Privacy Policy

1) Information about the Collection of Personal Data and Contact Details of the Person Responsible

1.1 We are pleased that you are using our application (hereinafter "app"). In the following, we inform you about the handling of your personal data when using our app. Personal data is all data with which you can be personally identified.

1.2 Responsible for data processing regarding this app within the meaning of the General Data Protection Regulation (GDPR) is Swiftmill UG(haftungsbeschränkt), Holzhofallee 21, 64295 Darmstadt, Germany, represented by the Managing Director Johannes Seidel, Tel.: 0151/123123132 , Email: johannes@swiftmill.io. The person responsible for the processing of personal data is the natural or legal person who alone or jointly with others decides on the purposes and means of the processing of personal data.

3) Data Processing

3.1 General Information

For the processing of contracts concluded via the app, we work together with the following service provider(s), who support us in whole or in part in the implementation of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

3.2 Revenuecat

In the case of in-app payments, payment is made via RevenueCat Inc., 300 Euclid Avenue San Francisco, CA 94118, USA. to whom we pass on the information you provided during the ordering process together with the information about your order. Your data will be passed on in accordance with Article 6 Paragraph 1 Letter b GDPR exclusively for the purpose of payment processing and only to the extent that it is necessary for this. Further information on data protection by RevenueCat can be found here: https://www.revenuecat.com/privacy

3.3 Microsoft Azure OpenAI for Image Processing and Analyzing

We use OpenAI Azure services for image processing within our app. The data processing is handled on servers located in Europe to ensure compliance with the GDPR. The information you provide when using image processing features within the app may be transmitted to OpenAI Azure, which processes this data on our behalf. The legal basis for this data processing is Article 6(1)(b) GDPR, as it is necessary for the performance of the contract between you and us. We have ensured that OpenAI Azure adheres to strict data protection standards and have signed a data processing agreement that includes standard contractual clauses to safeguard your personal data.

Further information on data protection by OpenAI via Microsoft Azure can be found here: Microsoft Privacy Statement.

3.4 Superwall

We use Superwall to manage and display paywalls within our app and to analyze conversion rates related to these paywalls. Superwall may collect limited data related to user interactions with the paywall, such as the number of views, clicks, and conversions, to help us understand the effectiveness of our paywalls. This data is primarily aggregated and does not include extensive personal information. The legal basis for this data processing is Article 6(1)(f) GDPR, as it serves our legitimate interest in optimizing our app's user experience and conversion rates.

Further information on data protection by Superwall can be found here: Superwall Privacy Policy.

5) Rights of the Data Subject

5.1 The applicable data protection law grants you comprehensive data subject rights (rights to information and intervention) vis-à-vis the person responsible for the processing of your personal data, about which we will inform you below:

• Right to information: You have the right to request information about your personal data that we process, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom your data was or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to correction, deletion, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if they were not collected from you by us, the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing on you, as well as your right to be informed about which guarantees pursuant to Art. 46 GDPR exist when your data is forwarded to third countries.
• Right to rectification: You have the right to immediate rectification of incorrect data concerning you and/or completion of your incomplete data stored by us.
• Right to deletion: You have the right to request the deletion of your personal data if the requirements of Art. 17 Para. 1 GDPR are met. However, this right does not apply in particular if the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
• Right to restriction of processing: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is being checked, if you refuse to delete your data because of inadmissible data processing and instead request the restriction of the processing of your data if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have lodged an objection for reasons of your particular situation, as long as it is not yet clear whether our legitimate reasons prevail.
• Right to information: If you have asserted the right to correction, deletion or restriction of processing against the person responsible, he is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
• Right to data portability: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request transmission to another person responsible, insofar as this is technically feasible.
• Right to revoke granted consent: You have the right to revoke your consent to the processing of data at any time with effect for the future. In the event of revocation, we will delete the data concerned immediately, unless further processing can be based on a legal basis for processing without consent. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent up to the point of revocation.
• Right to lodge a complaint: If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you live, work or where the alleged infringement took place.

5.2 Right to Object

If we process your personal data on the basis of a balancing of interests, you have the right at any time to object to this processing for reasons resulting from your particular situation with effect for the future.

If you exercise your right to object, we will stop the processing of the data involved. However, further processing remains reserved if we can prove comprehensive reasons for processing that override your interests, fundamental rights and fundamental freedoms, or if the processing is for the certification, exercise or defense of legal claims.

If your personal data is processed by us for direct advertising purposes, you have the right to object at any time to the processing of your personal data for the purposes of such advertising. If you exercise your right to object, we will stop the processing of the data involved for direct marketing purposes.

© Swiftmill UG(haftungsbeschränkt) 2024