Introduction

How Remini protects your images and other data

We want to help you understand how Remini processes your personal data, as well your options when it comes to managing it. It’s important that you also understand how Remini protects your images and videos.
You’ll find all this information in our privacy policy, which is below.
The following bullets highlight a few key details about the app and our security measures:
  • Remini is a photo- and video-editing app. It enhances photos and videos by improving aspects such as image resolution and colors. Also, it gives you the ability to generate new images with AI.
  • Remini's technologies are not used to identify or authenticate people in the images or videos.
  • You retain control over the images and videos you upload, enhance, and generate using Remini. We don’t sell, trade, or claim ownership of any of your images or videos—no matter whether you use Remini to edit your existing images or videos or to generate new ones.
  • Your images and videos aren’t used to train our AI technologies, unless you explicitly opt in for that.
  • Your images and videos are safeguarded with appropriate security measures, following privacy and data protection laws and industry standards. This includes encryption and cloud storage for enhanced security.
To know how we process your personal data when using Remini, please refer to the privacy policy.

Privacy policy

We’re Bending Spoons S.p.A. (“we” or “us”), the parent company of Splice Video Editor S.r.l. With this privacy policy, we’ll explain how we process the personal data of users (“user” or “you”) of the Remini mobile application (“app”), or those who otherwise interact with us. 
We provide this privacy policy in accordance with Regulation (EU) 2016/679–General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), and other applicable local laws, as amended or replaced (collectively, “applicable privacy laws”). If you’re using an app version older than iOS 14, you should refer to this version of the privacy policy.
Last updated: September 25, 2024
Contact details
Bending Spoons S.p.A. is the data controller. We’re an Italian tech company based in via Nino Bonnet 10, Milan, MI 20154. 
For any requests about how we use your personal data, you can email us or our Data Protection Officer by following these steps: 
  1. Access the app from your device (you can download and access it without purchasing a subscription)
  2. Long press four fingers on any screen within the app until a menu appears
  3. Tap Send a Privacy Request and follow the instructions
After following this process, you may uninstall the app if you’d prefer to.
Types of data, how data is used, and retention: Activities that we perform by default when you use the app
The following activities are always performed when you use our app. This means that if you decide to access the app and make use of its features, your personal data will be used for the purposes listed in this section. If you choose not to provide your personal data, you won’t be able to use the app.

a) Service delivery

We use your personal data to enable you to use the app, and to provide you with its functionalities. Examples of using the app include editing and enhancing your photos and videos, and generating AI images of yourself. Examples of the functionalities provided include the information shown to you about the app and your editing process, and the suggestions made about the best photos or videos  to edit.
Categories of data. The following data is used:
  • User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
  • Device information (such as device model, device type, OS version, device language, device name, and region)
  • Information about your subscription
  • Information about your interaction with the app
  • Images and videos that you upload, and images and videos generated by the app (such as enhanced photos and videos and AI images). To edit photos and videos or generate AI images, the app needs access to your library and your camera. You have to expressly allow this access through the request pop-up that appears on your device. When you allow access to your library and upload the first image for AI generation, Remini may find and automatically select other images in your gallery that feature the same person represented in the uploaded image. Until you decide to upload such images, the images don’t leave your device and are not stored on our servers.
  • Metadata and other information extracted from the images that you upload for enhancement (for example, gender, age, skin tone)
  • Information about faces in the images and videos you upload, including, for example, information that estimates the location and shape of facial features (”face data”). Depending on the applicable law of your jurisdiction,  face data may be considered biometric data.  We use face data only to enhance your photos and videos and create the AI images you request, unless you specifically consent to other processing of this data. In no instance does Remini process face data to identify or authenticate people in images or videos you upload.
Legal basis. These activities are based on the contract we have with you (Article 6.1.b GDPR). However, if you upload images that include people other than yourself, the activities described above are based on your legitimate interest in using the app (Art. 6.1.f GDPR). The processing of face data to perform these activities is based on your consent (Article 9.2.a GDPR). If you upload images that include minors, you as the holder of parental responsibility also consent to the processing of face data related to them.
Storage. We apply different retention periods depending on the categories of data and the purposes it is used for.
Enhancement:
  • Images and videos that you upload and enhanced images and videos are deleted after one (1) day from upload or enhancement.
  • Face data processed to enhance your photos and videos is deleted immediately after the enhancement.
AI generation:
  • Images and videos that you upload are retained for up to twenty (20) days (if you have a subscription to Remini) or up to seven (7) days (if you do not have a subscription to Remini) from your most recent use of the Remini feature to generate AI images. In any case, they will be deleted after two (2) years from the upload.
  • Face data processed to generate AI images are retained, in order to ensure the functioning of Remini's generative AI features, for up to twenty (20) days (if you have a subscription to Remini) or up to seven (7) days (if you do not have a subscription to Remini) from your most recent use of the Remini feature to generate AI images. In any case, it will be deleted after two (2) years from the generation.
  • AI images generated by Remini are retained for up to seven (7) days from the generation.
After the retention periods indicated above, the data will be deleted from our servers and those of our service providers, unless you have specifically consented to other processing of this data.
We retain the other categories of personal data described above for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. After this period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

