Privacy Policy

Privacy Policy

I. INTRODUCTION

HeadSnap ("we," "us" or "our") takes your privacy seriously. This Privacy Policy explains our data protection policy and describes the types of information we may process when you install and/or use the HeadSnap software application for mobile devices (the "App").

When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. A natural person can be identified directly or indirectly, especially by reference to an identification number or one or more factors specific to their physical, physiological, mental, economic, cultural, or social status.

Our Privacy Policy applies to all users and others who access the App ("Users"). For the purposes of the GDPR, we are the data controller unless otherwise stated.

Please read the following Privacy Policy carefully to understand how your personal information may be processed when you use the App. By using the App, you acknowledge that you have read, understood, and agree to be bound by these terms.

If you are a California resident, please read the following important notice. Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request:

• The categories of personal information that are processed.

• The categories of sources from which personal information is obtained.

• The purpose for processing user personal data.

• The categories of third parties with whom we may share your personal information.

• The specific pieces of personal information that we might have obtained about a particular user, provided that the data given in the request is reliable enough and allows us to identify the user.

I. PERSONAL INFORMATION

All about the categories of information, its sources, and purposes of processing. Please note that according to CCPA, personal information does not include de-identified or aggregated consumer information.

II. SHARING

How your information can be shared. Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of an agreement and pursuant to a business purpose.

III. OPT-OUT OPTIONS

If you don’t want us to process your personal information anymore, please contact us through the contact us section of the app. In most cases, there is no way to maintain the App’s further operation without functional data; therefore, you will be advised to remove the App from your device.

If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described below.

IV. REQUESTS

To submit a verifiable consumer request for access, portability, or deletion of personal data, please contact us through the contact us section of the app. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California.” When submitting a verifiable request, you should be ready to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, zip code, and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third-party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scam request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete it after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

V. EQUAL RIGHTS

Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different levels or quality of services for you if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.

VI. SALE OF DATA

We do not sell any of your personal data to third parties.

VII. INFORMATION WE PROCESS

There are several categories of information that can be processed.

Functional Information We process the following personal information about you when you use the App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it is impossible to provide complete functionality of the App and perform the requested services. What data can be processed:

• Content Information, i.e., photos, pictures, and other data - when you upload or create them using the App.

• Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form. We collect, store, and process it by our cloud storage provider (Amazon.com, Inc.). We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request.

Information That Is Processed Automatically When you use the App, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e., it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the grounds of our legitimate interest in improving our App and giving our users the best experience. If we do not access such data, we may not be able to provide you with all the features of the App.

We use third-party automatic data processing technologies to analyze certain information sent by your device via our App (advertising or analytics tools). Some of them launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location, or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first launch the App.

• Device Details

  • When you use a mobile device (tablet / phone / smartwatch) to access our App, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

• What data can be processed:

  • Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume, and battery, device memory usage.

  • Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp, and duration of sessions, speed, browser.

  • Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”).

  • Device identifiers: Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices, user identifiers (if they are set up by the App’s developer).

  • Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analyzes. Some services also record the list of applications and/or processes that are installed or run on your device.

  • Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.

  • Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including the time and date when you start and stop using the App and how you interact with the App.

  • Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.

  • In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Information provided automatically to advertising or analytics tools does not generally come under our control; therefore, we cannot be responsible for processing such information. Please note that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. In case when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise, or stand surety for how the third parties process your personal data, that might be collected by their own means (not through our App). Any information request regarding the disclosure of your personal information should be directed to such third parties.

VIII. PAYMENT INFORMATION

Our e-commerce provider (Apple / Google) is responsible for billing, processing, and charging for the in-app purchases, handles your personal information, and keeps it absolutely safe and secure. We cannot access or use your credit or debit card information. You may access the applicable “in-app” purchase rules and policies directly from the app stores.

IX. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

(a) To make our service available. We use the functional information and information that is processed automatically to provide you with all requested services. (b) To improve, test, and monitor the effectiveness of our App. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App. (c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing. (d) To communicate with you. We use the information we have to communicate with you through newsletters, i.e., to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us. (e) To prevent fraud and spam, to enforce the law. We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use.

If any new purposes for processing your personal data arise, we will let you know we start to process information for that other purpose by introducing the corresponding changes to this Privacy Policy.

X. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy Policy:

• With your consent. We may share or disclose your information at your direction.

• With our service providers. We engage service providers that support our business, such as processing payments, fulfilling orders, and providing analytics services. These providers have access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

• For legal reasons. We may disclose your information if it is required by law, subpoena, or other legal process, or if we believe it is necessary to enforce our terms, policies, or rights, to protect our operations or users, or to comply with a legal request.

XI. FACE DATA

We do not retain any face data collected through the use of our App. All face data is processed in real-time and is not stored or retained after the immediate purpose is fulfilled.

XII. CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at berk.ceylan18@gmail.com.

XIII. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. We will provide notice of any material changes to this Privacy Policy by updating the “Effective Date” at the top of this document. Your continued use of the App after any changes to this Privacy Policy will signify your acceptance of the changes.