Privacy Policy
Last updated: October 2025
Opt-out options: DO NOT USE MY DATA >>
I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)
AIBY Inc. (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you access, use and/or interact with us via web pages available at links with domain name “https://hitmeal.app/” (hereinafter, the “Website”) or make purchases on it.
Please note that this Privacy Policy applies only to data collected, stored, or processed when you access and/or use the Website or make purchases on it. This Privacy policy does not apply to data that is collected, stored, processed when you access and/or use HitMeal Calorie & Food Tracker mobile App introduced on the Website (hereinafter, “HitMeal Calorie & Food Tracker App”). Therefore, if you want to learn more about data processing practices applicable to HitMeal Calorie & Food Tracker App introduced on the Website, please visit the corresponding HitMeal Calorie & Food Tracker App Privacy Policy.
The Website is designed for general information and promotional purposes. It provides details about the HitMeal Calorie & Food Tracker App’s paid subscription features, additional purchases, and some information about the App’s functions.
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
The scope of data we process may vary depending on the types of actions and operations you perform using the Website (see Section II for more details).
This Privacy Policy (except for Annex below - “U.S. Multistate Privacy Notice”) applies to
all users of the Website regardless of where they are located. The U.S. Multistate Privacy Notice included in
the Annex to this Privacy Policy supplementary applies to those users who:
a) are residents of U.S. states where corresponding U.S. State Privacy Laws were enacted; and
b) fall within the scope of the U.S. Multistate Privacy Notice applicability.
II. INFORMATION WE PROCESS
There are several categories of information that may be processed when you access, use and/or interact with the Website.
Information that you voluntarily provide to us
We may process the information you provide when answering questions on the Website's quiz, including but not limited to age, weight, and height (“Survey Data”). We need to learn more about your current setup and your expectations to be able to assist you in choosing your personalized wellness plan.
When you have completed your Website's quiz and feel ready to purchase your subscription we ask you to provide your Email Address -we use it to identify your purchase, send you the relevant confirmations and . Once you purchase a subscription you will be able to perform a Sign In function in the HitMeal Calorie & Food Tracker App.
We receive certain information from our payment processor related to your Subscription. This data may include but not limited to details such as your subscription plan selected, subscription status, charge amount, payment date, your transaction ID. We use this information exclusively to activate and manage your subscription within the App, including your possibility to cancel it in the App’s settings, grant you access to the relevant services and provide customer support related to your subscription.
Also, we may collect, store and process some information when
you use the form available within the
“Contact us”
section or link on the Website (hereinafter, “Contact us” form) or
via email at
[email protected]. In particular, if you decide to make a
request via the “Contact
us” form or via email, the following categories of information are
voluntarily provided by you: your name, email address, the text of
your message and/or any files that you optionally choose to attach
to your request (“Contact Data”). We use the
Contact Data solely for the purpose of considering
and responding to your requests (if necessary).
We use the
Information you voluntarily provide to us to (a)
make our service available and ensure the efficient operation of the
Website and (c) communicate with you while we deliver our in-app, as
well as the Website-based services to you. We process this
information based on the
performance of our contracts, as outlined in the
Website’s
Terms of Use and End User License Agreement, as well
as the App’s
Terms of Use and End User License
Agreement.
Once you purchase a subscription or make additional purchases on the Website after completing the Website's quiz, we use your Survey Data and Email Address for different purposes.
We use your Email Address to (c) communicate with you by sending necessary information, updates, guides, articles, and news related to the HitMeal Calorie & Food Tracker App and the Website. For more details, please refer to the subsection "Email Newsletters" below.
We use the Survey Data (specifically age, weight, and height) to (a) to make our service available and ensure the efficient operation of the Website and the App, while personalizing our in-app services for you. This means that we use this information to pre-fill matched basic information in the App for streamlining your onboarding process and enhancing your experience. Note that if you don’t purchase a subscription or make additional purchases on the Website after completing the Website's quiz, you may also voluntarily provide us with an email address to (c) communicate with you by sending necessary information, updates, reminders, guides, articles, and news related to the HitMeal Calorie & Food Tracker App and the Website.
