Privacy Policy
Last Update: June 2023
Alpha Vision Labs and its subsidiaries and affiliates (collectively, "Alpha Vision", "we", "our" or "us") develops, publishes and operates AI-powered computer vision solutions for mobile environments ("Solutions"), as well as web and mobile applications (each, an "App") for integrating our vision technology across multiple devices and platforms.
We also operate the website www.alphavisionlabs.com, their subdomains, and related features, as well as an online store (collectively, "Sites", and together with the Solutions and App, collectively – the "Services").
Alpha Vision Labs respects your privacy and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and share your personal data, and it applies whenever you visit our Sites, install our App and use our Solutions, interact with us or otherwise access or use any of our Services.
We highly recommend that you carefully review and comprehend this Privacy Policy before proceeding. If you are not in agreement with the provisions stated in this Privacy Policy, we kindly ask you to refrain from using our Services. You retain the right to discontinue your use of our Services at any given time, as specified in this Privacy Policy.
Alpha Vision Labs is responsible for deciding how we hold and use Personal Data about you. We are required under certain data protection legislation to notify you of the information contained in this Privacy Policy. You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still use our basic vision features without connecting your social media accounts, but you will not be able to enjoy their advanced AI capabilities and social features).
1. Data Collection
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Data automatically collected or generated:
When someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services, including through the use of "cookies" and other tracking technologies (as further detailed below).
Such data consists of connectivity, technical or aggregated usage data, such as:
- IP address
- In-game identifier
- Game statistics and preferences
- Unique advertising ID (e.g. IDFA; you may reset such ID based on the operating system instructions)
- Non-identifying data regarding device, operating system, browser or App version
- Mobile carrier, locale and language settings
- User activity on our Services
- In-App activity (such as content/product interaction and advertising data)
- Diagnostic data (i.e. crash data and performance data)
We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services.
Data received from you:
You may provide us Personal Data voluntarily, such as when you:
- Set up an account with us
- Contact us (through Facebook, Messenger, e-mail, in-game chat or any other channel)
- Post on our public forums or groups
- Provide us your e-mail address
- Participate in competitions, contests, tournaments and promotions
- Place purchases in our Services
- Interact with other users through in-game chat
- Connect your social media accounts to our Services
Data received from Facebook and other channels:
Once you connect the Services to your Facebook, Google, Apple or similar account, we will receive access to your public profile, including (to the extent you defined it as "public"):
- Full name
- E-mail address(es)
- Gender
- Profile picture
- Location
- Time zone
- List of your friends using our Services
This will allow us to present your and your friends' public profile pictures inside the Services and to create your in-service friends list. Additionally, we or our advertising partners may receive general information concerning the performance of our advertising campaigns from these platforms.
If you access our Services through a third party such as Facebook, Google or Apple, or connect our Services to any third-party account, you should also read their terms and conditions and privacy policies.
Transaction Data:
In-Service purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as:
- Name
- Billing address
- E-mail address
- Items purchased
This information is necessary to fulfil your purchase and for our accounting purposes.
2. Data Uses
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
Legal Bases for Processing
- Performance of a contract: We will use this basis for processing necessary to make the Services available to you, including AI-powered features when you choose to log in with Facebook, Google or Apple, and support services, and to send you service communications, updates and rewards.
- Consent: In limited cases (where you choose to sign up to receive direct marketing emails, where you accept cookies on our Sites), we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details in Section 13.
- Legitimate interests: We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Services and through other channels, matching users for collaborative features, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.
- Compliance with a legal obligation: In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.
Specific Purposes
The purposes for which we use Personal Data are described in detail below:
- To facilitate, operate, and provide our Services
- To authenticate the identity of our users, and allow them access to additional features
- To provide our users with customer care, assistance and technical support services
- To enable you to interact with other users in the platform
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties, including by personalizing your profile and integration options
- To manage and deliver advertisements more effectively, including:
- Contextual advertising
- Behavioral advertising
- Interests-based advertising based on platform activity and preferences
- Re-targeting purposes
- To contact our users (via e-mail, social media, push notifications or any other available channels) with:
- General or personalized service-related messages
- Purchase confirmations
- System maintenance notices
- Promotional messages (such as platform updates, new features, premium services, etc.)
- To support and enhance our data security measures, including preventing and mitigating risks of fraud, error or any illegal or prohibited activity
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data, which we or our Service Providers may use to provide and improve our respective services
- To comply with any applicable laws and regulations
3. Storage and Retention
While privacy laws may vary between jurisdictions, Alpha Vision Labs has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
We retain your Personal Data in order to maintain our relationship and to provide you with our Services. We will retain your Personal Data for only as long as necessary to fulfil the purposes for which we collected it. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise.
We will take reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our Data Retention Policy.
If you have any questions about our Data Retention Policy, please mail to [email protected]
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you and it is no longer considered Personal Data within the meaning of this Privacy Policy.
4. Personal Data Deletion and Closure of Accounts
In addition to any other rights set out in this Privacy Policy, you at any time may direct that Alpha Vision Labs delete your Personal Data by accessing the "Account Deletion" option in your account settings and following the instructions.
Selection of this option will result in:
- Closure of your Account
- Deletion of all your usage history
- Removal of purchase information
- Disconnection of social media integrations
- Removal of all other information associated with your account
Deletion is irreversible. If you maintain multiple service accounts, you should request closure of each separately.
Upon receipt of your request, we will comply promptly but please allow some time for processing. We also reserve the right to retain a copy of any Personal Data that we are required by applicable law to retain.
5. Data Sharing
We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates. The circumstances in which we share data are summarised below:
For the removal of doubt, Alpha Vision Labs may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
6. Communications
Service Communications
We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc.
You will not be able to opt-out of receiving such service communications.
Promotional Communications
If you have signed up to receive such communications from us, we may also notify you about:
- New services and features
- Events and special opportunities
- Other valuable information we think you'll find interesting
We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
You have the right to withdraw your consent to receiving such promotional communications at any time. You can do this by:
- Contacting us at [email protected]
- Following the "unsubscribe" instructions in promotional communications
- Using the "change e-mail preferences" options in your account settings
7. Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies (collectively, "Tracking Technologies") which help us:
- Provide and improve our Services
- Personalize your experience
- Monitor the performance of our activities and campaigns
- Track usage of our Apps and Services
8. Data Security
In order to protect your Personal Data held with us and our Service Providers, we use appropriate:
- Physical security measures
- Procedural security measures
- Electronic security measures
- Data encryption where deemed appropriate
However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
If you discover any security or vulnerability issues related to the Services you should send an email to: [email protected]
9. Advertising
Our Services include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
Data Used for Advertising
Such data includes:
- Your device advertising identifiers (e.g. IDFA or Advertising ID, to the extent available)
- Data related to your connected social media profiles (if any, such as gender, region or country)
- Service usage content
- User ID
- Product interaction data
- Demographic information
- Interest-based information that we or our advertising partners may have received from or about you
This data collection and usage is based on your consent or another legal basis (i.e., as required to provide you with our respective services, or based on the legitimate interests described above).
The ads we or our advertising partners deliver may be shown:
- Within our Services
- Through other channels
- On third party websites and applications
This Privacy Policy does not apply to the practices of companies that we do not own or control. Any information you provide to sites, applications or services advertised through our Services will be covered by their respective privacy policies.
How to adjust your preferences regarding interest-based advertising
If you wish to prevent the use of your device's advertising ID or other identifiers for interest-based advertising, you can:
Please note that if you reset your advertising ID or opt-out of interest based advertising:
- You may still see advertisements in our Services
- Ads will not be targeted based on the above mentioned identifiers
- Ads may be based on context, such as your usage and preferences
- Such actions may result in a less enjoyable user experience
Aggregated and analytical information
We use the standard analytics tools of Google Analytics and may use other analytics tools from time to time. The privacy practices of these tools are subject to their own privacy policies.
Google Products
Google uses technologies such as cookies to track and analyse the use of our Site and/or an SDK to serve ads. To learn more:
- Review Google's partner site policies
- Use Google Analytics' opt-out tool
- Learn about Google SDK data processing
10. Data Subject Rights – European Economic Area, Switzerland and United Kingdom
If you are a resident of the European Economic Area (EEA), Switzerland or the United Kingdom (UK) about whom we process Personal Data, you have the right to:
- 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 information we hold about you corrected.
- 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 exercised your right to object to processing.
- Object to processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your Personal Data to another party.
Important Information About Your Rights
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
Right to Withdraw Consent
Please see Section 14 below.
If you wish to exercise your rights under applicable law (e.g., the General Data Protection Regulation (GDPR) or the UK GDPR) please contact us at [email protected]
If you wish to manage the information we receive about you from a third-party application or platform where you use our Services, such as Facebook, Apple or Google, please follow the third-party application's instructions for updating your information and changing your privacy settings.
11. Data Transfers
Your Personal Data may be maintained, processed, accessed and stored by Alpha Vision Labs and our authorized affiliates and Service Providers in and from the United States and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
We may transfer Personal Data we collect about you outside the EEA, Switzerland or UK, in order to perform our contract with you. To ensure that your Personal Data receives an adequate level of protection, we have put in place the following measures:
- Standard Contractual Clauses
- Countries that are the subject of an EU adequacy determination
If you require further information about these protective measures, you can contact us using the details in Section 14.
12. Minors
Our services are intended for individuals aged 16 and above. We reserve the right to request proof of age or parental consent at any stage. We may block Users whom we suspect are under the applicable age.
We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.
If you believe that we might have any such data, please contact us at [email protected]
13. Amendments and Controlling Version
We may amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date.
We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you.
If you do not agree to be bound by the terms of the new or modified Privacy Policy, you are required to stop using the Services.
The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy.
In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English-language version, the meaning of the English language version shall prevail.
14. Right to Withdraw Consent
15. Contact Us
If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Privacy, or to contact Alpha Vision's Data Protection Manager, please contact us at: