Updated November 24, 2024
Privacy Policy
FTM IT OÜ located at Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, registration number 17181632 (“we,” “Company,” “us”) is the owner of these Services. We are committed to being fully transparent about our privacy practices while operating the Services.
The Services include mobile application published on Google Play and/or the App Store namely “AI Tattoo Design: InkMaster”, hereinafter collectively referred to as the “Services” or "App".
We prepared this Privacy Policy to inform you (“you” or “user”) about how your personal data may be processed. We have tried to write it in clear, understandable terms so that you can be confident that your personal data is safe with us.
This Privacy Policy sets out:
If you have any questions about this Privacy Policy, how the Company processes your personal data, or how to exercise your rights as a data subject, please send your request to hello@ftm-it.com.
What is Personal Data?
“Personal data” (or “data”) is any information about you that, on its own or combined with other information, can be used to identify you as an individual. Generally, this may include your name, email address, location data, etc. Personal data can also include certain technical details such as Media Access Control (MAC) addresses, International Mobile Equipment Identity (IMEI) numbers, Unique Device Identifiers (UDIDs), Identity for Advertisers (IDFA), Internet Protocol (IP) addresses (static or dynamic), as well as browser and operating system information.
“Personal data processing” refers to any action taken with your personal data—for example, collecting, recording, organizing, storing, using, or disclosing that data.
“Sensitive personal data” is a specific category of information that must be handled with added security. Depending on applicable law, this may include details about:
What Data Do We Collect?
1. Data We Receive from Third Parties
You do not need to create an account to access certain basic features of the Services. However, you can authorize access to the Services through a third-party account such as Google, Apple, or Facebook, or through an email login. If you choose to sign up this way, we collect, store, and use the information you have permitted that service to share (e.g., your username, first and last name, email address, age, and any other data shared for the purpose of authorization). This allows you to connect your account to the App across different devices.
This data is not strictly required to use some of our basic features. You can still access limited functionality in the Services even if you do not grant permission to share this additional information.
2. Data Related to Your Use of the Services
Our Services enable you to generate tattoo designs via AI. In doing so, you may choose to upload or capture images that will serve as a basis or reference for your tattoo designs, along with textual prompts or other descriptive inputs. Any personal data (e.g., identifiable features, personal details in the images or text) included in these images or prompts is processed only to the extent necessary to provide the Services.
Some features may require storing your images and text-based prompts on our servers, in line with the retention period specified in Section 4 of this Privacy Policy. You alone are responsible for any content you provide through the Services.
AI-Based Features
We may offer certain AI-based functions—such as generating unique tattoo artwork from your textual prompts or uploaded reference images—requiring the processing of images or data that may be deemed personal under applicable data-protection laws. If you choose to use these AI-based features, we will request your consent, as described in this Privacy Policy. We will only process the data you provide in order to deliver these specialized features, and we may share necessary data with trusted third-party service providers for the purpose of facilitating these AI functions.
3. Data Related to Your Inquiries
If you send us inquiries via the App or by emailing us at hello@ftm-it.com, we may process any personal information you voluntarily include (e.g., your name, email address, user ID, information about your device, logs, etc.). Please avoid submitting unnecessary or sensitive personal data—particularly that of third parties—in your communications.
Depending on your request, we may ask for additional data to fulfill it or to respond adequately.
4. Newsletters
If you provide your email to us, we may use it for marketing purposes—such as sending newsletters, updates, or promotional information about our Services.
5. Financial Information
We do not collect or store your direct payment details (e.g., bank account or credit card numbers). Such data is handled exclusively by third-party payment providers with appropriate licenses and security measures, as described in our Terms of Use. However, we may store non-sensitive details related to your purchases made via Stripe, the App Store, or Google Play—this could include the merchant’s name, date, time, transaction amount, and related behavioral data.
6. Automatically Collected Data
General Information
We may automatically gather certain technical information about the devices you use to access Service. This can include:
Cookies and Similar Technologies
1. App: AI Tattoo Design: InkMaster
We use automated data collection to enhance your experience and ensure that AI Tattoo Design: InkMaster (“App”) operates effectively. For instance, when you open the App, we may use a one-time session ID for authorization, which is valid only for the duration of your session. Once you close the App, that ID expires and becomes invalid.
Mobile devices often rely on identifiers akin to cookies (e.g., Apple’s Advertising Identifier and Identifier for Vendor on iOS; Google’s Advertising ID on Android). Additionally, we may incorporate third-party Software Development Kits (SDKs)—code provided by our analytics or advertising partners—into our App. These SDKs help us and our partners understand how you interact with the App, including collecting device or network identifiers. You can learn more about how these partners handle data by consulting their respective privacy policies.
Technologies such as pixels, web beacons, and local storage may also be used in the App to collect information about your usage patterns. This helps us to:
You can adjust the privacy settings on your device to opt out of interest-based advertising—this may involve changing the “Advertising” or “Ads Personalization” settings. Even if you opt out, you may still receive ads in the App, but these will not be personalized to your interests.
2. Website
When you visit our Website (such as any pages hosted at ftm-it.com), we use cookies—small bits of code stored in your browser—that help enable various functionalities:
We may install different types of cookies. Some are strictly necessary for the Website’s basic functionality (e.g., the cookie that remembers your preference to refuse certain cookies), while others are used for analytics or advertising. Data collected via cookies can be aggregated to evaluate page popularity and our performance in delivering content to you.
Where cookies gather personal data, such as IP addresses or data that can identify you when combined with other information, we may share this with or store it via third-party providers (like Amplitude, Firebase, or AppsFlyer) who perform analytics on our behalf. Our staff and contractors may also access this data to help us operate and improve the Services.
Lawful Basis and Purposes for Processing Your Data
1. Lawful Basis
In summary, we collect and process personal data to:
How Long Do We Store Your Data?
We generally retain data only as long as needed to provide our Services and fulfill the purposes mentioned in this Privacy Policy. Retention periods vary based on the type of data and its usage. Once a retention period ends, personal data is securely deleted.
If you stop using our Services for an extended period, we may delete your personal data—including any uploaded content—once you are no longer considered an active user. For example, if you uninstall the App, we will remove your personal data immediately (except for certain data needed to meet financial, tax, or other legal obligations, which we keep for as long as required by law).
We are under no strict obligation to keep your data for a specified duration, except as required by law or specific agreements with you. We may securely delete it—without notice—at any time. For instance, project files you create via the web interface may only be stored for 30 days, after which they are permanently removed.
We do not store your payment credentials. These are handled directly by third-party providers (e.g., Apple’s in-app purchase mechanism). We only keep a token of such payment information—one that cannot be used to re-identify you—along with your chosen payment method.
Backup Period
Occasionally, we may back up all data processed within our Services, which may include snapshots of your personal data at the time a backup was made. This helps us restore the Services in case of technical issues. Data in backups will be used solely to restore our systems or your account if applicable, based on our legitimate interest. Each backup is stored for one month after creation.
Other Processing
In certain situations, we might keep your data longer than indicated here for statistical purposes—in compliance with Article 5 of the GDPR—alongside adequate safeguards in accordance with applicable data protection laws. “Statistical purposes” means any collection or processing of personal data to generate aggregated, non-personalized insights. We typically anonymize your data for these purposes, so it no longer constitutes personal data under privacy laws.
Granting Access to Third Parties
We may engage employees, contractors, or external service providers to maintain and develop our Services, gather statistics, and deliver personalized ads. These partners might access certain elements of your personal data.
In every case, The Company takes all steps to ensure full compliance with data protection legislation and to guarantee the security of your data at every stage. Our subcontractors and other third parties must offer the same or equivalent data protection standards as outlined in this Privacy Policy.
Because some third parties may be located outside the European Economic Area (EEA), we might transfer data to countries lacking an adequacy decision from the European Commission (e.g., the United States or Ukraine). In these cases, we rely on Standard Contractual Clauses or similar agreements to safeguard your rights and data. You may request copies of these legal instruments by contacting us.
1. Our Employees and Independent Contractors
We only give access to individuals—employees or vetted contractors—who have signed confidentiality agreements and, where necessary, data processing agreements. This ensures they protect your personal data in accordance with our policies and the law.
2. Third-Party Service Providers
To power various features of our Services—including AI-based capabilities—we work with trusted providers such as Amazon AWS, SendGrid, Amplitude, Firebase, and AppsFlyer, among others. These partners help us run analytics, streamline communication, serve more relevant ads, and more. We do not share your name or other data that directly identifies you for advertising purposes; instead, an advertising identifier is used.
We comply with GDPR obligations by implementing certified services and tools, signing data processing agreements with contractors, and using technical measures to protect data during storage, processing, and transfer.
3. Other Legally Required Transfers
We may disclose personal data to comply with legal obligations or valid requests from public authorities. If legally permissible, we will notify you of such disclosure requests unless prohibited by law.
Your Rights Regarding Data Processing
You can exercise the rights described below by emailing a request to us. To verify and protect your data, we may take steps to confirm your identity. We aim to respond within one month from receipt of your request, as mandated by law.
You Have the Right To:
Privacy notice for California residents
This section supplements our Privacy Policy and reflects our obligations under the California Consumer Privacy Act (CCPA). It applies to you if:
The App may collect information that identifies, relates to, describes, references, can be linked with, or might be associated with you or your device, including but not limited to identifying information (“personal information”). Specifically, in the past 12 months, we have collected the following categories of personal information:
We may disclose personal information for business purposes, primarily to:
We may also share information when we believe doing so is necessary to comply with the law or protect our rights or the rights of others. Additionally, some visitor information may be shared with other parties for marketing or advertising purposes.
Your Rights Under the CCPA1.
You have the right to confirm whether your personal information is being processed by us. Specifically, you may request that we disclose:
You may request a full copy of your personal information in a commonly used, machine-readable format. This allows you to transfer it to another service or entity if you wish.
3. Right to Opt Out
You may opt out of having your personal data sold or used by third parties. By notifying us at hello@ftm-it.com, you can limit third-party providers from accessing your personal information. If you opt out, you will still see ads, but they will not be personalized based on your data.
Note: Cookie-based opt-outs do not always work in mobile applications. Instead, you may reset your advertising identifier or limit ad tracking via your device settings. For more information on how to do this on iOS or Android, check these links:
You can also manage your ad preferences through the App Choices mobile application available on Google Play or the Apple App Store.
4. Rights Regarding Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA. This means we will not:
Deletion rights
You may request the deletion of personal information concerning you without undue delay. The Company will then delete your personal information from our records, instruct any service providers or contractors to delete it from their records, and notify all third parties to whom we have disclosed the information so they can delete it as well. We may refuse your request if compliance is impossible or involves disproportionate effort, or if we must retain the data for any of the following reasons:
How to Exercise Your Rights
To exercise your access, data portability, or deletion rights, please submit a verifiable consumer request by emailing us at hello@ftm-it.com. We use the data in your request solely to verify your identity or authority.
Your Age
We are particularly concerned about children’s privacy. If you are under 18 (or the age of legal majority in your location) and at least 13, a parent or guardian must review and consent to this Privacy Policy and your use of Services. This requirement is especially important for any paid Services or AI-based features—such as those processing potential biometric data—that you may wish to use. You may only use our Services through an account owned by a parent or guardian, provided you have their explicit permission and are supervised by them.
We do not intentionally gather personal information from children under 13 without verifiable parental consent. If we discover that such data has been inadvertently collected, we will take prompt action to remove it from our records.
Security of Personal Data
We apply suitable security measures to safeguard your personal data against accidental loss, destruction, or unlawful processing. Our staff and contractors are bound by confidentiality agreements, and only authorized personnel have access to personal data. We use password hashing, two-factor authentication, and other measures to mitigate potential risks to your rights and freedoms.
Disclaimer: No internet-based or electronic storage method is 100% secure. Should any data breach occur that presents a high risk to your rights, we will inform both you and the relevant data protection authorities without undue delay, and we will strive to minimize harm. However, if your jurisdiction entitles you to damages for inaccuracies, incompleteness, obsolescence, or unlawful use of personal data, this disclaimer may not affect those rights.
Changes to This Privacy Policy
We may revise or update this Privacy Policy periodically. If the modifications substantially impact your rights or legitimate interests, we will notify you via email or a prominent notice within The App when you first use it after the changes. We will also revise the “Last modified” date at the top of the Privacy Policy.
Contact Information
If you have any questions about this Privacy Policy or how FTM IT OÜ processes your data, feel free to contact us:
FTM IT OÜ located at Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, registration number 17181632
The Services include mobile application published on Google Play and/or the App Store namely “AI Tattoo Design: InkMaster”, hereinafter collectively referred to as the “Services” or "App".
We prepared this Privacy Policy to inform you (“you” or “user”) about how your personal data may be processed. We have tried to write it in clear, understandable terms so that you can be confident that your personal data is safe with us.
This Privacy Policy sets out:
- Which personal data we process
- The purposes of such processing
- The user’s rights concerning such data
- Any transfers of data to third parties
- The measures we take to safeguard personal data
- Other details related to personal data processing
If you have any questions about this Privacy Policy, how the Company processes your personal data, or how to exercise your rights as a data subject, please send your request to hello@ftm-it.com.
What is Personal Data?
“Personal data” (or “data”) is any information about you that, on its own or combined with other information, can be used to identify you as an individual. Generally, this may include your name, email address, location data, etc. Personal data can also include certain technical details such as Media Access Control (MAC) addresses, International Mobile Equipment Identity (IMEI) numbers, Unique Device Identifiers (UDIDs), Identity for Advertisers (IDFA), Internet Protocol (IP) addresses (static or dynamic), as well as browser and operating system information.
“Personal data processing” refers to any action taken with your personal data—for example, collecting, recording, organizing, storing, using, or disclosing that data.
“Sensitive personal data” is a specific category of information that must be handled with added security. Depending on applicable law, this may include details about:
- Racial or ethnic origin
- Political opinions
- Membership in a political association
- Religious or philosophical beliefs
- Professional or trade union membership
- Genetic data
- Sexual orientation
- Criminal records
- Genetic information (if not otherwise classified as health information)
- Health information
- Biometric templates
- Biometric data (when processed to uniquely identify a person), etc.
What Data Do We Collect?
1. Data We Receive from Third Parties
You do not need to create an account to access certain basic features of the Services. However, you can authorize access to the Services through a third-party account such as Google, Apple, or Facebook, or through an email login. If you choose to sign up this way, we collect, store, and use the information you have permitted that service to share (e.g., your username, first and last name, email address, age, and any other data shared for the purpose of authorization). This allows you to connect your account to the App across different devices.
This data is not strictly required to use some of our basic features. You can still access limited functionality in the Services even if you do not grant permission to share this additional information.
2. Data Related to Your Use of the Services
Our Services enable you to generate tattoo designs via AI. In doing so, you may choose to upload or capture images that will serve as a basis or reference for your tattoo designs, along with textual prompts or other descriptive inputs. Any personal data (e.g., identifiable features, personal details in the images or text) included in these images or prompts is processed only to the extent necessary to provide the Services.
Some features may require storing your images and text-based prompts on our servers, in line with the retention period specified in Section 4 of this Privacy Policy. You alone are responsible for any content you provide through the Services.
AI-Based Features
We may offer certain AI-based functions—such as generating unique tattoo artwork from your textual prompts or uploaded reference images—requiring the processing of images or data that may be deemed personal under applicable data-protection laws. If you choose to use these AI-based features, we will request your consent, as described in this Privacy Policy. We will only process the data you provide in order to deliver these specialized features, and we may share necessary data with trusted third-party service providers for the purpose of facilitating these AI functions.
3. Data Related to Your Inquiries
If you send us inquiries via the App or by emailing us at hello@ftm-it.com, we may process any personal information you voluntarily include (e.g., your name, email address, user ID, information about your device, logs, etc.). Please avoid submitting unnecessary or sensitive personal data—particularly that of third parties—in your communications.
Depending on your request, we may ask for additional data to fulfill it or to respond adequately.
4. Newsletters
If you provide your email to us, we may use it for marketing purposes—such as sending newsletters, updates, or promotional information about our Services.
5. Financial Information
We do not collect or store your direct payment details (e.g., bank account or credit card numbers). Such data is handled exclusively by third-party payment providers with appropriate licenses and security measures, as described in our Terms of Use. However, we may store non-sensitive details related to your purchases made via Stripe, the App Store, or Google Play—this could include the merchant’s name, date, time, transaction amount, and related behavioral data.
6. Automatically Collected Data
General Information
We may automatically gather certain technical information about the devices you use to access Service. This can include:
- Device and Identifier Data: IP address, location (by country or city), unique device identifiers, Google Advertising ID, Apple ID for Advertising, IMEI, TCP/IP address, browser type, operating system, screen resolution, device language, and domain name.