The processing described in the above paragraph is based on our legitimate interest. If you do not wish to receive information via email or do not want your Survey Data (specifically age, weight, and height) to be used to personalize our in-app services, please See Opt-out options
Email newsletters
If you subscribe to newsletters we may use the information about your email address to send you such newsletters regarding special subscription offers, new features and functionalities and other news related to HitMeal Calorie & Food Tracker App and/or the Website on the grounds of our legitimate interests. Sending you newsletters will allow you to stay up to date and receive the latest news about HitMeal Calorie & Food Tracker App and the Website, including about the best price offers. You may unsubscribe, opt-out of receiving newsletters to your email address at any time by using the resignation link provided in each email you receive from us. Your unsubscribe request shall be honored within a reasonable period of time.
To collect, store and process the information that you voluntarily provide us, we use the services of Advanced Hosters B.V.
We may use certain information related to the Survey Data in an aggregated form as part of Information that is processed automatically to (b) improve, test and monitor the effectiveness of the Website (see below). This information is used to analyze groups of people who interact with our Website in a non-personalized manner (aggregated Survey Data).
To collect, store, and process aggregated Survey Data, we use the services of Adapty Tech, Inc. and Amplitude, Inc. We manage this automatic processing so that we do not link, nor are we able to link, your email address or any other identifiers that you voluntarily provide to us with this aggregated Survey Data. If you reasonably believe that this information could be casually linkable to you (for example, due to the actions of our service providers or specifics of the automatic algorithms used), please contact us via our “Contact Us” form available on the Website or via email at [email protected]. We will review your case, check for any matches, and delete any of your identifiers if confirmed.
Information that is processed automatically
When you access, use and/or interact with the Website, some information about your device and your user behavior may be processed automatically to (b) improve, test and monitor the effectiveness of the Website. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest for improving the Website and giving our users the best experience unless another basis is specified in this Privacy Policy or the Cookies Policy.
We may use third-party automatic data processing technologies to analyze certain information sent by your device via the Website (analytics tools). Some of them may launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time access the Website.
-
Device Details. When you use a device (computer,
laptop / tablet / phone) to access the Website, some details about
your device are reported, including “device identifiers”. Device
identifiers are small data files or similar data structures stored
on or associated with your device, which uniquely identify your
device (but not your personality). Device identifier enables
generalized reporting or personalized content and ads by the third
parties.
What data may be processed:
-
Information about the device itself: type of your device, type
of operating system and its version, model and manufacturer,
screen size, screen density, orientation, audio volume and
battery, battery life, loading time, latency, framerate,
device memory usage.
-
Information about the Internet connection: mobile carrier,
network provider, network type, IP address, timestamp and
duration of sessions, speed, browser and version, browser
language.
-
Location-related information: IP address, the country code/
region/ state/ city associated with your SIM card or your
device, language setting, time zone.
- Device identifiers: advertising identifiers, Identity For Advertisers for iOS devices.
-
Information about the device itself: type of your device, type
of operating system and its version, model and manufacturer,
screen size, screen density, orientation, audio volume and
battery, battery life, loading time, latency, framerate,
device memory usage.
- Cookies and similar technologies. When you access, use and/or interact with the Website, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the Website. The text file is then sent back to the server each time you use the Website. This enables us to operate the Website more effectively. For example, we will know how many users access specific areas, content, or features within the Website, which links they clicked on, and how many users select particular quiz options (see above regarding aggregated Survey Data). We use this aggregated information to understand and optimize how the Website is used, improve our marketing efforts, and provide content and features that are of interest to you. Third party analytics tools use cookies or similar technologies for the purpose of analyzing the Website traffic. For further details regarding how we use cookies, please refer to our Cookies Policy. Please note that we also use aggregated automatically processed data (UTM and GCLID data) to measure the effectiveness of our advertising. For more details, please refer to our Cookies Policy and Google Privacy Policy.
-
Log file information. Log file information is
automatically reported each time you make a request to access the
Website. When you use the Website, analytics tools automatically
record certain log file information, including time and date when
you start and stop using the Website, and how you interact with
the Website.
Information provided automatically to analytics or advertising tools does not generally come to our control, therefore, we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device. In case when your user ID is linked to your account in a third-party service, such as Meta (Facebook), the service provider may use your device information in association with categorized data that were already recorded in its databases (eg. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data, that might be collected by their own means. Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).
We use Hotjar in order to better understand our users’ needs and to
optimize this service and experience. Hotjar is a technology service
that helps us better understand our users’ experience (e.g. how much
time they spend on which pages, which links they choose to click,
what users do and don’t like, etc.) and this enables us to build and
maintain our service with user feedback. Hotjar uses cookies and
other technologies to collect data on our users’ behavior and their
devices. This includes a device's IP address (processed during your
session and stored in a de-identified form), device screen size,
device type (unique device identifiers), browser information,
geographic location (country only), and the preferred language used
to display our website. Hotjar works with de-identified user IDs
when tracking website users and stores this information on our
behalf in a pseudonymized user profile. Hotjar is contractually
forbidden to sell any of the data collected on our behalf. For
further details, please see the ‘about Hotjar’ section of Hotjar’s support site
https://help.hotjar.com/hc/en-us/sections/115003204947.
If
you do not wish to allow tracking of your experience
while using the Website, please refer to the Opt-out options, please
See Opt-out options
III. THE PURPOSES OF PROCESSING YOUR DATA
Our mission is to constantly improve the Website and provide you with better user experiences. As part of this mission, we use your information for the following purposes:
(a) To make our service available and ensure the efficient operation of the Website and the App. We use the information you voluntarily provide, along with the information processed automatically, to fulfill our contract, deliver the requested services, tailor those services to you, provide them through the App and the Website, and ensure the efficient operation of the Website according to its intended purpose.
(b) To improve, test and monitor the effectiveness of the Website. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize the Website.
(c) To communicate with you. We may use information that you voluntarily provide to us via our support channels and contact forms for the purposes of processing and responding (if necessary) to your requests, receiving your feedback, comments or suggestions, also to send you marketing notifications about the operation of the Website, HitMeal Calorie & Food Tracker App or on other matters.
(d) To prevent fraud and spam, to enforce the law. We really want the Website to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks, enforce our Terms of Use and End User License Agreement and applicable law.
Details about specific categories of information processed for various purposes can be found in Section II of this Privacy policy. Please note that, in order to prevent fraud and spam or to enforce the law (d), we may process all categories of information if required by law.
If any new purpose for processing your data arises, we will let you know when we start to process information for that other purpose by introducing the corresponding changes to this Privacy policy.
IV. SHARING OF YOUR INFORMATION
We will not rent or sell your personal data to third parties, but we may share your information obtained via tools like cookies, log files, and device identifiers with third-party organizations that provide automatic data processing technologies for the Website. We do not control or influence these third parties’ tracking technologies or how they may be used.
Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your data, we cannot guarantee the absolute security of any information transmitted from the Website directly to such third parties. We are not responsible for any accidental loss or unauthorized access to your data through a fault of third parties.
