1. General Provisions This Privacy Policy (hereinafter – the "Policy") forms part of the User Agreement (hereinafter – the "Agreement") and governs the processing of data when using the Choisy mobile application (hereinafter – the "Application") for iOS devices. The current version of the Agreement and this Policy is available in the Application menu and/or at: https://choisyapp.com/privacy. By accepting the Agreement and installing the Application, the user (hereinafter – the "User") confirms that they have read and agreed to this Policy. Data Controller – Anastasia Sergeevna Kalinouskaya (hereinafter – the "Administration"), Republic of Belarus, Minsk, ul. Skryganova, 4a. The Administration acts in accordance with the laws of the Republic of Belarus and applicable international norms, including the General Data Protection Regulation (GDPR). Data Subject – any individual using the Application. The Administration is the owner of the Application. The Choisy Application does not collect, transfer, or store Users’ personal data on the Administration’s servers. All operations with photos and videos are performed exclusively locally on the User’s device.
2. Purposes of Data Processing 2.1. Data is processed exclusively to: • provide Users with functions of editing and processing photos and videos; • ensure proper functioning of the Application. 2.2. Data is not used for marketing, advertising, analytics, or other unrelated purposes. 2.3. When using the contact form on the Application website, data (name, email address, and message) is processed solely for the purpose of responding to the User’s request and maintaining communication.
3. Types of Data Processing 3.1. The Application does not request or store Users’ personal data on the Administration’s servers. 3.2. The Application may process locally on the User’s device only the following: • photos and videos selected by the User for editing; • settings and effects applied by the User within the Application. 3.2.3. To enable certain functions, the Application may request access to the camera, microphone, and photo gallery of the device. Such access is used exclusively for the Application’s functionality and never for hidden data collection. 3.3. The Application does not collect: • unique User identifiers (IDs); • social media account details; • device technical parameters, including region, model, or OS version; • User behavior data for analytics or advertising; • advertising identifiers (Google Advertising ID, Apple ID for Advertising). 3.4. All materials remain on the User’s device and may be deleted by the User at any time. 3.5. To ensure stability and error fixing, the Administration uses Firebase (Crashlytics), which may collect anonymized technical information such as device model, OS version, and error reports. Data is processed in accordance with Google’s Privacy Policy: https://policies.google.com/privacy. 3.6. Anonymous statistical data about downloads and usage may also be collected via App Store Connect in accordance with Apple’s Privacy Policy: https://www.apple.com/legal/privacy/. 3.7. The collection of such data is carried out not by the Administration, but by the respective services (Google and Apple) and is governed by their own privacy policies. 3.8. When filling out the contact form on the Application’s website, the User may provide their name, email address, and message text. This information is not stored in databases, not used for marketing or advertising purposes, not transferred to third parties, and is deleted once communication with the User is completed.
4. Data Storage and Transfer 4.1. The Administration does not store or transfer Users’ data. 4.2. The Application uses access to the photo gallery, camera, and/or microphone solely for its editing functions. Photos and videos are not copied or saved outside the device. 4.3. Users’ data is not transferred to third parties, including advertising and analytics services. 4.4. The Administration emphasizes that Users’ photos and videos are not transferred to Firebase or App Store Connect. These services may only receive technical data necessary to analyze the stability of the Application. 4.5. The Application does not store or create copies of Users’ photos and videos. It only displays materials to which the User has granted full or limited access via iOS system settings. If photos or videos are deleted from the device’s gallery, they automatically cease to appear in the Application.
5. Data Protection 5.1. The Administration takes reasonable measures to ensure the security of the Application but notes that all materials are processed exclusively locally on the User’s device. 5.2. Since data is not transmitted over the Internet, the risk of unauthorized access is minimized. 5.3. The person responsible for data protection is Anastasia Sergeevna Kalinouskaya (contact details in Section 13).
6. User Rights and Obligations 6.1. The User has the right to: • grant or revoke the Application’s access to the camera, microphone, and/or photo gallery via iOS settings; • delete all their photos and videos from the device at any time; • contact the Administration with questions about privacy. 6.2. The Administration undertakes to use the granted permissions only for the functioning of the Application and within the stated purposes.
7. Minors 7.1. The Application is not intended for individuals under 13 years old (or under 16 years old for residents of the EEA). 7.2. The Administration does not knowingly collect or process minors’ data.
8. Transfer of Data to Third Parties 8.1. The App does not transfer Users’ data to third parties, except where required by law (e.g., by lawful requests of government authorities).
9. Limitation of Liability 9.1. This Policy applies exclusively to data use within the Application. 9.2. The Administration is not responsible for the User’s use of third-party applications or services accessed outside the Application. 9.3. The Administration is not responsible for possible actions of third parties who gain access to the User’s device (e.g., loss, hacking, or unauthorized use). 9.4. The Administration is not a data operator of Users’ personal data, as it has no access to photos and videos. All processing takes place locally on the User’s device. The Administration only provides a technical tool for local photo and video processing. 9.5. The Administration is not responsible for the preservation of materials on the User’s device. File management (including deletion or backup) is fully carried out by the User.
10. Withdrawal of Consent 10.1. The User may withdraw their consent to provide access to the camera, microphone, or photo gallery through the device settings. 10.2. In this case, certain functions of the App may become unavailable.
11. Changes to this Policy 11.1. The Administration may amend this Policy from time to time. 11.2. The updated version of the Policy will be published in the Application and/or on the website at https://choisyapp.com/privacy. 11.3. By continuing to use the Application after changes to the Policy, the User is deemed to have read and accepted the updated Policy.
12. Applicable Law 12.1. This Policy is governed by the laws of the Republic of Belarus and also takes into account the provisions of GDPR, CCPA, and other applicable international acts. 12.2. In case of disputes, they are subject to consideration by the courts at the location of the Administration.
13. Contact Information Anastasia Sergeevna Kalinouskaya Citizen of the Republic of Belarus Address: Republic of Belarus, Minsk, ul. Skryganova, 4a Email: sup.choisy@gmail.com
