Last updated: 28^th December 2022

Linn Nielsen (“Company Name” “we” or “us”)) operates the AI Avatar mobile application (the “Service”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our term of use. We collect several different types of information for various purposes to provide and improve our Service to you.

Please, read the following carefully and make sure you fully understand this Privacy Policy. If you have any concerns about providing information to us or it being used as described in this Privacy Policy, please, discontinue and avoid using our Services.

1. What Information Do We Collect?

The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways: (a) data you provide to us; (b) data we collect automatically; and (c) data we collect from other sources. We do not knowingly collect (d) special categories of information.

A. When you use the App and select photographs or videos for editing, we cache them for processing to render the requested editing service:

Photographs or videos you select when you use the Apps, via your camera or camera roll (if you have granted the Apps the permission to access your camera or camera roll), or via the in-App internet search functionality. We process only specific photos and videos you choose to modify using the Apps; and we do not collect your photo or video albums even if you grant us access to them. We safeguard each photograph or video that you select using an encryption key stored locally on your device. This means that the only device that can view the photo or video is the device from which the photograph or video was submitted using the Apps – the user’s device. Please note that while we do not require or request any metadata attached to the photographs or videos you select for editing, metadata (including, for example, geotags) may be associated with your photographs or videos by default. We take steps to delete any metadata that may be associated with a photograph or video you provide when you use the Apps. Photographs or videos may remain cached in the cloud for a limited period of 24 hours after your last edit, so that you can return to it and make additional changes if you so choose.

B. Data You Provide To Us

Contact information (such as name and email address)

Your messages to the Services (such as chat logs and player support tickets)

Other data you choose to provide us when you contact us (through the Services, social media, e-mail or any other channels).

Profile information, such as name, social media account information, and profile image

Payment information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment

C. Data We Collect Automatically

Data and analytics about your use of our Services (e.g. your game progress, the date and time you used a Service, session length, features you have used, your in-app purchase history, your interaction with advertisements)

Usage information, we collect information regarding your use of the Services and any other User Content that you generate through or upload to our Services.

Device information, we collect certain information about the device you use to access the Service (such as your IP address, IMEI, advertising ID, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system)

Location data, we collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

Precise geo-location data (GPS, with your consent)

Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services.

Cookies, like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Services may then not function properly.

Note that we do not use such data to learn a person’s true identity or contact details, but mostly to understand how our users typically use and interact with our Services, so that we could maintain and improve them.

D. Data We Collect From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

Third-Party Services. We may collect information about you from third-party services, such as advertising partners, data providers, and analytics providers.

Third-party tools. Data we may receive if you choose to link a third-party tool with the Services (such as Facebook, Google or Apple). Exactly what information we receive from such third-party tool will depend on your privacy settings, but it would typically include your basic profile information such as your user id, username, gender, picture, e-mail, your friends playing the same game. We do not get access to or store your logins or passwords for any of these third-party tools.

Third-party platforms. In-app purchases are typically processed by the platforms (e.g. Apple App Store, Google Play, Amazon AppStore or Facebook). We do not collect or store your financial data, such as your credit card number or bank account. You are requested to provide payment details directly to the relevant platform. We may, however, receive limited non-financial data relating to the purchase (e.g. platforms may notify us if a purchase was successful). Any post-purchase processes are controlled by the platforms. We encourage you to review privacy policies and terms of service of the platforms for further information before making a purchase in the Services.

Advertising partners. From time to time, we may receive non-personal information from our advertising partners concerning the performance of our advertising campaigns (e.g. we may be provided with information from which ad network and advertising campaign the install of our Service originated from or data necessary to fight fraud (such as refund abuse in games or click fraud in advertising).

Other Sources. We may collect information about you from other publicly available sources.

E. No Special Categories Of Information

We do not request or intend to collect any “special categories of information” such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please, be cautious when sharing this information about yourself (or others) in our Services.

2. How We Use Your Data

We use your information to improve, support and administer the Service, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. Each face data in your picture or video will not retained in our app or any other third party partner.

A. To Make Our Services Work

To perform the contract with you, which you enter into when you download or access our Services and accept our Terms of Use, we process data necessary to:

Allow you to use our Services

Facilitate, operate, provide and maintain our Services

Verify and confirm payments in our Services

Provide and deliver in-app products and services you request

Send you Services-related communications

Respond to your comments and questions and provide player support

B. To Make Our Services More Suitable For Our Players

To provide great Services to our players, we process personal data based on our legitimate interest to improve our Services in the following situations:

Develop and improve the Services and player experience

Manage our relationship with you

Provide social features as part of the Services

Customize your Services experience

Provide you our offers in the Services

Send you related information, such as updates, security alerts, and support messages

Enable you to communicate with other players

Show you contextual advertisements in our Services

Cross-promote our Services, meaning to promote one of our games while you are playing a different game of ours

C. To Serve You Advertising

Our games may include advertising for third party products and services. Advertising includes serving you generic non-personalized advertisements and providing you with personalized advertising experience.
Track how our advertising campaigns perform and identify and prevent fraud for our advertising campaigns

We will retain your information for as long as the application is installed on your mobile device or as needed to provide you service. If you remove the application, we will remove your information and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

3. How We Share Your Data

Apart from Linn Nielsen, your data can be accessed by others in the following situations:

A. Other Players And Users

Social features are a core component of our Services. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

B. Service Providers and Business Partners

We share the categories of personal information listed above with service providers and business partners to help us perform business operations and improve our Services, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising.

We share your personal data with these third parties only where we have a legal basis as set out above or where such third parties process data on our behalf based on a data processing agreement.

4. International Transfers Of Data

Our Services are global by nature and your data can therefore be transferred and processed in other countries other than the country in which you are resident. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection for personal data of EU residents or standard contractual clauses approved by EU Commission.

5. Your Rights

You have the right to access your personal data that we hold about you, i.e. the right to require free of charge, including

information whether your personal data is collected, used, disclosed, or sold,
categories of your personal data which has been collected in the preceding 12 months,
categories of sources from which your personal data is collected,
business or commercial purpose for collecting or selling your personal data (if any),
disclosure of sale of your personal data (if any)

You have the right to obtain rectification of your inaccurate personal data;

You have the right to obtain deletion of your personal data where we do not have a compelling reason to continue to process such personal data in certain circumstances;

You have the right to ask to transfer your personal data in accordance with your right to data portability;

You have the right to object to or restrict how we use or process your data in certain circumstances. Please, note in case of such a request we may not be able to provide you with all of our Services or the quality of our Services may be decreased;

You have the right not to be subject to a decision based solely on automated processing, (including profiling), which produces legal effects or could significantly affect you;

You have the right to lodge a complaint with a data protection supervisory body.

Notwithstanding the foregoing, if the applicable laws in your country of residence provide otherwise, the corresponding laws shall govern.

6. Opt-Out Of Personalized Advertising

You can opt-out of personalized advertising on mobile applications by checking the privacy settings of your Android or iOS device.

Apple devices:

For iOS 14 and iOS 15:

Open Settings
Select Privacy
Select Tracking and disable “Allow Apps to Request to Track”

For iOS 13 and older:

Open Settings
Select Privacy
Select Advertising and enable "Limit Ad Tracking"

Please note that opting out does not mean that you will stop seeing advertisements in our Services, rather third-party advertising networks will show you contextual advertisements not tailored to your interests. Please, be aware that such actions may result in decrease of advertising quality and less enjoyable user experience.

7. Security And Storage

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

8. Your Rights And Options

You may ask us to correct inaccurate personal data about you and complete incomplete personal data. If we no longer need to retain this data, you can also ask us to delete your personal data. You also have the right to object to how we use or share your data and restrict how we use or share your data.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please get in touch with your local data protection authority. We will respond to all requests in accordance with applicable laws. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law.

Contact us Data Protection Officer (as shown in the "CONTACT US" section below) in order to permanently delete or anonymize data that we previously collected about you and/or your device.

9. Changes

We may update our Privacy Policy from time to time. When we do, we will revise the date at the top of the policy. If we make changes that are material, we will use reasonable efforts to notify you (such as by placing an in-game notice or a push-notification). We encourage you to check this Privacy Policy regularly for updates, so that you know our current practices.

10. CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, you can contact us through the in-app support feature “Contact Us” or via e-mail at contact@pinsotech.com. However, we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond.