TouchRetouch Privacy Policy (iOS)

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: [email protected]

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: [email protected]

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://amplitude.com/privacy

• When you use our mobile app, we may collect session replay data to improve user experience and diagnose technical issues. Session replays are reconstructed presentations of how you interact with our app, capturing actions like taps, scrolls, and navigation patterns. This data is collected via:
  Amplitude Session ReplayImportant Privacy Safeguards:
  • All image inputs and form fields are masked
  • Sensitive information like passwords and credit card numbers are never captured
  • Session replay data is retained for 30 days only
  • No actual video recording of your screen occurs – only a reconstruction of app events
  • You can opt-out of session replay collection through app settings

• • 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/

Sign in with Apple

When you choose to sign in using Sign in with Apple, we collect the following information provided by Apple:

• Your name (which you may edit before sharing)
• Your email address (either your real email or Apple’s private relay email, at your choice)
• A unique user identifier to authenticate your account

We do not receive your Apple ID password. Apple does not share information about which apps you sign in to. You control whether to share your real email address or use Apple’s private relay service, which creates a unique, random email address that forwards to your personal email.

Data Synchronization

When you sign in to your account, we synchronize certain data across your devices via our secure servers. Synchronized data includes:

• AI Credit balances (subscription, purchased, and promotional)
• Credit purchase history and transaction records
• Credit usage history

Synchronization requires an active internet connection and a signed-in account. Data is transmitted using industry-standard encryption. If you use the Application without signing in, your data remains local to that device and is not synchronized.

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/

Unsplash Integration

When you use our Unsplash integration feature, we collect and share data with Unsplash to enable the functionality of selecting and using backgrounds from Unsplash within our app. This integration requires us to adhere to Unsplash’s API Terms and Privacy Policy.

For more information about how Unsplash processes personal data, visit their Policy here:
https://unsplash.com/privacy

TouchRetouch is not responsible for the content selected and used by users from Unsplash. Users bear full responsibility for ensuring that their use of Unsplash images is appropriate and lawful.

Processing of your photos

Some features of the App use artificial intelligence to edit your photos (“AI Features”). Depending on the feature, your photo is processed in one of the following ways:

• On your device. The photo does not leave your device.
• On our cloud infrastructure. The photo, the area you select and any text prompt or preset are sent to AI models that we operate on infrastructure rented from cloud infrastructure providers in the EU and the United States.
• By a third-party AI provider. The photo, any reference photo and any text prompt are sent to a third-party AI provider, which processes them on our behalf solely to perform the edit you request. Our providers are OpenAI and Google (Gemini). They act as our processors and do not use your content to train their models. Before you first use such a feature, the App informs you that your photo will be processed by a third-party AI provider.

We do not use your photos to train AI models, and we do not build a permanent library of your photos. How long photos are kept is described in Section 14.

Content Credentials on exported images

When you export an image after editing it with an AI Feature that generates or substantially changes image content, TouchRetouch adds Content Credentials to the file: an invisible, signed record which states that the image was edited with an AI Feature of TouchRetouch. Content Credentials do not include your prompt, your account, your device or your location. We add them to comply with EU transparency requirements for AI-generated content, and they cannot be switched off in the App.

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
• Information about your activity across other apps and websites such as your engagement with our ads on third-party apps and websites, your clicks, your activities

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

AI Credits Information

When you use AI Credits features, we collect and store:

• Your current credit balances (subscription, purchased, and promotional credits)
• Credit purchase history, including transaction dates and amounts
• Credit usage history, including feature usage and generation timestamps
• Promotional credit grants and expiration dates

This information is used to manage your credit balance, process transactions, synchronize data across your devices, provide customer support, and comply with legal and accounting requirements.

Photos submitted to AI features

When you use an AI-powered feature, we process: the photo you submit; any text description or preset you select; technical parameters of the request; and the resulting edited image, for the time needed to return it to you. Photos may contain the faces and other personal data of you and of other people depicted in them. Where you submit a photo depicting another person, you are responsible for having a lawful basis to do so.

Face data

Some AI Features detect faces in your photo, or compare a face in one photo with the faces in another, in order to apply the edit you choose. This processing takes place on your device. The resulting face data is used only for that edit, is not retained after you leave the feature and is not used to identify you or any other person. Where an AI Feature sends a photo to our cloud infrastructure or to a third-party AI provider, it sends the photo itself, not face data derived from it.

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.
• To diagnose and fix technical issues by reviewing session replays showing how errors occurred;
• To improve user experience by identifying friction points and usability issues through reconstructed user sessions;
• To analyze user interaction patterns to optimize app navigation and feature placement;
• To provide better customer support by understanding the exact steps that led to reported issues;
• Sharing data with advertisers and ad-performance measurement: To share your data with third-party advertşsers so that they can measure the effectiveness of their ad campaigns on our app.
• Personalized apps: To track your activity across our app and also on third-party apps and websites so that we can deliver personalized ads to you on our app, tailored to your specific interests and needs.
• Ad retargeting: To retarget you with ads on other apps and websites.
• To provide the AI Features you request. Depending on the feature, this involves transmitting the photo you submit, together with any reference photo and your prompt or preset selection, to our cloud infrastructure or to a third-party AI provider, as described in Section 4, where image content is generated or altered in response and the result is returned for delivery to you.
• To keep AI Features safe. We check prompts and results automatically, on your device and on our servers, to prevent content that is unlawful or that our terms of use prohibit. Requests that fail these checks are declined. We keep no copy of the photo from a declined request and record only that the request was not completed.

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.

How to exercise these rights

To exercise any of your rights, please contact us at [email protected]. We may need to verify your identity before processing your request to ensure the security of your personal data. We will respond to your request within one month of receiving it. This period may be extended by two further months where necessary, considering the complexity and number of the requests.

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: [email protected]

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.

We retain your personal data only as long as necessary for the purposes described in this Privacy Policy or as required by law:

• Account data: Retained while your account is active and deleted upon account deletion request
• Credit balances and usage data: Retained while your account is active and deleted upon account deletion
• Purchase transaction records: Retained for 7 years after the transaction for accounting, tax compliance, and legal purposes
• Customer support records: Retained for 3 years after resolution for quality assurance
• Photos submitted to AI features: retained only for the duration of processing and in any event no longer than 1 hour, after which they are deleted from our systems. Where an AI Feature uses a third-party AI provider, the provider may retain them in accordance with the provider’s data policy, solely to detect and prevent misuse, and then deletes them.

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, except for the short time needed to process your AI Feature requests, as described in Section 14.

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.

Account Deletion

You may delete your account at any time through the Application by navigating to Settings > Account > Delete Account.

When you delete your account, we permanently remove all associated data from our servers, including:

• Your account credentials and authentication tokens
• All AI Credit balances (subscription, purchased, and promotional credits)

Account deletion is irreversible. Once completed, your data cannot be recovered, and any unused Credits are permanently forfeited without refund.

If you used Sign in with Apple, we will revoke your authentication tokens with Apple as part of the deletion process.

If you have an active subscription, you must cancel it separately through the Apple App Store. Account deletion does not automatically cancel your subscription, and you may continue to be billed until you cancel through Apple.

Account deletion typically completes within 10 days. You will receive a confirmation email when the deletion is complete.

Note: Purchase transaction records are retained for 7 years after deletion for accounting, tax compliance, and legal purposes, as required by applicable law. These records contain transaction details but are not linked to your personal account after deletion.

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:

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.

We do not knowingly collect personal data from children under 16. If you believe that a child under 16 has provided us with personal data, please contact us at [email protected] and we will delete it.

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