Trendformer Limited ("We") are committed to protecting your personal data and respecting your privacy.
- Pixio mobile application software ("App"), available on the App Store and Google Play Market, once you have downloaded a copy of the App onto your mobile or handheld device ("Device");
We offer users a number of activities, most of which are directed at children under the age of 16 (for the purpose of the General Data Protection Regulation). We assume that the activities proposed by our App will not be handled by children under the age of 13. In any case, if such a situation occurs, the provisions of the Children’s Online Privacy Protection Act shall be respected as much as it seems to be possible for us.
The Children’s Online Privacy Protection Act (COPPA) requires us to inform parents or legal guardians about how we collect, use, and disclose personal information from children under the age of 13. The COPPA also requires that we obtain the consent of parents or legal guardians before we allow children under the age of 13 to use certain features of our Apps.
The General Data Protection Regulation (GDPR) requires us to inform parents or legal guardians about how we collect, use, and disclose personal information from children under the age of 16. The GDPR also requires that we obtain the consent of parents or legal guardians before we allow children to use certain features of our Apps.
We do not knowingly collect and store personal data directly from:
- US resident children under 13 years of age without parental consent, except as permitted under COPPA;
- EU resident children under 16 years of age without parental consent, except as permitted under EU applicable law.
We do not use our Apps or Services to knowingly solicit any data or information from such users.
IMPORTANT INFORMATION AND WHO WE ARE
- Full name of legal entity: Trendformer Limited
- E-mail address: [email protected]
- Postal address: 604, Tower A, New Trade Plaza, 6 On Ping Street, Shatin, N.T., Hong Kong
You have the right to make a complaint at any time to a competent supervisory authority of an EU member state, the list of which you can find at the following link https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Our Apps don’t contain any third-party advertising banners, but they may contain information about our other Apps, Services, or goods with links to those Apps (either to Google Play, App Store, or Amazon).
Our Apps may contain external links to our pages on the App Store, Google Play, Facebook, Instagram, YouTube channel, Twitter, or Amazon. All external links such as our website, social media, and support e-mail are secured behind a parental gate (for example, the App requires to swipe two fingers in a specified direction).
THE DATA WE COLLECT ABOUT YOU
We understand the importance of our users' personal data and, more importantly, the information pertaining to children under 16 (for the purpose of GDPR) and 13 (for the purpose of COPPA) years of age.
We do not collect or require users to enter their personal information when they use our Apps. Some data may be required in case the User would like to have access to the full range of activities and options offered in our App.
For example, we do not collect any personal data mentioned in the "User Account Registration" below, if the relevant App function is not available to the users or is not used by the user.
We may offer you some paid services or features within our Apps. In all such cases, if they are available, you make payments for our offers via services and features provided and supported by Apple and Google. They directly process and collect your payment data according to your agreement with them with respect to your usage of their respective services and features. We do not collect any of your payment data and do not authorize or instruct Apple or Google to collect and store such data on our behalf or in our favor.
In some cases, our Apps provide you with the ability to indicate some personal data of your child (e. g. name or full name and age) or to make a photo. In each of such cases, we do not collect and store such data. This information is recorded only on your devices, where our Apps have been installed. This data will be irrevocably deleted upon uninstallation or deleting our Apps from your device.
User Account Registration
Generally, we do not require users to create an account in order to be able to use our Apps and Services, and, consequently, we do not collect any of your personal data in such cases.
However, user account registration grants more functions and features to the users of our App. All functions and features of our App that require the creation of users' accounts, if they are available, are intended for users over 13 years old provided that they have reached the appropriate age that allows (a) to consent to the processing of personal data in their country with prior approval of their parents or legal guardians if required by the applicable law; and (b) to enter independently into contracts in their own country, without prior approval of their parents or legal guardians or with such approval if required by the law.
By creating an account and using the Services and our Apps as a registered user, if such functions are available in your country, you confirm that you have reached the appropriate foregoing age requirements. If you do not comply with such age requirements, do not create an account and do not directly use our Services that require account registration.
If you are not sure about whether you can independently consent to the processing of personal data, please contact your authorized personal data protection authority in your country.
We may ask you to submit additional documents or to pass through additional procedures to make sure that you are already 13 years old (or more, as required by the laws of your country) if we have reasonable doubts about your age. We may also contact your parents or legal guardians to obtain consent or approval for the processing of your personal data if you have not reached the appropriate age. For a period of clarification or getting approval from your parents or legal guardians, we may restrict the processing of data on you and temporarily block your account.
If you create an account, we collect and store from you or from third parties the following information:
- Identity Data: first name, last name, user name, or another identifier;
- Contact Data: e-mail address only;
- Device Data: mobile operating system;
- Profile Data: details of your use of any of our Apps, namely features and functions available to or activated by you to provide you with our Service and your ability to use our Apps.
HOW IS YOUR PERSONAL DATA COLLECTED?
If we offer a function to register an account and you use it, we will collect and process the following data about you:
Information you give us. It is the information (including Identity and Contact Data) that you provide us about yourself by filling in forms on the App, by corresponding with us (for example, by e-mail or chat), or via third parties. It includes the information you provide when you register or create an account in our Apps, subscribe to any of our Services, make an in-App purchase, or report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence regardless of whether you have registered the account or not.
- Information we collect about you and your device. Each time you use one of our Apps, we will automatically collect personal data, including Device and Profile Data.
- Location Data. We do not collect your Location Data regardless of whether you have a registered account or not.
Information we receive from other sources including third parties
and publicly available sources. We will receive personal data about you from some third parties as
set out below:
- Identity and Contact Data from Google and Apple. If you choose to create an account or log into an account via a third party such as Facebook or Google, we collect and store personal data and other information made available by that third party, such as your first name, last name, e-mail, user name, or another identifier. We may also collect technical information in order to ensure that our Apps connect correctly. The third parties are responsible for obtaining your consent before sharing such data with us.
You agree that we may collect and use technical data and related information about your device and system which shall facilitate the provision of Apps updates, technical support, and other related services.
Information collected through or used by our Apps
Information used automatically by our Apps
Most of our Apps note Device Preferences and use these data to determine your country, language preferences, and mobile operating system. Generally, this information is not collected and stored by us, but our Apps need this information to initialize the Apps and enable their proper work. This information cannot be connected to a unique device, user, or other identifier and is never shared with third parties.
When you use our Apps as a registered user, if it is available for you, our Apps also collect your Identity Data to provide you with all functions, features, and Services that you have previously activated, bought, or that are available for you.
Information you provide through Apps
Child users and unregistered users do not have the ability to provide any personal data when using the Apps beyond what has been collected or used automatically (as noted above) and we do not collect or process any personal data of such users.
When you save a photo or tag such a photo by your or your child's name and/or age via our Apps, where available, such information is recorded and stored on your devices and will be available for you upon your next usage of our Apps. We do not collect, store, use or process such information in any manner or way and for any purpose. In each of such cases, we only provide our Apps for your ability to make and tag photos. You are able to independently determine how this data will be used and processed. This data will be deleted from your device automatically upon the Apps uninstallation or deleting. At your sole discretion, you may delete this data from your device at any time.
We do not collect any other information
When you download and use our Apps or Services, we do not require you to provide any information and data about you or your device, except for non-personal information that is necessary for the initialization and work of our Apps.
We do not collect any other personal data, except as explained above. We do not share such information with third parties.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data, if we collect it as described above and when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where we need to perform a contract that we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have consented before the processing.
By registering an account and using our Apps or Services, you and the Company conclude a contract for the provision of services or granting a license, or you and the Company may conclude additional agreements when you buy any features of functionality offered by the Company within Apps. In order to provide you with services under such contracts, we must collect and process certain data about you. For example, when you buy some features in our Apps, you expect to use such purchases within Apps on any device. We should collect information about you as a user because without it we will not be able to provide you with such features across multiple devices.
Legitimate interests mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
We may process a user's data if it is required by the law that applies to us. For example, we may provide data on users at the request of courts or other authorized bodies or when collection and identification are required by the legislation on financial monitoring and prevention of money laundering or by other applicable laws.
We rely solely upon the user's consent when using personal user data for the purpose of displaying targeted advertising, marketing, and promotional mailing, or for other purposes for which a specific user's consent must be granted.
DISCLOSURES OF YOUR PERSONAL DATA
Any personal data collected by us is used solely to provide you with the Service or your ability to use our Apps, to improve our Apps and Service, and we do not provide this information to any third party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e. g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving the Company.
We do not transfer your personal data outside the European Economic Area (EEA).
We have to keep basic information about you (including Contact, Identity, and Profile Data) for the time necessary to provide the requested services plus 3 years after. The purpose of your personal data retention shall be to fulfill a contract with you according to the GDPR Art. 6 (1) (b) and duly provide the requested services.
In some circumstances, you can ask us to delete your data: see "Your legal rights" below for further information.
In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
In certain circumstances, you have the following rights under the data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims;
- if you have objected to our use of your data, but we need to verify whether we have overridden the legitimate grounds to use it.
Request transfer of your personal data to you or to a third party. We will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at [email protected].