This Privacy Policy has been updated on May 10, 2023

DELTA-AI-DRAW PRIVACY POLICY

WE RESPECT YOUR PRIVACY!

If you have any privacy related concerns, please contact us at: contact@x5.agency
MOREADS oÜ is a company registered in Estonia, with registration number 16627899
and address at this date at Harju maakond, Tallinn, Kristiine linnaosa, Tulika tn 17, 10613
(“Delta-ai-Draw”, “We”, “Us”), who collects, uses and discloses information,
when you access or use mobile app “DELTA-AI-DRAW” available at App Store and Google Play
(the “Application”, “App”, “Delta-ai-Draw”), or our web-resources, such as https://
delta-ai-draw.com (“Web”), make In-App purchases, or when you otherwise interact with us.
This Privacy Policy describes how we collect and use the Personal Data you provide. It
also describes the choices available to you regarding our use of your Personal Data and
how you can access the information. We respect your privacy and we take protecting it
seriously.

Reading Privacy Policy is important so we hope you will give it time and attention.

This Policy applies to the following people:

  • people who use the Application (For the purposes of this policy, we define the term “User”, “you”, "your", "yours" as a person which has concluded the installation of an Application).
  • people who make complaints to us by email. Delta-AI-Draw do not sell your personal data to third parties. A “sale” of Personal data under the CCPAis defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal data of a Consumer to another business or third party “for monetary or other valuable consideration.” If we decide to sell Application , we will inform you about this, so you can forbid us to transfer your personal data together with our business. If so, we will delete your data from the databases prior to a business transfer.

We adhere to the following principles in order to protect your privacy:

  • principle of purposefulness - we process personal data fairly and in a transparent manner only for the achievement of determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing;
  • principle of minimalism - we collect personal data only to the extent necessary for the achievement of determined purposes and do not keep personal data if it is no longer needed;
  • principle of restricted use - we use personal data for other purposes only with the consent of the data subject or with the permission of a competent authority;
  • principle of data quality - we update personal data shall be up-to-date, complete and necessary for the achievement of the purpose of data processing;
  • principle of security - security measures shall be applied in order to protect personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures;
  • principle of individual participation - the persons shall be notified of data collected concerning him or her, the persons shall be granted access to the data concerning him or her and the persons have the right to demand the correction of inaccurate or misleading data.

1.PERSONAL DATA THAT WE COLLECT AND PROCESS

1.1.In order to fulfil our obligations on provision a license for mobile app “Delta-ai-Draw” for you and applicable terms of use, We are entitled to ask you to provide us with your Personal Data, including (but not limited):

name;
anthropometric data;
age,weight,height.

1.2.Personal Data collected by or transmitted to the Delta-AI-Draw in the course of accessing, interacting and operating of the Application may include, without limitation, the following Personal Data: device information, which may include (but is not limited to) information about the computer or mobile device you use to access the Application , including the hardware model, operating system and version, the web browser you use, and other device identifiers; server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at the Application and the websites you visit just before and just after the Application ; information collected by cookies and other tracking technologies. We and our Application providers use various technologies to collect information when you interact with the Application , including cookies and web beacons. ‘Cookies’ are small data files that are stored on your device when you visit an Application which enable us to collect information about your device identifiers, IP address, web browsers used to access the Application , pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons are graphic images that are placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email. They are often used in combination with cookies.

1.3.We may also receive information about you from other sources, such as when you log in to mobile app “Delta-ai-Draw” by using your account credentials for a separate third-party Application . We will receive information from that Application as indicated in the relevant third party's authorization screen.

1.4.Delta-AI-Draw may collect the Personal Data from you in a variety of ways and circumstances, including, but not limited to, installation of mobile app Delta-ai-Draw”, subscription to a newsletter, filling out a form, providing us with feedback. Delta-AI-Draw shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Application with any other relevant available information.

2.APPLE HEALTH APP INTEGRATION

2.1.You may opt to integrate the Application with Apple's Health App Database. If you grant Application access to Apple's Health App Database, Application will import your data from the Health App Database into the Application in certain circumstances, such as to aid you in the tracking of fitness goals. In addition, Application may transfer data that you store locally on your Device, such as active energy, mindful minutes, workouts to the Health App Database. Application cannot read from or write to the Health App Database unless you grant access. Data accessed from the Health App Database will never be shared with third parties, such as third party Application providers and/or advertisers.

2.2.Delta-AI-Draw is in no way responsible for the protection of the Fitness Data and/or other information stored within Apple's Health App Database. You and Apple are solely responsible for the protection of such information in the Health App Database. Please review Apple's applicable policies and procedures before syncing and backing up your Fitness Data and/or other information with the Health App Database.

2.3.Important Notice Regarding your Apple Health Data : Data accessed from the Health App Database will never be used for marketing, advertising or similar purposes, and will never be shared with third parties, such as third-party Application providers and\or advertisers.

3.USE OF COLLECTED PERSONAL DATA

3.1.We may use the information collected from you for a variety of purposes, primarily, relating to providing our Application s and information about our Application s. We may also use the information for such other purposes as otherwise allowed by law. For example, we (or a supplier or our affiliate company acting on our behalf and only under our instructions) may use your personal data, including personally identifiable information, for such purposes, including but not limited to:

to provide license and access to mobile app “Delta-ai-Draw”;
to handle your orders and requests, including requests for technical
support and assistance;
to properly fulfil tax-related and accounting obligations imposed by
applicable laws;
to detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Use of mobile app “Delta-ai-Draw” and this Privacy Policy;
personalize your experience with our Application ;
contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyse the data collected for market research purposes;
conduct internal research and development and to improve, test and enhance the features and functions of our Application ;
marketing and promotion ofour Application s or related products, including those of a third party’s products which are related to our Application s (If you do not want us to use your data in this way, please let us know by contacting us at: contact@x5.agency;
meet our internal and external audit requirements, including our information security obligations;
tracking purchases and usage information;
any other purpose as we determine, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Application, or to comply with requirements of any applicable law.

4.CONSENT TO PERSONAL DATA PROCESSING

4.1.EU Persons Consent to Personal Data processing

4.1.1.If you are an EU Person and to process your Personal Data we need to receive your consent, as it is prescribed by GDPR, we will process your Personal Data only in the case we have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ("Consent").

4.1.2.You may give your Consent by ticking a box when visiting the Application. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that Delta-AI-Draw shall be entitled to process your Personal Data as it is indicated by your Consent.

4.1.3.Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the Processing has multiple purposes, your Consent should be deemed given for all of them.

4.1.4.You have the right to withdraw your Consent at any time. You can submit such a request by sending us an email to contact@x5.agency. Your withdrawal of Consent shall not affect the lawfulness of your Personal Data processing based on Consent before its withdrawal.

4.1.5.Except as required or enabled by law we will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards Delta-AI-Draw or in any other way permitted by law.

4.2.Non-EU Persons Consent to Personal Data processing

4.2.1.If you are not an EU Person, by transferring to us your Personal Data via the Application or otherwise, you irrevocably and unconditionally consent and agree that the Delta-AI-Draw shall be entitled, in accordance with this Policy:

To Process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to us, as well as your Personal Data collected from your use of the Application (i.e. your Personal Data which we collect automatically and/or from other sources); and to use cookies and web beacons (pixel tags) to collect your Personal Data.

5.СOMPLIANCE WITH GENERAL DATA PROTECTION REGULATION (GDPR), CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND BRAZIL'S GENERAL DATA PROTECTION LAW (LGPD (LEI GERAL DE PROTEÇÃO DE DADOS))

5.1.If you are located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).

5.2.If you are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).

5.3.If you are located in Brazilia, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).

5.4.The Child Online Privacy and Protection Act(“COPPA”) regulates online collection of information from persons under the age of 13 (covered person). Covered persons are required to obtain parental consent before providing personal data via Application . If you are a parent of a COPPA covered person, you have the option to agree to the collection and use of your COPPA covered person’s information. You may revoke your consent, review your COPPA covered person’s personal data, ask to have it deleted, and/or refuse to allow any further collection or use of your COPPA covered person’s information at any time, contact us at contact@x5.agency.

5.5.We process Personal Data as a Controller, as defined in the GDPR.

6.DATA ACCESS, DATA CORRECTION, DATA DELETION, DATA PORTABILITY AND WITHDRAWAL OF THE CONSENT

6.1.You can review, correct, update, delete or transfer their personally identifiable information. For that, contact us directly at contact@x5.agencyWe will acknowledge your request within seventy- two (72) hours and handle it promptly and as required by law.

6.1.1.Right to access. You may contact us to get confirmation as to whether or not we are processing your personal data. When we process your personal data, we will inform You of what categories of personal data we process regarding You, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed and the envisaged storage period or criteria to determine that period.

6.1.2.Right to withdraw consent. In case our processing is based on consent granted, You may withdraw the consent at any time by contacting us or by using the functionalities of our Application s. You can withdraw your consents at any time by replying to the email with your withdrawal and your Personal Data will be deleted in 48 hours. Withdrawing consent may lead to fewer possibilities to use our Application s.

6.1.3.Right to object. In case our processing is based on our legitimate interest to run, maintain and develop our business, You have the right to object at any time to our processing. We shall then no longer process your personal data unless for the provision of our Application s or if we demonstrate other compelling legitimate grounds for our processing that override your interests, rights and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, You have the right to prohibit us from using personal data for direct marketing purposes, by contacting us or by using the functionalities of the Application s or unsubscribe possibilities in connection with our direct marketing messages.

