Privacy Policy


Valid as of March 1st, 2022


IMPORTANT INFORMATION

Introduction: This Privacy Policy ("Policy") will help you understand how we collect and use personal information if you download and access our Application or make use of any of our services, and what we will and will not do with the information we collect.  We only collect, store, process and share personal information that you consent to, and we obtain your consent when you sign up to our services and ticked the consent box – however, you have the right to change your mind about your consents given at any time. 

Changes: We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

Children and privacy: We do not solicit or target persons under 18 years of age. We do not permit children under the age of 18 to become users and we do not knowingly collect any information relating to children under the age of 18. By submitting information to us you represent that you are over the age of 18.

Contents

This Policy contains the following sections:

  1. About us and our services
  2. Applicable laws
  3. Your rights depending on your country of residence
  4. Information that we collect about you and when
  5. How we use your information
  6. Sharing your information
  7. Marketing
  8. Where we store your data
  9. How long we keep your data for
  10. Security
  11. SDK
  12. Third Party links
  13. Governing law Important contact information
  14. Complaints


1. ABOUT US AND OUR SERVICES

We, High Aspirations Limited, 1ST FLOOR, 9 EXCHANGE PLACE, I.F.S.C.,DUBLIN 1, D01 X8H2, IRELAND, ("us/we/our") are the 'data controller', meaning that we are company that is responsible for the collection, processing and storage of your data when you use our services.

You can opt out at any time by contacting us as described below

We have a number of partners that provide services to us to enable us to provide our services to you. For data protection purposes, these companies are considered data processors subject to data processing agreements with us, and we remain the controller with responsibility for your data.

2. APPLICABLE LAWS

We value our users' privacy, and we comply with all applicable data privacy laws of the jurisdictions in which we operate, including

  1. the General Data Protection Regulation ((EU) 2016/679);
  2. the UK's Data Protection Act 2018;
  3. the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC;
  4. the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended, collectively the “Data Laws”.

The specific law that will apply to you and your data will be determined by the location in which you live: if you live in Europe, the EU GDPR will apply, and if you live in the UK, the UK's Data Protection Act 2018 will apply. Any reference to 'personal data' within this Policy, has the meaning ascribed to it by either of these applicable regulations. If you are a resident of California, USA, the California Consumer Privacy Act may be applicable as explained in this Policy.



3A. YOUR RIGHTS

International Data Laws give users a number of rights which you are free to exercise at any time regarding any personal data that you have provided to us. Some of these are rights required by law, if you reside in UK or EU states, for example, however, others are applicable to all users as we wish to ensure that you have open access to your data, and the ability to amend your consents easily.


(a) Right to access personal data we hold about you

You can request a copy of the personal data that we hold about you and we aim to respond within 14 to 30 days. To obtain a copy of your data, simply email our data protection team at support@edpic.app attaching a photo or scan of your photo ID (passport or driving licence) and a utility bill (to provide proof of your address). We need to make sure you are who you claim to be when requesting copies of data, and once we are satisfied about your identity we will email a copy of your data to you. Your identification documents will be viewed for the purpose of verifying your identity prior to us making any personal data disclosures to you, and the identification documents will not be stored for any period of time longer than this, nor will they be used for any purpose whatsoever other than facilitating your request for access. If you are not a resident of the UK or EU, we reserve the right to charge a small administration fee for provision of this information, if so permitted by the data laws governing your place of residence.


(b) Right to amend/correct the data we hold on you

We want to make sure we have everything right in our database so please simply contact us at to make any amendments to our records by emailing support@edpic.app


(c) Changing your consent and opting out

It's ok to change your mind about what personal data you are allowing us to use and keep and what you don't want us to use or keep. You can amend your settings through your account at any time, or contact support@edpic.app We have to advise you however, that opting out of some personal data processing/storage will result in a loss of functionality of the services and a reduced user experience.


(d) Right to “be forgotten” (Applicable to residents of EU or UK only)

You have the right to have all of your personal data erased when you stop using our services and close your account.  Sometimes we need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations) or for payment processing (to prove to banks that we were authorized to take payments from you if you pay to use the services). There's more about how long we keep data for below at Section 9 of this Policy. To request erasure of all of your personal data please contact Support or support@edpic.app



3B. YOUR RIGHTS IF YOU ARE A RESIDENT OF CALIFORNIA, USA


We act in compliance with the California Consumer Privacy Act (CCPA) and this section applies to you as an individual if you are a resident of California, USA, with references to personal information having the meaning given in that Act. 


We collect the following categories of Personal Information, as defined by the CCPA: Inferences, Identifiers, Commercial Information, Employment Information, all of which is described at Section 4 of this Policy.  This information is collected for the purposes described in Section 5 of this Policy and shared as described in Section 6.


If you reside in California, then under the CCPA you have the following rights:

- You have the right to obtain from us access to the information we hold on you, and you are entitled to know if we have shared that information with any third parties. If you would like to request this information, please submit your request by emailing support@edpic.app. It is important to protect you that we ensure the person making the request is really you and we will contact you to let you know what else we need from you before we send you a copy of your personal information, which currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days. 

- You have the right to ask us to delete all the personal information we hold on you. If you would like to request the deletion of your information, please submit your request by emailing support@edpic.app. It is important to protect you that we ensure the person making the request is really you and we will contact you to let you know what else we need from you before we send you a copy of your personal information, which currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days. 

- Please note that Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information or the security of the business's systems of networks. 

- You have the right to understand how we share your personal information (as described in this Privacy Policy). We do not sell your Personal Information to anyone. 

- You have the right to appoint an authorized agent to submit a request on your behalf if you provide the authorized agent written permission to do so. If you use an authorized agent to submit a request, he or she must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly with us. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent's authority to make the request on your behalf. Written permission is not required if the agent provides proof of power of attorney.



4. WHAT INFORMATION WE COLLECT ABOUT YOU


This section explains the types of data we collect about you, and when it may be collected. Please read this section carefully, together with Sections 5 and 6 which explain how we then use that data.


(a) We collect data when you upload your Content to our App

- We will collect your personal details (which may or may not be considered personal data within the meaning of the Data Laws) including but not limited to email address, date of birth, and any other information you submit when you download our App and sign up to our services; 

- You may choose to upload photographs– see Section 5F below.


(b) We collect data when you communicate with us

- If you contact customer support we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record written correspondence for training and security purposes. 

- If you provide feedback or testimonials to us, or take part in any customer survey, or participate in events, promotions, product launches, or competitions, we will keep any information you provide.


(c) We collect data when you visit or otherwise make use of the services. 

If you're just browsing our App making payments to upgrade your subscription, or doing any other activity within our services we will collect different data as you do it, some of which may be considered personal data:


- Any information you upload to our App at any time, including your photos and all other personal and non-personal information described above; 

- Any messages you send to or receive from us; 

- A record of all of your activity on our App including search histories; 

- Details of any transactions that you carry out, including any information we require to provide the products or services that you sign up or upgrade to, such as financial information that you provide to us or our payment service provider (usually in the form of payment card data) for the purposes of paying for any products, features or services offered by us; 

- Usage data about how you use our App, this is what we consider Anonymous Data, which we collect using SDK (more details below).


Some of these activities are described in a bit more detailed way so please read below about the specifics of some of these data types and how we collect them from you.



5. HOW WE USE YOUR PERSONAL DATA AND INFORMATION


In summary, we process data, including personal data and photographs, that we collect from you for the following legitimate purposes:


- To administer your use of our App (including notifying you of tips, announcements, updates, special offers or services, should you consent to this); 

- To process your activity on the services including making payments; 

- To help us improve the structure, layout and usability of the App; 

- To help personalise your usage of the App; 

- To provide you with information on products or services or news and offers that you request from us; 

- To answer any questions you may raise or respond to any comments you may send to us; 

- To notify you about changes to our service or the functionality of the App; 

- To carry out market analysis and research and to conduct marketing activities; 

- To ensure that you are complying with the terms and conditions of use and to comply with our statutory and regulatory obligations.


The following sections provide more detail on how we use your information, including personal data.



5A. Providing our products and services


We use the information we collect about you: 

  1. to fulfil your requests for our products, programs, and services; 
  2. to respond to your enquiries about our offerings; 
  3. to provide, personalize, and improve our offerings; and 
  4. to offer you other products, programs, or services from us and our affiliates, business partners, and selected third parties that we believe may be of interest to you.


We may also use information that we collect about you to: 

  1. perform research and analysis about your use of, or interest in, our products, services, or content, or products, services, or content offered by others; or 
  2. develop and display content and advertising tailored to your interests on our App and other apps/websites, including providing our advertisements to you when you visit other apps/websites.



5B. Communications


We use information about you to communicate with you, including: 

  1. to notify you when we make changes to our terms; 
  2. to otherwise enforce or exercise any rights in our terms; 
  3. to confirm purchasers you have made through our App; or
  4. to provide you with customer support.



