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Es un ejemplo.de política de privacidad en diversos iiomas
Tipo: Ejercicios
Subido el 02/12/2023
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Lightricks プライバシーポリシー LIGHTRICKS 개인정보처리방침
November 22 , 2023 Lightricks Ltd., including our subsidiaries and affiliates (collectively, “ Lightricks ”, “ we ”, “ our ” or “ us ”), puts great efforts in making sure that the personal data we process is stored securely and used properly, and that our data processing practices are accurately communicated to our users and prospective users. Lightricks is a pioneer in innovative technology that bridges the gap between imagination and creation. Lightricks’ photo and video editing tools offer endless possibilities and inspiration, providing individuals, content creators, or influencers the ability to monetize their work and offer brands opportunities to scale their content through tailored creator partnerships. Lightricks is a global company, offering these services, apps and technology worldwide. This Privacy Policy (“ Policy ” or " Privacy Policy ") describes how we collect, store, use and disclose information while using any of the services, technologies and apps detailed herein. We tried to detail these processes in a simple and friendly manner, however, as Lightricks offers various mobile and web- apps (each an “ App ”), features and feeds (“ Lightricks Feed ”), and an online marketplace (“ Popular Pays Marketplace ”) connecting brands and agencies (“ Brand(s) ”) and individuals, content creators, influencers (“ Creator(s) ”), all of which process your information differently, we encourage you to read carefully and reach out to us if you have any further questions. This Policy is applicable to (collectively and separately, referred to as " you " or “ your ”): (i) prospects and visitors browsing our websites, landing pages, engaging with ads and campaigns promoting our services, blogs or other web-forms (“ Prospect ” or “ Visitor ”); (ii) users installing and using our Apps; (iii) Brands and Creators using the Popular Pays Marketplace; and (iv) any individuals using our services. You are not required, at any time, to provide us with personal data or personal information. POLICY TOPICS:
1. UPDATES AND AMENDMENTS .............................................................................................................. 3 2. CONTACT INFORMATION AND ROLES .................................................................................................. 3 3. TYPE OF DATA SETS PROCESSED ........................................................................................................... 4 4. PURPOSE, LAWFUL BASIS, AND PROCESSING OPERATIONS ............................................................... 4 TABLE A: APPS ............................................................................................................................................ 4 TABLE B: AI MACHINE LEARNING AND INTERNAL DEVELOPMENT ......................................................... 10 TABLE C: POPULAR PAYS MARKETPLACE ................................................................................................. 11 TABLE D: PROSPECTS AND INDIVIDUALS INTERACTION WITH OUR WEBSITE, ADS OR DIGITAL ASSETS 14 5. HOW WE COLLECT YOUR INFORMATION ........................................................................................... 16 6. COOKIES AND SIMILAR TECHNOLOGIES ............................................................................................. 16 7. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH ......................... 17 8. USER RIGHTS ........................................................................................................................................ 18 9. DATA RETENTION ................................................................................................................................ 19 10. SECURITY MEASURES .......................................................................................................................... 19
DPR Contact Information : dpr@lightricks.com By Mail: Lightricks GmbH, c/o Mazars Tax GmbH, Theodor Stern Kai 1, 60596 Frankfurt am Main, Germany.
iOS users, creating an account is optional). You may choose to login using your Apple, Facebook or Google account or otherwise by entering your email address and choosing a password. If you login through Facebook, Google or Apple, we will receive information connected to such account (depending on the privacy settings you chose) such as your name, profile picture, friends list, demographic data, and location. have signed in, we will be able to identify you across those various Apps and share the information processed in each of the Apps. We will further send you invoices, materials and content, including marketing materials, through the email address you provided during your registration (“ Direct Marketing ”). Processing for Direct Marketing is subject to our legitimate interest, you may opt-out at any time by unsubscribing. Note, even if you unsubscribe certain operational emails will still be sent. Online Identifiers and Usage Data: When you use the Apps, we, or our third-party partners, identify you through Online Identifiers. “ Online Identifiers ” are unique identifiers, including IDFA or AAID, IP address, device ID, cookie ID, agent, etc. We further process, directly or indirectly through our third-party partners, usage data, which may or may not be associated with the Online Identifiers. When associated with an Online Identifier it will be treated as Personal Data, otherwise, if the usage data is aggregated, anonymized or de-identified, it will not be considered as Personal Data. The usage data includes information regarding your interaction with the App, features used, duration of use, click stream data, errors that occurred, as well as your interaction with the content or ads displayed, records of advertising and content displayed on pages or App screens Online Identifiers and Usage Data are used for analytics and operational purposes, correcting errors and bugs, adjust language preference, if applicable, to enable you to use the app and to provide you with its functionalities. Some of the Apps further display interest-based ads or other marketing and promotions which are based on the Usage Data. When the processing is for marketing or tracking, we will process the Personal Data solely based on consent. When the processing of Personal Data is for operations and providing the App functionalities, the lawful basis would be contract necessity. Last, the Personal Data maybe processed subject to our legitimate interest of understanding how our services are used, correcting errors and enhancing experience, including by personalizing offers and promotions.
magical avatars (“ Avatars ”), motions and effects, art styles, text to image, and synthetic voice speech (collectively “ Outputs ”). To make these features work, we process the original images, videos, or audio recordings that you upload (“ Inputs ”) on the Lightricks Cloud.
To provide the voice Output, our AI technology will use the audio recording you upload to create a voice sample and generate a model of the voice appearing in the audio record you upload (“ Voice Model ”), and may process non-user Personal Data as further described in the section below. Voice Models are not used to identify you or anyone else. However, Voice Models may be deemed “biometric identifiers” according to applicable laws of you jurisdiction, and including Illinois and Texas.
Party Platforms: Our AI technology may be further accessible through third party platforms, by using our bots, tags, etc. (“ Third Party Platforms ”), which enable you to generate and receive the Outputs within such Third-Party Platforms. Please your voluntarily choose to provide us, such as the color tone that most accurately reflects your skin.
retention: The Inputs are deleted within 24 hours, except in the following cases: Where the Input is provided for creating the Avatar, it will be deleted immediately once the Avatar is created; Voice Inputs are stored for up to 30 days as of their upload and Voice Models are stored for a period of up to 3 years after your last use of them and then deleted automatically (all, unless you have requested their deletion earlier), in order to make such voice Inputs and Voice Models accessible to you through the App.
note that, and information that you upload to, or obtain through, Third Party Platforms (even where using our pages and bots), shall be further subject to such Third Party Platforms’ terms and policies that apply to you as their user and we do not have control nor responsibility in this regard. the Inputs and Outputs will be uploaded to the Lightricks Cloud and stored for a period of 30 days. Non-user Personal Data: You may only provide Inputs that include non-user Personal Data of others if you are authorized to consent (or otherwise acknowledge or approve, as applicable) and have consented to the terms of this Privacy Policy on their behalf. Where we are able to determine that you have shared non-user Personal Data with us, such as the images or videos that you submit in connection with our “couples’ avatars” feature, we will use the images or videos to generate the avatar, or other Output and delete the Inputs permanently from the Lightricks Cloud. In addition, you may invite friends to use our Apps. By doing that you will be requested to share the contact details of your friend(s) (such as email address or phone number). We process the photo or audio recording solely for the purpose of providing the Services, we will not have any other use of the original photo or audio recording. We will process your friend contact details only for the purpose of sending them an invite to use the Services, we will not use this data for any other purpose. Legitimate interest in providing the Services to our User. Support: When you contact us for customer support, we will process your contact information. We will use the contact information to provide the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided. We process such information to provide the support services and fulfill the contractual obligations. Survey and Feedback: We may ask you to provide feedback on our services. If you We use this information to improve, revise and enhance our We process such information subject to your consent. You may withdraw your consent at any time by contacting us
We use third-party analytics service providers such as Google Analytics, Google’s Crashlytics and Firebase services, and Facebook. We may disclose your information to these analytics providers to help us learn more about how you and others use our services: AppsFlyer SDK Nimble SDK AppLovin SDK Facebook iOS SDK Firebase iOS SDK Google signing iOS SDK Survey-Monkey iOS SDK TikTok SDK Braze SDK Full Story SDK Pendo.io correcting errors and bugs, adjust language preference, if applicable, to enable you to use the app and to provide you with its functionalities. these SDKs subject to our legitimate interest. TABLE B: AI MACHINE LEARNING AND INTERNAL DEVELOPMENT DATA SET PURPOSE AND OPERATIONS LAWFUL BASIS
and others). The Input cannot be linked to you, identified with you, or used to identify. We will not use the Input in whole but rather we will process certain copies extracted from the Input. We will not be able to, and we do not aim to, authenticate or uniquely identify you, or any other person, using these models. In addition, we automatically label certain images detected in your Input such as “dog”, “cat”, and male or female to improve the performance of the AI features, such as text-to-image and Avatar creation and for purposes of labeling data for use in machine learning. Note that labeled data is not tied to any identified individual. learning and are deleted within 180 days. Please note that we do our best to moderate the setting of the AI model to not include any inappropriate or harmful content, however, it is your sole responsibility to upload images, videos, and other content that is not unlawful, libelous, defamatory, obscene, pornographic, indecent, lewd, suggestive, harassing, threatening, invasive of privacy or publicity rights, abusive, inflammatory, fraudulent, or can be otherwise interpreted as harmful content. Please contact us at dpo@lightricks.com if you find any content to be offensive. The use of the AI technologies is subject to the AI Terms as well, available at: https://static.lightricks.com/legal/ai-terms-of-use.pdf#page18. TABLE C: POPULAR PAYS MARKETPLACE DATA SET PURPOSE AND OPERATIONS LAWFUL BASIS Registration: When the Brans signs up on Popular Pays Marketplace it shall fill in the contact information of the authorized users (name, phone number, email address, website, etc.). We use this information to create an account, provide account management, enable your interaction with the Creators, perform the marketing campaigns, provide support and any requested Services. Processing is necessary for the performance of a contract.
and actions conducted on the Popular Pays Marketplace. Customer Support: When you contact us for customer support, we will process your contact information, and, where applicable, our call records. We will use the contact information to provide the customer support needed. We will retain the correspondence with you, and where applicable the call records, for as long as needed, and to evidence the support was provided, offers being made or agreed, etc. We process such information to provide the support services and fulfill the contractual obligations. Call records will be processed subject to your consent which will be obtained at the beginning of our conversation. Direct Marketing: We will send you service communications and marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable. We will use this information to keep you updated with offers and content and for operations (invoices, offers, etc.). We process such information subject to our legitimate interest. You can opt-out at any time through the “ unsubscribe ” link within the email at any time. Campaigns: As a Brand, we provide services that enable you to deliver relevant content to end users, by targeting specific audience. The targeted campaign will be directed to potential customers who appear to have the same or similar interests as the Brand’s existing customers, based on the segments we collect and analyze (“ Insights ”). We use such Insights for targeting campaigns on behalf of the Brand, as part of the services provided through the Marketplace. We process this on behalf of the Brand as a Processor (as such terms is defined under the GDPR) and subject to the Brand’s instructions. Booking a Demo: In the event you choose to book a free demo, you will be requested to provide us with your full name, phone number, and company email address. We will use this to provide you with the information or services that you have requested. We process such information subject to our legitimate interest. Purchase Details: Certain features and Services are subject to payment, either We use this information to process your payments. Contract Necessity
IAP or subscription payments by third party payment services; however, we process the commercial transaction data such as, records of purchases and prices; shipping details (if applicable); address, contact telephone number and email address. We may use third parties’ services and platforms to process the Payment Data, such as Adyen, Stripe, Braintre, and Paypal, or through IAP in which Google Play or Apple Store would govern such payments Consequently, any transactions are processed by the third parties’ platforms will be governed by its own privacy policy and terms, which we recommend that you review. TABLE D: PROSPECTS AND INDIVIDUALS INTERACTION WITH OUR WEBSITE, ADS OR DIGITAL ASSETS DATA SET PURPOSE AND OPERATIONS LAWFUL BASIS Online Identifiers and Usage Data: When you interact with our website, we, directly or indirectly collect Online Identifiers and Usage Data (i.e., access time and date, movement within the website, click stream, duration, referred URLs, content viewed, etc.). We process this information to improve the website, identify errors and bugs as well as for statistic, analytic and marketing purposes. The Personal Data collected for operating the website, through first party cookies are based on our legitimate interest of enable the operation of the website and services. Depending on your jurisdiction, third-party cookies will be able to process Personal Data solely if you provided consent through the cookie notice and the consent management tool that is used on the website. You may withdraw consent at any time by using the cookie preference settings. Advertising: When we market the services, we use third party providers or tools to manage these ad campaigns. Through these tools, we collect information such as the individuals’ journey, when they clicked our ad and if they installed, subscribed or engaged with such campaign or app. To perform, facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Subject to your consent through in-app permission or cookie banner, as applicable.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website, Apps, Web-Services and the Popular Pays Marketplace, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.
5. HOW WE COLLECT YOUR INFORMATION Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: ● Automatically, when you visit our website or interact with our services, including through the use of Cookies (as detailed below) and similar tracking technologies. ● When you voluntarily choose to provide us with information, such as when you contact us or request a demo, all as detailed in this Policy. ● By our third parties service providers which collect personal data on our behalf, such as analytics service providers. 6. COOKIES AND SIMILAR TECHNOLOGIES We may use cookies, tracking pixels (also known as clear GIFs and web beacons), third party software development kits (SDKs) as detailed in Table A above, and other technologies in order to maintain, provide, and improve our website, online platform and its services or our Apps. We use Cookies for various purposes : - Preferences: this type of cookie helps us to secure and maintain our services, and remembers your preferences so you don’t have to re-set them each time you visit. - Statistics Cookies: these tools are used for analytic purposes, to better understand the use of the services, Apps and websites. - Registration Cookies: When you register and sign in, we generate cookies that let us know whether you are signed in or not. - Marketing Cookies: These cookies allow us to know whether or not you’ve seen an ad or a type of ad, how you interacted with such an ad, and how long it has been since you’ve seen it. We also use cookies to help us with targeted advertising. We may partner with ad networks and other ad serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of our website and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising. For more information on the cookies used please see our Cookie Policy.
We share your data with third parties, including our partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients. CATEGORY OF RECIPIENT
Essential Service Providers, which process data on our behalf, for the purpose of providing the services, securing and improving the services. All data except for data which is stored locally on your device. We may disclose Personal Data to our trusted service providers that provide technology or platforms that are essential for providing the Services (“ Essential Service Providers ”). Such Essential Service Providers include hosting, and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platforms, data and cyber security services, fraud detection services, billing and payment processing services, shipping and handling services, session or activity recording services, support and customer relation management systems. Essential Service Providers have access, or process on our behalf. The Essential Service Providers are prohibited from using your personal information for any purposes other than providing us with requested services. Marketing Service Providers Behavior data, Usage Data, Online Identifiers, Account Data, and profiling data. Our marketing service providers, that either process on our behalf certain data which we use to target you and offer you our Services, or they provide us with tools to do so (“ Marketing Service Providers ”). Consultants Account and registration data, contact information, and any other data except for data which is stored locally on your device. Our legal, financial and compliance advisors (“ Consultants ”) may be exposed to certain Personal Data. The Consultants are bound by privilege obligations or confidentiality agreements and are prohibited to share any Personal Data except for providing the services we requested. Third-party platforms Registration data, Creations, and Popular Pays Marketplace activity. Our services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit, store or otherwise use with such websites and third-party services, are beyond the scope of Lightricks’ terms of use and Privacy Policy and will therefore be governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. Moreover, if the Services integrate with a third-party service, the API that performs the integration will enable the relevant third party to serve you certain content as well as access some of your content. For example, if you wish to upload or otherwise
Depending on your relationship with us, your jurisdiction and the data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed. For detailed information on your rights and how to exercise your rights, please see the Data Subject Request Form (“ DSR ”) form available here and send it to our DPO: dpo@lightricks.com. Further, certain rights are available within the App: you may correct, revise and delete information from the App settings at any time, any consent provided may be easily withdrawn, and you may opt-out from certain features and tracking, therefore we recommend you use the technical solutions we have provided you with to exercise your rights.
9. DATA RETENTION In general, unless a different retention period is described above , we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, when permissible by law or regulation, or until you express your preference to opt-out, where applicable. Other circumstances in which we may retain your Personal Data for longer periods of time when permissible by law or regulation include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at: dpo@lightricks.com. 10.SECURITY MEASURES We implement appropriate and industry-standard technical, organizational, and security measures to reduce the risks of damage to (or loss of) information, or any unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your Personal Data, it is not guaranteed, and you cannot expect that the services will be immune to information security risks or attacks. Also, as the security of information depends in part on the security of the computer, device or network you use to communicate with us, the security of your Personal Data depends on you as well. Please make sure to take appropriate measures to use secured networks, devices and to protect your access credentials. Please contact us at : dpo@lightricks.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data. 11.INTERNATIONAL DATA TRANSFER Our data servers in which we host and store the information are located globally including in the US and EU. The headquarters are based in Israel where we may access the information stored on local servers, cloud-hosting servers or other systems and platforms used. In the event that we need to transfer your
Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area (" EEA "), United Kingdoms or Swiss, is transferred outside of such jurisdiction, to a country that has not received an adequacy decision from the European Commission or the ICO, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the EU, UK or Swiss Standard Contractual Clauses. Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections that regulators have pre- approved to ensure your data is protected. 12.ELIGIBILITY AND CHILDREN PRIVACY The services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law), and we do not knowingly process children's information. We will discard any information we receive from a user that is considered a "child" immediately upon discovering that such a user shared information with us. Please contact us at: dpo@lightricks.com if you have reason to believe that a child has shared any information with us. 13.SPECIFICATIONS i. Additional Notice to California Residents: This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“ CCPA ”) effective November 2020, and as amended by the CPRA, effective January 1, 2023. Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident. ii. Additional Notice to Colorado Residents: Under the Colorado Privacy Act (“ CPA ”) if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below. “ Personal Data ” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data. “Sensitive Data” includes (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely
