PRIVACY POLICY

Effective date: 2023-07-19

  1.       Introduction

Welcome to GETHINS LIMITED.

GETHINS LIMITED (“us”, “we”, or “our”) operates https://virtwin.app (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to https://virtwin.app, and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

  1.       Definitions

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

PERSONAL DATA means any data about a Data Subject.

DATA PROCESSORS (OR SERVICE PROVIDERS) mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT means an identified or identifiable natural person who is the subject of Personal Data.

SERVICE means the gethins.app website operated by GETHINS LIMITED.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

  1.       Personal Data Collection and Use

We collect several different types of Personal Data for various purposes to provide and improve our Service to you.

  1.       Types of Data Collected
    1.   Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

0.1. Email address

0.2. First name and last name

0.3. Nickname

0.4. Phone number

0.5. Address, Country, State, Province, ZIP/Postal code, City

0.6. Cookies and Usage Data

0.7. Picture Path since user's avatar, may be taken from a third-party authentication provider.

0.8. Urchin Tracking Module (UTM) tags – a tracking mechanism used in web analytics to track the effectiveness of online marketing campaigns across traffic sources and media channels. This is applicable only in the context of web applications or website.

0.9. Password hash (a cryptographic representation of user’s password). The password has is used for authorization and registration.

10. Provider name and provider key in the context of third-party authentication. Provider name refers to the name or identifier of the third-party authentication provider such as Google, Facebook, Twitter, or other identity providers that allow users to log in using their credentials from these external services. The provider key is a unique key or identifier associated with the user's account on the third-party authentication provider. It is used to link the user's account on the external service with their account in the application. Third-party authentication indicates that this combination of provider name and provider key is used as part of the authentication process when users log in using their accounts from external identity providers. Instead of creating a separate account with a username and password for the application, users leverage their credentials from a trusted third-party service.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

  1.   Usage of Personal Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device.

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

  1.   Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity of our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

0.1. Session Cookies: We use Session Cookies to operate our Service.

0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

0.3. Security Cookies: We use Security Cookies for security purposes.

0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

  1.   Other Data

While using our Service, we may also collect the following information: gender, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile).

  1.   Image Usage
    1.      The photos uploaded by users are processed using artificial intelligence algorithms solely for the purpose of generating AI-generated content within the VirTwin app. These photos are retained temporarily during the generation process and not stored longer than necessary. Users can delete their uploaded images at any time within the app setting. More information about it can be found in section 4.6 below.
    2.      The app does not allow, process, or store nude, explicit, or sexually suggestive content. We have implemented security measures to protect user-uploaded photos from unauthorized access. Users have control over the visibility and accessibility of their uploaded photos within the app. The processing of user-uploaded photos strictly adheres to the content guidelines of the respective App Stores or Google Play, and the app does not use these photos for any undisclosed purposes.
    3.      Users are reminded to respect copyright and intellectual property rights when uploading images. Do not upload images that you do not have the right or permission to use or share.
    4.      By uploading images to VirTwin, you confirm that you have the right to use and share the uploaded images. You grant us permission to process these images for the purpose of generating AI content within the app.
    5.      User-uploaded content must adhere to the content guidelines of Google Play and the App Store. Content that violates these guidelines may be subject to removal.
  2.   Use of Facial Data

In order to maintain transparency and ensure user trust, we provide the following detailed information regarding the collection, use, storage, and deletion of face data by our application:

  1.      Collection of Face Data:

We may collect facial data to customize the stable diffusion model using eight (8) or more user-uploaded photos, along with the user's age. Users have the option to abstain from selecting gender by choosing the option “Other.”

This facial data may include, but it is not limited to, facial images, facial features (such as the size and shape of eyes, nose, mouth and other distinguish characteristics), facial expressions including emotions.

The collection and use of facial data are crucial for personalizing the experience within our application and for generating new photos based on user inputs.

We wish to emphasize that your privacy is important to us. By continuing to use our application, you explicitly consent to the collection and processing of your facial data for the stated purposes.

  1.      Utilization of Collected Facial Data: The facial data, comprising user-uploaded photos, is employed for the purpose of retraining the LoRa - small stable diffusion model. Subsequently, this retrained model is applied to produce new photos tailored to each individual user. The principal objective behind the utilization of this data is to optimize the user experience by delivering personalized and pertinent photo generation services.

  1. Storage and Security: Your facial data is securely stored and maintained in accordance with industry standards. The retrained model, along with the uploaded photos and an avatar's thumbnail (512x512 pixels), is stored securely on Amazon Web Services. We take reasonable measures to protect your facial data from unauthorized access, disclosure, alteration, and destruction. Your facial data is treated with the utmost care and is securely stored to protect your privacy.
  1.      Sharing and Third-Party Processing: We unequivocally affirm that your facial data is not leased, sold or shared with external third parties beyond our Company or its Affiliates without your explicit consent, except when mandated by law or for essential services related to our application. In such cases, we diligently ensure that third-party processors adhere to stringent data protection standards.

  1. Consent: By using our application, you consent to the collection and processing of your facial data for the stated purposes. You have the right to withdraw your consent at any time as described in the next section.

 

  1. User Control: You have the right to access, correct, or delete your facial data. You can manage your facial data preferences within the application settings, where you can specifically delete your facial data by selecting the option “Delete Information”. Alternatively, you may submit a request related to the access, correction or deletion of your facial data to info@virtwin.app , and we will make the best efforts to respond promptly. Upon receiving a deletion request, all personal data, including the retrained model, photos used for retraining, and the avatar's thumbnail, will be permanently deleted from our records.

We are committed to transparency and ensuring that you have control over your Personal Data.

  1. Facial Data Retention: Your facial data is retained for a duration of one month following the user's last activity within the application. After this period, the data is securely and permanently deleted to uphold user privacy and maintain stringent data security measures.
  1. Children's Privacy: Our application is expressly intended for individuals aged 18 years, the age of majority in their respective jurisdiction. We do not knowingly collect facial data from individuals below this age threshold. If you are a parent or guardian and have reason to believe that your child has provided us with facial data, please contact us immediately.
  1. Changes to the Privacy Policy: We reserve the right to update and modify this facial data section. In the event of any material changes to this section, we will notify you by posting an official announcement.

By continuing to use our application, you agree to the terms outlined in this facial data section.

  1.       Use of Personal Data

GETHINS LIMITED uses the collected Personal Data for various purposes:

0.1. to provide and maintain our Service;

0.2. to notify you about changes to our Service;

0.3. to allow you to participate in interactive features of our Service when you choose to do so;

0.4. to provide customer support;

0.5. to gather analysis or valuable information so that we can improve our Service;

0.6. to monitor the usage of our Service;

0.7. to detect, prevent and address technical issues;

0.8. to fulfil any other purpose for which you provide it;

0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

0.11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

0.12. in any other way we may describe when you provide the information;

0.13. for any other purpose with your consent.

  1.       Retention of Personal Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

  1.       Transfer of Personal Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Cyprus and choose to provide information to us, please note that we transfer the data, including Personal Data, to Cyprus and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

GETHINS LIMITED will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

  1.       Disclosure of Data

We may disclose Personal Data that we collect, or you provide:

 

  1.    Business Transaction

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

 

  1.    Other cases. We may disclose your Personal Data also:
  1. to our subsidiaries and affiliates;
  2. to contractors, service providers, and other third parties we use to support our business;
  3. to fulfill the purpose for which you provide it;
  4. for the purpose of including your company’s logo on our website;
  5. for any other purpose disclosed by us when you provide the information;
  6. with your consent in any other cases;
  7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
  1. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

  1.   Your Data Protection Rights Under General Data Protection Regulation (GDPR)

In accordance with the GDPR, you have the following rights related to your Personal Data:

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at info@virtwin.app.

You have the following data protection rights:

  1.      the right to access, update or to delete the Personal Data we have on you;
  2.      the right of rectification. You have the right to have your Personal Data rectified if that Personal Data is inaccurate or incomplete;
  3.      the right to object. You have the right to object to our processing of your Personal Data;
  4.      the right of restriction. You have the right to request that we restrict the processing of your Personal Data;
  5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
  6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your Personal Data;
  7. the right to lodge a complaint with a Supervisory Authority. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Data, you may contact our respective Data Protection Officer at info@virtwin.app. We will investigate your complaint promptly and will reply to you within 30 (thirty) calendar days. If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed, you have the right to lodge a complaint at any time to Cyprus supervisory authority, the Office of the Commissioner for Personal Data. https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1i_gr/page1i_gr?opendocument
    We would appreciate the chance to deal with your concerns and address your queries before you approach the supervisory authority.

While we recognize that the rights of Data Subjects under GDPR are fundamental, there are certain circumstances where these rights might be subject to exceptions or limitations. Any exceptions or limitations to these rights are either defined by applicable laws or are necessary, proportionate and respect the essence of fundamental rights and freedoms of the Data Subject.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.

  1. Your Data Protection Rights under the California Online Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California residents to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

0.1. users can visit our site anonymously;

0.2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the home page of our website;

0.3. users will be notified of any privacy policy changes on our Privacy Policy Page by a posted announcement clearly stating what has been changed;

0.4. users are able to change their Personal Data by emailing us at info@virtwin.app.

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

  1.   Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

  1. What Personal Data we have about you. If you make this request, we will return to you within a reasonable time:
    1.   The categories of Personal Data we have collected about you.
    2.   The categories of sources from which we collect your personal information.
    3.   The business or commercial purpose for collecting or selling your Personal Data.
    4.   The categories of third parties with whom we share Personal Data.
    5.   The specific pieces of Personal Data we have collected about you.
    6.   A list of categories of Personal Data that we have sold, along with the category of any other company we sold it to. If we have not sold your Personal Data, we will inform you of that fact.
    7.   A list of categories of Personal Data that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the Personal Data we collected about you in the previous 12 months.

  1. To delete your Personal Data. If you make this request, we will delete the Personal Data we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your Personal Data, you may not be able to use certain functions that require your Personal Data to operate.
  2. To stop selling your Personal Data. We don’t sell or rent your Personal Data to any third parties for any purpose. We do not sell your Personal Data for monetary consideration. However, under some circumstances, a transfer of Personal Data to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

If you submit a request to stop selling your Personal Data, we will stop making such transfers.

Please note, if you ask us to delete or stop selling your Personal Data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your Personal Data to function. But under no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by email: info@virtwin.app.

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

  1.   Service Providers

We may employ third party companies and individuals to facilitate our Service provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

  1.   Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

 

  1.   CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

 

  1.   Behavioral Remarketing

We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

 

  1.   Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Data is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

  1.   Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

  1.   Children’s Privacy

Our Services are not intended for use by children under the age of 18 or the age of majority in their jurisdiction (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

  1.   Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

  1.   Contact Us