IMPRESSIONS PRIVACY POLICY

Synthesized Media, Inc ( "Impressions" or "we" or "us" or "our") respects the privacy of our users ("user" or "you"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Impressions (the "Impressions Service", the "Service") which includes our mobile application (the "Application") and our website located at https://www.impressions.app (the "Site"). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE IMPRESSIONS SERVICE .

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Impressions Service after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments or the browser which you utilize to access the Site, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect via the Impressions Service depends on the content and materials you use, and includes:

Personal Data

Demographic and other personally identifiable information (such as email address) that you voluntarily give to us when choosing to participate in activities related to the Application, such as sending feedback, opening support tickets, or signing up for monthly newsletters.

Face Data

When you record and upload a video, the Application transfers it to our cloud servers to extract relevant facial frames, to process the data, and to create an enhanced video result. Once the result has been generated, we delete all facial frames and store only the original video and the video result on our servers.

Derivative Data

Information our servers automatically collect when you access the Service, such as your native actions that are integral to the Service, including navigation, content creation, or other interactions with the Service via server log files.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s camera and microphone and access to your device storage. If you wish to change our access or permissions, you may do so in your device’s settings. If you choose to refuse, disable, or delete mobile device access, some of the functionality of the Application may no longer be available to you.

Browser and Mobile Device Data

It is standard for your Web browser to automatically send information to every website you visit, including ours. Such information includes your computer's Internet Protocol ("IP") address, access times, browser type and language, and referring website addresses.

When using the Application, device information such as your mobile device ID number, model, and manufacturer, version of your operating system, and any other data you choose to provide is also shared. We combine information about devices you use to access Impressions Service and information about your usage and activity on the Site and the Application.

Media Content

We obtain media you provide via your camera, microphone, or media library (if you have granted us permission to access your camera, microphone, or media library). We obtain only the specific media you chose to upload and modify using the Application; we do not collect your albums even if you grant us your access to them.

Media Content

We obtain media you provide via your camera, microphone, or media library (if you have granted us permission to access your camera, microphone, or media library). We obtain only the specific media you chose to upload and modify using the Application; we do not collect your albums even if you grant us your access to them.

Push Notifications

We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings and/or the Application settings.

Data From Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.

We may use non-media information collected about you via the Service to:

  1. Compile anonymous statistical data and analysis for use internally.
  2. Create and manage your account.
  3. Email you regarding your account.
  4. Process your requests and transactions.
  5. Generate a personal profile about you to make future visits to the Service more personalized.
  6. Increase the efficiency and operation of the Service.
  7. Monitor and analyze usage and trends to improve your experience with the Impressions Service.
  8. Notify you of updates to the Impressions Service.
  9. Offer new products, services, mobile applications, and/or recommendations to you.
  10. Perform other business activities as needed.
  11. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  12. Request feedback and contact you about your use of the Service.
  13. Resolve disputes and troubleshoot problems.
  14. Respond to product and customer service requests.
  15. Assist law enforcement and respond to subpoena.
  16. To perform and analyze the effectiveness of marketing activities;
  17. Send you a newsletter.

Any Media Content which you voluntarily disclose for posting to the Service, becomes available to other Impressions users and to the public. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied, shared or saved that information.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

Third-Party Service Providers

We do not disclose user contributions and media to third parties (with the exception of uploading to our cloud providers Google Cloud Platform and Amazon Web Services to provide the editing features of the Application).

We may share your non-media information with third parties that perform services for us or on our behalf, including data analysis, email delivery, notification delivery, & hosting services.

We do not sell or disclose any personal information to other businesses or a third party for monetary or other valuable consideration.

Face Data

Face data is not used for any other purpose outside of the creation of an enhanced video result. No face data is shared with any third party for monetary or other valuable consideration.

Sale or Bankruptcy

Your information and other data collected by us may be transferred to another company that has acquired our stock or assets, for example, as a result of a sale, merger, reorganization, dissolution or liquidation.

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies as outlined in our Terms of Use, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection.

Third-Party Disclosure

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies & Other Tracking Technologies

We may use cookies, tracking pixels, and other tracking technologies on the Service to help customize the Service and improve your experience. When you access the Service, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Service.

Analytics

We may also partner with selected third-party vendors, such as Amplitude, Google Analytics, Facebook Analytics, and Crashlytics to allow tracking technologies on the Service through the use of first and third-party cookies and other tracking methods, to, among other things, analyze and track users’ use of the Service, determine the popularity of certain content, and better understand online activity.

STORAGE OF INFORMATION & TRANSFER OF DATA

If you are using the Impressions Service from a country other than the country in which our servers are located the various communications will necessarily result in the transfer of information across international boundaries.

Uploaded data is transferred to our third-party cloud servers for processing and storage. Our servers are located in the United States. The data is hosted by Google and Amazon, but neither hosting provider is given access to the data.

