Pursuant to Articles 13 and 14 of the GDPR, this is to inform you of the following about the processing of your personal data.

Data Controller

The Data Controller is CLEMENTONI S.p.A., with registered office in Recanati, Zona Industriale Fontenoce, VAT number 00092380435, hereinafter referred to as "Clementoni" or "Controller".

Categories of processed data

The app collects the following personal data:

• Audio and Videos
• TrueDepth data from TrueDepth API (iOS only)
• Photo Library
• Device ID

Purposes of the processing and legal basis for processing

• Audio and videos are required to allow the functioning of app technology. The user can record and edit videos and then share them. All these videos are only processed and stored locally on user’s devices and optionally shared only using the native sharing functionality.
• The app uses data from the TrueDepth API as part of Unity's ARKit Face Tracking plugin. Thanks to this technology the user can place 3d objects on his face in augmented reality. All the data from the TrueDepth API are only processed locally on user’s devices and not stored in any way.
• The app requires access to the device’s Photo Library only to store the recorded videos. The app doesn’t collect or process any data from the user’s Photo Library.
• Device ID is required to allow the functioning of app technology and to enable app analysis.

Data provision is mandatory for the use of the app. Data processing is based on the User’s consent (Article 6, paragraph 1, letter A of the GDPR), given for the above mentioned purposes. If consent is denied, the app will only have limited functionality.

Data retention time

Data are stored only on the User’s device and in no case they will be stored on Clementoni’s servers.

Data are retained for the time strictly needed to achieve the above-mentioned purposes during app usage. In no case, data are retained after consent is withdrawn or after the app is uninstalled.

By uninstalling the app, all data will be automatically cancelled.

Data disclosure

Data will not be disclosed to third parties.

Users’ rights and enquires

Clementoni S.p.A. has appointed a Data Protection Officer (D.P.O.), pursuant to article 37 of the GDPR.

For any enquiries or in order to exercise their rights, pursuant to articles 15-21 of the GDPR, users may contact the D.P.O. by writing to the following email address: privacy@clementoni.it or by sending a request to the following postal address:

Data Protection Officer
Clementoni S.p.A.
Zona Ind.le Fontenoce snc
62019 Recanati (MC), Italy

Security measures

Appropriate procedures will be adopted to protect the confidentiality, integrity and availability of the information in compliance with current regulations.

Changes to this privacy policy

Clementoni reserves the right to make changes to this privacy policy at any given time, duly informing the Users who shall be entitled to withdraw their consent to the processing of their personal data.