Made on
Tilda
How is your protection ensured by the law
| Your rights are safeguarded under the laws of Georgia and other applicable legislation. You are entitled to receive information regarding the processing of your personal data, as stipulated by law, within the determined timeframe therein.
We will only process your personal data if:
You have explicitly given consent for the processing of data for one or more specific purposes;
Processing is essential to fulfill an obligation arising from a transaction concluded between us or to engage in a transaction at your request;
Processing is mandated by law;
Processing is necessary to fulfill obligations imposed on us by law/regulation;
As per legislation your information is accessible to the public or if you have voluntarily made it publicly accessible;
Processing of data is essential for safeguarding significant public interests;
Processing of data is imperative for reviewing your application (to render services), and/or Processing of data is grounded on other legal basis.
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Information we collect
| We collect and process some data directly, while other data is collected and processed by third-party services.
Data We Collect Directly We collect the following categories of information to provide and improve our services:
Personal and contact details: When you gain access to the app, you provide your first name, email address, and phone number. We use this information to securely provide our services.
Demographic information (optional): You may choose to share details such as your gender, age, experience of posing for photos, and preferred language. This helps us personalize POSELY for you.
Instagram community: If you choose to join our community on Instagram (https://www.instagram.com/poselyapp), with your consent, we may use information from your account, such as your username, friends, contacts, and other data available through Instagram, to enhance your experience within the app. You can stop sharing this information with us at any time by revoking our access in your Instagram account settings.
Data Collected by Third-Party Services In addition to the information we collect directly, we use third-party services to improve app functionality and analyze usage patterns. These services operate under their own privacy policies. They may collect and process certain technical data related to your interactions with POSELY.
We do not store this data on our servers or have direct access to personally identifiable information collected by third parties.
The types of data these services may gather include:
Analytics and tracking: We use Google Analytics, Firebase, and similar tools to understand how users interact with POSELY. These services may collect your IP address, device identifiers, browser type, and app activity. For more details, see the section “Analytics services” below.
Log data: Our hosting and analytics partners automatically record certain details about your interactions with POSELY. This may include browsing history, search queries, and timestamps.
Cookies and tracking technologies: Some third-party services use cookies to track usage patterns and optimize app performance. For more details, see the section “Cookies and Similar Technologies” below.
Device data: Some services collect information about the device you use to access POSELY, such as the hardware model, operating system, and app activity.
ML Kit Pose Detection API: If you use the camera function, we may process spatial positioning data of a person’s head or body within an image frame. This data is used in real time for applying effects and editing tools. However, this data never leaves your device, is not persistently stored, and is not shared with third parties.
Access to Third-Party Data In some cases, we may receive aggregated, anonymized, or statistical data from third-party services like Google Analytics or Firebase. This data helps us analyze user behavior, improve app performance, and enhance the overall user experience. However, it does not allow us to identify individual users and is processed in accordance with the privacy policies of the respective service providers. | |
Do we store your image data? | We do not store any user content in any way, nor do we store any image data on servers. POSELY does not take ownership over any user content, nor do we track, measure, store or collect any image data.
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How we use the information we collect, and legal bases for use
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What do we use your personal information for
| Our legitimate interests: | Legal basis |
To manage our relationship with you. |
Updating information, identifying products and services tailored to your interests, and delivering pertinent information to you;
Developing new products and services;
Establishing a client focus group to introduce innovative products and services;
Efficiently fulfilling our legal obligations.
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Your consent;
Implementation of contractual obligations;
Our lawful Interests;
Our legal responsibilities. |
To provide you with our services and products. | ||
To ensure your safety and security. | ||
To plan and execute marketing activities. | ||
To analyze how customers use our products and services. | ||
To diagnose technical and service-related issues and to administer our website and app. | ||
To receive feedback, advice, or recommendations regarding our products and services. | ||
To fulfill your requests and explore potential collaboration opportunities. | ||
To verify your identity and comply with applicable laws. | ||
The categories of third parties having access to your personal data | Your personal data may be accessed by service providers, based in the EU and outside the EU, acting as processors, to provide us with the following services:
Hosting provided by, such as Heroku;
Analytics provided by, such as Amplitude, AppsFlyer, Adjust, Google Analytics / Firebase Analytics, Sentry, Crashlytics;
Recipients of your personal data, such as Facebook Ads, TikTok Ads and Google Ads, who use cookies to collect or receive information from our website and elsewhere on the Internet and use that information to provide measurement services and target ads;
Sending push notifications using services such as OneSignal or Firebase Cloud Messaging (FCM);
Regulators and other authorities who require reporting of processing activities in certain circumstances;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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How and when we share your information
| We share your information with:
Service providers: We use third-party service providers to help operate and improve our services. These service providers may collect and process certain data about you, as described in this Privacy Policy, and in accordance with their own privacy policies. For example, they may assist with web hosting, maintenance, security, spam detection, data storage, sending push notifications, analytics, and advertising (both described further below). We only engage businesses we believe are trustworthy and who have confirmed their privacy practices are consistent with ours, and we only provide the information necessary for them to perform these services on our behalf. However, the data collected by these providers is governed by their own privacy policies, and we do not control or have access to this data beyond what is necessary to provide the services.
Ad networks and other ad serving providers (collectively, our “Ad Network”) that serve ads on behalf of others on our platform. These practices are described below in “Interest-based advertising.”
Government and law enforcement bodies. We share information when we believe that disclosure is reasonably necessary to comply with law, regulation, or legal request; to protect the safety, property or rights of the public POSELY or any third party; or to detect, prevent or stop any illegal, unethical or legally actionable activity.
Our subsidiaries and affiliates. We share your personal data with our subsidiaries in order to provide our services to you. We require that our subsidiaries protect your personal information consistent with this privacy policy. If we were to engage in a merger, acquisition, bankruptcy, or other transaction that involves the transfer of the information described in this Privacy Policy, we may share your information with the parties involved in that transaction.
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Cookies and similar technologies
| We use cookies, tracking pixels, web beacons and similar technologies to analyze use of and improve our website and services, to see which areas and features of the website are most popular, to count the number of devices accessing the website, to personalize your experience, and to remember your preferences as described in "Interest-based advertising".
Most web browsers are initially set up to accept cookies. You can set your web browser to refuse all cookies or to indicate when a cookie is being sent; however, certain features of the website or services may not work if you delete or disable cookies. Some of our service providers may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.
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Analytics services
| We use third-party analytics and advertising service providers such as Google Analytics, Google Crashlytics, Firebase Analytics, Adjust, AppsFlyer, Amplitude, Sentry, TikTok Ads, Google Ads, and Facebook Ads. These providers independently collect data about your usage of our site or app to help us understand how you and other users interact with our services. The data collected by these providers is governed by their own privacy policies.
To learn more about Google Analytics, visit https://support.google.com/analytics/answer/181881?hl=en
To learn more about Crashlytics and Firebase, visit https://firebase.google.com/support/privacy
To learn more about Adjust, visit https://www.adjust.com/terms/privacy-policy/
To learn more about AppsFlyer, visit https://www.appsflyer.com/legal/privacy-policy/
To learn more about Amplitude, visit
To learn more about Sentry, visit
To learn more about how TikTok Ads uses your data, log on to your TikTok account and access your settings, or visit https://www.tiktok.com/legal/page/global/partner-privacy-policy/
To learn more about how Google Ads uses your data, log on to your Google account and access your settings, or visit https://policies.google.com/privacy
To learn more about how Facebook Ads uses your data, log on to your Facebook account and access your settings, or visit https://www.facebook.com/help/325807937506242/
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Interest-based advertising
| Our Ad Network may serve advertisements to you using personal information, such as your email address, that they may collect directly from you both on our website, mobile application, social media and on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of our website, mobile app, social media and other websites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising. Your use of POSELY is supported, in part, by interest-based advertising, without which POSELY would not be able to provide a cost-effective experience. Accordingly, you agree that POSELY may display interest-based advertising to you and, if you are using our website, you may enable such activity directly through the website.
Some third party companies who utilize cookies or beacons on our website enable you to opt out of this behavioral advertising. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt out. Electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our website may not function as intended. Some of these companies may also be members of the Network Advertising Initiative.
You can opt out of receiving marketing emails by using the "unsubscribe" link or other means specified in marketing emails you receive from us. However, you cannot opt out of receiving all emails from us, such as service announcements.
For interest-based advertising, you can visit the DAA Webchoices tool at www.aboutads.info to learn how to opt out. You can also visit the NAI Consumer Opt Out to learn more about the Network Advertising Initiative and your opt-out options.
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Your legal rights
| Under data protection laws in relation to your personal data you are entitled to exercise the following rights:
1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 2. 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. 3. 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 continuing 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. 4. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 5. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 6. Request the 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. 7. 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.
To exercise any of these rights, including to delete your data, please email us at rodion@posely.app.
You may be entitled to additional rights based on applicable data privacy laws in your jurisdiction. Please review “European Union and UK Privacy Rights” and “US State Privacy Rights” below for more information regarding your privacy rights in those jurisdictions.
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Data Security | We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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Our policy on children's information
| You are not allowed to use our services if you are under the age of 13, and our services are not directed at children under the age of 13. You must also be old enough to consent to the processing of your personal data in your country. If we become aware that we have received personal Information from a person under the age of 13, we will delete this information and terminate access to the app.
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International transfer
| We operate worldwide, and we may move, process, and store your data in the Georgia and any other country where we operate, which may be outside the country where you live. Not all data protection laws are the same. Some countries where we transfer personal data may allow government authorities greater access than your country does.
See the section for EU and UK residents below to learn more about data transfers to and from that region.
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European Union and UK Privacy Rights
| If you reside in the UK or another member state of the European Union, you have certain rights under applicable data protection legislation. You can ask us to:
Confirm we process your personal data, and ask what personal data we have about you;
Change or fix your data;
Delete your data;
Stop using some or all of your data if we have no legal right to keep using it;
Give you a copy of personal data you provided to us, in machine readable format.
To exercise any of these rights, including to delete your data, pleaseemail us at rodion@posely.app. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If you think we haven’t complied with applicable data protection laws, you also have a right to file a complaint with your local data protection authority.
The data controller for POSELY’S website and services is individual entrepreneur Rodion Zhukov, registered in Georgia, ID 304675242, address: Nino and Ilia Nakashidze St., N 1, (former Avlevi), flat 3, building N3, Tbilisi, Georgia. Our data protection officer may be reached at rodion@posely.app.
To verify your identity when you make a request, you must provide us with your email address and respond to an email verification request. We will match that information to the information we have in our systems.
Because POSELY is a worldwide service, we may transfer the personal data of EU residents to a country outside of the EU and the UK. When we do, we do so under the EU’s model contracts for the transfer of personal data to third countries (known as "standard contractual clauses").
We process and retain most personal information we have about you for as long as you are a user of our services. We begin deleting certain personal information that we no longer have a business reason to retain. We may be required to retain certain information about you, such as when there is a legal requirement to do so.
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US State Privacy Rights
| If you are a resident of California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, you may have the following rights under the applicable privacy laws in your state ("State Privacy Laws"):
The right to know what personal information we have collected about you, including sources, purpose of collection, and third parties we have shared it with;
The right to delete your personal information;
The right to share or sell your information with any third party.
To exercise any of these rights, including to delete your personal information, please email us at rodion@posely.app. You must use "Request to Know Information", "Right to Know Categories," "Right to Delete," or "Right on Opt out of Sale/Sharing" or "Right to Correct Information" in the subject line of your email, as appropriate. For requests to know, delete and correct, you must provide us with your first name, phone number and the email address you used to gain access to the app. Each request must be sent separately.
To fulfill your requests, we must be able to verify your identity in our systems against the identity you provide. You’ll need to provide us with your email address and respond to an email verification request, so we can match that information to the information we have in our systems.
To designate an authorized agent to act on your behalf, you must send a signed, written authorization containing your first name, last name, email address, and phone number to:
Individual entrepreneur Rodion Zhukov, Nino and Ilia Nakashidze St., N 1, (former Avlevi), flat 3, building N3, Tbilisi, Georgia
We will process your request in an efficient manner, but we may not be able to delete your personal information (a) if we have to complete an ongoing transaction with you, (b) if we detect or need to address a data security incident, if we need to preserve the integrity or security of our systems, or if we need to investigate, report or prosecute those responsible for any such action, (c) in order to correct or repair an error, (d) in order to protect against harassment or malicious, deceptive, fraudulent or illegal activity, (e) in order to comply with a legal requirement or to assist another party with any of its legal obligations under applicable privacy laws, or (f) if we need it for other legitimate purposes, such as if we use it internally in a lawful manner to improve our services or to communicate with you about your account. We will also maintain a record of your requests. If we delete your personal information, many of our services will not work the same for you.
Do Not Sell or Share/Use My Personal Information for Targeted Advertising
Residents in states with State Privacy Laws can opt-out of both sales of their personal information and the use of their information for targeted advertising (known as “sharing” in California). “Sale” includes most circumstances in which a business makes personal information available to a third party for monetary or other valuable consideration. In California “sharing” includes circumstances in which a business makes personal information available to a third party specifically for the purpose of cross-context behavioral advertising (also known as retargeting or interest-based advertising across platforms), even if no money is exchanged. Thus, when we use the term “share” under this section, we are using it in the narrow meaning of how it is defined under California law. Other State Privacy Laws do not use the term “share,” but describe the activity as using personal information for targeted advertising.
Through our participation in digital advertising networks to deliver advertising tailored to your interests, we may sell or share/use for targeted advertising the following categories of personal information: identifiers, internet and electronic activity and commercial information. You can opt-out of us selling or sharing/using your personal information for targeted advertising for online activity by emailing us at rodion@posely.app to submit your request.
Right to Appeal
If you are a Colorado, Connecticut or Virginia resident and we were unable to fulfill your request, you may appeal by emailing us at rodion@posely.app within fourteen days of our decision and submitting an appeal request with a detailed reason for your appeal, as well as your state of residence.
Sensitive Personal Information
We do not collect or process Sensitive Personal Information, as defined by California Law, for inferring characteristics or use or disclose Sensitive Personal Information for purposes other than those permitted by law. In addition, we do not “sell” or “share” Sensitive Personal Information, as “sell” and “share” are defined above in the “Do Not Sell or Share/Use My Personal Information for Targeted Advertising” section.
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Retention
| We will store your personal information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data.
If you want further information about details of retention periods for different aspects of your personal data please сontact us.
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Withdrawal of consent | You have the option to submit a request to withdraw your consent for the processing of personal data, including direct marketing, at any time. Consent can only be revoked if the basis for processing your data is your consent.
In the event of withdrawing consent, there is a possibility of service interruption, and we may be unable to provide you with an optimal service.
If you choose to withdraw your consent for data processing, kindly reach out to us through one of the communication methods specified in this Privacy Policy.
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How we make changes to this policy
| We may change this Privacy Policy from time to time to reflect our current practices and ensure compliance with applicable laws, so please check back frequently for changes. The most current version will always be at https://posely.app and it is advisable to regularly review these changes. Personal notification of alterations will only be provided if required by applicable law.
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Contact us
| We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details: Individual entrepreneur Rodion Zhukov Data Protection Officer (DPO)
You have the right to make a complaint at any time to the Personal Data Protection Service of Georgia - PDPS (https://pdps.ge/en). We would, however, appreciate the chance to deal with your concerns before you approach the PDPS so please contact us in the first instance. | |