PRIVACY
POLICY
Last Updated:
March 16, 2026
IRONTECH LIMITED (“we”,
“us” or “our”) values your privacy. This Privacy Policy (“Privacy
Policy”) explains how we collect, use, share, and otherwise process your
personal information when you use the “Photo Collage - Collageable” mobile application (the “App”).
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. This
can include your name, identification number, or any information specific to
your physical, economic, cultural, or social identity.
Our
Privacy Policy applies to all users of our App (“Users”).
PLEASE
READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE PROCESS YOUR PERSONAL
INFORMATION AND YOUR CHOICES REGARDING IT. BY USING THE APP, YOU ACKNOWLEDGE
THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY.
In
line with the EU General Data Protection Policy (EU-GDPR) and the UK General
Data Protection Regulation (UK-GDPR), we are the data controller unless stated
otherwise.
I.
INFORMATION WE PROCESS AND HOW WE DO
THE PROCESSING
Depending
on the circumstances described below, we may collect and process the following
categories of personal information:
|
|
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 about 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:
●
We do not collect audio or video
information from you.
●
We do not have access to or process
your image or face data made or edited with the App.
●
We cannot collect, store, or use data
from your camera roll or photo library.
●
Any visual data (such as images,
photos, and portraits) edited with the App is stored locally on your device
and/or in your iCloud storage and is inaccessible to us. Only you can share
files by exporting them through the App.
●
If you upload photos for editing using the App,
the photos are sent to our server for processing and sent back directly to the
App on your device. We do not store your photos or any visual data after that
processing.
However,
if you use the “AI Styles” feature
available in our App for editing your photos, such photos will be sent to the
servers that we use for processing the photos.
The list of the
servers that we use for processing the photos is available in Section IV of
this Privacy Policy (IV. HOW WE SHARE YOUR INFORMATION).
Be
aware that a third-party service provider Google LLC is used to provide you with the “AI Styles” feature in our App.
Using
“AI Styles” allows you to generate personalized pictures (avatars)
from your photos.
How does it work?
Additionally,
we do not collect any special categories of personal data (e.g.,
details about your race, ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership, health,
genetic, and biometric data). We also do not collect information about criminal
convictions and offenses.
Furthermore,
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. It handles your personal information securely.
This information is processed as part of the performance of the contract
between you and us. You can access the applicable in-app purchase rules and
policies directly from the App Store.
We
collect the following categories of personal information from the following
sources:
1.1.
Information You Provide to us Directly
Following
the principle of data minimization, our App does not require you to set up an
account. You do not need to provide any information to access the App (e.g.,
full name, username, social media usernames, phone numbers, email addresses).
However,
if you contact us via email or support form (e.g., to inquire about the App or
request support), we may collect and use the contact information you provide
(name, email address, and message contents). This is necessary for us to
respond effectively, fulfill your requests, and provide the requested services
as part of the performance of the contract between you and us.
We
process visual data from photos you submit to us via the App when you use the
“AI Styles” feature. This processing is necessary to perform the
contract between you and us. Please note that we engage a third-party
service provider Google LLC - for the purpose of processing and creation of
AI-generated content. Please check Section IV
to learn more about the privacy policy and
practices of Google LLC.
1.2.
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 grounds 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.
When
you use the App, some information about your mobile device and user behavior is
processed automatically. This information is generally non-personal, i.e., it
does not, on its own, permit direct association with any specific individual,
and is accessed in aggregated form only. We process this data based on our legitimate
interest in improving the App and enhancing user experience. Without
accessing this data, we may not be able to provide all App features.
We
use third-party automatic data processing technologies (advertising or
analytics tools) to analyze information sent by your device via our App. Some
tools may process your personal data, including profiling, to analyze or
predict your personal preferences, interests, behavior, location, or movements.
Processing starts automatically when you launch the App.
The
types of information collected by automated means include:
●
Device Details. Type
of mobile device, operating system and version, model and manufacturer, screen
size, screen density, orientation, battery and device memory usage.
●
Internet Connection Details.
Mobile carrier, network provider, network type, Internet Protocol (“IP”)
address, session timestamps and duration, speed, browser.
●
Location-related Information. IP
address, the country code/region/state/city associated with your SIM card or
device, language setting, time zone, and neighboring commercial points of
interest.
●
Other Device Identifiers.
E.g., user identifiers like Identify for Advertisers (IDFA) if set up by the
App’s developer).
●
App Information. App
name, API key (identifier for the App), version, and properties for automated
processing and analysis.
●
Cookies and Similar Technologies. Cookies,
pixels, web beacons, and scripts may be used. Cookies are text files downloaded
to your device when accessing the App and sent back to the server each time you
use the App. This helps us operate the App more effectively, understand usage
patterns, improve marketing efforts, and provide content and features of
interest to you. Advertisers or partners may use cookies or similar
technologies to serve ads or services in the App.
●
Log File Information. Log
file information is automatically reported each time you access the App,
including the time and date you start and stop using the App, and your
interactions with the App.
●
Ad-Related Information. Date
and time an ad is served, records if an ad was clicked or shown as a
conversation event, ad offer details, ad type (text, image, video), ad
placement, and user response to the ad.