- Usage Data: Platform type, clicks, content viewed, features used, screens viewed, navigation paths, time/date/frequency of use, error logs, and other diagnostic data.
Cookies and Similar Technologies
1. App: AI Tattoo Design: InkMaster
We use automated data collection to enhance your experience and ensure that AI Tattoo Design: InkMaster (“App”) operates effectively. For instance, when you open the App, we may use a one-time session ID for authorization, which is valid only for the duration of your session. Once you close the App, that ID expires and becomes invalid.
Mobile devices often rely on identifiers akin to cookies (e.g., Apple’s Advertising Identifier and Identifier for Vendor on iOS; Google’s Advertising ID on Android). Additionally, we may incorporate third-party Software Development Kits (SDKs)—code provided by our analytics or advertising partners—into our App. These SDKs help us and our partners understand how you interact with the App, including collecting device or network identifiers. You can learn more about how these partners handle data by consulting their respective privacy policies.
Technologies such as pixels, web beacons, and local storage may also be used in the App to collect information about your usage patterns. This helps us to:
- Provide, improve, and test the App’s functionality.
- Identify and resolve technical issues.
- Enhance the App’s security.
- Analyze trends and usage metrics.
- Develop and test new features.
- Tailor services and advertisements to your interests.
- Use data collected from cookies and similar tools to enhance both the App and your overall experience.
You can adjust the privacy settings on your device to opt out of interest-based advertising—this may involve changing the “Advertising” or “Ads Personalization” settings. Even if you opt out, you may still receive ads in the App, but these will not be personalized to your interests.
2. Website
When you visit our Website (such as any pages hosted at ftm-it.com), we use cookies—small bits of code stored in your browser—that help enable various functionalities:
- Facilitating navigation on our Website.
- Remembering your choices (such as language settings).
- Displaying advertisements that may align with your interests.
We may install different types of cookies. Some are strictly necessary for the Website’s basic functionality (e.g., the cookie that remembers your preference to refuse certain cookies), while others are used for analytics or advertising. Data collected via cookies can be aggregated to evaluate page popularity and our performance in delivering content to you.
Where cookies gather personal data, such as IP addresses or data that can identify you when combined with other information, we may share this with or store it via third-party providers (like Amplitude, Firebase, or AppsFlyer) who perform analytics on our behalf. Our staff and contractors may also access this data to help us operate and improve the Services.
Lawful Basis and Purposes for Processing Your Data
1. Lawful Basis
- Performance of a Contract
- FTM IT OÜ located at Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, registration number 17181632 (“we,” “Company,” “us”) collects and processes most of the personal data mentioned in the previous sections to fulfill our contractual obligations under our Terms of Use. This includes data related to your requests and when you log in via a third-party account (e.g., Google, Apple, or Facebook). It also covers data on how you interact with AI Tattoo Design: InkMaster or the Website—for instance, granting the App permission to access any images on your device that you want to use for generating tattoo designs, or providing text prompts to guide the AI-generated artwork.
- Your Consent
- We may process your email address for marketing purposes if you explicitly provide it to us via the App. This allows us to send you promotional or informational emails about updates, new features, or other changes to the App. You can unsubscribe from such emails at any time using the “Unsubscribe” link in each email.
- Important: Our AI-driven features may process data related to your voice or facial images, which may be considered biometric information (a “special category of personal data”). If you wish to use these features—for instance, uploading a reference photo of yourself for AI tattoo design—and you request such features, you thereby give your explicit consent for us to process this biometric data. If you have any questions about how we handle biometric information, you can contact us at hello@ftm-it.com.
- Legitimate Interests
- We may process your data to operate our App and the Website effectively, ensuring the Services function correctly and delivering requested features. This includes analyzing aggregated data and compiling reports or analytics that guide internal decision-making or are shared publicly or with trusted third parties. We also use legitimate interests to enhance and personalize the Services—for example, automatically detecting your device’s language settings, testing new features, or preventing and investigating potential misconduct. In these scenarios, we strive to balance our needs with your privacy rights.
In summary, we collect and process personal data to:
- Provide and maintain our Services.
- Respond to user inquiries.
- Analyze and optimize functionality.
- Develop new features and improvements.
- Enhance user experience and deliver relevant content or advertisements.
