PRIVACY POLICY

Effective date: February, 2024

Jiecong Guo (hereinafter, "the Developer", "I", "Me", "My") is firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in this Privacy Policy (hereinafter, "this Policy"), the User (hereinafter, "the User", "you", "your") of PhotoTrim&File Cleaner (hereinafter, "the/My app") will find all the relevant information to better understand what I do with your personal data. If you do not agree with this Policy, please do not access or use My app.

I may update this Policy according to new legislative or jurisprudential requirements and/or business needs, among other reasons. Any updates or modifications to this Privacy Policy will be considered applicable from the moment of their publication on the app. Therefore, I recommend that you review this Policy regularly. This Policy will always be available on the app so that you can consult it at any time.

What does this Policy apply to?

This Policy applies to the personal data that I collect and process from you as a User of My app, as well as the services offered within it.

Please note that in order to access and use My app, you must be an adult according to the laws and regulations of your country or state of birth or residence.

What does personal data mean, and which data do I collect and process?

For the purposes of this Policy, "personal data" refers to all data that identifies you or that could be used to identify you, such as:

Device details:

When you access My app or log in, some of your device details are received. Note that such data is received as disaggregated data (strictly device identifier information), meaning it is not associated with a particular User or their personal information. It only pertains to general usage information about how all Users interact with My app.

App usage information:

Information about how you use My app (e.g., the sections you consult), including access to your device to identify duplicate information by exploring videos and photographs in your camera roll. Note that I do not store or use the data on your device; I only require access to provide the entrusted services. Therefore, all information remains exclusively on your device and/or iCloud account.

Device location information:

Your IP address and, if you consent, geolocation data. When accessing the app, you will be prompted to consent to the collection of geolocation data in accordance with Apple/Google policies. You are solely responsible for allowing temporary access while using the app or refusing access. If you accept, you can withdraw this consent at any time by going to "Settings" on your device.

Apple/Google account information:

When you have provided consent to these platforms to share this data with third-party partners who develop apps offered through their platforms.

Data collected from Cookies:

As defined in the Cookies Policy below.

In all cases, I only process personal data that is strictly necessary to fulfill the purposes described above. If you provide Me with more information than is expressly required, you consent to its processing for the informed purpose(s) for which it was granted.

To properly provide the services offered within the app, you must provide Me with accurate, truthful, updated, and complete information that reflects your real circumstances. If you provide Me with information and/or personal data of third parties via email, you guarantee that you have obtained their consent and informed them about the purpose of the processing, which is to optimize your device storage by deleting duplicate information.

If you provide Me with personal data of third parties (adults), you confirm that you have informed them about the purposes for which their personal data will be processed and guarantee that you have obtained their prior and express consent to share their personal data with Me.

What do I use your personal data for?

You are only required to provide personal data and information that is strictly necessary to fulfill the purposes explained below. If you provide Me with more information than is expressly required, you consent to its processing for the purpose(s) for which it was granted.

I use your personal data for the following purposes:

To make available and render the services offered through My app;
To collect fees for subscription plans to the services offered through the app;
To manage your information queries regarding My app and/or services offered through it;
To comply with legal obligations, legal requirements, laws and regulations, and/or to respond to judicial, police, or other authorities' requirements;
To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through My app;
To improve My app's functionalities and services by analyzing disaggregated data not associated with a particular user's personal information;
To improve your experience based on your preferences and to show you advertisements related to My app while browsing social media or third-party websites.

What is the legal basis for processing your personal data?

I only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why I collect and process your personal data. In almost all cases, the legal basis will be:

Your consent:

Provided for the processing of your personal data to provide you with the services offered through the app and other purposes informed at the time of data collection. This includes tracking your activity or advertising purposes, such as geolocation, when you voluntarily enable such options.

Apple/Google consent:

Provided to install similar technologies on your device(s) for tracking your activity on these platforms, such as the apps you have installed or information shared with third-party partners for advertising purposes.

Legal obligations:

To comply with legal obligations and/or respond to administrative, judicial, police, or other authorities' official requirements.

Legitimate interests:

offering an enhanced user experience when accessing and using the app;
providing advertisements based on user interests;
monitoring fraudulent activity to preserve the security and integrity of My app;
defending My rights in the event of claims regarding My app and/or services;

How long do I keep your personal data?

I will keep your personal data only for as long as necessary to fulfill the purposes for which it is being processed. Beyond that, your personal data will be securely blocked and retained for the necessary period to meet legal obligations and/or legitimate reasons (e.g., addressing claims or investigating fraudulent activity).

For similar technologies used by Apple/Google to collect and store information on your device, I recommend consulting their Privacy and Cookie Policies for information on revoking consent.

Once the retention period has elapsed, your personal data will be securely deleted from My systems.

Who do I share your personal data with?

I may share your personal data with the following third parties, including but not limited to:

Service providers: Such as Apple, Google Inc, etc.
Authorities: Administrative, police, or judicial authorities, as required by applicable laws and regulations.
Law firms: To respond to claims regarding My app or services.

These third parties may be located outside the European Economic Area (EEA), resulting in international data transfers. In such cases, I ensure that recipients are located in countries with adequate data protection levels or that appropriate safeguards are in place, as required by applicable laws.

How do I protect your personal data?

Your trust is important to Me. Your personal data is stored confidentially and securely in My systems. I have implemented appropriate technical and organizational measures to safeguard your data against unauthorized access, loss, destruction, or misuse.

What rights do you have, and how can you exercise them?

You may exercise your data protection rights (e.g., access, rectification, erasure, objection, portability, and restriction of processing) by sending a written request to zhangsan9080@163.com.

I will generally respond to such requests within one month. In complex cases, this period may be extended by two additional months, and I will notify you of the delay and its reasons.

If you believe your rights have not been adequately addressed, you may lodge a complaint with the relevant Supervisory Authority.

For any questions about this Policy, please contact Me at zhangsan9080@163.com.