●
In-App Events.
Analytics tools automatically record in-app information when you use the App
(tutorial steps, payments, in-app purchases, custom events).
Information
provided automatically to advertising or analytics tools is generally not under
our control. We cannot be responsible for processing such information. Some
services may profile personal data and obtain information related to your
personality or device using technologies beyond our scope. We do not control,
supervise, or guarantee how third parties process your personal data. Any
information requests regarding your personal information should be directed to
such third parties (see Section IV).
II.
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:
(i)
To provide and improve the App. We
use the information you provide directly and the information processed
automatically to deliver, maintain, improve, test, and monitor the
effectiveness of our App. This helps us understand user behavior and trends,
detect potential outages and technical issues, support existing functions, and
add new features and services.
(ii)
To
provide interest-based (behavioral) advertising. We may use information processed
automatically for marketing purposes to show ads that may interest you based on
your preferences. This includes personalized content and information, such as
online ads or other marketing forms.
(iii)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 messages. Similarly, we use your contact information to respond
to you when you contact us.
(iv) To prevent fraud and enforce the law. We aim to keep our App free of spam and
fraudulent content. We may use your information to prevent, detect, and
investigate fraud, security breaches, and illegal activities, protect our
trademarks, and enforce our Terms of Use.
If new purposes for processing your
personal data arise, we will notify you by updating this Privacy Policy.
III.
YOUR
PRIVACY RIGHTS
If you are a resident of the European
Economic Area (EEA) or the UK, or California, specific rights to access, edit,
and delete your information apply. These rights can be found in Subsections 3.1
(EEA and the UK) and 3.2 (California) of this Privacy Policy respectively.
For those not residing in the EEA, UK, or
California, you may still request to access, correct, or delete certain
personal information. Verification of identity and residency may be required
before processing these requests. Contact us at [email protected]
for such requests. Note that changes or deletions may impact the App’s features
and functionality.
3.1.
Information
for Residents of the EEA and the UK
If you reside in the EEA or the UK,
applicable privacy laws (in particular EU-GDPR and UK-GDPR respectively) grant
you specific rights concerning your personal data:
●
Data
Access and Portability. You
can request copies of your personal information.
●
Change
or Correct Data. You have the right to
request corrections or updates to your personal data.
●
Data
Retention and Deletion. You
have the right to request deletion of all or some of the personal data.
●
Restriction
of Processing. Under certain
circumstances, you may have the right to limit how your personal information is
used.
●
Lodge a complaint. You
can file a complaint with a supervisory authority if your privacy rights are
violated.
To exercise these rights, contact us
through the [contact form]. Please note that these rights apply to
information we physically access and store. You may also object to automated
data processing for direct marketing by contacting the recipients listed in
Section IV.
For privacy inquiries in the EEA, contact
us at [email protected].
For privacy inquiries in the UK, contact
our regional representative at [email protected].
3.2.
Information
for Residents of California
The California Consumer Privacy Act of
2018 (CCPA) provides California residents with specific rights regarding their
personal information:
● Right to Know. You have the right to request
information about the personal data we collect, sources, purposes, third-party
sharing, and specific data collected in the past 12 months.
●
Right
to Delete. You have the right to
request deletion of personal information, subject to CCPA exceptions.
●
Right
to Opt-Out (“Do Not Sell”). You
have the right to request that we stop sharing your personal information with a
third party in exchange for something of value. As noted herein, we do not sell
your personal information.
● Right to Non-Discrimination. You are entitled to exercise the rights
described in this Section free from discrimination. We will not discriminate
against you because you exercise your CCPA rights.
●
Right
to Correct. You have the right
to request correction of personal information.
●
Right
to Limit. You have the right
to request that we only use your sensitive personal information (for example,
your social security number, financial account information, your precise
geolocation data, or your genetic data) for limited purposes, such as providing
you with the services you requested.
How to Exercise Your California Privacy
Rights. To exercise these
rights, contact us via the [contact form] or email [email protected].
Verification of identity and residency is required for these requests.
Authorized agents may also submit requests on behalf of consumers. Please
include the wording “Consumer rights to maintain confidentiality in the state
of California” in the text of your request.
We will respond to verified consumer
requests within 45 days, with possible extensions as needed.
IV.
HOW WE SHARE YOUR INFORMATION
We share your information with third
parties only as described in this Privacy Policy.
We do not rent or sell your personal data
to any third parties.
We may share your information (such as
log files, device identifiers, and location data) with third-party
organizations that provide automatic data processing technologies for the App.
We do not control these third parties’ tracking technologies or how they may be
used.
We may share certain information, such as
cookie data, with third-party advertising partners. This allows ad networks to
deliver targeted advertisements that they believe will be of most interest to
you.
While we choose third-party service
providers who apply necessary technical and organizational measures to protect
personal data, we cannot guarantee the security of any information transmitted
to such entities. We are not responsible for any accidental loss or unauthorized
access to your personal data through the fault of these entities. These
entities are separately responsible for their privacy policies and practices.