We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of the Website:
| Entity name | Services performed | Entity location | Link to Privacy Policy |
|---|---|---|---|
| Advanced Hosters B.V. | Cloud service provider | Netherlands | https://advancedhosting.com/en/documents/privacyPolicy |
| Adapty Tech Inc. (FunnelFox) | Cloud service provider | U.S.A. |
https://adapty.io/privacy/ https://adapty.io/data-processing-agreement/ |
| Amplitude, Inc. | Analytics service provider | U.S.A. | https://amplitude.com/privacy |
| Google Analytics (Google LLC) | Analytics service provider (Tool for Website traffic analysis) | U.S.A. |
Google Privacy Policy: https://policies.google.com/privacy?hl=en How Google uses information from sites or apps that use its services: https://policies.google.com/technologies/partner-sites?hl=en Google Analytics uses various types of cookies to analyze user activity on the Website. To learn more about the types of data collected, visit https://support.google.com/analytics/answer/6004245 and https://policies.google.com/technologies/cookies. To disable Google Analytics cookies, follow the instructions in Section IX of the Privacy Policy. Please note that we are not responsible for any use of your data by Google LLC that violates our instructions. |
| Meta Platforms, Inc.(Facebook) | Ad management service provider (using Conversions API to send user action data for ad optimization) | U.S.A. | https://www.facebook.com/privacy/explanation |
| Hotjar (Hotjar Ltd.) |
Analytics service provider (Tool for Website traffic analysis) | European Union (EU) |
Privacy Policy: https://www.hotjar.com/legal/policies/privacy/ Data Processing Agreement: https://www.hotjar.com/legal/support/dpa/ |
| TikTok, Inc. | Analytics service provider (Events API) |
U.S.A. |
https://www.tiktok.com/legal/page/us/privacy-policy/en How TikTok uses information from sites or apps that use its Business Products: https://ads.tiktok.com/help/article/events-api https://ads.tiktok.com/i18n/official/policy/business-products-terms |
| PayPal, Inc. / PayPal (Europe) S.à r.l. et Cie, S.C.A. | Payment processing service provider | U.S.A. / Luxembourg | https://www.paypal.com/us/legalhub/privacy-full |
| Stripe Inc. / Stripe Payments Europe Limited | Payment processing service provider | U.S.A. / Ireland |
https://stripe.com/privacy https://stripe.com/privacy-center/legal |
Third-party service providers may engage their own third-party service providers. To view a list of these providers, please refer to the Privacy Policy links above and the Data Processing Agreement with our service provider, available at https://adapty.io/data-processing-agreement/.
As it is indicated above we use Google Analytics service that tracks and reports the Website traffic. Google Analytics service uses different types of cookies to analyze user activity on the Website. If you want to learn more about the types of cookies and other data collected and processed by Google Analytics service provider (Google LLC) please visit https://support.google.com/analytics/answer/6004245 and https://policies.google.com/technologies/cookies. Note that we are not responsible for any usage of your data by the abovementioned third-party service provider (Google LLC) in violation of our instructions.
If you don’t want Google Analytics to use cookies you can block data collection following the instructions provided in Section IX of the present Privacy policy.
The Website may contain links to third party sites/services. You also may visit the Website following a link from a third party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).
We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
● as required by law;
● when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
● if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our Website of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
V. INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide the Website to users around the world.
We and third-party organizations that provide automatic data processing technologies for the Website or our third-party partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as in your home jurisdiction. We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information.
By using the Website, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
VI. HOW DO WE STORE YOUR DATA
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
In particular, we recourse to the services of Advanced Hosters B.V. and Adapty Tech Inc. that have adopted technical and organizational measures to protect your personal data against unauthorized/unlawful processing and accidental loss, destruction or other damage (please refer to the Privacy Policy links in Section IV and the Data Processing Agreement with our service provider, available at https://adapty.io/data-processing-agreement/).
VII. HOW LONG WE USE YOUR PERSONAL DATA
We generally retain your personal information for as long as is necessary for performing the functional service of the Website and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and/or close your account.
The information you provide when answering questions in the Website's quiz (such as gender, weight, age and height) is stored and used in the App for the duration of your active subscription. If you do not subscribe or make a purchase, this information will be deleted immediately. Data recorded by Hotjar is retained for 365 days from the date of capture.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.
VIII. USER PRIVACY RIGHTS
Applicable data protection laws give you the following rights regarding your personal information:
- The Right to Know (also referred to as the Right to Access). You have the right to obtain a confirmation as to whether or not personal data concerning you is being processed. Additionally, you can request a copy of personal data we hold about you and additional details on how such data is processed.
- The Right to Data Portability. You are entitled to request your personal information in a portable, structured and machine-readable format that makes it easier to reuse such information or transfer it directly to another service, move it wherever you want.
- The Right to Correct Inaccuracies (also referred to as the Right to Rectification). Where you cannot update your data by yourself through your account (if available) or the Website settings, you can ask us to correct, change, complete or rectify your data.
- The Right to Data Deletion (also referred to as the Right to Erasure or the Right to Be Forgotten). You have the right to request the deletion of all or some pieces of your personal data we process. In this regard you should bear in mind that applicable data protection laws may provide exceptions to the Right to Data Deletion, which means that under certain circumstances we may need to keep some pieces of your data to comply with legal obligations, detect fraud, exercising or defence of legal claims, for other legal reasons. Therefore, upon receiving your verified request, we’ll delete your personal data and direct our service providers to do the same unless a legal exception applies.
- The Right to Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is processed. These specific circumstances are addressed in data protection laws that may apply to you. For example, you can ask for restriction of data processing in the case of disputed accuracy: if you believe that the personal data we hold about you is inaccurate, you can request a restriction of processing while we verify its accuracy.
- The Right to Object to Processing of Personal Data. When your personal information is processed automatically with the involvement of third party service providers, you may object to such processing in some circumstances. Additionally, when your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right to object please submit us the corresponding request. You may also contact the third party service providers listed in the Section IV of this Privacy Policy to learn how you can object to their processing of your data. Most of them have clear instructions on their privacy pages, functional API or other options.
To exercise any of the rights described above, you can contact us via our “Contact Us” form available on the Website or via email at [email protected]. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store. We also would like to draw your attention to the fact that in order to process your request we first have to identify you as a user of the Website or HitMeal Calorie & Food Tracker App.
You also have the right to lodge a complaint with your local data protection or a supervisory authority if you reasonably believe that your rights under applicable data protection laws have been breached. Please note that when you exercise your right to lodge a complaint with your local data protection or a supervisory authority, you may be required to provide additional information and support your complaint with sufficient objective evidence. By lodging a complaint you agree to provide sufficient explanation as to what you believe impaired your rights. Additionally, in some cases prior to lodging a complaint to your local data protection or a supervisory authority, you may be required to send your initial claim directly to us and ask for clarifications if necessary.
When your information is processed automatically you may object to such processing in some circumstances. Where your information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise this right please contact the third party service providers listed in the Section IV of this Privacy policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.
If you are located in the European Union, you may address our representative when you have questions on privacy issues: Konrad Gutowski, privacy @ aiby.com.
IX. HOW TO OPT OUT
You may prevent and/or manage the collection and processing of some information related to your use of the Website following the instructions provided below. Note that it is applicable only with respect to the Information that is processed automatically.
Google Analytics. If you want to opt-out of being tracked by Google Analytics you can install and enable Google Analytics Opt-out Browser Add-on. Additionally, you can manage cookies and/or delete cookies already set by Google Analytics through your browser settings. Further information on Google Analytics’ data practices and relevant instructions can be found at https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’).
Advertising Industry Opt Out Tools. You may also limit the collection of cross-app data for interest-based ads and exercise your right to opt out using the following Advertising Industry Opt Out Tools:
- Digital Advertising Alliance for Websites: https://optout.aboutads.info;
- European Interactive Digital Advertising Alliance (EDAA) https://youronlinechoices.eu/;
- Network Advertising Initiative: https://optout.networkadvertising.org/.
TikTok Events API. If you want to opt-out of being tracked by the TikTok Events API, you can refuse or disable cookies for the Website by adjusting your device's browser settings. Because each browser is different, please see the instructions provided by your browser. Please note that your opt-out selection is specific to the particular browser or device you are using when you opt out, so you may need to opt out separately for each browser or device.
Cookies. You may prevent your browser from accepting cookies
entirely by adjusting your browser's cookie settings. These settings
are typically found in the "Options" or "Preferences" menu. Please
refer to the instructions on our cloud service provider's website
(Section 3.6, "To personalize our ads":
https://adapty.io/privacy/) or consult the instructions related to your browser.
Bear in
mind that if you choose to disable all cookies, this can affect the
Website functions, some of the features that make the Website more
efficient may not function.
Hotjar user experience tracking. If you do not wish to allow tracking of your experience while using the Website through behavior analytics software (Hotjar), you can enable the Do-Not-Track setting in your browser. This will prevent Hotjar from processing your data. Please follow this link to access the current guide: https://www.hotjar.com/policies/do-not-track/. By default, Hotjar works with de-identified information. We and Hotjar cannot match any of your identifiers (such as your email address) with information processed during the tracking of your experience while using the Website. If you reasonably believe that we or Hotjar have the opportunity to match you with automatically processed information (for example, if you intentionally included your email in a Survey response), please contact us via our “Contact Us” form on the Website or by email at [email protected]. We will review your case, check for any matches, and delete any of your identifiers if confirmed.
The information you provide when answering questions on the Website's quiz. If you do not wish for the information you provide when answering questions in the Website's quiz to be used for personalizing our in-App services, you may replace this information with alternative information in the App`s settings, or contact us via the “Contact Us” form available on the Website.
Newsletters and other communication with you by sending necessary information, updates, guides, articles, and news related to the HitMeal Calorie & Food Tracker App and the Website. If you subscribe to newsletters, you may unsubscribe, opt-out of receiving newsletters to your email address by using the resignation link provided in each email you receive from us. Your unsubscribe request shall be honored within a reasonable period of time. Even if you unsubscribe from newsletters, we may still use your email address to send you some necessary information related to the HitMeal Calorie & Food Tracker App and/or the Website functioning.
X. SECURITY
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information provided to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about the security of the Website, you can contact us with the corresponding message via our support channels or contact forms.
XI. CHILDREN’S PRIVACY
Our Website is not intended for children. Therefore, we do not
knowingly or intentionally collect or solicit any personal
information from children. For the purposes of this Section XI the
terms “child” and/or “children” in the context of data processing
activities may be interpreted on a case-by-case basis as prescribed
by applicable data protection laws. No one who is considered a
“child” under applicable data protection laws is allowed to directly
provide any personal information to the Website.
As a general
rule we consider a person under the age of 16 to be regarded as “a
child” until we have legal grounds to conclude that a person under
16 should be treated as an adult as per provisions of local data
protection rules or based on the parent authorization provided to us
directly.
Solely the holders of parental responsibility are
liable for preventing their children from providing personal
information via the Website without relevant verifiable parental
consent. If we learn that we have collected personal information
from a child without verification of parental consent, we will erase
that information as quickly as possible. If you reasonably believe
that we might have any information from or about a child, or a child
has directly provided us with personal information via the Website
without verifiable parental consent, please contact us.
XII. CHANGES TO THE PRIVACY POLICY
In case we change our Privacy policy, we will post the changes on this page. Please check the Website regularly for any changes.
XIII. HOW TO CONTACT US
If you have any questions about this Privacy policy, please feel free to contact us via our “Contact Us” form available on the Website or via email at [email protected].
Copyright © 2024-2025 AIBY Inc.
Annex to Privacy Policy
U.S. Multistate Privacy Notice
INTRODUCTION. THE SCOPE OF APPLICATION
This U.S. Multistate Privacy Notice (“Notice”) supplements the information contained in Privacy Policy and may apply to individual residents of the U.S. states (“Covered U.S. Individual Residents”) that have enacted comprehensive data privacy laws including but not limited to California Consumer Privacy Act of 2018 (CCPA) as amended by California Privacy Rights Act of 2020 (CPRA), Texas Data Privacy and Security Act of 2023 (TDPSA), Virginia Consumer Data Protection Act of 2021 (VCDPA), Colorado Privacy Act of 2021 (CPA), Connecticut Data Privacy Act of 2022 (CTDPA) and others (collectively referred to as “U.S. State Privacy Laws” and separately as “U.S. State Privacy Law”). Notice addresses specific requirements common to U.S. State Privacy Laws and outlines additional information on the rights of Covered U.S. Individual Residents. It also describes how we collect, use, disclose and protect your personal information in compliance with these U.S. State Privacy Laws.
