Privacy Policy
Last updated: 31.08.2023
I. General Provisions
This Privacy Policy explains how Mira (“we”, “us”, “our”, the “Service”, the “App”, the “Website”) gathers, processes, uses, discloses and safeguards the information about all individuals, who uses or otherwise accesses the websites and applications of the Service (“you”, “your”, “User”). Additionally, it outlines your choices in connection with data collection and utilization.
Mira is a service that allows its users to generate unique photos using artificial intelligence (AI) capabilities and communicate with other users by means of video chat. Mira is developed and designed for your personal, non-commercial use only. You may access and utilize the App solely for the purposes mentioned above.
In accordance with this Policy, we act as the data controller, unless otherwise specified. We kindly urge you to thoroughly read and understand this Policy, as well as our Terms of Service. By using the Service, you explicitly acknowledge that you have read, comprehended, and agreed to be bound by these provisions.
Should any changes occur in this Privacy Policy, we will provide you with timely notice.
II. Limitation of Use
To use our Services, you must be at least 18 years of age. We do not knowingly collect or retain information from individuals under the age of 18. If you are under 18, you must adhere to the following conditions:
a. Confirm that your parent or guardian has read and consented to this Agreement on your behalf, securing their approval for your access and use of the Website.
b. Ensure that you possess the legal capacity to enter into a binding contract with us, free from any legal restrictions that may prohibit such actions in accordance with applicable laws.
If a parent or guardian becomes aware that their child has provided us with information without their consent, they should promptly contact us. We will take reasonable steps to ensure the removal of such information from our records.
III. How We Collect Your Data
To enhance your user experience and continually provide improved services, we may access or gather the following categories of information from various sources, that may include:
- directly from you or your representative;
- directly or indirectly from your activities in the Service;
- from our third-party partners.
The data about you that we may collect, access and process, may include:
- Content data (including photos, images, text, videos, and other data uploaded, generated, and exchanged via the Service);
- Service-related data (data about your activities in the Service);
- Facial data. This is the data that includes facial features necessary for processing related facial images and providing special effects to your photos. We do not retain your facial data nor do we share this data to any third party upon completion of the analysis process;
- Face recognition. The Service may collect avatar photos or videos that you upload or capture for certain services. We may request access to your mobile device's camera or album, which requires your permission. When utilizing facial recognition features, we capture the positions and shapes of your facial features, analyze facial feature data, and store this information on our server for photo processing. Processed photos, facial features, or renderings are not stored or shared with any third party;
- Voluntarily provided data. We may collect, store, and process information that you voluntarily provide, for example via the "Contact Us" form on the Website. This information may include your name, email address, the content of your message, and any other attached data;
- Automatically collected data. This type of data does not disclose your specific identity, is collected during your accessing of our Service and may include IP addresses, browser specifications, operating systems, language preferences, URLs, device names, location, and details regarding your usage of the Service. This data primarily serves the purpose of maintaining security and functionality of the App, as well as for internal analytics and reporting.
- Analytics data. Our Service may automatically gather information about your device or computer through tracking technologies like cookies, web beacons, log files, embedded scripts, and location-identifying tools. We may combine this information with other personal data and employ it for usage and device information collection. For data analysis, we may also employ third-party automatic data processing technologies (e.g., Google). We do not have control over the processing of your personal data by third parties, and therefore any claims regarding your personal information should be directed to those third parties;
- Data provided by other Users. We may receive, process and assess content, communication, and information from other users when they use our Services. This may include information about you, such as when other users invite you to install and use our Application and provide us with your phone number, name, and other data. We require that these Users possess the legal rights to collect, use, and share your data before sharing it with us.
We may disclose your personal data under the following circumstances:
- With your prior consent;
- In accordance with applicable laws and under legal procedures or in response to requests from various agencies.
- To protect our legitimate rights and interests.
Please note that we do not control and therefore are not responsible for the actions of other users with whom you share information. We cannot oversee the information you exchange with other users through our Service, nor can we control how they utilize this information. Additionally, we are not accountable for third parties circumventing our security measures.
IV. How We Use Your Data
We may employ your data for the following purposes:
- To meet the purpose of your information submission;
- To provide you with requested information, products, or services;
- To deliver marketing services, including personalized advertisements and information;
- To fulfill and execute any kind of legal obligations and rights;
- To improve the functioning, security and maintenance of the Service, to gain insights into user behavior and trends, identify potential technical issues, and operate, protect, enhance, and optimize the Service;
- To enhance the effectiveness of targeted advertisements and other information (if any);
- To communicate with you through newsletters, including sending marketing notifications, gathering feedback on our App, or responding to your inquiries;
- To fulfill lawful requests from law enforcement agencies and organizations if required so;
- To assess or execute any kind of transfer of our assets;
- To perform any kind of activity required for security purposes (including but not limited to customer screening, scanning, identity verification, risk monitoring, file backup, etc.) to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, safeguard our trademarks, and enforce our Terms of Use.
Information from other categories will not be used for substantially different purposes without prior notice. Information provided voluntarily to us or legally obtained is our property, and we may employ it for lawful purposes (including selling, renting, or transferring the information to publishers, advertisers, and data aggregators for marketing purposes). Should new purposes for processing your personal data arise, we will notify you and introduce corresponding changes to this Privacy Policy.
V. How We Share Your Data
While we do not rent or sell your personal data to third parties, we may share information obtained through tools like cookies, log files, and device identifiers with third-party organizations that provide automatic data processing technology for our website. Please note that we do not have control over or influence these third parties' tracking technologies or their usage. Nor can we guarantee the security of information transmitted directly from our website to these third parties. We will not assume responsibility for any accidental data loss or unauthorized access caused by third-party negligence.
The Service may contain links to third-party sites or services, and you may access our website through links provided by third-party sites. We are not responsible for the privacy practices of these third-party sites or services, including their information or content unless we are the providers of those sites and/or services.
The Service may share your data with third parties solely upon your consent in order to:
- deliver our services;
- improve or promote our services;
- deliver our services in partnership with other service providers.
Your personal data may be disclosed under some circumstances, including but not limited to:
- When we genuinely believe that disclosure is essential to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.
- In cases of mergers, acquisitions, or any other transfer of our assets, where we will notify you via prominent notice on our website regarding changes in ownership or the use of your personal information, along with any choices you may have.
- When sharing information with our affiliates, subsidiaries, contractors, business partners, or other third parties who perform services on our behalf is required.
VI. How We Store and Retain Your Data
We take all possible measures to secure the storage and integrity of personal information, utilizing specific hardware and software practices. Additionally, we uphold physical and procedural safeguards designed to fortify the protection of personal information. Despite these precautions, we cannot guarantee that our security measures will keep personal information invulnerable to unlawful access, theft, or unauthorized modification. In the event of a security breach that compromises your personal information, we will promptly notify you in accordance with applicable legal requirements.
We generally retain your personal data for the duration required to fulfill the functionality of the Service, the original or directly related objectives for which the information was collected, or to meet our legal obligations. If you wish to cease the use of your physically accessed and stored information, you can request that we erase your personal data and close your account. However, certain data may be retained for a defined period (not exceeding the purpose of storage) if needed to comply with legal obligations (e.g., taxation, accounting, audit), maintain security and data backup settings, prevent fraud, or address other activities.
In cases where personal data retention is necessary, the following rules will apply:
- Personal data will be processed and stored for the duration required to fulfill the specific purpose for which it was originally collected.
- Should the user grant consent for processing, the company may retain personal data for a more extended period, provided such consent remains valid and is not revoked. Additionally, companies may be compelled to retain personal data for extended durations to adhere to legal obligations or as directed by competent authorities.
- Upon the end of the retention period, personal data will be promptly deleted. Consequently, rights related to access, deletion, correction, and data portability may not be enforceable after the retention period.
VII. Third Party
The Service may resort to technologies and services of third parties in order to provide our services. These third-party services may include hosting, analytics, bug reporting services, etc.
Publishers who advertise online may utilize their own cookies, web beacons, and similar technologies to gather information about you. Our control does not extend to how publishers employ these technologies. The websites of our publishers may include hypertext links to third-party websites. We do not assume responsibility for the privacy practices or content found on such external sites.
We reserve the right to disclose or transfer personal information to entities that are wholly owned or controlled by us at our sole discretion.
It is important to bear in mind that our Privacy Policy does not apply to the practices employed by websites or services linked to or from our Service, nor does it cover the information or content contained therein. When you follow a link from our Service to another website, please be aware that the privacy rules and policies of third-party websites or services will apply to your browsing and interactions. We recommend reviewing these rules and policies before proceeding.
VIII. Your Rights
As an individual whose personal data is processed, you have the right:
- To access your data (to seek an explanation regarding the processing of your personal data).
- To rectify (to modify inaccurate or incomplete information).
- To erase (to submit a request for the deletion of your personal data from our systems).
- To object (to raise objections to the processing of your data).
- To restrict (to partially or fully restrict us from processing your personal data).
- To withdraw consent to processing.
- To request all the data you provided to us as well as request its transfer to another data controller.
- To lodge a complaint regarding processing of your data.
To exercise these rights, please contact us via our contact email.
IX. Lodging of requests
If you wish to submit a request regarding accessing, processing or deleting of your personal data, please contact our support. When submitting a request, you should be ready to provide us additional information (which includes full name, address, zip code, as well as any other information we may deem necessary) that would help us identify you as the User, whose personal data we are processing. If the request is submitted by your representative, this representative must also send us a written authorising confirmation signed by you. Please, provide a detailed description of your request so that we could understand and respond to it properly. We will not be able to process your request if we cannot identify you or your representative, or confirm that the information referred to in your request is related to you. We reserve the right to hold necessary checks and investigations to verify your identity before processing your request, and we warrant that any personal data provided in your request will be used and stored only to verify your identity and for the period of time necessary for this purpose. We take all possible measures to respond to requests within forty-five (45) days since their receipt. If our processing of your request would take more time, we will inform you on that event.
X. Contact
If you have any questions, claims or complaints regarding this Privacy Policy, please contact us at info@mira.chat.