6.1.4.Right to restriction of the processing. You have the right to obtain from us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g. to allow our verification of accuracy of personal data after your contesting of accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use our Application s.

6.1.5.Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your consent and carried out by automated means.

6.1.6.How to use these rights. To exercise any of the above-mentioned rights, You should primarily use the functions offered by our Application s. If such functions are however not sufficient for exercising such rights, You shall send us a letter or email to the address set out below under Contact, including the following information: name, address, phone number, email address, and a copy of a valid proof of identity. We may request additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

7.STORING OF INFORMATION AND DELETION

7.1.We store your Personal Data for as long as needed to provide you with our Application s. We may store Data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, we delete it using reasonable measures to protect the Data from unauthorized access or use.

7.2.EU Territory. We store Personal Data as long as it is needed for the provision of our Application s. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable Application s, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Application s information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities, or up to the time when a user opts out from such use in accordance with this Privacy Policy. Other information is stored for as long as we consider it to be necessary for the provision of our Application s. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the Application you requested.

7.3.As explained in the GDPR statement, we strive to anonymise the data when possible. If you decide to exercise your right to erasure we will also inform our Providers to delete all your data.

7.4.US Territory. We will retain collected information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

7.5.Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalising our Application.

7.6.We do not use Application to knowingly solicit information from or market to children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at contact@x5.agency .

8.INFORMATION SECURITY

8.1.We care to ensure the security of personal data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process Your information, we also make sure that your information is protected from unauthorised access, loss, manipulation, falsification, destruction or unauthorised disclosure. This is done through appropriate administrative, technical and physical measures.

8.2.There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security.

8.3.We never process any kind of sensitive data and criminal offence data. Also we never undertake profiling of personal data.

9. CONTRACTORS

9.1.We work with third party services providers who provide website, application development, hosting, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to, or process Personal Data on behalf of us as part of providing those services for us. We limit the information provided to these Application providers to that which is reasonably necessary for them to perform their functions.

9.2.All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Economic Area may be possible only in the case, when we have obtained your consent for it.

9.3.Note on Apple HealthKit Data : Your Data collected from Apple Health will never be used for marketing or advertising purposes.

9.4.All data processed by us is stored exclusively in secure hosting facilities provided by Google Cloud and Google BigQuery.

9.5.We use Facebook. Facebook remarketing Application is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/ 164968693837950. To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/ help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http:// www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/ privacy/explanation. Your data will be stored in Facebook data centers, located in Sweden, Denmark, and Ireland.

9.6.We use AmplitudeAnalyticsfor analytic user behavior and understand how users are navigating through App(s) and which features engage the most. For more information on the privacy practices of Amplitude Analytics, please visit the Privacy Policy: https://amplitude.com/privacy

9.7.We use Adjusts to analyze and optimize mobile advertising campaigns and user activities on the internet. For more information on the privacy practices of Adjusts, please visit the Privacy Policy: https://amplitude.com/privacy

9.8.We use AppsflyerFor more information on the privacy practices of Appsflyer, please visit the Privacy Policy: https://www.appsflyer.com/ Application s-privacy-policy/

9.9.We useFirebase.Firebase is Google's mobile application development platform that helps to build, improve, and grow Application . For more information on the privacy practices of Firebase, please visit the Privacy Policy: https://firebase.google.com/support/privacy

9.10.We use PooshWoosh. PooshWoosh is a Application that enables push notifications to be sent. For more information on the privacy practices of PooshWoosh, please visit the Privacy Policy https:// www.pushwoosh.com/privacy-policy/

10. OPT-OUT

10.1.You can deactivate local notifications by changing the notification settings in accordance with the instructions of the operating system running on the Users’ device.

11. APPLICATION OF THIS PRIVACY POLICY

11.1.This Privacy Policy is applicable to our Application. Once redirected to another website or App, this Policy is no longer applicable.

12. ACCEPTANCE OF THESE CONDITIONS

12.1.We assume that all Users have carefully read this document and agree to its content. If one does not agree with this Privacy policy, they should refrain from using the Application.

13. CHANGES AND UPDATES TO OUR PRIVACY POLICY

13.1.From time to time, we may update this Privacy Policy. We encourage You to periodically check back and review this Policy so that You always will know what information we collect, how we use it, and with whom we share it.

14. CONTACT US!

14.1.If you have any questions please contact us at contact@x5.agency.

MoreAds OÜ Address: Harju maakond, Tallinn, Kristiine linnaosa, Tulika tn 17, 10613

We follow applicable rules, guidelines and legislation. That’s why NO ⁃ Face Swaps, Deep Fakes or Voice Impersonations can be created!

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