Privacy

Last updated August 29, 2018

Andor Communications Private Limited ("we" or "us" or "our") respects the privacy of our users ("user" or "you"). Thank you for choosing to be part of our community, we are very delighted that you have shown interest in our app, Photoleaf mobile application (the "Service").Data protection is of a particularly high priority for the management of the Andor Communications Private Limited. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "Application"). Please read this Privacy Policy carefully.

Andor Communications Pvt. Ltd has built the Photoleaf mobile application.The use of the Photoleaf application is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our app, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, device id, advertiser id or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Andor Communications Private Limited. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Andor Communications Private Limited has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this application. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by email.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

This privacy policy applies to all information collected through our mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites"/ "Apps" interchangeably).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. Definitions

The data protection declaration of the Andor Communications Private Limited is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

• a) Personal data
  Personal data means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• b) Data subject
  Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
• c) Processing
  Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• d) Restriction of processing
  Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
• e) Profiling
  Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• f) Pseudonymisation
  Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
• g) Controller or controller responsible for the processing
  Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
• h) Processor
  Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• i) Recipient
  Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
• j) Third party
  Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
• k) Consent
  Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Andor Communications Private Limited

19/103, East End Apartment, Mayur Vihar Phase1

110091 Delhi

India

Phone: +91-9810265170

Email: support@photoleaf.app

Website: www.photoleaf.app

4. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

5. Rights of the data subject

• a) Right of confirmation
  Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
  
• b) Right of access
  Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
• Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
  If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
  
• c) Right to rectification
  Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
  
• d) Right to erasure (Right to be forgotten)
  Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
• If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Andor Communications Private Limited, he or she may, at any time, contact any employee of the controller. An employee of Andor Communications Private Limited shall promptly ensure that the erasure request is complied with immediately.
  Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Andor Communications Private Limited will arrange the necessary measures in individual cases.
  
• e) Right of restriction of processing
  Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
• If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Andor Communications Private Limited, he or she may at any time contact any employee of the controller. The employee of the Andor Communications Private Limited will arrange the restriction of the processing.
  
• f) Right to data portability
  Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
  In order to assert the right to data portability, the data subject may at any time contact any employee of the Andor Communications Private Limited.
  
• g) Right to object
  Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
  The Andor Communications Private Limited shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
  If the Andor Communications Private Limited processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Andor Communications Private Limited to the processing for direct marketing purposes, the Andor Communications Private Limited will no longer process the personal data for these purposes.
  In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Andor Communications Private Limited for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  In order to exercise the right to object, the data subject may contact any employee of the Andor Communications Private Limited. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
  
• h) Automated individual decision-making, including profiling
  Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
  If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Andor Communications Private Limited shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
  If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Andor Communications Private Limited.
  
• i) Right to withdraw data protection consent
  Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
  If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Andor Communications Private Limited.
  

6. Data protection provisions about the application and use of Facebook Audience Network

In Photoleaf application, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

Audience Network is a network of publisher-owned apps and sites where you can show your ads.

People spend a lot of their time on Facebook and Instagram. But they are also spending time on other apps and sites. Audience Network helps advertisers reach more of the people they care about in the other places where they're spending their time.

In a Facebook ad campaign study, conversion rates were 8x higher among people who saw ads across Facebook, Instagram and Audience Network than people who only saw the ads on Facebook.

Audience Network ads use the same targeting, auction, delivery and measurement systems as Facebook ads.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our application by the data subject€"and for the entire duration of their stay on our Internet application, which specific screens of our app was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

7. Data protection provisions about the application and use of Google Analytics (with anonymization function)

In Photoleaf application, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing In Photoleaf applications from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on In Photoleaf application. Google uses the collected data and information, inter alia, to evaluate the use of In Photoleaf application and to provide online reports, which show the activities on In Photoleaf applications, and to provide other services concerning the use of In Photoleaf application for us.

First-party Cookies

Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites and/or apps that use Google Analytics. Customers may customize cookies and the data collected with features like cookie settings, User-ID, Data Import, and Measurement Protocol. Learn more

Google Analytics customers who have for instance, enabled the analytics.js or gtag.js collection method can control whether or not they use cookies to store a pseudonymous or random client identifier. If the customer decides to set a cookie, the information stored in the local first-party cookie is reduced to a random identifier (e.g., 12345.67890).

For customers who use the Google Analytics for Apps SDK, we collect an App Instance Identifier, which is a number that is randomly generated when the user installs an app for the first time.

Advertising identifiers

Where customers use Google Analytics Advertising Features, Google advertising cookies are collected and used to enable features like Remarketing on the Google Display Network. These features are subject to the users' Ads Settings, the Policy requirements for Google Analytics Advertising Features and Google's EU User Consent policy, which requires customers to obtain consent for cookies where legally required—including consent for personalized ads. For more information about how Google uses advertising cookies, visit the Google Advertising Privacy FAQ. It is possible to implement Google Analytics without affecting normal data collection where Advertising features are disabled until consent is obtained.

IP Address

Google Analytics uses IP addresses to derive the geolocation of a visitor, and to protect the service and provide security to our customers. Customers may apply IP masking so that Google Analytics uses only a portion of an IP address collected, rather than the entire address. In addition, customers can override IPs at will using our IP Override feature.Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

8. Data protection provisions about the application and use of FireBase

In Photoleaf application, the controller has integrated the FireBase as a component. Firebase is platform which allow to build web and mobile applications without server side programming language. You can store users data on its real-time database which sync data among users data in no time.

The operating company of Firebase is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Firebase SDK has been integrated, the app on the information technology system of the data subject automatically downloads a display of the corresponding Firebase SDK of Google through the respective component. During the course of this technical procedure, Google is made aware of what specific sub-page of In Photoleaf application was visited by the data subject. More detailed information about Firebase is available under https://firebase.google.com/support/privacy/

If the data subject is logged in at the same time to FireBase, Google recognizes with each call-up to In Photoleaf application by the data subject and for the entire duration of his or her stay on Photoleaf application, which specific sub-pages of our app screen were visited by the data subject. This information is collected through the FireBase SDK.

Further information and the data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

9. Data protection provisions about the application and use of Crashlytics

On this application, the controller has integrated components of Crashlytics by Google. Crashlytics, a business division of Google Inc., (herein referred to as "Crashlytics") offers a suite of services to provide mobile application developers with information about the functioning of publicly released and beta versions of their mobile applications. The Crashlytics Privacy Policy ("Privacy Policy") governs the Crashlytics crash reporting and beta testing solution and www.crashlytics.com as well as our other websites (collectively, the "Services"). Effective November 20, 2015. https://try.crashlytics.com/terms/privacy-policy.pdf

The operating company of Crashlytics by Google is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

Crashlytics services automatically collect certain information that does not personally identify End Users who access or use mobile applications that use the Services. This information includes, but is not limited to, device state information, unique device identifiers, device hardware and OS information, information relating to how an application functions, and the physical location of a device at the time of a crash.

Further information and the applicable data protection provisions of Crashlytics may be retrieved under DoubleClick by Google https://www.google.com/intl/en/policies/.

10. Data protection provisions about the application and use of YouTube

In Photoleaf application, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of In Photoleaf application was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of In Photoleaf application was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited In Photoleaf application, if the data subject at the time of the call to In Photoleaf application is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to In Photoleaf application is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

11. Data protection provisions about the application and use of Google Admob

On this app, the controller has integrated components of Admob by Google. Admob is a trademark of Google, under which predominantly special online marketing solutions are marketed to advertising agencies and publishers.

The operating company of Admob by Google is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

• AdMob's privacy policy is available at www.google.com/intl/en/policies/privacy<

AdMob by Google helps us monetize your mobile app through in-app advertising. Ads can be displayed as banner ads, interstitial ads, video ads, or native ads—which are seamlessly added to platform native UI components. On Android, you can additionally display in-app purchase ads, which allow users to purchase advertised products from within your app.

AdMob uses the Google Mobile Ads SDK. The Google Mobile Ads SDK helps app developers gain insights about their users, drive more in-app purchases, and maximize ad revenue. In order to do so, the default integration of the Mobile Ads SDK collects information such as device information, publisher-provided location information, and general in-app purchase information such as item purchase price and currency.

Further information and the applicable data protection provisions of DoubleClick may be retrieved under DoubleClick by Google https://www.google.com/intl/en/policies/.

12. Legal basis for the processing>

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

13. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

15. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

16. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

Link to third party applications

Photoleaf provides option to share edited images using third party social applications such as Facebook, Google+, Twitter etc. Such applications are governed by their respective privacy policies, which are beyond our control. Once you share your image using these applications, use of any information provided by you is governed by the privacy policy of these Application. If you can't find the privacy policy of any of these sites via a link from the Application's homepage, you should contact the Application directly for more information.

General information about data collection and user rights>

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.

We collect personal information that you voluntarily provide to us when registering at the Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps.

We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Information collected through our Apps

In Short: We may collect information regarding your mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, photos, album, contacts, social media accounts, storage, sensors, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
• To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
• To send administrative information to you for Business Purposes, Legal Reasons and/or possibly for Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• Administer prize draws and competitions for our Business Purposes and/or with your Consent. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
• Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Apps.
• To enable user-to-user communications with your Consent. We may use your information in order to enable user-to-user communications with each user's consent.
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps, products, services, marketing and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• With your Consent. We may disclose your personal information for any other purpose with your consent.
• Offer Wall. Our Apps may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.

4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Google+ logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable social logins.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Apps. You should review the policies of such third parties and contact them directly to respond to your questions.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right

Your Choices

• Access, Update, Correct or Delete Your Information. All account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at privacy@Photoleaf.app to accomplish the foregoing or if you have additional requests or questions.
• Email communications. You may opt out of newsletters and marketing-related emails by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at privacy@Photoleaf.app. You may continue to receive service-related and other non-marketing emails.
• Withdrawing consent. If you gave us consent to use your personal information, but wish to update or delete it, please contact us at privacy@Photoleaf.app.
• Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, 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 the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
  
  If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
• If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account.
  Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.
  
  Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
• Access your account settings and update preferences.
• Note your preferences when you register an account with the site.

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

10. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Prashant Kumar, by email at prashant.kumar@andor.mobi. If you have any further questions or comments about us or our policies, email us at privacy@Photoleaf.app.

PERSONAL DATA MANAGEMENT

According to the Privacy Policy, you agree to share your personal data with our service. However you still have the right to update, transfer or delete it from us. Users / data subjects can update, modify their information within app on their profile page. Data subject can delete account from settings within app.