b) Customer support

We use your personal data to send you administrative and technical updates, and to process and respond to your customer support requests and any other communications you send us.
Categories of data. The following data is used:
  • Identifiers (such as name and email address)
  • The content of your communication
Legal basis. This activity is based on the contract we have with you (Article 6.1.b GDPR).
Storage. We retain personal data processed for this purpose for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the data retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

c) Service improvement

Your personal data may be used to improve and develop our products and services. For example, we may process your data to conduct statistical analyses or other research activities to optimize our features and provide you with new ones.
Categories of data. The following data is used:
  • User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
  • Device information (such as device model, device type, OS version, device language, device name, and region)
  • Information about your subscription
  • Internet and network activity information (such as IP address, and information about network usage, Internet connectivity, latency, failures, crashes, and error logs)
  • Information about your interaction with the app
  • Inferences we generate and other related information about your use of and experience with the app (such as your responses to in-app surveys and your feedback if you take part in our interviews)
  • Metadata and other information extracted from the images that you upload for enhancement (for example, gender, age, skin tone)
  • Your gender (if you choose to share this information with us)
Legal basis. These activities are based on our legitimate interest to improve our products (Article 6.1.f GDPR). You can find information concerning the collection of personal data through analytics tracking technologies in the section In-app tracking technologies.
Storage. We retain personal data processed for this purpose for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

d) Troubleshooting

We use your personal data to ensure the quality and the proper functioning of our apps by analyzing, preventing, and correcting failures and bugs, and to prevent the illicit use or misuse of the app.
Categories of data. The following data is used:
  • User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
  • Device information (such as device model, device type, OS version, device language, device name, and region)
  • Internet and network activity information (such as IP address, and information about network usage, Internet connectivity, latency, failures, crashes, and error logs)
  • Inferences we generate about your usage of the app
Legal basis. These activities are based on our legitimate interest to ensure the quality and the proper functioning of our service (Article 6.1.f GDPR). 
Storage. We retain personal data used for this purpose for a maximum of one (1) year from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

e) Profiling

We analyze information about you and the way you use the app to create your user profile. We use the user profile to improve our products, develop new features, and provide you with relevant offers and a customized in-app experience. For example, we may use your data for the following activities:
  • To conduct user experience research activities (such as A/B testing)
  • To customize offers and the in-app experience
  • To conduct in-app surveys
  • To measure the effectiveness of our advertising campaigns and make them more relevant
  • To customize information and marketing communications
Categories of data. The following data is used:
  • User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
  • Information about your interaction with the app
  • Inferences we generate about your use of and experience with the app
  • Your answers to the surveys and the data included in such answers
  • Your gender (if you choose to share this information)
Legal basis. These activities are based on our legitimate interest to improve and customize our services (Article 6.1.f GDPR).
Storage. We retain personal data used for this purpose for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.
Types of data, how data is used, and retention: Activities that we perform only with your consent
When performed, the following activities are performed only with your consent. This means it’s up to you to decide whether or not to provide your personal data, and you have the right to withdraw your consent at any time. If you choose not to provide your data, you’ll still be able to enjoy the app's services and features.

a) Editing Improvement & AI training

In some jurisdictions, only with your consent, we may use personal data to improve our photo-video editing and generative features in Remini and other apps provided by us and our subsidiaries and to offer a better service. For example, we may use your images and videos to train and validate our photo-video editor algorithms.
Categories of data. The following data is used:
  • Images and videos you upload
  • Face data processed to generate AI images
  • Enhanced images and videos and AI images generated by Remini 
While face data may be considered biometric data in some jurisdictions, the technologies we implement in the app don’t identify or authenticate people in the images or videos you upload, nor are we training our technologies to do so. We don’t collect or use face data of US-based users to improve our photo-video editing and generative features, nor to train our photo-video editor algorithms.
Legal basis. Where this activity is performed, it is based on your consent (Article 6.1.a GDPR and Article 9.2.a GDPR). Without your explicit consent, we don't perform this activity. You can check and update the permissions you've granted at any moment in the app’s privacy settings.
Storage. When we retain images and videos that you upload, face data, images and videos enhanced, and AI images generated by Remini for the purpose of improving our photo-video editing and generative features, this data is retained for a maximum of one (1) year from the collection. After this period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

b) Image generation improvement

Only with your consent, when you report issues about the AI generation, we may use your images and videos to check and rectify the reported issues and improve the generation of future images.
Categories of data. The following data is used:
  • Images and videos you upload when reporting issues about the AI generation
Legal basis. This activity is based on your consent (Article 6.1.a GDPR).
Storage. We retain the data used for this purpose up to thirty (30) days from the upload.

c) Marketing

We use your personal data to carry out marketing activities and to send you information and marketing communications about our apps (such as tips, offers, and newsletters) through emails and push notifications.
Categories of data. The following data is used:
  • User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
  • Information about your interaction with the app
  • Inferences we generate about your use of and experience with the app
We’ll send you push notifications only if you grant the relevant permission by enabling push notifications on your mobile operating system settings.
Legal basis. These activities are based on your consent (Article 6.1.a GDPR). Without your explicit consent, we don't perform these activities. You can check and update the permissions you've granted any moment in the app’s privacy settings. When we use your email to send you information about products and services related to or similar to the app (“soft opt-in”), the legal basis is our legitimate interest (Article 6.1.f GDPR).
Storage. We retain personal data used for this purpose for a maximum of two (2) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

d) Targeted advertising

We use third-party tracking technologies to serve you personalized ads. You can find more information on how these third parties use your personal data by reading their privacy policies linked in the section In-app tracking technologies.
Categories of data. The following data is used:
  • User identifiers (such as Apple ID) and mobile identifiers (such as IP address, IDFA, AAID, device identifiers, and custom identifiers)
  • Information about your interactions with the app
  • Advertising data (such as ad conversion information and advertisements seen)
  • Your ad tracking choices and consent to receive personalized ads (if granted), and inferences about your interests and preferences
IDFA (on iPhone or iPad) and AAID (on Android devices) are unique device identifiers provided by the operating system that allow advertisers to track and identify a user for advertising purposes. You can turn off this tracking from your mobile settings by following these steps:
  • On iOS and iPadOS 14.5, go to Settings > Privacy & Security > Tracking and tap to turn off or turn on “Allow Apps to Request to Track” or “Permission to Track” for a specific app. On previous iOS or iPadOS versions, go to Settings > Privacy > Advertising and turn on “Limit Ad Tracking.”
  • On Android devices, go to your device's Settings app or the Google Settings app > Services > Ads and turn on “Opt out of Ads Personalization.”
Legal basis. The collection of your personal data through third-party profiling tracking technologies is based on your consent (Article 122 of the Italian Privacy Code). To learn more, see the section  In-app tracking technologies.
Storage. To learn more about the retention period of the data used for this purpose, see the third parties’ privacy policies linked in the section In-app tracking technologies.
Types of data, how data is used, and retention: Activities that we perform only in extraordinary circumstances
Although it doesn’t happen by default, your personal data may be processed in certain extraordinary circumstances that aren’t related to the functioning of the product. These extraordinary circumstances are as follows:

a) Extraordinary circumstances: For compliance with legal obligations

Your personal data may be used to comply with our legal obligations, including requests from public authorities, and to prove that we have complied with them, such as in the event of a request from a public authority.
Categories of data. We may process any kind of information that may be required by law or under the instructions of public authorities.
 
Legal basis. When this activity is required by a specific legal obligation, your personal data may be used to the extent required to comply with the legal obligation itself (Article 6.1.c GDPR). When the applicable law leaves some discretion in assessing the appropriate way to comply with it, your personal data is used based on our legitimate interest to prove our compliance (Article 6.1.f GDPR).
Storage. We retain personal data used for this purpose for a maximum of five (5) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.

b) Extraordinary circumstances: For defense

Your personal data may be used to establish, exercise, or defend our rights and those of our employees, and to carry out corporate transactions or operations. For example, your data may be processed in the event of bankruptcy, merger, acquisition, reorganization, and sale of assets or assignments, and the due diligence related to any such transactions.
Categories of data. We may process any kind of information necessary to ensure the correct execution of the activity.
Legal basis. This activity is based on our legitimate interest to establish, exercise, or defend our rights, and to carry out corporate transactions or operations (Article 6.1.f GDPR).
Storage. We retain personal data used for this purpose for a maximum of ten (10) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.
Recipients of your data
Your personal data may be transmitted to trusted and reliable third parties. This happens only when there are lawful grounds for the transmission. We don’t sell your data, including your images, to third parties under any circumstances.
The types of third parties to which your data may be transmitted are as follows:
  • Third parties that carry out activities related to our business and operations. Such parties can operate either on our behalf as data processors (for example, IT or storage service providers) or as autonomous data controllers (for example, professional advisors providing advice or otherwise protecting and managing our business interests).
  • Third parties that collect personal data about you to show personalized advertising (if you consent to the installing of tracking technologies). To learn more about their activities, see the third parties’ privacy policies linked in the section In-app tracking technologies.
  • Advisors and new owners, in the event that we carry out a corporate transaction or operation such as a merger, acquisition, reorganization, sale of assets or assignments, and as a part of the associated due diligence.
  • Public, judicial, or police authorities, within the limits established by applicable laws.
  • Other parties as necessary (for example, competent authorities), if we have reason to believe that your actions are inconsistent with our user agreements or policies or that you’ve violated the law, or if it’s necessary to protect our rights, property, and safety or that of our users, the public, or others.
Additionally, we may share your personal data if it’s required for the fulfillment of a legal obligation, or if you give us your consent to do so.
Transfers of data outside the European Economic Area
Bending Spoons is located in Italy. Sometimes, we may transfer your personal data outside the European Economic Area (“EEA”). When we do so, the transfer is always based on appropriate safeguards in accordance with applicable privacy laws, including the standard contractual clauses developed by the European Commission, the decisions of adequacy of the European Commission, or binding corporate rules.
If you want to know more about the safeguards in place for the transfer of your data, you can contact us by following these steps: 
  1. Access the app from your device (you can download and access it without purchasing a subscription)
  2. Long press four fingers on any screen within the app until a menu appears
  3. Tap Send a Privacy Request and follow the instructions
After following this process, you may uninstall the app if you’d prefer to.
Your Rights
You can always retain control of your personal data. Depending on your location, you have certain rights in relation to your data that you can exercise at any time and without charge, in accordance with the limitations and exceptions stated by the applicable privacy laws. These include the following:
  • Right to access and receive a copy of information about the processing of your personal data (access).
  • Right to request that your personal data be updated, rectified, or integrated (rectification).
  • Right to request that your personal data be deleted (erasure).
  • Right to request that processing of your personal data be restricted (restriction of processing).
  • Right to receive a portable electronic copy of your personal data (data portability).
  • Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing in whole or in part (objection). In particular, you have the right to object to the processing of your personal data for direct marketing, including profiling.
  • Where we rely on your consent to process your personal data, you have the right to withdraw your consent (consent withdrawal). If you do so, the processing carried out before your withdrawal will remain valid, but thereafter we’ll no longer process your data for that purpose.
You also have the right to complain before the competent national data protection authority, or any other applicable regulator in the jurisdiction where you reside, in the event that you think we’ve violated the applicable privacy laws and we haven’t addressed your request.
To exercise your rights, you can submit a request directly within the app by following these steps: 
  1. Access the app from your device (you can download and access it without purchasing a subscription)
  2. Long press four fingers on any screen within the app until a menu appears
  3. Tap Send a Privacy Request and follow the instructions
After following this process, you may uninstall the app if you’d prefer to.
  • We may take some reasonable steps to verify your identity before responding to your request, such as asking you for information and making sure it matches the data available to us. If you submit a request to exercise a right as an authorized agent, we may ask you to provide proof of your authorization or we may contact the subject of the request for confirmation, in accordance with applicable privacy laws.
    • If you consent to the installing of tracking technologies, third parties will collect personal data about you so they can show you personalized advertising. We have no control over the third parties and the way they handle the data they collect. To exercise your rights in relation to such data, reach out directly to the relevant third parties as per the privacy policies linked in the section In-app tracking technologies.
    You won’t be discriminated against for exercising your privacy rights. 
    Children’s data
    The app isn’t meant to be used by people under the age of 16. We don’t knowingly collect personal data from children. If you believe that we’ve received personal data from children under the age of 16, please contact us by following these steps: 
    1. Access the app from your device (you can download and access it without purchasing a subscription)
    2. Long press four fingers on any screen within the app until a menu appears
    3. Tap Send a Privacy Request and follow the instructions
    After following this process, you may uninstall the app if you’d prefer to.
  • If we learn that a user is under the age of 16, we’ll take reasonable steps to delete any processed data and close the associated account.
    • Third-party websites and services
    The app may include links to other websites or services operated by third parties. The activities described in this privacy policy don’t apply to data processed by third-party websites and services. We’ve got no control over, and we're not responsible for, the actions and privacy policies of third parties and other websites and services.
    Additional information for users in California
    In California, there are consumer privacy laws that grant their residents certain rights and that require additional disclosures (“state laws”). If you’re a resident of California, this section applies to you.
    We collect personal information from several sources, as follows:
    • Directly from you (for example, your selections when you make an in-app purchase or participate in a survey)
    • Automatically from the app when you use it (for example, your device information when you open the app)
    • From other sources (for example, from mobile measurement partners to determine marketing campaign performance) 
    We generate inferences about you based on your use of the app and other information we collect.
    In the past 12 months, we’ve collected the following categories of personal information:
    • Identifiers
    • Internet or other electronic network activity information
    • Characteristics of protected classifications under California or US federal law (such as gender if you submit that answer in a survey)
    • Commercial information (such as in-app purchases)
    • Approximate geolocation information (such as the country you’re in)
    • Audio and visual information (such as the photos and videos you upload to the app)
    • Inferences and other information that relate to or are reasonably capable of being associated with you
    For details about the personal information we collect, please see the section Types of data, how data is used, and retention. We collect personal information for the business and commercial purposes listed in the chart in the section Types of data, how data is used, and retention.
    We may disclose your personal information with the categories of third parties as described in the section Types of data, how data is used, and retention.
    In the past 12 months, we’ve disclosed the following categories of personal information for business purposes:
    • Identifiers
    • Internet or other electronic network activity information
    • Characteristics of protected classifications under California or US federal law (such as gender if you submit that answer in a survey)
    • Commercial information (such as in-app purchases)
    • Approximate geolocation information (such as the country you’re in)
    • Audio and visual information (such as the photos and videos you upload to the app)
    • Inferences and other information that relate to or are reasonably capable of being associated with you
    We disclose the following categories of personal information to third parties for the purpose of engaging in targeted advertising (these disclosures may be considered “sales” or “sharing” under certain state laws).
    Categories of personal information “shared,” “sold,” or used for targeted advertising:
    • Identifiers 
    • App usage
    • Diagnostic information
    • Inferences
    Categories of third parties: 
    Advertising and marketing partners.
    We don’t knowingly collect, sell, or share personal data about users under the age of 16.
    We don’t collect information that’s considered “sensitive” under state laws, except in certain extraordinary circumstances. In these extraordinary circumstances, we don’t use or disclose sensitive personal information to make inferences about your characteristics.
    We retain personal data as described in the section Types of data collected, how this data is used, and data retention periods.
    Right to opt out of sales, sharing, targeted advertising
    Some of the activities described in this privacy policy may be considered “sales” or “sharing” of your personal information, or use of your information for “targeted advertising” under the law that applies to you. You or your authorized agent may opt out of these activities by following the instructions in the section In-app tracking technologies.
    Access, correction, and deletion
    Your rights include the following:
    • Right of access. You have the right to access and receive a copy of information about the processing of your personal data.
    • Right to rectification. You have the right to request that your personal data be updated, rectified, or integrated.
    • Right to erasure. You have the right to request that your personal data be deleted.
    For details about how to exercise your rights, please see the section Your rights.
    Additional information for users in Illinois
    In accordance with Illinois law, this section provides additional disclosures related to face data. As described in the section Types of data collected, how this data is used, and data retention periods, we collect and process face data to enhance your photos and videos and generate AI images. We don’t collect or use face data to improve our generative features nor to train our photo-video editor algorithms. We retain personal data as described in the section Types of data collected, how this data is used, and data retention periods. We use cloud storage providers to store face data. We’ll never sell, lease, or trade face data to third parties. As described above, face data may be considered biometric data in some jurisdictions. Face data is not used to identify or authenticate individuals in the photos and videos you upload.
    Changes to this privacy policy
    We may modify, integrate, or update—in whole or in part—this privacy policy. We’ll notify users of any modification, integration, or update in accordance with applicable privacy laws.
    If we make modifications, we’ll notify you by revising the date at the bottom of this privacy policy and, under certain circumstances, we may also notify you by additional means (such as via email, pop-up, or push notification).
    In-app tracking technologies
    When we refer to “tracking technology” or “tracking technologies” in this policy, we mean any technology that stores or accesses information on the user’s device, including SDKs, tracking pixels, HTML5 local storage, local shared objects, and fingerprinting techniques. 
    Tracking technologies are usually classified by purpose (technical, analytics, profiling) and by publisher (first-party, third-party). The legal requirements vary based on these classifications.
    The tracking technology classifications and some practical examples now follow.

    By purpose

    Technical tracking technologies
    These are used to transmit messages over an electronic communication network or to provide a service specifically requested by the user. Therefore, they’re necessary for the app to function correctly, and for providing the service requested by and offered to the user. 
    For example, technical tracking technologies can be used to monitor sessions, store specific server access information related to the user configuration, facilitate the use of online content, keep track of items in a shopping cart, or keep track of information used to fill in a form.
    As technical tracking technologies are necessary, they don’t need your consent.
    Analytics tracking technologies
    These are used to assess the effectiveness of an information society service provided by a publisher, evaluate and improve the design of an app, or help measure traffic. In other words, they serve to track the traffic and performance of an app by collecting aggregate data on the number of users and how they interact with the app, which helps to improve its services. 
    For example, analytics tracking technologies may collect information about how users access an app, including the number of users and potentially grouped by geographical area, time zone, how long they stay on the app, which parts of the app they interact with, and the number of users who used a particular feature.
    Normally, analytics tracking technologies are used only with your explicit consent. However, in the following cases they’re treated like technical trackers, so don’t need your consent:
    • When they’re used only to produce aggregated statistics that are performed through the controller’s own resources and that don’t turn into activities that go beyond statistical counting and assisting business-related decision-making
    • When the third parties don’t match the analytics trackers' data with any other information, and don’t send any data gathered to other third parties
    Profiling tracking technologies
    These are used to evaluate some personal aspects of certain users, and to trace specific actions or recurring behavioral patterns in the use of the app in relation to specific, identified or identifiable individuals, so they can be grouped within homogeneous, multi-sized clusters. This enables the company to analyze and predict personal elements, provide users with customized services beyond what’s strictly necessary for the delivery of the service, and sending targeted advertising messages in line with the preferences they express during their in-app activities. These serve to convey behavioral advertising, measure the effectiveness of ads, and customize the services offered in line with the user’s monitored behavior.
    For example, profiling tracking technologies can be used for the following activities:
    • To create user profiles and offer content in line with the user’s interests
    • To send targeted ads or messages
    • To conduct statistical analysis or other research activities to improve our products and services and measure the effectiveness of our campaigns 
    Profiling tracking technologies are used only with your explicit consent. 

