Privacy Policy

Welcome to CTMT APP!

CTMT APP is an offline-based face swap application that allows you to generate a unique content.

Here at CTMT

APP we are committed to protecting and respecting your privacy. We take your

privacy seriously and will use your personal information to provide the

Services only after obtaining your consent to the collection and processing of

your personal data on the terms specified below.

This

information about you, how we use the information, the conditions under which

we may disclose it to others, your rights in respect of your personal

information, as well as how we keep it secure.

This

(“Terms”) and applies to all visitors, users, and others who access the

Services.

Information we collect

We collect

from you the following data:

Information you provide us directly. When you use our Services, we collect the

information that you provide us directly:

Photos. We

may collect the photos, that you upload from your mobile device while using our

application. Please note, you won’t be able to upload content from your camera

roll unless we can access your device’s camera.

Facial

features. We may collect the facial feature data separately from your photos

only to provide you with the face-swapping functionality of CTMT APP. Please

note, we collect the facial feature data that is not biometric data.

b. Usage

data. When you use our Services, we may collect information about your activity

within our Services, for example, which pages you have viewed and for how long.

We also may collect IP-addresses, the source of the traffic, information

regarding the device and operation system, information about your wireless and

mobile network connections, unique device identifiers, browser type, language,

battery level, and time zone.

We collect

usage data with the help of Google Analytics. With the use of Google Analytics,

we collect such data as IP-Address, your device model, screen resolution and

operation system, session durations, your location. Basing on these data, we

analyze your needs and interests, evaluate effectiveness of our campaigns and

improve our Website to make its content relevant to you and the Website itself

available for smooth viewing with your device.

c. Cookies

and similar technologies. Like most online services and mobile applications, we

may use cookies — tiny pieces of code that remain in your device after you have

visited any websites and online services. When you use that website or

application for the next time, these pieces enable their owners to provide you

with information customized for your needs.

We use

cookies for authentication purpose only. When you access the Services or

content, CTMT APP uses session cookies, meaning that if you close the Services,

cookies expire and no longer have any effect. You shall specifically agree to

our use of cookies when you use our Services by clicking the respective button

in the notification.

Please

note that you may block, delete, or disable saving cookies on your device. You

can turn the cookies off by choosing the appropriate settings of your browser.

The following links might be useful for you to choose the best option of your

browser:

For the

users of Chrome For the users of Safari web and iOS.

When you

use the Services, we may also use technologies like pixels, web beacons, and

local storage to collect information about how you use CTMT APP and provide

features to you.

2. How We

Use Information

CTMT APP

does not use your photos and facial features for any reason other than to

provide you with the face-swapping functionality of CTMT APP. In no way will CTMT

APP use your photos and facial features for face recognition, as CTMT APP does

not introduce the face recognition technologies or other technical means for

the processing of biometric data for the unique identification or

authentication of a user.

We may use

the information other than photos or facial features to:

- provide,

improve, test, and monitor the effectiveness of our Services;

- perform

troubleshooting, diagnose or fix technology problems;

- enhance

the safety and security of the Services;

- monitor

and analyze trends and usage;

- develop

and test new features of the Services;

understand your needs and provide services and advertisements that are relevant

to you;

- use the

information we’ve collected from cookies and similar technologies to enhance

our Services and your experience with them.

Uploaded

Content is collected for its display in the library for the user’s repeated use

and convenience of the Services usage. Uploaded Content is stored at the

on-line secured data storage and displayed to you exclusively during your use

of the Services. By submitting this content for the swapping you expressly

agree for its collection and storage as set forth herein. In no way will CTMT

APP use your Uploaded Content for face recognition, as CTMT APP does not

introduce the

face

recognition technologies or other technical means for processing of biometric

data for the unique identification or authentication of a user.

If CTMT

APP decides to change the purposes of processing specified above, we will

inform you on such changes prior to use your personal information within the newly

set purposes and ask for your separate consent if required by the applicable

laws.

3. How We

Share Information

In order

to provide high-quality Services, CTMT APP hires people, may enter the

agreements with independent contractors as well as cooperates with other

services providers, companies and organizations. For those reasons some of your

personal information may be passed to the persons mentioned. First of all, our

employees may have access to your data. Then, we may transfer your data to our sub-contractors

and affiliates.

CTMT APP

uses only secure places of storage, such as Google Cloud. Google LLC is located

in the United States of America and complies with the requirements of the EU-US

Privacy Shield. Here is some information on data protection practices of Google

LLC. So, this well-known software provider ensures your data is processed in

accordance with the strictest data protection standards.

CTMT APP

also integrate in the application the following platforms: - Amplitude –

behavioral analytics platform for product intelligence helping CTMT APP

understand user behavior and build engaging experiences; - Firebase – a

Google's mobile platform, helping CTMT APP develop a high-quality application.

- Sentry – an error monitoring platform helping CTMT APP discover, triage, and

prioritize errors in the application real-time. - AppsFlyer – a mobile

attribution and marketing analytics platform helping CTMT APP market the

application.

CTMT APP

does not control third party platforms, websites or online services, and CTMT

APP is not responsible for their actions. These platforms, websites and online

services follow different rules regarding the collection, use and sharing of

your personal information. CTMT APP encourages you to read the privacy policies

of these platforms, websites and online services to find out more about how

your usage data may be used by these vendors.

Please

note, CTMT APP is managed by Nguyen Trong Dao. Your data may also be accessed

by third-party providers CTMT APP engages in other regions.

If you are

from the EU, it is important for you to know that the transfer of your data to

the recipients in these countries is secured either by the participation of the

contractors from the United States in the Privacy Shield Program or on the

basis of standard contractual clauses adopted by the European Commission and

compliant with the EU data protection laws. By using our Services, you agree to

such transfer and processing within the purposes set herein.

In all

cases we pass the information to other persons, we ensure that your information

is being protected and used only within the purposes specified in Section 2 of

this Privacy Policy. This is achieved by using only certified services and

products, signing agreements on protection of personal data and non-disclosure

agreements with contractors as well as taking technical measures to ensure the

information is protected when stored, used and while being transferred.

You also

have to be aware of the fact that CTMT APP may disclose your personal

information to enforce and comply with the law. In other words, CTMT APP may

disclose to officials the information necessary for the investigation or legal

process on official request or the official bodies acting within their

powers.

4. How We

Store Information

Data

retention. Your data will be stored by CTMT APP no longer than is necessary for

the purposes for which the data are processed. That is why,

- your

photos are stored on the CTMT APP’s server until you finish the editing

session, but not longer than within 24 hours after the finishing of the editing

session. For the rest of the time your photos used in CTMT APP application are

stored locally on your mobile device and may be removed any time by either

deleting these photos from your mobile device’s file system directly or by

deleting CTMT APP application;

- your

facial feature data is stored on the CTMT APP’s server for a limited period of

30 calendar days after your last use of the CTMT APP application;

anonymous, aggregated or de-identified data will be stored as long as necessary

to fulfill the purposes CTMT APP has set out in this Privacy Policy.

Data

security. CTMT APP processes your data using computers and/or other IT enabled

tools. CTMT APP takes technical and organizational measures to ensure the

information is processed in a manner that ensures appropriate security of

information, including protection against unauthorized or unlawful processing

and against accidental loss, destruction or damage. For example, CTMT APP uses

verified contractors that might have access to the data as specified in Section

2 of the Privacy Policy with which the relevant data processing agreements are

signed. We also guide and train our personnel to process your data securely

according to our internal data protection policies.

5. Your

Rights Regarding Information

You have a

right to access to your personal data processed by CTMT APP and right to data

portability

This means

that you can ask CTMT APP what personal data of yours is processed. You can

also ask for the clarifications on the information described above, i.e.

purpose of collecting and processing, period of processing, third parties which

have access to information. You have a right to request from CTMT APP your

personal data in a structured, commonly used and machine-readable format. You

also have the right to transmit those data to another controller, if the

processing is based on your consent or on contract and the processing is

carried out by automated means.

You have a

right to request from CTMT APP to rectify your personal data

This means

you can require all the inaccurate personal data concerning you be ing

corrected. You can also complete the personal data if you feel there is a need

to do so.

You have a

right to request CTMT APP to erase personal data

You can

request CTMT APP to erase personal data if its processing is no longer

necessary to achieve purposes for which it was collected as well as if there

are no legal grounds for the processing. For this purpose, you can contact us.

In most cases, CTMT APP will erase it unless otherwise required by

legislation.

You have a

right to restrict the processing of your personal data by CTMT APP

In some

cases, prescribed by law you will be able to restrict the processing of your

personal data, for example, if you contest the accuracy of your personal data

being processed or in case CTMT APP is not interested in processing of your

personal data any longer, but you want CTMT APP to do this on different

reasons, for example, to bring some claim for somebody and, instead of the

erasure of information, its processing will be just restricted.

You have a

right to withdraw your consent

You can

withdraw your consent for the collection and processing of your personal data

by CTMT APP at any time by contacting us, without affecting the lawfulness of

processing based on consent before its withdrawal. After we at

CTMT APP

receive such withdrawal request from you, we will process it in a timely manner

and we will no longer process your personal data, unless otherwise is set by

law.

You have a

right to object to processing of your personal data by CTMT APP

In some

cases, prescribed by the applicable laws you can object to processing of your

personal data.

You have a

right to object to processing of your personal data when the processing is

related to the performance of our task carried in the public interest or in the

exercise of official authority vested in us; or we process your data to pursue

our or third party’s legitimate interests, and you believe that such interests

are overridden by your interests or fundamental rights and freedoms.

If you

make a request objecting to processing, we will no longer process the personal

data unless we are able to demonstrate compelling legitimate grounds for the

processing.

Please

note that when processing of your personal data is carried for direct marketing

purposes, you have the right to object at any time to such processing without

providing any justification. We will no longer process your data for such

direct marketing purposes. You may refer to relevant sections of this Privacy

Policy to learn whether we process your data for direct marketing purposes.

How to

exercise your rights as to your personal data?

Any

requests to exercise your rights can be directed to CTMT APP through the

contact details provided below. These requests are free of charge.

6. Time

for Reply and Reaction

CTMT APP

will provide information on action taken on your request related to your rights

specified above within one month of receipt of the request for the

longest.

That period may be extended by two further months if CTMT APP is overwhelmed by

the number of requests or the request at issue is complicated and requires a

lot of action. CTMT APP will inform you of any such extension within one month

of receipt of the request, together with the reasons of such delay.

If you

have doubts as to our reply or reaction, or absence of such, you have the right

to lodge a complaint with a supervisory authority that is empowered to process

such complaints in your country.

Children’s Privacy

The

privacy of children is one of our major concerns.

General

age limitation. At CTMT APP we can provide you the Services only in case you

are aged 13 or older and any use or access to the Service by anyone under

thirteen (13) is strictly prohibited and in violation of the Terms and these

Policy. If you are under 18 you will need to get your parent’s/guardian’s

permission before providing any private information to CTMT APP. We reserve the

right to request reasonable proof of such permission, and you must provide such

proof within a reasonable period of time, but no later than in three (3)

business days following such request. Shall we not receive any answer or proofs

concerning your maturity, we r reserve the right to terminate your access to

the Services.

Age

limitation for EU residents. Due to requirements of the EU General Data Protection

Regulation you shall be at least 16 years old in order to use our Services. To

the extent prohibited by applicable law, we do not allow use of the Service by

the EU residents younger than 16 years old, unless with the parent’s/guardian’s

permission as provided above.

If we

unintentionally collect personal data, find any content with, or related to a

child under age 13 (or 16 in the EU), we will delete such information as

quickly as possible. Besides, if you are aware of anyone younger than 13 (or 16

in the EU) using our Services, please contact us.

8. Change

to our Privacy Policy

We may

change this Privacy Policy from time to time if doing so will be deemed

necessary in order to comply with the applicable laws and actual circumstances

of the functioning of the Services, so please periodically check this page to

ensure that you’re satisfied with any changes. Additional notifications on any

amendments will be displayed or otherwise communicated to you when using the

Services after the amendments were made. If within one week after such

notification has been shown to you, you continue to use the Services, you will

be considered as having accepted all the amendments made, unless there is an

obligation imposed on CTMT APP by an applicable law to obtain your explicit

consent to the amendments. This can be a case when, for example, the nature of

your data processing and purposes for processing change.

Contacts

We hope

this Privacy Policy helped you understand how your personal information is

dealt with at CTMT APP. CTMT APP will undertake its best effort to make your

personal data protected. If you have any questions regarding this Privacy

Policy and our Services, please contact us.

CTMT APP

team