5C. Mobile device data usage


When you access our App on a mobile device, we may use the information collected for any purpose stated in this privacy policy.



5D. Use of non-personal information


We use aggregate information about our users and non-personal information that we collect to improve the design, functionality, and content of our Website and to allow us to personalize your experience with our Website and offerings. We use this information: 

  1. to provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business; 
  2. to analyze usage and performance of our App (including to perform ad tracking and mobile application analytics); and 
  3. for us and our affiliates, business partners, and selected third parties to offer you products, programs, or services.



5E. Safety and security


We may monitor your activity to ensure that you and other users are complying with our terms and conditions, and our privacy policy, and to monitor any suspicious activity on our App. This may include monitoring your photos, content, and other activities you perform on the App.



5F. Important notice about how we use your photographs


When you upload your photographs to use redacting tools available on our App you give us your consent to process your photo, for us to be able to perform services we provide. After you complete edits of the photograph and upload the edited variant to your device a copy of such photograph and its edited version is deleted from our servers, we do not store your photos after the edits are completed.



6A. SHARING YOUR INFORMATION - Legal disclosures


We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties' rights by users or any criminal activity.



6B. Change of ownership of the business


As we continue to develop our business, we might sell or buy assets or ownership. In such transactions, the information we have collected about you will generally be one of the transferred business assets. 

We may share information about you with: 

- A buyer or prospective buyer of our business; 

- Our professional advisers, such as our lawyers, where it is necessary for them to advise; 

- Other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.



6C. Third Party Service Providers


We share your personal information with third party service providers in order to provide our services to you including third parties who assist us with information processing, credit and payment processing, fulfilment of your subscription order, managing and hosting data, conducting consumer research or satisfaction surveys. These disclosures relate to providing our services, improving our services and delivering targeted advertising to you. We do not provide your contact details to third parties for direct marketing by them to you without your express consent. We do not store credit card details nor do we share customer details with any 3rd parties. 

We may require to share your information with third parties service providers to allow us to provide the services to you, as such third parties service providers support us in the context of being service providers, which may include, data hosting, server maintenance, customer support, data analytics, marketing, legal and financial services, payment processing and safety and security services.



6D. Business partners


When you register or make purchases on our App or click-through our advertisements offered on third-party websites or applications, we may share your personal information with the businesses with which we collaborate to offer you the applicable products, services, or any advertisements. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other information to that merchant.



6E. Advertisement servers


On our services, third parties may present or serve advertisements, provide us with data collection, reporting, ad response measurement, and app analytics, as well as assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own SDK files. The use of these technologies by these third parties is subject to their own privacy policies and is not governed by this privacy policy. They may also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit, and other information about you or your device in order to help analyze and serve anonymous targeted advertising on the App and elsewhere.



6F. Aggregated or non-personal information


We may share your non-personal information we collect under any of the above circumstances. We may also share it with other companies and third parties to develop and deliver targeted advertising on our App and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources.



7. MARKETING


(a) When third parties market to you (Our “third party Partner Services”)

If you have consented to receive marketing communications from third parties, your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party's communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.


(b) Opting Out of Marketing

If you change your mind about the marketing consent you have granted to us, you can amend your preferences under the “Settings Apple” section of your device, you should go to Settings -> EdPics -> Switch toggle and not send data.



8. WHERE WE STORE YOUR DATA


The personal data that we collect from you may be transferred to, and stored at, a location which is different to where you ordinarily reside, in particular, if you are a resident of the European Economic Area ('EEA') we may transfer your data outside of the EEA to countries including but not limited to Canada where we host our servers. By submitting your personal data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and we enter into appropriate binding processor agreements with any such parties in compliance with Data Laws.



9. HOW LONG WE KEEP YOUR DATA FOR


Generally speaking, we only store data for as long as it is necessary to provide products and services to you and others, with information typically being held until you cancel your membership. For data storage purposes however our users are considered as either being: 

(a) Active Users; this means you regularly access our services and use the services in any way; 

(b) Inactive Users: this means that you have not deleted our App from your device but you haven't accessed it for 9 months, or conducted any activity on our App in that time; 

(c) Cancelled: this means that you have followed our cancellation process and removed our App from your device.


(a) Active Users

If you are an Active User we will store your data until you cancel your account.


(b) Inactive Users

If you are an Inactive User, you should be aware that we will continue to store your data until you cancel your subscription (if you have one) and remove our App from your Device, including continue to market to you if you have consented to marketing. Just because you haven't logged on for a few months, we hope you will return to use our services regularly and we want your information to be there for your convenience. The responsibility to change your preferences or cancel your subscription and delete our App lies with you.


(c) Cancelled Users

If you are a Cancelled User, we will delete all of your data 9 months after the date of cancellation. It is important that we retain your data for this short period after cancellation to ensure that we can answer any payment or other account related queries, or provide information to third parties in line with our disclosure provisions outlined in this policy e.g. assisting police investigations. Even after you remove information, copies of that information may still be viewable and/or accessed on the Internet to the extent such information has been previously shared with others, or copied or stored by other persons     or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.


(d) Banned and terminated users

If your use of our App is ever terminated by us, or you are detected as a potential or actual scammer, or a potential or otherwise threat to our business or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users.



10. SECURITY

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using Secure Sockets Layer (SSL) software, which encrypts the personal information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Moreover, we cannot assure you that your personal information that we collect will not be used or disclosed inconsistently with this privacy policy. 


We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control. We recommend and encourage you (and all our users) to think carefully about the information they disclose about themselves. If you upload anything that is inconsistent with our terms, we reserve the right to terminate your account.



11. SDK USE


We may collect information about your Device by using SDK. SDK are placed on your Device by our App and provide statistical data to us, that does not identify you personally but tell us a lot about your browsing habits to tailor your user experience to suit your needs. We use SDK to enhance our security, help us gather information during subscription and understand our web traffic trends and to share your non-personal information with carefully selected third parties for marketing purposes. 


They enable us: 

- To estimate our audience size and usage pattern; 

- To store information about your preferences, and so allow us to customise our services according to your individual interests; - To recognise you when you return to our application; 

- To provide anonymised statistical information: Non-personal data may be gathered on our behalf using SDK, log file data, and code that is embedded on our App by specific third party partners to help these selected third parties to deliver relevant advertisements to you. 


We use this information to help improve the services we provide to you.


Controlling and deleting SDK

You have the right to choose whether or not to accept SDK and we explain how you can exercise this right below. However, please note that if you choose to refuse SDK you may not be able to use the full functionality of our App and the websites/apps of other companies. You may block SDK in several ways: 

- by using the opt-outs provided below; 

- by changing settings of your Device. 


In order to do this follow these instructions: enter your device settings, tap on the name of our App “EdPic”, switch togglein order to not send data.


What SDK are used for and why we use them on this App

This scheme shows fully the SDK functions and why they are used, although our uses may change over time and it is important that you revisit this page to understand these uses:


Behavior analytics - We use the information collected by SDK to compile reports and to help us improve the App. The SDK collect information in an anonymous form, including the number of users of the App, Also, these SDK provide the functionality that our users enjoy. We also use SDK to help provide experiences, such as links to other sites, apps, social plugins and video content. In some cases, the App feature you choose may allow a third party to place SDK or local storage devices on your device. The third party who places SDK on your device is responsible for how they process their data you should always read their privacy policies.


Attribution - These SDK helps us to collect information about where visitors have come to the App from.


Performance - We need to use certain SDK to ensure our users have the best possible experience and to understand the number of errors our user may have to fix them in most quick and efficient way possible.



12. LINKS TO OTHER THIRD PARTY WEBSITES

Our App, and promotional materials, may, from time to time, contain links to and from the websites of our third party networks, advertisers and affiliates. If you follow a link to any of these websites/apps, please note that these websites/apps have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites/apps.



13. GOVERNING LAW


The laws of Irish govern this privacy policy and any dispute or claim arising out of or in connection with it or its subject matter (including non-contractual disputes or claims) and parties submit to the exclusive jurisdiction of the courts of Ireland. If a conflict exists between this English language version and any translated copies of the privacy policy, the English version will prevail.



14. IMPORTANT CONTACTS


General contact: 

If you have any questions about this privacy policy, or you wish to exercise any rights hereunder, then please contact our privacy team in the first instance: 

F.A.O. DATA PROTECTION OFFICER - Roderick Wearen - support@edpic.app


In accordance with the applicable UK and EU Data Laws, the following representatives are authorised to receive written communications on our behalf from the relevant supervising authorities and any data subjects exercising their rights under the UK Data Protection Act 2018, or the European General Data Protection Regulation: 


UK Representative (in accordance with the UK Data Protection Act 2018): Laroch Data Management, Technology House (Office 1), 9 Newton Place, Glasgow, G3 7PR. 


EU Representative (in accordance with the EU GDPR): Due to our business being located within the EU we do not require to appoint a representative. Please contact the above Data Protection Officer for all enquiries.



15. COMPLAINTS


We hope that we will be able to resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time to your country's national data protection authority.