PHOTOMYNE IS COMMITTED TO AND COMPLIANT WITH THE EU GDPR

Below we detail Photomyne’s updated compliance with the 2018 EU GDPR regulations regarding data privacy

The General Data Protection Regulation (GDPR) is a new and important EU legislation designed to make data protection laws clearer and more accessible to all individuals within the European Union. This new regulation was approved and adopted in 2016 and will be enforceable on May 25, 2018.

Photomyne is committed to the new GDPR laws. Below we explain in plain language what is the GDPR, what information we collect about our users, and how this information is used.

Please note: The content of this page may change from time to time. We encourage you to revisit this page periodically to stay updated with the most recent adjustments to Photomyne’s GDPR compliance.

WHAT IS THE GDPR?

It’s one of the most important data protection legislations to be introduced in the EU in the last 20 years. The new General Data Protection Regulation of 2018 will replace the 1995 Data Protection Directive.

The main goal of the GDPR is to standardize and regulate the handling of personal data about individuals in the EU, including its collection, storage, transfer or use by companies and third parties. Under the GDPR, “personal data” refers to any information relating to an identified or identifiable individual (“data subject”), including, name, address, phone number, email address, government-issued identifier, credit card information, unique identifier, biometric information, photos, videos, location information, device ID or IP address, or any other combination of these.

The GDPR gives individuals (legally titled “data subjects”) more rights and control over their personal data on one hand, and considerably increases the legal obligations of companies processing such data, on the other hand. Under the GDPR, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

EU-based individuals will now have more control and rights over their personal data. This is achieved by companies’ compliance with the new regulations, including the former’s transparent disclosure of how they process the personal data of the data subjects using their service or products.

SUMMARY OF THE KEY CHANGES INTRODUCED BY THE 2018 GDPR:

More data subject rights

Data subjects now have the right to receive “fair and transparent” information about the processing of their personal data. Additionally, data subjects now have the right to be forgotten (Data Erasure), the right to request that any complete or correct data (Data Rectification) and the right to request a copy of any personal data stored in their regard (Data Portability). See below the explanation on your Rights with regard to your use of Photomyne.

One of the fundamental aspects of the GDPR are stricter consent requirements meaning that companies and organizations must obtain data subject’s specific and "active" consent to distinct purposes

In any event of violation of data subject’s rights, he or she has the right to lodge a complaint with a supervise authority. If you're based in the European Economic Area and think that we haven't complied with the GDPR, you have a right to lodge a complaint with the Data Protection Commission with your local supervisory authority.

Data breach security and notification

Under the new GDPR laws, companies must report data breaches to data protection authorities within 72 hours of “first having become aware of the breach.” Companies classified as Data Processors will be required to notify their customers, the controllers, “without undue delay” after first becoming aware of a data breach.

GDPR compliance requirements

The GDPR requires companies and organizations to implement relevant policies and security protocols, including codes of conduct, perform privacy impact evaluations, have and maintain detailed records on data activities, and enter into written agreements with vendors or any third party that comes in contact with “personal data”.

Profiling and monitoring requirements (new)

Under the GDPR legislation, companies and organizations must meet additional requirements if they are involved in profiling or monitoring behavior of EU individuals. Data subjects have the right not to be subject to a decision-based solely on automated processing, including profiling.

Greater enforcement and liability

The GDPR allows authorities to fine organizations up to the greater of €20 million or 4% of a company’s annual global revenue, depending on the gravity of the breach and damages incurred.

What if you’re not a resident of the EU?

This is still information you should be aware of and understand. The new GDPR legislation applies to any organization that collects and/or uses personal data of individuals in the European Union. This includes tracking individuals’ online activities regardless of whether the organization has a physical presence in the EU.

Data transfer outside the EU

The GDPR requires that transfer of personal data outside the EU should not undermine the level of protection of data subjects’ rights. Therefore, controllers and processors must comply with GDPR terms and conditions while doing so, including by making data transfers on a lawful mechanism of data transfer or to an adequate jurisdiction as determined by the EU competent authorities.

For more information on these new changes and what they include, please visit the EU GDPR official page.

INFORMATION PHOTOMYNE COLLECTS AND WHY

If you choose to provide the following (optional):

  • Your first and last name
  • Email address
  • Telephone number
Why? To get in touch with you, offer support, and special offers

Mobile device & scanned photos:

  • Your mobile device configuration (primarily country & language)
  • Photos you scan with the app and related details you entered (saved to the cloud for backup)
  • App usage patterns
Why? Mainly in order to enable the use of our services, to safeguard your scans, and to retrieve your content should anything happen.

INFORMATION WE DON’T COLLECT

  • Your mobile device’s location
  • Any personal information on your mobile device unrelated to the Photomyne app (including other photos on your device, contacts, calendars, phone calls, messages, etc.)
Why? Because it’s none of our business :-)

HOW LONG WE HOLD PERSONAL INFORMATION FOR

In all circumstances, data will be retained in accordance with the GDPR requirements as following:

  1. for no longer than is necessary in relation to the purposes for which such personal data was collected or otherwise processed, including for the purpose of ensuring your photos are saved and backed up for easy retrieval, should you need it; or
  2. In the event you withdraw your consent and there are no more legitimate grounds for the processing.

Once data is no longer lawfully required it will be destroyed securely.

If you wish to change this default setting, you’re welcome to contact us and request that we permanently delete your information, in accordance with the “Contacting Us” section below.

IMPORTANT INFORMATION ABOUT SHARING YOUR PHOTOMYNE PHOTOS

The Photomyne app offers various ways to share the photos you scanned. Here is an explanation of what it means to share one or more photos, in terms of your privacy and your produced content:

Publishing a photo on the app’s ‘Discover’ feed

Posting a photo onto the app’s Discover’ section means that it will be public and visible to people online, outside of the app. Such photos could also find their way to strangers on the web. Photomyne has no control over how other people may interact with your published photo (taking a screenshot, downloading the photo, etc.). Please keep that mind before publishing a photo onto the ‘Discover’ feed.

Sharing photos with the app (generated web link)

Choosing to share photos through the app’s sharing option generates a unique web link which you can then pass on to your contacts and recipients. Anyone with that web link can have access to the photos you shared. Photomyne has no control over how other people you shared your photos with via the web link may interact with your content (taking a screenshot, downloading the photo, etc. or passing the web link on to others). This means it’s possible that your shared photos could find their way to strangers on the web. To minimize the risk of inappropriate use of your content, the generated web link will work for a maximum of 1 year (365 days), after which it will become invalid.

Sharing photos by creating a family website

Under the app’s Family tab, you can create a photo gallery website, showcasing the photos you scanned with the app. When you share your family website with others, they will have access to your website, and may pass its content or its address on to others. Photomyne has no control over how other people may interact with your content or the website. This means it’s possible that your family website or its content could find its way to strangers on the web. There is an option to add a 4-digit password protection to your family website, but please keep in mind that this DOES NOT constitute guaranteed protection of your content’s privacy.

THIRD PARTIES ASSOCIATED WITH THE PHOTOMYNE SERVICE

The following is a list of third party providers Photomyne uses to make it possible to offer you our product and the services services. The table mentions whether each third party has a Data Protection Agreement (DPA) with Photomyne.

Third Party Company Has DPA with Photomyne? Third Party GDPR Information
Google (BigQuery / Firebase / Google Analytics) Yes Link
Amazon AWS (servers and photo backup) Yes Link
Hotjar (website analytics) Yes Link
FiveTran Yes Link
AppsFlyer (Mobile marketing Yes Link
Facebook Has GDPR compliant representation Link
Zooz Yes Link

RIGHT TO BE FORGOTTEN

According to Art. 17 of the GDPR, data subjects in the EU have a right to erasure (‘right to be forgotten’). This means you have the right to obtain from the controller (in this case Photomyne is the controller) the prompt erasure of your associated personal data. Should you decide to exercise this right with regard to your use of Photomyne, we will be obligated to erase your personal data without undue delay.

Please keep in mind that once you request to exercise your Right to be Forgotten with regard to your use of Photomyne, any deleted content and/or information will not be retrievable.

Steps to exercise your Right to be Forgotten by Photomyne:

  1. Contact us using the Photomyne app: Open the app’s side-menu and select Help & Support. Next, select Contact us for support.
  2. In your message, please mention “Right to be Forgotten” in the message’s subject field.
  3. We will then confirm the receipt of your message, and may ask follow-up questions for verification.
  4. Photomyne will delete ALL of your information, content and data, internally.
  5. We will then make a formal request from our associated third party providers to delete and confirm the deletion of the relevant information.
  6. We will update you on the progress of Step #5.
  7. We will confirm via email that your data has been successfully deleted by Photomyne AND by our third party providers.
  8. We will ask you to delete the Photomyne app from any or all devices, in order to complete the erasure.

RIGHT TO RECTIFICATION

According to Art. 16 of the GDPR, EU data subjects have the right to rectification of any inaccurate personal data. This means you may request to correct, amend or delete information we hold about you.

Steps to exercise your right to update, complete or amend your personal data (Data Rectification):

  1. Contact us using the Photomyne app: Open the app’s side-menu and select Help & Support. Next, select Contact us for support.
  2. In your message, please mention “Right to amend my Data” in the message’s subject field.
  3. We will then confirm the receipt of your message and may ask follow-up questions for verification.
  4. Photomyne will amend or alter your information according to your request and instructions.
  5. We will then make a formal request from our associated third-party providers to do so as well and to amend or alter your information accordingly.
  6. We will update you on the progress of Steps #4 and #5.
  7. We will confirm via email that your data has been successfully amended by Photomyne AND by our third party providers.

RIGHT TO DATA PORTABILITY

According to Art. 20 of the GDPR, EU data subjects have the Right to Data Portability. This means you have the right to request a copy of any personal data stored in your regard by Photomyne. This is assuming you haven’t yet exercised your Right to be Forgotten. See below the steps to achieve that.

Steps to exercise your right to get a copy of your personal data (Data Portability):

  1. Contact us using the Photomyne app: Open the app’s side-menu and select Help & Support. Next, select Contact us for support.
  2. In your message, please mention “Right to a Copy of My Data” in the message’s subject field.
  3. We will then confirm the receipt of your message, and may ask follow-up questions for verification.
  4. Photomyne will assemble ALL of your information, content and data, internally.
  5. We will then make a formal request from our associated third party providers to send us or allow us to view your relevant information.
  6. We will update you on the progress of Step #5.
  7. We will confirm via email that your data has been successfully gathered by Photomyne AND by our third party providers, and we will then send you your files via email.

CONTACT US

If you have any questions or concerns regarding how we use your information, please contact us at support@photomyne.com and mention “GDPR” in your message’s subject line.

Asset 24
Photo Scanner
by Photomyne
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