile apps such as making a purchase or clicks In addition, we may collect data related to your use of our mobile app such as: Number of sessions Session duration Operating systems Device model Geography App opens App updates In-app purchases
Professional advisors	We may disclose your data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us	Data related to how you access, use and interact with our Website, our mobile app, and services. For instance, we collect data about actions you take within our mobile apps such as making a purchase or clicks In addition, we may collect data related to your use of our mobile app such as: Number of sessions Session duration Operating systems Device model Geography App opens App updates In-app purchases

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.

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: support@adva-soft.com

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.

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.

We use Facebook Pixel on our Website, which is a piece of code that enables us to track our users’ activity on our Website.

Via Facebook Pixel, we collect the following types of personal data about you when you visit our website:

• The HTTP header information containing particulars such as user agent, country of residence, and language preferences of the web browser or app used (Details such as user agent, country of residence, language preferences);
• Information about events such as “Page view”, clicks;
• Online identifiers, such as IP addresses and Facebook-related identifiers, or device identifiers.

Notice about Apple Pay

When you make a purchase via Apple Pay to access and use our services, Apple collects and uses your personal data.

To learn more about what types of personal data Apple collects and how your data is used, please refer to Apple Privacy Policy:

• https://www.apple.com/legal/privacy/en-ww/
• https://www.apple.com/uk/legal/privacy/data/en/apple-pay/

Notice about Paypal

When you make a payment via Paypal, Paypal collects and processes your personal data.

To learn more about what types of personal data Paypal collects and how your data is used, please refer to Paypal privacy notice:

• https://www.paypal.com/us/legalhub/privacy-full

Notice about Google Pay and other methods

When you make a payment via Google Pay, Google play Gift Cards and Promo Codes, Google collects and processes your personal data.

To learn more about what types of personal data Google collects and how your data is used, please refer to Google Payments Privacy Notice:

• https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en
• https://support.google.com/googlepay/answer/7643925?sjid=7011834154728981607-EU&visit_id=638211240334863876-3733807392&rd=1

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.

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 RETOUCH app — Settings, Privacy Details, ALLOW RETOUCH TO ACCESS, Photos, None;
• From default Settings app — RETOUCH, ALLOW RETOUCH TO ACCESS, Photos, None.

You can turn off the sharing of your data related to your usage of the app for analytics purposes directly within the app:

To turn off data sharing, go to Settings > Share App Usage Analytics and toggle off the data sharing.

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 the following ways:

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF


Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

For country specific complaint processes, you may refer to the following directory to contact the relevant supervisory authority:

https://iapp.org/resources/global-privacy-directory/

We reserve the right to make changes to this Privacy Policy as we deem appropriate.

You should regularly check our Privacy Policy page to see new changes.

ADVA Soft GmbH
Scherenbergstraße 8
10439 Berlin
Germany

Email: support at adva-soft.com
Website: adva-soft.com
Tel.: +49-30-2241-4693

Managing director: Robert Werner
Commercial register: HRB 158929 B
VAT Identification No.: DE 286493806