    By publisher

    First-party tracking technologies
    These are installed and managed directly by the owner of the app (in this case, Bending Spoons S.p.A). As the owner, we process the collected data for our own purposes.
    Third-party tracking technologies
    These are installed and managed by different apps or developers, either for our purposes or for those of the third party.
    The data collected by the third parties for their own purposes is governed by their specific privacy policies and terms and conditions. For further information about these data processing activities, you can directly refer to the privacy policy of the relevant third parties as indicated in the subsection Types of tracking technologies used by the app.
    Third-party tracking technologies need your consent, unless they’re anonymized and only used for analytical purposes. You can manage consent at any time from within the app’s privacy settings.

    Types of tracking technologies used in the app 

    The table below outlines the trackers used in this app. If you can't see the table in full, we suggest rotating your device to landscape mode for better visibility. Alternatively, you can view the full table on your computer by following this link.
    Name & Purpose
    Retention period
    Type of publisher 
    Description
    Remini SDK (technical)
    Technical
    3 years.
    See the section Types of data, how data is used, and retention for more details.
    First-party
    Our internal software development kit (SDK). It’s necessary for the app to function correctly.
    Firebase Crashlytics
    Technical
    3 years.
    See the section Types of data, how data is used, and retention for more details.
    A tool provided by Google that’s necessary for the app to correctly interact with the backend and provide you with key features. 
    Firebase Dynamic Links
    Technical
    3 years.
    See the section Types of data, how data is used, and retention for more details.
    A tool provided by Google that’s necessary for the app to correctly interact with the backend and provide you with key features. 
    FirebaseAuth
    Technical
    3 years.
    See the section Types of data, how data is used, and retention for more details.
    A tool provided by Google that’s necessary for the app to correctly interact with the backend and provide you with key features. 
    Remini SDK (statistical analytics)
    Analytics
    3 years
    First-party
    Our internal software development kit (SDK). It allows us to produce aggregated statistics.
    Firebase
    Analytics
    3 years
    A tool provided by Google that’s necessary for the app to work properly. When analytics features are enabled, it can help us to improve app traffic and performance.
    Remini SDK (profiling)
    Profiling
    3 years
    First-party
    Our internal profiling software development kit (SDK). It allows us to provide customized services.
    Firebase
    Profiling
    3 years
    A tool provided by Google that’s necessary for the app to work correctly. When profiling features are enabled, it can help us to measure the effectiveness of our ads.
    Adjust
    Profiling
    3 years
    A mobile attribution tool. It helps us to measure the effectiveness of our ads.
    AppLovin
    Technical/ Profiling
    Defined by the third party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Unity
    Technical/ Profiling
    Defined by the third party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Meta Audience Network
    Technical/ Profiling
    Defined by the third party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Pangle (Android only)
    Technical/Profiling
    Defined by the third party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Mintegral
    Technical/Profiling
    Defined by the third party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    IronSource
    Technical/Profiling
    Defined by the Third Party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Vungle
    Technical/Profiling
    Defined by the Third Party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Fyber
    Technical/Profiling
    Defined by the Third Party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    Google Mobile Ads (AdMob)
    Technical/Profiling
    Defined by the Third Party
    A tool that allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.
    The advertising network services (ad networks) used by the app are not operational in China.

    Tracking technologies settings

    You can turn on or turn off—in whole or in part—profiling and third-party analytics tracking technologies at any time through the app’s privacy settings. As for Meta Audience Network SDK, if you’re an Android user, you can manage your choices directly on Meta's website.
    When you withdraw consent, your data will no longer be collected through those trackers. However, we’ll continue processing the data collected before the withdrawal.
    You can’t turn off first-party analytics tracking technologies—they’re treated like technical trackers, so aren’t contingent on consent. However, you can opt out of the further processing of your data that’s been collected via these trackers. To do so, contact us by following these steps: 
    1. Access the app from your device (you can download and access it without purchasing a subscription)
    2. Long press four fingers on any screen within the app until a menu appears
    3. Tap Send a Privacy Request and follow the instructions
    After following this process, you may uninstall the app if you’d prefer to.
    With regards to your rights under applicable Data Protection Laws, please refer to the section Your rights.

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