DATA RETENTION & DELETION

Facial frames extracted from uploaded videos are deleted from our servers once a video result has been generated. Original videos and the video results are stored on our servers until deleted. The user may request the deletion of a video through the application. When a video is deleted, all relevant video and related data are removed from our servers.

The retention period of other collected information depends on the type of information and the reasons why we collect it. Your account information is retained while your account is active, unless you request us to delete it or remove your account.

You can request us to delete all videos and other account information via the "Request Data Removal" button in the Application settings. When you request us to delete your information, some information, such as your anonymized mobile device ID, which we believe in good faith is necessary, may still be retained for a reasonable time to enhance your experience in case you decide to return and for legal and regulatory compliance, business matters, and improvement of our Services.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

OPTIONS REGARDING YOUR INFORMATION

We respect your right to control and make choices about your information. You may request Impressions to:

Your request can be made via the Application or, in some instances by emailing us at legal@impressions.app.

We believe that you proceed to use our Impressions Services upon accepting all the terms in our Terms and Conditions of Use, which incorporate also the terms of this Privacy Policy. And as such we have your consent in processing and using your data as defined above. However, you are also free to choose to withdraw your consent and request us to cease processing your information by sending us a notice. In such case your withdrawal will not affect the legitimacy of prior processed data.

You may also opt out of receiving promotional communications from us, including, but not limited to, promotional emails via the Application settings. Transactional service communications (such as messages about your account) are not subject to the foregoing opt-out procedures, as are necessary for the regular conduct of our business records.

Requests to delete your account, information and media can be made via the Application settings.

CHILDREN UNDER 13

THE IMPRESSIONS SERVICE IS NOT MEANT FOR PEOPLE UNDER 13. We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities and interests. We do not knowingly collect information from children under the age of 13 and we do not target the Impressions Service to children under 13. If we receive a valid notice through legal@impressions.app that a minor under age of 13 has provided us with personal information, we will take measures to delete it as soon as possible.

CALIFORNIA CONSUMER PRIVACY COMPLIANCE RIGHTS

Impressions places the utmost importance on privacy and not only complies with the California Consumer Privacy Act (referred to in this Privacy Policy as "CCPA") as set forth by the State of California, but also adheres to these privacy rules as a standard for all of our users. In accordance with the CCPA this Privacy Policy provides you with information regarding how to receive information about our privacy practices, as well as request access to, and deletion of your personal information.

Impressions does not sell the personal information collected. We only disclose your personal information as described in this Privacy Policy. For detailed information about the personal information we have collected over the last 12 months, and the categories of sources of such information, please see the "COLLECTION OF YOUR INFORMATION". We collect this information for business purposes set forth in the "USE OF YOUR INFORMATION". We share this information with the categories of third parties as set forth in the "DISCLOSURE OF YOUR INFORMATION" Our users, whether a resident and non-resident of California, may make a request pursuant to their rights under the CCPA by contacting legal@impressions.app. Upon receiving a request, we will verify your request using the information associated with the Impressions Services, including your email address. Government identification may be required. Consumer can also designate an authorized agent to exercise these rights on the consumer’s behalf.

EEA ADDENDUM

Controller: Synthesized Media, Inc. is the controller of the personal data that we have about you and can be reached through email at legal@impressions.app.

You may request us to take the following actions:

Access: Request information about our processing of your data and gain access to it.

Rectify: Update or correct your personal data.

Remove: Delete your data.

Transfer: Export a copy of your personal data for transfer to a different service.

Restrict: Limit the processing of your personal data.

Object: Object to our use of legitimate interests as the legal basis of processing your data if that processing adversely impacts your rights.

If you request one of these actions, we may ask for additional information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Legal bases for processing:

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described below.

For app operation and improvement: You have entered a contract with us and we need to use some of your personal data to provide services you have requested or take steps that you request prior to providing services. If you do not provide information indicated as required or mandatory within our service, or that is otherwise necessary to provide a requested service or feature within the service, it will not be available to you.

Compliance with law: We may have to process or share your personal data to comply with legal obligations, such as to comply with a subpoena or legal process.

Legitimate interests: We process your personal data for purposes that constitute our legitimate interests, such as fraud prevention and safety; protecting our, your or others’ property rights; exercising or defending legal claims; investigating violations of and enforcing our Terms of Use; analyzing and improving our services; and marketing activities.

Consent: In some cases, we may process your personal data based on your consent, such as where we request access to camera, microphone and photo library on your mobile device through the prompts in your device’s operating system. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.

Updates: Privacy laws are undergoing significant changes in Europe and we may need to further update our Privacy Policy as laws take effect and regulators provide additional guidance. While we will always notify you of any material updates, we encourage you to revisit our Privacy Policy from time to keep current with any changes.

Feedback: If you have any questions or concerns, please contact us. In addition, you can always submit a complaint to your data protection regulator. You can find your data protection regulator here.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at: legal@impressions.app

Last updated June 1, 2020