Privacy Policy

Effective date: May 1, 2023 Captchagram Ltd ("us", "we", or "our") operates the

Captchagram app (the "Service").

This document informs you of our policies regarding the collection, use, and disclosure

of personal data when you use our Service and the choices you have associated with

that data.

We use your data to provide and improve the Service. By using the Service, you agree to

the collection and use of information in accordance with this policy. Unless otherwise

defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings

as in our Terms and Conditions, accessible from within the Captchagram app.

Definitions

Service

Service is the Captchagram app operated by Captchagram Pty Ltd

Personal Data

Personal Data means data about a living individual who can be identified from those

data (or from those and other information either in our possession or likely to come

into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or

from the Service infrastructure itself (for example, the duration of a page visit).

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in

common with other persons) determines the purposes for which and the manner in

which any personal information are, or are to be, processed. For the purpose of this

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes

the data on behalf of the Data Controller. We may use the services of various Service

Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of

Personal Data.

Definitions

We collect several different types of information for various purposes to provide and

improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally

identifiable information that can be used to contact or identify you ("Personal Data").

Personally identifiable information may include, but is not limited to:

• Email Address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or

promotional materials and other information that may be of interest to you. You may

opt out of receiving any, or all, of these communications from us by following the

unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol

address (e.g. IP address), the pages of our Service that you visit, the time and date of

your visit, the time spent on those pages, unique device identifiers and other diagnostic

data.

Location Data

We may use and store information about your location if you give us permission to do

so (“Location Data”). We use this data to provide features of our Service, to improve and

customize our Service.

You can enable or disable location services when you use our Service at any time,

through your device settings. This may limit some of the features within the service.

Face Analysis and Face Recognition

Face Analysis is a process by which the facial features from photos provided to the

Service can be analysed. The Service’s face analysis is not linked with any personal

information and is held securely by AWS (our App Service Provider).

We do not share any of your data with any 3rd parties.

Face Recognition is an optional feature where a photo provided by a user (a “selfie”) can

be compared to the face analysis of photos stored.

The results can display the photos that are a likeness of the selfie. Face Recognition is a

search feature enabling photos to be found more quickly. The selfies uploaded are

stored in our system or our Service Providers system and used to facilitate future photo

matching and/or to allow other users of the app to identify/recognise you, when you

want to be recognised, for certain services and features of the app to be provided.

Face data collected for the detection of the user's presence in any media is transient

and is only stored while the face detection process is run.

After processing, the face data is deleted.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service

and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique

identifier. Cookies are sent by our app and stored on your device. Tracking technologies

also used are beacons, tags, and scripts to collect and track information and to improve

and analyze our Service.

Examples of data we use:

• Session Cookies. We use Session Cookies to operate our Service.

• Preference Cookies. We use Preference Cookies to remember your preferences

and various settings.

• Security Cookies. We use Security Cookies for security purposes.

Use of Data

Captchagram Ltd uses the collected data for various purposes:

• To provide and maintain our Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service when you

choose to do so

• To provide customer support

• To gather analysis or valuable information so that we can improve our Service

• To monitor the usage of our Service

• To detect, prevent and address technical issues

• To provide you with news, special offers and general information about other

goods, services and events which we offer that are similar to those that you have

already purchased or enquired about unless you have opted not to receive such

information

Legal Basis for Processing Personal Data Under General Data Protection

Regulation (GDPR)

If you are from the European Economic Area (EEA), The Service’s legal basis for

collecting and using the personal information described in this Privacy Policy depends

on the Personal Data we collect and the specific context in which we collect it.

The Service may process your Personal Data because:

• We need to perform a contract with you

• You have given us permission to do so

• The processing is in our legitimate interests and it's not overridden by your

rights

• To comply with the law

Retention of Data

The Service will retain your Personal Data only for as long as is necessary for the

purposes set out in this Privacy Policy. We will retain and use your Personal Data to the

extent necessary to comply with our legal obligations (for example, if we are required to

retain your data to comply with applicable laws), resolve disputes, and enforce our legal

agreements and policies.

The Service will also retain Usage Data for internal analysis purposes. Usage Data is

generally retained for a shorter period of time, except when this data is used to

strengthen the security or to improve the functionality of our Service, or we are legally

obligated to retain this data for longer time periods.

Transfer of Data

The Service is capable of storing your information in the country where you operate. If,

for legal or compliance issues, you require your information stored in your country

please contact us and we can enable that.

Unless you request otherwise, your information, including Personal Data, may be

transferred to, and maintained on, computers located outside of your state, province,

country or other governmental jurisdiction where the data protection laws may differ

than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information

represents your agreement to that transfer.

Disclosure Of Data

Disclosure for Law Enforcement

Under certain circumstances, The Service may be required to disclose your Personal

Data if required to do so by law or in response to valid requests by public authorities

(e.g. a court or a government agency).

Legal Requirements

The Service may disclose your Personal Data in the good faith belief that such action is

necessary to:

• To comply with a legal obligation

• To protect and defend the rights or property of the Service

• To prevent or investigate possible wrongdoing in connection with the Service

• To protect the personal safety of users of the Service or the public

• To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of

transmission over the Internet, or method of electronic storage is 100% secure. While

we strive to use commercially acceptable means to protect your Personal Data, we

cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation

(GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data

protection rights. The Service aims to take reasonable steps to allow you to correct,

amend, delete, or limit the use of your Personal Data.

We extend these rights to anyone using the Service not just from EEA countries.

If you wish to be informed what Personal Data we hold about you and if you want it to

be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete your information.

Whenever made possible, you can access, update or request deletion of your

Personal Data directly within your account settings section. If you are unable to

perform these actions yourself, please contact us to assist you.

The right of rectification.

You have the right to have your information rectified if that information is

inaccurate or incomplete.

The right to object.

You have the right to object to our processing of your Personal Data.

The right of restriction.

You have the right to request that we restrict the processing of your personal

information.

The right to data portability.

You have the right to be provided with a copy of the information we have on you

in a structured, machine-readable and commonly used format.

The right to be forgotten.

You have the right to ask for all information (including photos and data

associated with those photos) be to removed from the Service.

The right to withdraw consent.

You also have the right to withdraw your consent at any time where the Service

relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such

requests

You have the right to complain to a Data Protection Authority about our collection and

use of your Personal Data. For more information, please contact your local data

protection authority in the European Economic Area (EEA).

Service Providers and Service Features

We may employ third party companies and individuals to facilitate our Service ("Service

Providers"), to provide the Service on our behalf, to perform Service-related services or

to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on

our behalf and are obligated not to disclose or use it for any other purpose.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports

webApp traffic. Google uses the data collected to track and monitor the use of our

Service. This data is shared with other Google services. Google may use the collected

data to contextualize and personalize the ads of its own advertising network. You can

opt-out of having made your activity on the Service available to Google Analytics by

installing the Google Analytics opt-out browser add-on. The add-on prevents the Google

Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google

Analytics about visits activity. For more information on the privacy practices of Google,

please visit the Google Privacy Terms

web http://www.google.com/intl/en/policies/privacy/

Links To Other Apps

Our Service may contain links to other Apps that are not operated by us. If you click on a

third party link, you will be directed to that third party's App. We strongly advise you to

review the Privacy Policy of every App you visit.

We have no control over and assume no responsibility for the content, privacy policies

or practices of any third party Apps or services.

Children's Privacy

Our Service does not knowingly address anyone under the age of 16 ("Children")

We do not knowingly collect personally identifiable information from Children. If you

are a parent or guardian and you are aware that your Children have provided us with

Personal Data, please contact us.

To protect photos of Children we have a number of security features including

password protection, privacy of viewing photos and facial blurring in photos. Please

Privacy and Security features

Some customers will be offered additional features that help provide Privacy and

Security of photos.

These features may require the upload and storage of a persons photo (selfie) to be

used in face recognition process to attempt to remove them from photos made

available.

It should be noted that no technology is 100% perfect and although the Service provides

Privacy and Security features they are not 100% reliable and cannot be used by the user

as the sole method for Privacy and Security of photos.

The Service, it’s Company, the App, its affiliated and associated companies, and their

respective directors, officers, employees, agents, representatives, independent and

dependent contractors will not be held responsible for any issues arising from the usage

of the Privacy and Security features of the Service.

Infrastructure security in Amazon Web Services

The Service uses Amazon Web Services (AWS) a universally trusted and secure partner

for hosting global webApps. As a managed service, Amazon Face Analysis and Face

Recognition is protected by the AWS global network security procedures.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes

by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the

change becoming effective and update the "effective date" at the top of this Privacy

Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to

this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, please contact us:

• By email: admin@captchagram.com