1. About This Policy
This policy also provides information based on laws related to the processing of your personal data. Further, this policy sets out the basis by which we will process any personal data that you provide to us or that we obtain from other sources.
For the purpose of data protection law, Generation Transfer, Inc. ("we", "us", and "our") is the data controller with respect to your personal data.
- Our main office address: 108 West 13th Street, Wilmington, DE 19801
- Our email address: firstname.lastname@example.org
In this policy:
4. How We Collect Your Personal Data and What Personal Data We CollectInformation you provide while using the app.
- Your “personal data” means any data which relates to you and from which you can be identified. It may include contact details, other personal information, photographs, and videos.
- “Processing” means any activity or operation that is carried out in respect of your personal data, including collecting, storing, using, transferring, and deleting.
- “App” refers to the family photograph/video-sharing mobile and web applications collectively named “LifeArk”.
- “Child” means any individual under the age of 13 registered as a “child” in the LifeArk app.
This may include your nickname, email address, relation to the child, and payment information (including credit card details and shipping information), as well as the child’s nickname, gender, and birthdate. Other personal data may also be contained in photographs and video clips you upload to the app.
In order to use the app, you are required to provide nicknames for yourself and the child, as well as your relation to the child. Other personal data is not required. Any additional personal data will only be obtained if and when you choose to provide it to us.Information we collect.
This may include your device information (such as operating system/version, hardware model, browser type/version), IP address, LifeArk login information, usage log for the app, device IDs (such as Apple IDFA or Google AAID), and cookies and similar technologies.
This may include:
5. Purpose and Legal Basis of Processing Personal Data
- Information about ad clicks and app installs from marketing platforms
- Purchase information/history from Apple, Google, and other payment platforms for products and services ordered through the app
- LifeArk usage activity from analytics platforms
- Shipping information provided by other app users when ordering DVDs, photobooks, and/or other products and services purchased through the app as a gift
- When uploading to LifeArk via Google Photos: Photos/videos selected for upload and profile information registered to Google Photos (If you choose to use this feature, your name, email address, and profile picture are accessed to display in the app while using the feature. This information is not saved to our servers.)
We use your personal data for the following purposes based on our legitimate interests and/or with your consent:
6. Disclosure of Personal Data to Recipients
- To provide you with our services. Our services include the app, customized content (such as 1s Movies, auto-generated photobooks, DVDs, and other content), payment processing for products and services purchased within the app, and improvements to the app.
- To provide user support. This includes handling inquiries and complaints, troubleshooting and solving technical issues, and making necessary changes to our services.
- For marketing analytics. This includes collecting and analyzing data to research usage of the app.
- To protect against cyberattacks. This includes maintaining the privacy of our users and investigating and deterring unauthorized or illegal activity.
- For marketing. This includes operating promotional campaigns, measuring the performance of these campaigns, and sending information about our services, products, and features. We do not sell your data to any third parties. We also do not share your data to any third parties for advertising purposes.
Your personal data may be shared with the following recipients in the situations described below:
- Authorized employees or affiliates. When necessary, these authorized individuals will access the minimum amount of data required to provide customer support, operate our system and services, or investigate fraud or security issues.
- Manufacturers and service/shipping providers of products/services ordered through the app (including photobooks, DVDs, and other products/services). We provide only the minimum amount of information necessary for them to carry out the specific services listed in our contract with them. Further, the information is only used for the exact purposes specified in the contract and all information is deleted after the required task has been completed.
- Payment service providers. Payments for products/services ordered through the app are processed by secure and trusted payment processors, such as Apple, Google, Stripe, and GMO. We do not store payment information.
- Infrastructure vendors and other service providers. We store all data on servers provided by secure infrastructure services. We also provide data to service providers who support our business, such as by analyzing how our app is used, providing customer service, conducting surveys, measuring promotional campaigns, and/or sending emails and push notifications to users, for the purpose of processing the data described in the above.
- Law enforcement bodies. In response to legal requests, we will share the minimum amount of data necessary with law enforcement bodies.
- Other users invited to your album by you or your partner. The only information accessible by other album members is information that you have provided when using the app.
In order to process personal data as described in “5. Purpose and Legal Basis of Processing Personal Data” above, we retain third-party service providers including but not limited to the following:
- Amazon Web Services, Google Cloud Platform (to store data, provide our service, etc.)
- Google Firebase (for analytics, to send push notifications, etc.)
- Apple In-App Purchase, Google Play Billing, Stripe, GMO-PG (to process payments)
- Zendesk (to provide customer support)
- AppsFlyer (for marketing analytics)
- Facebook, Twitter (for advertising and analytics)
- NewRelic (to monitor our service)
- SendGrid (to send emails)
- SurveyMonkey, Google Forms (to conduct user surveys)
In all cases, we apply strict measures to keep your data safe and your privacy protected. We share your personal data only for the purposes described in “5. Purpose and Legal Basis of Processing Personal Data” above. We do not sell your personal data to any third parties, even in the form of anonymized statistical data.7. Cross-Border Transfer of Personal Data
Whenever we transfer, store, or process your personal data, we take reasonable steps to safeguard the privacy of your data. When using or disclosing personal data transferred from the European Economic Area, we adhere to the standard contractual clauses approved by the European Commission, adopt other means under European Union law to ensure adequate safeguards, or obtain your consent.8. Storage Limit of Personal Data
We retain your personal data for the periods listed below, except when required by law to retain it for a longer period of time. In that case, we retain your data for the period required by law.
- We retain your personal data until we receive a request from you to delete your account.
- Photos and videos deleted from the app are removed from our servers automatically within 30 days.
- Your personal data will be deleted from our servers within 30 days of receiving a request to delete your account.
We utilize cookies and similar technologies within the app in order to collect certain information, including the following:
- Tracking IDs.Tracking IDs are used by various third-party service providers to associate multiple sessions (and any activity within those sessions) with a unique ID. Your device sends this unique ID with related engagement data, allowing third-party service providers to attribute all relevant activities to one user.
- IP addresses.We and our third-party service providers collect IP addresses in services relating to the app.
It is possible to disable cookies and other tracking IDs on your device. To learn more, visit the appropriate link below:10. Your Rights
We acknowledge that you have the right to access and correct your personal data, discontinue our usage of your personal data, and other rights stipulated in each applicable jurisdictional law. You also have the right to lodge a complaint with a data protection authority in the jurisdiction where you reside, where you work, or where the alleged infringement of your rights took place. We will comply with any such request in full accordance with the applicable laws and regulations.11. Required Personal Data
The following personal data is required to use the app:
- For users who are creating an album: Your nickname, the child’s nickname, and your relation to the child
- For users who are invited to an album created by another user: Your nickname and your relation to the child
Please note that you cannot use the app if we cannot obtain the personal data listed above.12. Privacy of Children
We do not knowingly collect or solicit information from anyone under the age of 13 without parental consent. The app is not directed at children under the age of 13 who register themselves without parental consent, and we do not knowingly allow such persons to register. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have obtained any information from a child under 13 without parental consent, please contact us.13. Information for California consumers
Categories of personal information collected, disclosed or sold in this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, internet information and sensorial information.We will not collect additional categories of personal information without notifying you.How do we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose?
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.To find out more about the purposes of processing, please refer to the relevant section of this document.
Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.Your California privacy rights and how to exercise them.
You have the right to request that we disclose to you:the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:for sales, the personal information categories purchased by each category of recipient; andfor disclosures for a business purpose, the personal information categories obtained by each category of recipient.The disclosure described above will be limited to the personal information collected or used over the past 12 months.If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.How to exercise your rights\
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
How and when we are expected to handle your request
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.You can submit a maximum number of 2 requests over a period of 12 months.
Should you have any questions or concerns regarding this Privacy Notice, please do not hesitate to contact us.LifeArk at Generation Transfer, Inc
108 West 13th Street, Wilmington, DE email@example.com