Privacy Policy
This Privacy Policy outlines how Sotalabs Technology JSC (Sotalabs, "we", "us", or "our") is committed to safeguarding your privacy when you interact with our ShotX: Pro AI Headshot application software, accessible on Google Play and the App Store (collectively referred to as our “App” or “ShotX App”).
PLEASE TAKE THE TIME TO READ THIS PRIVACY POLICY THOROUGHLY. BY ACCESSING OR UTILIZING OUR SERVICE, YOU CONSENT TO BE BOUND BY THESE TERMS AND CONDITIONS, INCLUDING ALL TERMS INCORPORATED BY REFERENCE. IF YOU DISAGREE WITH ANY PART OF THESE TERMS AND CONDITIONS, YOU SHOULD NOT USE THE SHOTX APP.
If you reside in the European Union, you affirm that you have attained the legally required minimum age in your country for the processing of your personal data and possess the consent of a guardian or parent.
This Privacy Policy pertains to information (including personal information) collected through the ShotX App. For the purposes of this Privacy Policy, "personal information" is defined as data that identifies you personally, either alone or in combination with other available information. Personal information excludes technical, device, or usage data that cannot personally identify you, as well as "aggregate" data, which is information we gather about the use of the ShotX App or about a group or category of services or users from which individual identities or other personal information has been removed. This Privacy Policy does not restrict or limit our collection and use of aggregate and non-personal information, and we may share such data with third parties for various purposes.
Responsible Entity for Your Personal Data Processing
Sotalabs Technology JSC acts as the data controller for the collection and processing of your personal data. In the event of in-app purchases, Sotalabs collaborates with the payment service provider, each bearing its own responsibilities. For instance, the payment service provider, not Sotalabs, is responsible for processing your data for financial transactions and billing you for in-app purchases.
Information Collection Methods and Purposes
We collect certain personal information that you voluntarily provide to us. This may include your name, email address, username, and other information when you register, create an account, contact us by email, or use our services. We may also obtain information from other companies and combine it with the information we collect through the ShotX App; for instance, when you link your account with social media platforms, we may access your name.
User Content: We gather personal information included in any User Content you create, share, store, or submit to the App, which may comprise photos, written comments, data, texts, and interactive features generated, provided, or made accessible by the ShotX App.
Use of Technology to Collect Information: When you access the ShotX App via a mobile device, we may, through third-party integrations, receive or collect and store unique identification numbers associated with your device ("Device ID"), mobile carrier, device type and manufacturer, and, depending on your device settings.
Face Data Usage:
The ShotX App determines whether an image contains a face when a user selects that image.
The app uses this information to prompt the user to choose another image if no face is detected.
Sotalabs does not collect, store, or upload this face data.
Sotalabs does not share this face data with third parties.
Purposes for Data Processing and How We Use Your Personal Information
We use the personal information collected through the ShotX App for the following purposes:
To communicate with you or third parties, including payment service providers;
To process your requests and transactions;
To improve the ShotX App and to keep you informed about updates, upgrades, and notices concerning the App;
To personalize the services and/or products we offer you;
To assist with our product and service development;
For statistical analysis and understanding the usage of our services;
To detect and prevent abnormal use or fraud;
To implement necessary technical and organizational security measures to protect your personal data;
To comply with legitimate requests or orders from competent public authorities and courts, including data protection authorities.
For Users in the European Union: Legal Basis for Processing Your Personal Data
For the purposes mentioned above, Sotalabs relies on the necessity of processing your data for the execution of the contract with you for points a, b, c, and d. For points e, f, and g, Sotalabs invokes its legitimate interest. For points h and i, Sotalabs relies on legal obligations, including Article 32 of the GDPR, which pertains to the security of processing personal data.
Sharing Your Personal Information
Your personal information (and non-personal information) collected through the ShotX App may be shared with companies and organizations that provide services on our behalf, such as data management or support services like data storage and web hosting. We may also share your non-personal information with third parties to serve you relevant advertising and to market our products.
We may share your personal information with:
Other companies owned by or under common ownership with Sotalabs, including our subsidiaries and our ultimate holding company and its subsidiaries, who will use your personal information in the same manner as outlined in this Policy;
Third-party vendors, consultants, and other service providers who perform tasks on our behalf, which may include targeted advertising, content or service fulfillment, or analytics services;
Our business partners who jointly offer services with us, such as in co-sponsored contests or promotions;
Third parties we believe might offer you products or services you may enjoy;
Third parties at your request, such as when sharing User Content with friends through email, SMS, or social media;
The public at your request, such as when you interact with our app on social media by tagging your content with our branded hashtags, leading to potential public display of your User Content;
Other parties in connection with any company transaction, like a merger, sale of assets or shares, reorganization, or acquisition, as well as in bankruptcy or similar proceedings;
Third parties as necessary to comply with laws, regulations, court orders, or other governmental requests, enforce our Terms of Use, protect our rights or safety, and address fraud, security, or technical issues.
We may also share information in an aggregated and anonymous form that does not reasonably identify you as an individual.
Digital Advertising
We may collaborate with ad networks and ad serving providers ("Advertising Providers") that serve ads on our behalf and others on non-affiliated platforms. Depending on your settings, we may provide certain information to Advertising Providers to serve you with ads. This information may include, without limitation, age, gender, device identifiers, information about your use of the Services or other websites, and information about the advertisements viewed. To exercise your rights in this context, please utilize the relevant tools within the ShotX App settings. For security reasons, we can only respond to your request if you confirm it with your email address. If you request data correction, please specify which personal data are inaccurate and provide evidence of the inaccuracies.
Sotalabs may transfer your data to the USA if necessary for providing our services. The security of your personal data in such cases is governed by the EU-US Privacy Shield framework for certified recipients.
For Users in the European Union: Data Retention Period
We process your personal data as long as necessary for the purposes outlined above. Sotalabs will de-identify your personal data when they are no longer required for these purposes, unless:
A legitimate interest of Sotalabs or a third party in archiving your personal data in an identifiable form outweighs your interest in de-identification;
A legal, public authority, or court order prevents de-identification.
For California Residents and Users in the European Union: Your Data Processing Rights
You have the right to:
Request access to all personal data we process about you;
Request correction of any inaccurate, incomplete, or outdated personal data we process about you;
Object to the processing of your personal data for serious and legitimate reasons related to your specific circumstances;
Request deletion of all personal data we process about you when they are no longer necessary for the purposes for which they were collected;
Withdraw your consent for the processing of your personal data, bearing in mind that this request will be assessed against our overriding interests and any legal or judicial decisions that oppose erasure;
Request restriction of the processing of your personal data under certain conditions;
Obtain your personal data in a structured, commonly used, and machine-readable format and have the right to transfer them to another service provider (right to data portability).
To exercise these rights, please contact us at [insert contact email]. Some rights can also be exercised through the ShotX App settings. For security reasons, we can only address your request if you confirm it with your email address. If requesting data correction, please specify the inaccuracies and provide evidence.
Your right to object to direct marketing is unconditional and can be exercised by clicking the "unsubscribe" link in any promotional email we send.
We aim to respond to requests promptly. Please note that we may decline requests that are intended to cause harm or prejudice to Sotalabs or our affiliates, such as frequent unfounded requests in a short period. We may also assess your request for erasure against statutory or regulatory obligations that conflict with such erasure.
Data Transfer
In general, ShotX will not transfer your Personal Information to any third party.
Requesting Deletion of Your Personal Information
You are entitled to request the deletion of your Personal Information directly through the app.
You can initiate this process via the 'Delete Account' function located in the account management settings of the ShotX mobile app after logging in.
Alternatively, if you need assistance, please contact us at [email protected].
Upon processing your deletion request, all associated data including your email, username, and all media uploaded or generated by your account will be immediately removed from the ShotX database.
Links to Third-Party Websites
The ShotX App may contain links to third-party websites, including those of our business partners, advertisers, and social media sites. We do not accept responsibility or liability for the privacy policies of these websites. We encourage you to review their policies before submitting any personal information.
CALIFORNIA RESIDENTS
If you are a California resident, California Civil Code Section 1798.83 allows you to request information about the disclosure of your personal information by ShotX to third parties for direct marketing purposes. To make this request, please email [email protected].
California residents under 18 who are registered users of online sites where this policy is posted have the right under California Business and Professions Code Section 22581 to request and obtain the removal of content or information they have publicly posted. To exercise these rights, please use the relevant tools within the ShotX App settings. For security reasons, we can only address your request if you confirm it with your email address. If requesting data correction, please specify the inaccuracies and provide evidence.
Changes to this Privacy Policy
We may update this Privacy Policy periodically. If we make significant changes that affect your rights, we will post the updated policy on this site and update the "Last Revised" date below. We encourage you to review this Privacy Policy whenever you use the ShotX App to stay informed about how your personal information is used.
Last Revision Date
This Policy was last revised and is effective as of 15 May 2024.