- Comply with applicable legal requirements and secure our legitimate business interests, including protection against legal liability.
- Account Data (when you authorize using a third-party account):
- We use this to let you synchronize your account across multiple devices and identify you as the user.
- Data Related to Use of the Services:
- We collect this information so the AI Tattoo Design: InkMaster (“App”) can function as intended and deliver the features you expect under the Terms. For example, we save your content within the App to ensure you can retrieve it.
- Data Related to Your Requests:
- This includes any inquiries you send us—whether via the App or hello@ftm-it.com —and helps us respond thoroughly to your questions or issues and confirm you’re satisfied with our Services.
- Data Provided for Receiving Newsletters:
- If you share your email for this purpose, we use it to keep you updated on any enhancements, innovations, or improvements we introduce within the Services.
- Data Collected Through Automated Means:
- Depending on the exact type of data (e.g., cookies, device info, analytics data), we use it to ensure the App and Website run properly, for analytics or statistical purposes (like developing new features or optimizing user experience), or to serve more relevant advertisements. We base these data-processing activities on our legitimate interests or your consent (where required). We do not use your data in these ways if our interests are overridden by the impact on you, unless you have provided consent or we are otherwise permitted by law.
- Crime Prevention and Security: Detecting and preventing fraud or malicious activity and ensuring network and information security.
- Legal Compliance: Meeting any legal or regulatory obligations.
- Enforcing Our Rights: As outlined in the Terms of Use.
How Long Do We Store Your Data?
We generally retain data only as long as needed to provide our Services and fulfill the purposes mentioned in this Privacy Policy. Retention periods vary based on the type of data and its usage. Once a retention period ends, personal data is securely deleted.
If you stop using our Services for an extended period, we may delete your personal data—including any uploaded content—once you are no longer considered an active user. For example, if you uninstall the App, we will remove your personal data immediately (except for certain data needed to meet financial, tax, or other legal obligations, which we keep for as long as required by law).
We are under no strict obligation to keep your data for a specified duration, except as required by law or specific agreements with you. We may securely delete it—without notice—at any time. For instance, project files you create via the web interface may only be stored for 30 days, after which they are permanently removed.
We do not store your payment credentials. These are handled directly by third-party providers (e.g., Apple’s in-app purchase mechanism). We only keep a token of such payment information—one that cannot be used to re-identify you—along with your chosen payment method.
Backup Period
Occasionally, we may back up all data processed within our Services, which may include snapshots of your personal data at the time a backup was made. This helps us restore the Services in case of technical issues. Data in backups will be used solely to restore our systems or your account if applicable, based on our legitimate interest. Each backup is stored for one month after creation.
Other Processing
In certain situations, we might keep your data longer than indicated here for statistical purposes—in compliance with Article 5 of the GDPR—alongside adequate safeguards in accordance with applicable data protection laws. “Statistical purposes” means any collection or processing of personal data to generate aggregated, non-personalized insights. We typically anonymize your data for these purposes, so it no longer constitutes personal data under privacy laws.
Granting Access to Third Parties
We may engage employees, contractors, or external service providers to maintain and develop our Services, gather statistics, and deliver personalized ads. These partners might access certain elements of your personal data.
In every case, The Company takes all steps to ensure full compliance with data protection legislation and to guarantee the security of your data at every stage. Our subcontractors and other third parties must offer the same or equivalent data protection standards as outlined in this Privacy Policy.
Because some third parties may be located outside the European Economic Area (EEA), we might transfer data to countries lacking an adequacy decision from the European Commission (e.g., the United States or Ukraine). In these cases, we rely on Standard Contractual Clauses or similar agreements to safeguard your rights and data. You may request copies of these legal instruments by contacting us.
1. Our Employees and Independent Contractors
We only give access to individuals—employees or vetted contractors—who have signed confidentiality agreements and, where necessary, data processing agreements. This ensures they protect your personal data in accordance with our policies and the law.
2. Third-Party Service Providers
To power various features of our Services—including AI-based capabilities—we work with trusted providers such as Amazon AWS, SendGrid, Amplitude, Firebase, and AppsFlyer, among others. These partners help us run analytics, streamline communication, serve more relevant ads, and more. We do not share your name or other data that directly identifies you for advertising purposes; instead, an advertising identifier is used.
We comply with GDPR obligations by implementing certified services and tools, signing data processing agreements with contractors, and using technical measures to protect data during storage, processing, and transfer.
3. Other Legally Required Transfers
We may disclose personal data to comply with legal obligations or valid requests from public authorities. If legally permissible, we will notify you of such disclosure requests unless prohibited by law.
Your Rights Regarding Data Processing
You can exercise the rights described below by emailing a request to us. To verify and protect your data, we may take steps to confirm your identity. We aim to respond within one month from receipt of your request, as mandated by law.
You Have the Right To:
- Access Your Data
- Request details on what personal data we hold, how we obtained it, the purpose of processing, and third parties with whom the data is shared. You may also request a copy of your personal data.
- Rectify or Erase Your Data
- If you believe certain data we hold is incorrect or no longer needed, you may request we correct or delete it. Please note that some data may be retained if required by law or necessary for protecting our legitimate interests.
- Withdraw Consent
- If we rely on your consent for processing (e.g., marketing emails or AI-based biometric data), you can withdraw that consent at any time. Upon withdrawal, we must stop the relevant processing unless other legal bases apply.
- Object to Processing
- You can object when your data is processed based on a “legitimate interest,” for instance, receiving marketing messages. If we have no other legal basis for processing, we will delete the data in question.
- Restrict Processing
- If you challenge the accuracy or lawfulness of our processing, you can request a restriction on further processing. However, this might limit your ability to use certain features of the Services.
- Data Portability
- Request that we provide your personal data in a commonly used, machine-readable format (e.g., CSV) so you can transmit it to another controller.
- Lodge a Complaint
- File a complaint with a supervisory authority or initiate legal proceedings if you believe your data protection rights have been violated.
- Automated Decision-Making
- We do not solely rely on automated processing (including profiling) to make decisions that produce legal or similarly significant effects for you. If we ever implement such processes, we will explain how they function, and you may request human review of any automated decisions.
Privacy notice for California residents
This section supplements our Privacy Policy and reflects our obligations under the California Consumer Privacy Act (CCPA). It applies to you if:
- Your state of residence or establishment is in California;
- You are in California for any purpose other than a temporary or transitory one; or
- You are domiciled in California but are currently outside the state for a temporary or transitory reason.
- Personal Information:
- Information that identifies, relates to, describes, could be reasonably linked to, or might be associated, directly or indirectly, with a particular consumer or household. This can include:
- Identifiers: Such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar data.
- Internet or Other Electronic Network Activity: For example, browsing history, search history, and information about a consumer’s interactions with a website, app, or advertisement.
- Geolocation Data
- Sensory Data: Audio, electronic, visual, thermal, olfactory, or similar information.
- Inferences: Profiles drawn from any of the above data that reflect preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sensitive Personal Information: Credentials or account log-in details, financial or payment data, or other information that grants access to your account, plus biometric details used to identify a person uniquely.
- Processing: Any operation performed on personal information, including collecting, recording, organizing, storing, using, or disclosing that information, whether by automated means or otherwise.
- Sell: Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating (by oral, written, or electronic means) personal information to another business or third party in exchange for monetary or other valuable consideration.
The App may collect information that identifies, relates to, describes, references, can be linked with, or might be associated with you or your device, including but not limited to identifying information (“personal information”). Specifically, in the past 12 months, we have collected the following categories of personal information:
- Identifiers: Real name, alias, unique personal identifier, online identifier, IP address, email address, account name, or other related data.
- Internet and Similar Network Activity: Information about your interactions with the App or advertisements.
- Sensory Data: Visual materials (images, photos, or other content you upload).
- Sensitive Personal Information: Biometric data (e.g., your voice recordings, facial images). If you upload or otherwise provide content containing your face or voice, we may automatically process information about your physical characteristics to generate AI-based designs—for example, overlaying or placing digital content around your eyes, nose, mouth, or ears to create augmented or modified images, or using your voice in the App’s voice-related features.
We may disclose personal information for business purposes, primarily to:
- Provide the Services you request.
- Perform analytics.
- Ensure the App functions as intended.
- Fix errors.
- Protect the App from malicious attacks.
We may also share information when we believe doing so is necessary to comply with the law or protect our rights or the rights of others. Additionally, some visitor information may be shared with other parties for marketing or advertising purposes.
Your Rights Under the CCPA1.
You have the right to confirm whether your personal information is being processed by us. Specifically, you may request that we disclose:
- The categories of personal information we collected about you in the 12 months prior to your request.
- The categories of sources from which the personal information was collected.
- The business or commercial purpose for collecting or sharing personal information.
- The categories of third parties with whom we share personal information.
You may request a full copy of your personal information in a commonly used, machine-readable format. This allows you to transfer it to another service or entity if you wish.
3. Right to Opt Out
You may opt out of having your personal data sold or used by third parties. By notifying us at hello@ftm-it.com, you can limit third-party providers from accessing your personal information. If you opt out, you will still see ads, but they will not be personalized based on your data.
Note: Cookie-based opt-outs do not always work in mobile applications. Instead, you may reset your advertising identifier or limit ad tracking via your device settings. For more information on how to do this on iOS or Android, check these links:
You can also manage your ad preferences through the App Choices mobile application available on Google Play or the Apple App Store.
4. Rights Regarding Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA. This means we will not:
- Deny services to you.
- Charge different prices or rates for services (including through discounts or imposing penalties).
- Provide you with a different level or quality of services.
- Suggest that you may receive a different price or rate for services or a different level or quality of services if you exercise your rights.
- If you wish to exercise any of these rights, have questions, or need further information, please contact us at hello@ftm-it.com.
Deletion rights
You may request the deletion of personal information concerning you without undue delay. The Company will then delete your personal information from our records, instruct any service providers or contractors to delete it from their records, and notify all third parties to whom we have disclosed the information so they can delete it as well. We may refuse your request if compliance is impossible or involves disproportionate effort, or if we must retain the data for any of the following reasons:
- Security and Fraud Prevention: Detecting, protecting against, or prosecuting malicious, deceptive, or unlawful activity.
- Debugging: Identifying and fixing errors that compromise existing functionality.
- Legal Compliance: Meeting requirements under the California Electronic Communications Privacy Act, the Penal Code, or other laws.
- Lawful Internal Use: Using your personal information in a manner consistent with the context in which you provided it.
How to Exercise Your Rights
To exercise your access, data portability, or deletion rights, please submit a verifiable consumer request by emailing us at hello@ftm-it.com. We use the data in your request solely to verify your identity or authority.
- Only you or an authorized representative may submit a verifiable consumer request related to your personal information.
- You can only request access or data portability twice within a 12-month period.
- The request must include enough information for us to verify that you are the person about whom we have collected data—or a person with valid authorization—and a description of your request sufficient for us to understand and respond.
Your Age
We are particularly concerned about children’s privacy. If you are under 18 (or the age of legal majority in your location) and at least 13, a parent or guardian must review and consent to this Privacy Policy and your use of Services. This requirement is especially important for any paid Services or AI-based features—such as those processing potential biometric data—that you may wish to use. You may only use our Services through an account owned by a parent or guardian, provided you have their explicit permission and are supervised by them.
We do not intentionally gather personal information from children under 13 without verifiable parental consent. If we discover that such data has been inadvertently collected, we will take prompt action to remove it from our records.
Security of Personal Data
We apply suitable security measures to safeguard your personal data against accidental loss, destruction, or unlawful processing. Our staff and contractors are bound by confidentiality agreements, and only authorized personnel have access to personal data. We use password hashing, two-factor authentication, and other measures to mitigate potential risks to your rights and freedoms.
Disclaimer: No internet-based or electronic storage method is 100% secure. Should any data breach occur that presents a high risk to your rights, we will inform both you and the relevant data protection authorities without undue delay, and we will strive to minimize harm. However, if your jurisdiction entitles you to damages for inaccuracies, incompleteness, obsolescence, or unlawful use of personal data, this disclaimer may not affect those rights.
Changes to This Privacy Policy
We may revise or update this Privacy Policy periodically. If the modifications substantially impact your rights or legitimate interests, we will notify you via email or a prominent notice within The App when you first use it after the changes. We will also revise the “Last modified” date at the top of the Privacy Policy.
Contact Information
If you have any questions about this Privacy Policy or how FTM IT OÜ processes your data, feel free to contact us:
FTM IT OÜ located at Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, registration number 17181632
- Email for privacy matters (exercising rights, questions about this Policy): hello@ftm-it.com
- General Contact Email: hello@ftm-it.com