Privacy policy
1. General
This Privacy Statement explains how Fractal Works (Pty) Ltd (“we” or “us”) collects, stores, uses, transfers, and shares Personal Data from our users (“you”) in connec on with the Keepsakes mobile iOS applica on (“the App”).
2. What Personal Data do we collect?
In order to use the App and to provide you with the Services as defined in our Terms and Condi ons we process the following categories of personal data:
2.1 In order for you to use the App and create and purchase your personalised photobook, we need to process the following categories of Personal Data:
– Images and Albums stored on your iOS device to create your photo book
– Your contact informa on (name, address, zip code, phone number, email) to ship your photo book to your shipping address
– Your payment informa on (payment data and/or credit card) to process the payment and conclude the sale
2.2 In order for you to use the App and create and purchase your personalised photobook and/or any photo products, we need to process the following categories of Personal Data:
– Your contact informa on (name, address, postal code, phone number, email) to ship your order to your shipping address
– Your payment informa on (payment data and/or credit card) to process the payment and conclude the sale
2.3 We may collect aggregated data when you are using our App and this can be:
– Frequency of use of the App
– Geographic informa on of App
– Usage pa erns of the App
3. How we use your Personal Data
Keepsakes will not collect or use your personal data without informing you. So, for any purpose of processing your personal data, we need to have some valid ground or so-called “legal basis”.
Depending on the case, we will process your personal data based on the following legal bases:
3.1 Your contractual rela onship with us. We process your personal data related to your user account and to support you in compiling and producing a photobook based on the images stored on your device and deliver the photobook to you. We also process your personal data related to payments made to us.
3.2 Legi mate Interest. We may process some of your personal data to pursue commercial interests, such as to inform you on offers similar to the photobook you have purchased via email or push no fica ons. Should you not wish to receive these types of emails, you can unsubscribe by clicking the unsubscribe bu on in any email or contact us directly. You can also opt out of receiving push no fica ons via the se ng on your iOS device.
3.3 Keepsakes also processes personal data in an aggregated form provided via third-party SDK’s (soware development kits), such as Google Analy cs/Firebase and Appsflyer. An SDK is part of the source code of the App and the Website. The SDK is used to analyse how the App are used and provide us sta s cal insights in the data and insights into the business performance of the App. For example, sta s cal informa on about crashes of the App, a ributes, and events of certain groups of individuals, and demographic informa on. Thanks to IP address anonymisa on, the data collected by these SDKs cannot be traced back to individual users.
4. Securing your data
4.1 It is of great importance to us to protect your personal data. Therefore, we take precau ons which include, but are not limited to the following: the personal data we receive from you is located on a secured server behind a firewall, and we u lize other physical, electronic, and procedural safeguards to protect the security and confiden ality of the informa on we have collected and to prevent unauthorised access to or disclosure of your informa on.
4.2 It is important for you to know that the compila on of your photobook when using the App takes place locally on your iOS device. Only in the case where you choose to purchase your personalised photobook by clicking the purchase bu on in the App, the images are transmi ed from your device to our secured servers via an encrypted communica on channel.
5. Data retention
Keepsakes will retain copies of your personal data in a form that allows for iden fica on only for as long as:
5.1 (i) It is required by law. For example, we are obligated to retain certain personal data regarding our customers under South African tax law, such as orders, invoices, and payment data for a period of five years;
5.2 (ii) We maintain an ongoing rela onship with you. For example, where you are included in our mailing list and have not unsubscribed. We retain your data for 1 year a er the rela onship has ended or immediately when you have requested the dele on of your data;
5.3 (iii) Your personal Data is necessary in connec on with the purposes set out in this privacy statement and we have a valid legal basis.
6. Third par es & Keepsakes
To provide Keepsakes’ product, personal data might be disclosed to a number of recipients. The following recipients could receive your personal data:
6.1 Third par es to provide us insights in the business performance of the App.
6.2 Third par es that support us with sending push no fica ons to your device and emails : Customer.io and Sendgrid.
6.3 Third par es that support us with our marke ng and remarke ng efforts : Criteo, Google AdSense and Facebook Remarke ng.
6.4 Third par es that support us with accessing to third-party accounts : Facebook account access and Stripe account access.
6.5 Heat mapping and session recording : Hotjar Heats Maps & Recordings.
6.6 Content commen ng : Facebook Comments.
6.7 Commercial affilia on : ShareAsale and ReferralCandy.
6.8 Reviews publishing : Trustpilot.
6.9 Tag Management : Google Tag Manager.
6.10 Transferring the images from your device to a storage and processing loca on: Filestack.
6.11 Storage and processing: Amazon AWS.
6.12 Third par es to facilitate payments: Payfast
6.13 Soware for customer support: Zendesk.
6.14 Prin ng partners and connected prin ng facili es.
6.15 Third par es to facilitate delivery: PAXI
7. Storage and interna onal data transfers
We may transfer your personal informa on to par es outside the European Economic Area under certain circumstances. In that event, we will take suitable measures with these par es, for example by agreeing to the standard contractual clauses adopted by the European Commission.
8. Your rights as a data subject
Under the GDPR, you have various rights to request from Keepsakes:
8.1 You have the right to access and receive a copy of your personal data, and other supplementary informa on.
8.2 You have the right to rec fica on of inaccurate personal data concerning you.
8.3 Under certain circumstances, you have the right to have your personal data erased.
8.4 Under certain circumstances, you have the right to request the restric on of the processing.
8.5 You have the right to receive your personal data which you have provided to us from Keepsakes in a structured, commonly used, and machine-readable format.
8.6 Under certain circumstances you can object to the processing of your personal data.
9. How to exercise your privacy rights?
9.1 Contact us at info@keepsakesbooks.com to exercise any of your privacy rights. We will ensure to get back to you in 30 days. Due to the complexity of some cases, this can take us 90 days. We will ensure to inform you about this as well.
9.2 If you have a concern about our privacy prac ces, including the way we handled your personal data, you can report this to the data protec on authority in your country of residence.
9.3 If we change the way we handle your personal data, we will update this statement. We reserve the right to make changes to our prac ces and this statement at any me, please check back frequently to see any updates or changes to our statement.
9.4 Effec ve date of this privacy statement: 01 November 2024.