Privacy Policy
This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) of the Arin - AI Chatbot mobile application (“app”) by Bending Spoons S.p.A. (“we” or “us”), the parent company of Splice Video Editor S.r.l., 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 (jointly, “Applicable Privacy Laws”).
1. Data Controller and Data Protection Officer
The Data Controller is Bending Spoons S.p.A., based in Via Nino Bonnet 10, Milan, MI 20154 (Italy), VAT 08931860962. For any requests regarding the processing of your personal data, please email us at privacy@bendingspoons.com.
Our Data Protection Officer can be contacted by sending an email to dpo@bendingspoons.com for any requests relating to the processing of your personal data or this Privacy Policy.
2. Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing
We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.
| Purpose | Legal Basis | Categories of Processed Data |
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The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR). | Identifiers and internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, and unique identifiers, including IDFA or AAID), and other information necessary to enable you to use the app. We also process the content data included in the input to execute your request and return the generated output to you. |
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The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to improve our products and services. | Identification and contact information you provide us (such as name, age, country or email address, when requested), identifiers and internet and network activity information (such as IP address) and information collected or generated to improve the app’s functionalities (such as information about your interactions with the app, inferences we generate and other related information about your usage of the app, frequency of use, payment details, app version, and other apps/platforms/services on which app is used). We may process the content data included in your input to develop and improve our features. |
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The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to improve our products and services. | Any information necessary to ensure the performance of these purposes. |
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The legal basis for the processing is compliance with legal obligations to which we are subject (art. 6(1)(c) of the GDPR). | Any information which may be required by law or under the instructions of public authorities. |
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The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR). | Identification and contact information you provide us (such as first and last name, email address) and the content of your communication or request. |
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The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations. | Any information necessary to ensure the performance of these purposes. |
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The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) | Your identification and contact information (such as name, age or email address, when requested), identifiers and Internet and network activity information that we collect (such as IP address, IDFA or AAID), information about your interactions with the app, and other related information about your usage of the app. |
3. Data Storage and Protection
Personal data may be processed by both automated and non-automated means, and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.
Personal data processed for the purposes referred to in Section 2.a), 2.b), 2.e), 2.g) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 3 years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app. The content data included in the input will be kept on our servers for 7 days to develop and improve our features. In addition, it will be stored on your device as long as you delete it by clearing the chat. However, we will have no access to data stored on your device.
Personal data processed for the purposes referred to in Section 2.c) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 1 year from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app. Such data will also be retained on OpenAI’s servers for 30 days only for abuse and misuse monitoring purposes.
Personal data processed for the purposes referred to in Section 2.d), will be kept up to 5 years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
Personal data processed for the purposes referred to in 2.f) will be kept up to 10 years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
4. Your Choices with Regard to the Use of Your Personal Data
It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.d) and 2.e). If you do not provide the personal data, you will not be able to enjoy the app’s services and features.
Where we rely on our legitimate interest for the purposes referred to in Sections 2.b), 2.c), 2.f) and 2.g), your provision of personal data is still optional and you may, at any time, exercise your right to object to such processing as explained in Section 7 (Your Rights) below.
You can also manage how you share certain information with us by adjusting the privacy and security settings on your mobile device (such as “Limit Ad Tracking” on iOS, or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android). You should refer to the instructions provided by your device’s operating system or its manufacturer to learn how to adjust your settings.
5. Sharing Your Personal Data
We may share or disclose your personal data to the following categories of recipients:
Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners, suppliers of mobile marketing services, social networks). We share your personal data with OpenAI to provide you with the functionalities of the app and for abuse and misuse monitoring purposes.
If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers and may be one of the assets that are transferred to another owner.
Public, judicial, or police authorities, within the limits established by applicable laws.
Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.
6. Transfers of Personal Data Outside the European Economic Area
We may transfer personal data from the European Economic Area (“EEA”), the UK or Switzerland to other countries outside the EEA. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Laws, including (a) the standard contractual clauses developed by the European Commission; (b) Swiss-U.S. Privacy Shield, and the decisions of adequacy of the European Commission; or (c) binding corporate rules.
More information on the appropriate warranties are available by sending an email to privacy@bendingspoons.com.
7. Your Rights
At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Applicable Privacy Laws:
Right of access. You have the right to obtain information about the processing of your personal data and to access it.
Right to rectification. You have the right to ask for the updating, rectification or integration of your personal data.
Right to erasure. You have the right to request the deletion of your personal data.
Right to restriction of processing. You have the right to request the restriction of the processing of your personal data.
Right to data portability. You have the right to obtain a portable electronic copy of your personal data.
Right to object. Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation. In particular, you are entitled to object to the processing of your personal data for direct marketing purposes, including profiling.
Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent, although the processing carried out before your withdrawal of consent will remain valid.
You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
To exercise your rights, you may contact us by sending an email to privacy@bendingspoons.com. We may take reasonable steps to verify your identity prior to responding to your request.
Note that the service we provide through our app is based on Open AI’s models. It generates responses by reading users’ requests and then predicting the next most likely words that might appear in response. In some cases, the most likely next words may not be the most factually accurate ones. For this reason, you should not rely on the factual accuracy of output from our models.
If you notice that the output generated contains factually inaccurate personal information about you and you would like the inaccuracy to be corrected, you may submit a correction request to OpenAI’s email address dsar@openai.com. Given the technical complexity of how OpenAI’s models work, it might not be possible to correct the inaccuracy. In that case, you may request the removal of your personal information from the model’s output by filling out this form. The form will be directly received and managed by OpenAI which will process the personal data provided in the form as an autonomous data controller. We will not process such data and have no chance to correct or remove your personal data from the model since we have no control over OpenAI’s model. For further information about the use of personal data by OpenAI, please read the applicable Privacy Policy.
8. Children’s Personal Data
The app is not intended for anyone under the age of 13. Users between 13 and 18 need consent to be given by the holder of parental responsibility to use the app. We do not knowingly collect personal data from children under 13 or from children between 13 and 18 without parental consent. If you believe we have received personal data from children under the age of 13, or from children between 13 and 18 without parental consent, please email us at privacy@bendingspoons.com. If we learn that a user is under the age of 13, or is between 13 and 18 and has no parental consent, we will take reasonable steps to delete any processed data and close such user’s account.
9. 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 do not apply to data processed by such third-party websites and services. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.
10. Changes to this Privacy Policy
We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws. If we make modifications, we will 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 pop-up or push notifications within the app or our website, or email.
11. Additional Information for California Consumers
This section provides additional disclosures required by the California Consumer Privacy Act (“CCPA”).
a) Additional Information Related to Collection, Use, and Disclosure of Personal Information
We collect personal information from several sources: directly from you (for example, when you make purchases within the app or participate in a survey); automatically when you use the app (for example, device information); and from other sources (for example, mobile measurement partners). We also generate inferences about you based on your use of the app and other information we collect.
We may collect the following categories of personal information: identifiers; internet or other electronic network activity information; characteristics of protected classifications under California or U.S. federal law (such as gender if you participate in a survey); commercial information (such as purchases you make in the app); approximate geolocation information (such as country); audio and visual information (such as photos and videos you share with us); inferences; and other information that relates to or is reasonably capable of being associated with you. For details about the personal information we collect, please see Section 2 (Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing) above. We collect personal information for the business and commercial purposes listed in the chart in Section 2 above.
We may share your personal information with the categories of third parties as described in Section 5 above. We may disclose the following categories of personal information for business purposes: identifiers, internet and electronic network activity information, characteristics of protected classifications under California or U.S. federal law; commercial information; approximate geolocation information; audio and visual information, and other information that we have inferred about you or that relates to or is reasonably capable of being associated with you.
We do not sell your personal information.
b) Rights of California Consumers
Subject to certain limitations, the CCPA provides California consumers the right to:
Request more details about the categories and specific pieces of personal information that we process.
Request the deletion of their personal information.
Opt out of “sales” of personal information that may be occurring.
Not to be discriminated against for exercising these rights.
If you’re a California consumer, to exercise these rights, you can submit a request following the steps below:
Access the app from your device (if you do not have it on your device any longer, you can download it again and then access it without the need to purchase a subscription).
Long press four fingers on any screen within the app until a menu opens up.
Tap Send a Privacy Request and follow the instructions.
After you have sent your request through Send a Privacy Request, you may uninstall the app if you don’t want to use it anymore.
If you have any other questions about privacy or data protection at Bending Spoons, you can contact us by sending an email to privacy@bendingspoons.com. We may take steps to verify your request by asking you to provide information that matches the information we have on file about you. California consumers can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on their behalf and may also still ask them to verify their identity with us directly.
Last updated: 9 May 2023
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