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Privacy Statement
Last updated: July 4th, 2023 (version 2.4)
Hi Swoover!
If you've downloaded the Swoove App (“Swoove”, “App”) then we collect and process your personal data. In this privacy statement we'll explain what data we collect and why.
Who are we?
We are a company named Internet Intelligent Machines B.V. (“IIM”) and we've developed the Swoove App. For all data that is being processed we're the so-called “controller”.
What data do we collect from you and why do we do so?
What data we collect and how we use it, depends on your usage of the App: you're either just using the App (as a visitor) or you create your own account. We've divided those options below. Please read the section relevant to you. In the last section, you can read about the data we process if you contact us.
You've downloaded the App, but you do not create an account
If you've downloaded the App and did not create an account (yet), then we're processing the following data. Note that some of this data may not qualify as personal data.
We use your country to determine which version of the App we need to show to you, as the content we offer can be different per country. We use your IP-address and interaction data to measure which elements in the App work for you and which don't. This helps us to further develop the App, improve its functioning and make it more interesting for you to use. We also use your IP-address and interaction data to diagnose, troubleshoot and fix issues with the App. We're processing this data based on our 'legitimate interest', which is product and service improvement. We retain this data indefinitely. In our retained logs we will remove the last octet of the IP number. This will effectively anonymize our records.
You've downloaded the App and you create an account
If you've downloaded the App and you want to create an account, then you provide the following data directly to us:
You can provide data by inserting it directly into the interface of the App or by using the option to log in with your Google account credentials or use sign-in with Apple on your Apple mobile device.
We need your login credentials to create an account for you. We need your email address to verify your account. During registration, you provide us with your date of birth so that we can verify your age. After verification, we anonymize your date of birth. You may decide to supplement the data in your profile, including a photo. That is fully optional. A completed profile will help your friends to find you and make it easier for you to share your avatar and dances. When you create an account, we will be processing your data on the basis of the agreement that we have entered into with you to provide the functionality of the App. If you don't want to provide us with the above information, we cannot create an account for you. Without an account, you won't be able to create your own avatar or dances.
If you use your Google account to log in, you will permit Google to share specific and identified data from your Google account profile with us. When you use sign-in with Apple you will be presented with a request to submit your name and e-mail address to us. Your e-mail address may be the actual address associated with your Apple account, or alternatively, you may use an Apple provided anonymous relay email address. Please ensure that you make a conscious choice.
We also process data that you provide to us indirectly, simply by using the App:
We use your country to determine which version of the App we need to show to you, as the content we offer can be different per country. We use your content data for proper app functioning. We use your IP-address and interaction data (such as videos selected, avatars selected, videos viewed, selected music etc.) to determine your preferences, but also to measure which elements in the App are successful and which aren't. This helps us to further develop the App, improve its function and make it more interesting for you to use. We also use your IP-address and interaction data to diagnose, troubleshoot and fix issues with the App. We process your data based on our 'legitimate interest', which is product and service improvement.
We may send you messages related to your use of the Service. For example, we may send you a push notification to inform you about certain functionalities in the App. We send these service-related messages based on our 'legitimate interest', which is improving app usage. If you've given us your consent during the account sign-up flow, we may also send you direct marketing messages. For example, we may notify you about new collections in the shop. Note that you can always opt-out from receiving these messages in your account. If you don't give us your consent, you simply don't receive these messages.
If you use specific functionality provided in the App, this may require that you provide personal data to us using an interface of your device, e.g., camera or microphone. Currently, you have the option to add voice elements to dances that you create in the App or animate a face of a character in a dance by tracking your facial movements through your device’s camera. To be able to use these features, you will need to opt-in to the use of your device’s microphone or camera in your account settings. This may evolve over time. If that happens, we will update this privacy statement.
When you use the voice option, we will add your recorded voice track to the dance that you have created. When you use the option to track your facial movements, we will track and record specific points located on the image of your face to enable you to animate the face of your character. We will not process or store a complete image of your face. In both instances, our processing is based on the agreement that we have entered with you to provide the functionality of the App.
For how long do we retain your data?
We retain your account (and the information related to your account) until you delete it in the settings overview in the App. Once you've deleted your account, we'll delete your account and all associated data within 48 hours. We'll retain your interaction data for statistical purposes. This data however is anonymized, meaning we can no longer relate it to you.
If you haven't logged on to the App for more than 2 years, then we will assume that you're no longer interested in the App. We don't want to retain your data any longer than necessary. Therefore, we'll deactivate your account if you're inactive for 2 years. We'll send you a notification in which we'll inform you about it. Note that your account (including the content you created) will be archived for 5 years. If you log in to the App during this period, we can still restore your account. If you do not log in to the App, we'll delete or anonymize your account. Anonymizing your data means that we no longer can relate it to you. Again, we'll send you a notification in which we'll inform you about it.
If you contact us
If you contact us (refer to 'How you can contact us?') then we process the data that you share with us. Most probably, you'll contact us via e-mail. Generally, we will process:
We process your data based on fulfilling our obligations to you. We will delete or anonymize your data once we're convinced that we properly answered your message.
Cookies
No cookies or other trackers will be used in the App. The App does collect your interaction data and uses the information for non-intrusive analytical purposes. E.g., to understand performance and behaviors. We do measure whether our ads on social media for the App have led to a download of the App. We will make sure though that we will not exchange any specific information related to your device with the concerned social media platforms.
Children
The App is not meant for children under the age of 13 years, meaning we use a minimum age limit. If we learn that you're under the age limit (13), we'll deactivate your account and delete or anonymize your data, unless we're legally obliged to retain your data.
If you're a parent of a child under the age limit and you become aware that your child has provided data to us, please contact us (refer to 'How you can contact us?').
Do we share your data with others?
Except as provided for below we do not share your data.
We work with companies that process data on our behalf. Microsoft hosts the back end of the App. Furthermore, we work together with Growth Division, a marketing agency that processes interaction data on our behalf. When you sign-up for the App with your own e-mail address (and do not use social login), you do so via Auth0.Inc. Auth0.Inc provides authentication services to us. The Auth0 service platform will process the data that you provide when you sign-up for an account. We have signed a data processing agreement with all of them.
We may share information about App usage with other companies. However, if we do so, we'll only share anonymized data, meaning that the receiving company cannot link the data to you. E.g., they'll receive information such as: 80% of our App users use the App for at least 1 hour per day.
When you use your Google account, Google will receive data connected with your login and use of Swoove. For this data, Google is an independent controller. Google will process this data in accordance with its terms of service and privacy policy. You can access and review the terms of service and the privacy policy here. Apple processes limited data in connection with your use of Sign in with Apple. For more information, please read “Sign in with Apple & Privacy” provided here.
Google processes your data for various purposes. These purposes include ad targeting, personalizing your Google experience, and improving Google products and services. If you want to exercise your rights with respect to data processed by Google, you can do so via your Google account settings. Apple's use of your data is described in the document Sign in with Apple & Privacy as referenced above. Apple states that it does not track the apps or services that you use.
Please note that you are in charge of whoever sees your created content. You can decide to share your content with other App-users or to download your created dances and upload it to other Apps that you use.
Do we process your data outside the European Union?
We don't share your data outside the European Union. Your data is stored in a Microsoft data center. We have indicated to Microsoft that the location of this data center should be within the borders of the European Union. Auth0 stores any data that it processes on our behalf in an Amazon Web Services data center that is similarly located within the borders of the European Union. That means that European Union data protection laws apply to the processing of your data.
For fail-over and latency reasons we may process content that you have generated outside of the borders of the European Union. This content is linked only to a pseudo-anonymous user ID and cannot be linked back to you by any third party using reasonable means that this third party may have available.
If you use your Google account to log in or when you use sign in with Apple, Google or Apple may transfer your data to the United States. If they do, they will need to ensure as independent controllers, that any such data transfer is conducted in accordance with the requirements on international data transfer imposed on them by the GDPR.
What are your (privacy) rights?
It's stated in the law that you have certain 'privacy rights'. For example, you have the right to gain insight into the data a company collects from you, to have your data updated or even deleted. You also have the right to object to certain data processing, to restrict further processing, and to data portability. If you want to make use of these rights, then please contact us ('How you can contact us?').
We'll handle your request as soon as possible, at least within 30 days. If we are not able to make that deadline, we will tell you and can extend this term by another 30 days. E.g., you may have sent us a very complicated request, or we've received such a huge number of requests, that we need more time for it.
Note that we'll ask you to identify yourself to 'proof' that you are really you. So, it might happen that we ask you to share additional information with us. We'll only do so to prevent that we provide your data to the wrong person (e.g., someone who pretends to be you), or that we incorrectly change your data.
If you aren't satisfied with how we handle your data, then you can always file a complaint with the data protection authority. You can find the contact details on the website http://www.gegevensbeschermingsautoriteit.be or on the website of your local data protection authority.
How can you contact us?
For any questions about this privacy statement (or other privacy related questions), please send us an e-mail. You can contact us via:
Internet Intelligent Machines B.V. (IIM)
Hessenplein 27
2000 Antwerpen, Belgium
E-mail: privacy@swoove.com