Categories of Recipients. The following third-party providers and
advertising partners may be engaged by us to process your information for
various business purposes (inter alia, to provide us with the necessary
infrastructure for the delivery and improvement of our App, and to perform
App-related services):
|
Recipient |
Type |
Location |
Recipient’s Privacy Policy |
|
Akenes
SA (Exoscale) |
Cloud Storage Service Provider |
Switzerland |
|
|
Amplitude Inc. |
Analytics Service Provider |
USA |
|
|
Apple Inc. |
Cloud Storage Service Provider |
USA |
|
|
Appodeal Inc. |
Analytics and Ad Management Service Provider |
USA |
|
|
AppsFlyer LTD |
Analytics Service Provider |
Israel |
|
|
Cloudflare,
Inc. |
Cloud Storage Service Provider |
USA |
|
|
DigitalOcean LLC |
Cloud Storage Service Provider |
USA |
|
|
Google Cloud EMEA Limited |
Cloud Storage Service Provider |
Ireland |
|
|
Google LLC |
Analytics and AI-generated Content
Service Provider |
USA |
|
|
Hetzner
Online GmbH |
Cloud Storage Service Provider |
Germany |
|
|
Meta Platforms, Inc. (Facebook Inc.) |
Analytics Service Provider |
USA |
|
|
Microsoft Corp. |
Analytics Service Provider |
USA |
|
|
OneSignal Inc. |
Mobile push notification solutions Provider |
USA |
|
|
Qonversion Inc. |
Analytics Service Provider |
USA |
All third-party service providers and
advertising partners engaged in processing user data use such information based
on an agreement and according to the stated business purposes. For more
information about these services and their privacy options, including opt-out
options, consult their websites and privacy policies. We are not responsible
for any misuse of your personal data by these third parties in violation of our
instructions.
The App may include links to third-party
websites, services, plug-ins, and applications, e.g., allowing users to share
content on social media platforms or access the App from third-party sites.
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
their privacy practices or content. We encourage you to read the privacy notice
of every website, service, plug-in, or application you use.
Disclosure for legal and other reasons. In addition, we may disclose your
personal information:
● As required by law;
● When we believe in good faith that
disclosure is necessary to protect our rights, 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 our 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.
V.
INTERNATIONAL
DATA TRANSFERS
We operate globally and provide our App
to users worldwide. We, along with our data processing partners and third-party
advertising partners, may transfer your data across borders, from your country
to other countries or jurisdictions around the world.
Please note that these transfers may
include personal data to countries that may not offer the same level of data
protection as your home country. We strive to ensure that any recipient of
personal data provides adequate protection, complying with current data
protection legislation. By using the App, you consent to the transfer of your
personal data to any third country or international organization.
For data storage, we use hosting services
and encrypt your personal data, if possible, before transferring it for
storage. We collaborate only with hosting organizations that have passed our
security and reliability checks.
VI.
DATA
RETENTION
We retain your personal information as
long as necessary to provide the App’s services and comply with legal
obligations. If you no longer want us to use or store your data, you can
request its deletion.
However, some data may still be retained
for a specific period to comply with legal obligations (such as taxation,
accounting, or audit) or to ensure safety, data backup, prevent fraud, or other
malicious acts.
VII.
SECURITY
We prioritize the security of your
personal information and follow industry standards to protect it during
transmission and once received.
We take reasonable and appropriate
measures to protect personal information from loss, misuse, unauthorized
access, disclosure, alteration, and destruction. These measures include
implementing technical and organizational safeguards and using strong
encryption algorithms, including hashing where possible.
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.
While we strive to protect your data, no
method of transmission over the Internet or electronic storage is completely
secure. We cannot guarantee absolute security, but we will promptly notify you
of any data breach as required by law.
If you have any questions about our App's
security, please contact us via the email provided below.
VIII.
CHILDREN’S
PRIVACY
Our App and its services are not intended
for children. We do not knowingly collect personal information from children.
No one under the age of 18 (or older if required by applicable law) may use the
App.
If we discover that we have collected
personal information from a child, we will delete it promptly. If you believe
we might have information from or about a child, please contact us immediately.
Opt-out of Marketing Tracking
● For iOS: Go to Settings > Privacy >
Advertising and enable "Limit Ad Tracking" (https://support.apple.com/en-us/HT202074).
● For general options: Visit https://youradchoices.com. Please note that we have no control
over this website and any options it provides.
Please note that 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
● For iOS: Go to Settings > Privacy >
Location Services, select the App, and set "Share My Location" to
"Never" (https://support.apple.com/en-us/HT203033).
To stop receiving push notifications,
adjust your settings on your mobile device. Uninstalling the App will stop all
information collection except for some information concerning you that may
still be stored as described in Section VI above.
X.
CHANGES
TO THE PRIVACY POLICY
We recognize that information privacy is
an ongoing responsibility. Therefore, we will update this Privacy Policy as
needed. Changes will be posted on this Privacy Policy and other relevant
places. Additional notifications may be provided as appropriate.
XI.
HOW
TO CONTACT US
For questions about this Privacy Policy,
contact us via the [contact form] or email [email protected].
Copyright © 2026 IRONTECH LIMITED