Effectiveness date: February 2023

- PRIVACY POLICY

GRIMLAX TRADE, S.L. (hereinafter, “the Company”, “We”, “Us” and the like) is firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in the present Privacy Policy (hereinafter, “this Policy”), the User(hereinafter “the User”, “you”, “your”) of AI Cleaner: Clean up storage (hereinafter, “the/our app”) will find all the relevant information to better understand what We do with their personal data. If you do not agree with this Policy, please do not access and use our app. 

We may update this Policy according to new legislative or jurisprudential requirements and/or business needs, among others reasons. Any updates or modifications of this Privacy Policy will be considered applicable from the moment of their publication on the app. Therefore, the User is recommended to review this Policy regularly. This Policy will always be available on the app so that the data subjects can consult it at all times. 

What does this Policy apply to?

This Policy applies to the personal data that We collect and process from you as a User of our app as well as the services offered within it. 

Please bear in mind that in order to access and use our app you must be older than fourteen (14) years of age or older, in accordance with the applicable law in your country or territory.

What does personal data mean and which data do We collect and process?

For the purposes of this Policy, "personal data" refers to all data that identifies you or that could be used to identify you, such as:  

- Some of your device details, as when you access our app or login, is received but note that such data is received as disaggregated data (strictly device identifier information), that means that is not associated with a particular User or their personal information, but it only has to do with information concerning the general use that all Users make of our app.

- Information about the use that the User makes of our app (the sections you consult on our app), as for example access to your device to match repeated information by exploring, among others, the contact list, events located in the device calendar, videos and photographs in your camera roll. To this regard, note that we do not store or use the data placed in your device, but we only require you access to provide you with the entrusted services and, therefore,  all information is exclusively located in your device and/or iCloud account;

- Information about the location of your device (that is, your IP address);

- When accessing the app, you will be required for your consent, by means of a pop-up, to enable us to get to know your geolocalization data according to Apple policies. In this sense, you are the sole responsible to allow us to get access, temporarily access while using the app or to refuse access on our part to such data. If you accept, note that you can go to “Settings” on your device, and withdraw such consent at any time.

- Information about your Apple account when you have provided your consent to these platforms to communicate this data to third party partners who develop apps offered through the platforms.

- Advertisements while using the app when applicable by means of AdMob from Firebase (Google Inc). For further information, please consult Google’s partner privacy policy. 

- Data collected from Cookies, as defined in our Cookies Policy below.

In all cases, We only process personal data which is strictly necessary for the fullfilment of the purposes described above. That is, if you provide Us with more information than the one expressly required, you consent to its processing for the informed purpose(s) for which it was granted.

In order to properly provide the services offered within the app, the User must provide Us with accurate, truthful, updated and complete information, being this a reflection of the User’s real circumstances. In this sense, please note that if you provide us via email with information and/or personal data of third parties, you guarantee us that you have obtained their consent and that you have informed them about the purpose of the processing, which is to optimize your device storage memory by deleting duplicate information.

Having said that, if you provide Us with personal data of third parties (adults), you confirm that you have informed them about the purposes for which their personal data will be processed and you guarantee Us that you have obtained their prior and express consent to communicate their personal data to Us. 

In light of the above, the Company will not be held responsible if:

- The User is under fourteen (14) years of age. In this sense, it is the sole responsibility of the parents and/or legal guardians to exercise adequate control over their minor children’s/wards’ online activity and to prevent their access to apps whose content is not suitable or recommended for minors. Therefore, the communication of a minor's personal data without the prior authorization of their parents/legal guardians is under the exclusive responsibility of the latter. If We become aware that We have collected personal data about a User under the aforementioned age, We will delete that data as soon as it is possible from a technical standpoint.

- The Company has received an adult’s personal data and/or private information to provide the services offered in the app by a third party who has not requested the adult’s consent to communicate their personal data to us. In such case, the Company reserves the right to  inform the interested person of how their personal data and/or private information has been collected and, where appropriate, We will ask the individual who provided the personal data to the Company to confirm that they requested the consent of the data subject and/or to amend this circumstance, as well as, if appropriate, to suspend the services and/or the User account.

- For circumstances that are beyond our reasonable control, such as being provided with erroneous, incomplete, and/or fraudulent information from you as a User,  you will be solely responsible for the inaccuracy or lack of veracity of the information provided. In this regard, the Company will not be held responsible for the impossibility of providing the Services or for the Services not being correct or complete because the User has not complied with this requirement.

Who is the personal data controller?

GRIMLAX TRADE, S.L. is the controller of the User’s personal data mentioned above.

What do We use your personal data for?

Please be informed that you only are required to provide personal data and information that is strictly necessary to fulfill the purposes explained below. In this regard, if you provide Us with more information than is expressly required, you consent to its processing for the purpose(s) for which it was granted.

Having said that, We use your personal data for the following purposes:

- To make available and render the service offered through our app;

- To collect the fees of the subscription plans to the services offered through the app;

- To manage your information queries regarding our app and/or services offered through it;

- To comply with our legal obligations, legal requirements, laws, and regulations and/or to respond to judicial, police or the corresponding authorities’ requirements;

- To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our app;

- To improve our app’s functionalities and services offered by analyzing disaggregated data not associated with a particular user’s personal information.

- To improve the User's experience, based on their preferences, and to show you advertisements related to our app while you are browsing your social media or third party websites.

What is the legal basis for processing your personal data?

We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:

- The consent that you provided Us with for the processing of your personal data in order to be able to provide you with the services offered through the app and other purposes informed at the time of collection of your data. As well as for the purpose of tracking your activity or advertising purposes as for geolocalization purposes when the User enables such option voluntarily.

- The consent you have provided Apple to install similar technologies on your device(s) for the purpose of tracking your activity in these platforms, for example, what applications you have installed or which information you share with third party partners about your browser or device for advertising purposes.

- To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities’ official requirements.

- Our legitimate interests in (i) offering an enhanced user experience when you access and use the app and operating it efficiently, (ii) providing advertisements to users according to their interests; (iii) monitoring fraudulent activity in order to preserve the security and integrity of our app; (iv) defending and addressing our rights in the event that a claim regarding our app and/or Services may arise.

How long do We keep your personal data for?

We will keep your personal data only for as long as it is necessary to fulfill the purposes for which they are being processed and, beyond that, your personal data will be retained, and securely blocked, for the necessary retention period to meet our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the services offered through the app; to finish the investigation of detected fraudulent or illicit activity). 

Regarding similar technologies used by Apple to collect and store the information on your device that is later shared with the partners of the services offered by these platforms, we recommend that you consult the Privacy and Cookie Policies of these platforms for information on how to revoke the consent that you have given to them for the installation of similar technologies.

Once the necessary retention period has elapsed, your personal data will be securely deleted from our information systems.

Who do We share the User’s personal data with?

We may communicate your personal data to the following third parties, including but not limited to:

- our main service provider Apple; 

- other providers such as RevenueCat and Google Inc;

- administrative, police or judicial authorities as long as the data is required in accordance with the applicable law and regulations; 

- law firms to respond to claims regarding our app or services offered through it; 

The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will be object of international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, in order to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed with standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.

How do We protect your personal data?

Your trust is very important to Us. For this reason, your personal data is stored confidentially and securely in our information systems. We have established the appropriate technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss or accidental destruction, damage, use, and illegal or unauthorized disclosure.

What rights do you have and how can you exercise them?

You may exercise your data protection rights (i.e access, rectification, erasure, to object, portability, erasure and restriction of the processing of your data) by written request addressed to our Company to the following email: info@aicleaner.app.

As a general rule, We will respond to data protection rights requests within one (1) month from the communication of the exercise of the right by the User. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you.

Finally, We inform you that should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed. 

We remain at your disposal for any doubts or questions you may have about this Policy, please contact Us by email at info@aicleaner.app.

If User is using our App from the United States please bear in mind that you can exercise the following rights according to the California Consumer Privacy Act (“CCPA”):

- Opt-out of marketing tracking: our Company does not show, nor do our partners,  personalized ads within our App. Even though the above mentioned please bear in mind that if that happened, and in the event you do not want third parties to use personalized ads based on your interests, please activate the "Limit Ad Tracking" function of your device, which you can access through the "Settings" icon, then “Privacy” and “Advertising” section.Also, please note that even if you have chosen this option, you may still receive interest-based information from third parties. 

- Opt-out of location Data processing: our Company does not process location data nor even our third parties. Even though the above stated, please note that in case a third party did process such data, and in the event you do not want third parties to use it, please turn the Location Services off function of your device, which you can access through the “Settings” icon, then Privacy and “Location Services” section, and then setting “Share my Location” status to “Never”.

- COOKIES POLICY

This policy explains what cookies are and which cookies we use on the app. Please read this policy carefully to understand what cookies are and how they are used, the type of cookies we use, the information that is collected and how you can control your cookies preferences. 

This Cookie Policy applies to all Users and those who access the app. please bear in mind that the User can withdraw his/her consent or change his/her cookie settings at any time.

What are cookies and what are they used for?

For the purposes of this Policy, “cookies” are small files that are installed on the browser of your mobile device with information regarding your interaction with our app, for different purposes such as facilitating your navigation through our app (i.e acceleration of searches in the app), remembering your browsing preferences (language, country), customizing the services offered on this app, among others. 

The memorized data recorded by cookies takes up a small space on a device’s memory and does not harm the device in any way.

When are cookies installed?

Interacting with our app and purchasing the paid services offered in it implies the installation of cookies, which may be ours or from third parties.

The use of third-party cookies is subject to the Cookies and Privacy Policies of these third parties. Therefore, We will not be responsible for the content or the veracity of the mentioned policies of said third parties. Please consult the website(s) and/or app(s) of said third parties to obtain more information or in the event that you want to change your preferences for setting these cookies. In this regard, you can check out the section “How can the User block or refuse cookies?” of this Policy.

What type of cookies are installed?

Cookies that can be installed include the following:

- Session cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and are automatically deleted when the browser on the User’s device is closed.

- Persistent cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and remain installed for a certain time in the browser of the User’s device.

- Owned cookies: these are sent to the User's device from our app and/or computer equipment, managed by Us, and their information is collected for our own purposes.

- Third-party cookies: these are sent to the User's device from a computer equipment or Website or app managed by another company (partners and/or service providers) and their information can be collected for our own purposes (i.e to know the geographical location of the User) and/or to manage or improve the services that these third-party companies offer (i.e to manage the payment of the app’s services.). 

- Technical cookies: these allow the management and operation of this app and enable its functions and services, for example, to carry out the purchase process and manage payment, etc. 

- Analytical cookies: these allow Us to analyze the use of this app and recognize which functionalities interest users the most, in order to improve the quality and functionalities of our services (i.e the app’s look and feel, messages’ design for usability, etc.) This information is obtained from disaggregated data which is not associated with a particular User or their personal information, as it would be with the login information provided by them in order to use our app, but it only has to do with the general use that all Users make of our app. 

- Preference or personalization cookies: they allow the storage of personalized information so that the User can access the service with certain characteristics such as the language, the number of results to be displayed in a search, the appearance or content of the service depending on the type of browser, etc.

To install cookies in your device's browser, We need your express consent, although there are other cookies that are exempt from such consent. The exempt cookies are: 

- User Login cookies

- User authentication or identification cookies (session cookies only)

We have enabled adequate mechanisms to obtain your consent for the installation of cookies that require it. However, please be informed that, in accordance with the applicable laws and regulations, (i) it will be understood that your consent has been given if you modify the configuration of the browser by disabling the restrictions that prevent the installation of cookies and that, (ii) when the installation of cookies is necessary to provide you with the services that you have expressly requested, your consent will not be necessary.

How can the User block or refuse cookies?

You can, at any time, revoke the consent given for the installation of cookies by (i) configuring browser settings of your mobile device to disable the use of cookies in your browser and (ii) deleting the cookies stored in your browser associated with this app.

Please bear in mind that in the event that you decide to block, disable or delete cookies on your browser, you will not be able to access the functionalities of this app and, therefore, you will not enjoy the services offered through it. Also, We inform you that technical cookies ensure the proper functioning of the app in order to provide a service requested by the User and disabling them could cause problems in the User's experience, for which the Company shall not be held responsible.