Privacy Policy

This Privacy Policy describes how LINEROCK INVESTMENTS LTD. ("LINEROCK INVESTMENTS", "We", "Us", or "Our") protects your privacy when you use LINEROCK INVESTMENTS services ("Services") which includes the Web site located at pho.to the "Site") and all LINEROCK INVESTMENTS mobile phone applications ("Mobile").

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICE, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS DESCRIBED HEREIN AND ALL TERMS AND CONDITIONS INCORPORATED BY REFERENCE. IF YOU DO NOT AGREE TO ALL OF THE TERMS AND CONDITIONS SET FORTH BELOW, YOU MAY NOT USE THE LINEROCK INVESTMENTS SERVICES.

This Privacy Policy together with our Terms of Service applies to information (including personal information) collected during your use of LINEROCK INVESTMENTS services. For the purpose of this Privacy Policy, "personal information" means information that identifies you personally, either alone or in combination with other information available to us. Personal information does not include technical, device, or usage information that cannot be used to identify you personally, nor does it include "aggregate" information, which is data we collect about the use of the Services or about a group or category of Services or users, from which individual identities or other personal information have been removed. This Privacy Policy in no way restricts or limits our collection and use of aggregate and non-personal information, and we may share such data about our users with third parties for various purposes.

What Information We
Collect

We respect the privacy of every individual who uses our Services. We collect certain personal information that you voluntarily provide to us. For example, we collect your name, email address, user name, social network information and other information you provide when you register, set up an account, contact us by e-mail or use our services. See more in LOGIN DATA.

With your permission we may access and store photos and videos you provided while using our Mobile applications and Site. See more in SERVICE DATA.

LOGIN DATA

In order to share your content within our apps and services where such an option is provided you will be asked to log in.

If you set up your account in one of our apps via Facebook, Apple ID, or other third-party accounts, we use information from those accounts, like name, email address, user name, social network information and other information you provide when you register.

The login information stored by us will be removed when you delete the account.

You can always request the removal of your account and all related data by contacting our support team. See more in REMOVE YOUR PERSONAL INFORMATION.

TECHNICAL INFORMATION

When you use a website or mobile application like ours, certain internet and network activity information gets generated and logged automatically. These are the types of technical information we collect:

Log data. Our servers passively keep an electronic record of your interactions with our Site or Services or Mobile apps, which we call "log data". For example, when you visit our website, sign into our services, or browse content, we collect data about these interactions that includes, but not limited to, the information on where you navigate within our website and apps, your IP address, browser type and settings, the date and time of your visit, search terms, which elements of our site and services you use the most, device information, and cookie data. We use log data to operate our services, maintain security, ensure reliable performance, and improve your experience.

Cookie data. We use "cookies" and similar technologies to collect log data and operate our services. You can learn more about how we use cookies in "COOKIES" below.

Device data. We collect and combine data about the devices you use to access our Mobile apps and Services, including, but not limited to, device type and model, operating system, time zone, app store country, battery level, device usage and activity.

Metadata of visual information. We collect the metadata linked to your content. For example, your images may be accompanied by additional content like a hashtag (e.g., to mark keywords), comments. This makes your content more searchable by others and more interactive.

All this information is only used to assist us in providing an effective service. We may, from time to time, supply the owners and operators of third party websites and mobile applications which have a link to our site or application with general download and usage statistics on our Services or Mobile apps. You cannot be identified from any of this information unless your or other users’ actions within our Services reveal your identity directly or indirectly (e.g. an image you upload contains a reference to your name or social network; or another user adds a comment with your name under your photo).

SERVICE DATA

To use our Services, you should provide a photo or video prior to the event of photo or video editing. Since the processing requires Internet connection and is performed on our servers the photos and videos are sent there through the encrypted connection. We use Secure Socket Layer technology to protect the privacy and integrity of the transmission process.

For non-registered users and users who don’t share their results within the Services, the original photos and results are automatically removed from our servers by two weeks after the last interaction. For registered users who share their results within the Services that provide special social network features, the shared results and original photos or videos associated with them will be stored on the servers and shown within the Services unless a user either removes the images themselves or requests such a removal by contacting our support team.

In addition, most of the Services involve facial recognition mechanism, which is used in two ways:

• Locally on your device. Provided that the access to Gallery is granted we use facial recognition mechanism to scan your Gallery for facial photos and group them. This makes part of the recommendation system and can also be used in other ways with the only aim to improve your experience within the Service. The detected facial key points are stored on your device and will be removed either (1) when you delete the Service or clear the Service data, (2) until the initial purpose for the collection of this data has been satisfied, or (3) within three years after your last interaction with the Service, whichever comes first.
• On the server. Whenever you apply an effect that involves a face manipulation we use other special face recognition technologies on the server side in order to:
  - detect a face in a photo;
  - find required facial key points (the set of points varies with the effect);
  - and apply the effect to your photo based on the detected key points.

In this case the key points are temporarily cached in server’s RAM between the processings and get removed shortly after the last effect has been applied to the corresponding photo.

Furthermore, when an effect implies, our Service may involve figure (silhouette) detection, head position detection, independent facial zones, skeleton key points (e.g. neck, shoulders, wrists) detection, and image depth map generation. The only aim of getting the data is to accurately apply the effect entailing the corresponding technology. Maximum store period for this kind of data is one hour from the last interaction (i.e. the application of an effect with such a requirement).

While a photo or video is stored on our servers, we may apply additional effects to them to demonstrate different functionalities of the app to you inside the app and through available personal channels of communication (like email, push-notifications, etc.).

The detected facial key points and other data that can be obtained when an effect implies, will not be collected or otherwise obtained without prior consent of the individual which is expressed in providing access to the Gallery.

In circumstances where We retain the detected facial keys points and other data that can be obtained when an effect implies, We will use a reasonable standard of care to store, transmit and protect from disclosure any data collected. Storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which We store, transmit and protect from disclosure other confidential and sensitive information that is used to uniquely identify an individual, including Login data, like email address.

Cookies

When you visit our Sites we automatically collect certain information through the use of "cookies". Cookies are small data files that are stored locally. We use cookies to collect information about your device, including where available your IP address, operating system and browser type, for system administration and to report information to our branded partners.

We may store some information locally when you visit our Sites. This information facilitates your use of the Sites, personalizes your experience, and helps us to remember your preferences. The information stored in a cookie provides features that recognize your account as logged in and other Sites’ features. We do not have any control over cookies which our advertisers or branded partners may use.

Security

The technology that we use and the policies that we have implemented are intended to safeguard your privacy from unauthorized access and improper use. We will continue to update these measures as new technology becomes available. However, we cannot guarantee that unauthorized third parties will not be able to defeat our security measures. If you use a password on our Services, you are responsible for keeping it confidential. Do not share it with any other person. If you believe your password has been misused or your account compromised, please advise us immediately.

How We Use Your
Personal Information
And Service Data

We use personal information and service data collected through the Services:

• to communicate with you;
• to process your requests and transactions;
• to improve the Services;
• to customize the services and/or products we provide to you;
• to assist with our product and service development;
• and for other purposes related to our business.

With Whom We Share
Your
Personal
Information
And Service Data

Personal information (and non-personal information) collected through the Services may be shared with companies and organizations that perform services on our behalf (for example, companies that provide data management or other support services to us such as data storage and Web hosting services). We may share your log data (without revealing personal information) with third parties to serve you relevant advertising (learn how advertising partners collect and use data) and market our products.

Also, we do not disclose the personal information we collect through the Services unless:

• you or your legally authorized representative consents to the disclosure;
• the disclosure or is required by State or federal law or municipal ordinance;
• the disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

We do not disclose your images or videos, which you have uploaded for editing and manipulation to any of the Services unless you share them (along with the results) yourself at our Site, Mobile and other Services, or at third party services.

Your personal information and other data collected by us may be transferred to another company that has acquired our stock or assets, for example, as a result of a sale, merger, reorganization, dissolution or liquidation. If such a transfer occurs, the acquiring company's use of your personal information will still be subject to this Privacy Policy.

Modifying Your

Information —
Opt-Out/
Opt-In

We respect your right to make choices about the ways we collect and use your personal information. You may update or modify your information or change your privacy preferences at any time via our Services. You may opt out of receiving promotional communications from us, including, but not limited to, promotional emails, by clicking a special unsubscribe link in the e-mail or other Content from us. Transactional service communications (such as messages about your registration) are not subject to the foregoing opt-out procedures. Requests to disable your account or reset your password should be sent to support@pho.to for faster processing.

Remove
Your
Personal
Information

You can delete your account from within the Mobile app via the About section. Once your account is deleted all associated content and data will get removed as well.

If you connect your Facebook, Apple ID, or other third-party accounts to one of our apps, you can choose to stop sharing this information with us at any time by going to Facebook or other third-party accounts and unlinking your account from our app. Please note that unlinking the account won’t delete your personal data in our Mobile app or Service.

If you for any reason lost access to your account, to completely delete your account and all associated content and personal data please contact our support team at support@pho.to.

Links, Hosted Sites
&
Advertisers

We do not have any control over the privacy practices of any external websites linked from the Site or Mobile (or any of the websites that are hosted on our server and aren't affiliated with us). Therefore, you should review their privacy policies separately from ours and know that we in no way have any control over their practices.

Third party advertisers may collect certain information that is available to them through your interaction with their advertisements. LINEROCK INVESTMENTS has no control or knowledge as to their practices and it is suggested that you read their privacy policy separately before clicking on any advertisements.

CHANGES TO THIS
PRIVACY
POLICY

We may change this Privacy Policy from time to time. If we make any changes to this Privacy Policy that we think materially alter your rights, then we will post the latest policy to this site. We encourage you to review this Privacy Policy whenever you visit the Services to understand how your personal information is used.

QUESTIONS

If you have any questions about this Privacy Policy, please contact us via support@pho.to.