Applicability. Please note that if you are a user of our Website and a resident of one of the U.S. states where the corresponding U.S. State Privacy Law was enacted, you’ll be regarded a Covered U.S. Individual Resident and this Notice shall apply to you only if the processing of your personal data in connection with your use of the Website falls within the scope of such U.S. State Privacy Law. Please refer to the corresponding U.S. State Privacy Law for further details. If you are still unsure whether this Notice is applicable to you, please do not hesitate to contact us and we will spare no effort to assist you.
The correlation between Privacy Policy and Notice. This Notice does not replace and cannot be used interchangeably with Privacy Policy. On the contrary, Notice serves as a supplemental part of Privacy Policy for Covered U.S. Individual Residents.
The concept of personal data under U.S. State Privacy Laws. Applying Notice, you should also bear in mind that it pertains only to the processing of personal data which is understood as information linked or reasonably linkable to an identified or identifiable individual. Generally U.S. State Privacy Laws do not apply to the processing of de-identified, aggregated data or publicly available information, as these categories fall outside the scope of personal data.
THE CATEGORIES OF PERSONAL DATA PROCESSED. PURPOSES OF PROCESSING
Detailed information about the categories of personal data that may be processed when you use the Website is contained in Section II of Privacy Policy >>
To learn about the purposes of personal data processing please review Section III of Privacy Policy >>.
SHARING OF PERSONAL INFORMATION WITH SERVICE PROVIDERS (PROCESSORS). CLARIFICATIONS ON ISSUES OF DATA SELLING
U.S. State Privacy Laws require us to provide you with information about who we share your personal data with and for what purposes. You can find comprehensive data in this regard in Section IV of Privacy Policy >>. The legal entities indicated in Section IV of our Privacy Policy act as our “service providers” or “processors” within the meaning of U.S. State Privacy Laws and process your information on our behalf for business purposes. The examples of business purposes are the following: auditing related to current interaction with users, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions; providing customer service, advertising, marketing, analytic services; detecting security incidents; debugging; provision of Website services to users; improving, enhancing, upgrading the Website functionality. Please refer to the table in Section IV of our Privacy Policy to learn what specific services the processors/service providers perform for the Website. When we use the services of our processors/service providers and disclose your information for business purposes, we enter into corresponding written contracts with them. These contracts incorporate data processing provisions, parts, sections or annexes that require our processors/service providers not to use personal information transferred by us other than for the purpose of performing the services specified in the contracts. Additionally, the contracts with our processors/service providers specifically prohibit them from and/or do not contain permissions for selling the personal information transferred by us.
We do not “sell” you personal information for monetary gain, which means that we do not and will not disclose your personal information to third parties in direct exchange for money or some other form of payment. However, certain U.S. State Privacy Laws provide expansive definition of the term “sell”, which leads to cases where some disclosures of personal information to a third party even for non-monetary benefit of the disclosing party (“valuable consideration”) may qualify as data selling. In particular, sharing of personal information with third parties for the purposes of “interest-based advertising”/ “cross-context behavioral advertising” may constitute a sale under broad definition and interpretation of this and similar terms (“sell”/”selling”/”sold”) according to some U.S. State Privacy Laws. Even if such kind of data sharing qualifies as sale under U.S. State Privacy Law applicable to you, you’ll always have an option to opt out (see the subsection Instructions on Online Tracking Opt Out below for more details on available opt out mechanisms).
PRIVACY RIGHTS
If you are a Covered U.S. Individual Resident and this Notice applies to you, you’ll be able to exercise all user privacy rights specified in Section VII of Privacy Policy >>, particularly:
- the Right to Know (also referred to as the Right to Access);
- the Right to Data Portability;
- the Right to Correct Inaccuracies (also referred to as the Right to Rectification);
- the Right to Data Deletion (also referred to as the Right to Erasure or the Right to Be Forgotten);
- the Right to Restriction of Processing;
- the Right to Object to Processing of Personal Data.
User privacy rights listed above have similar content and exceptions in different jurisdictions. Their general meaning is addressed in Section VII of Privacy Policy. However, some minor aspects related to these rights may vary slightly from one jurisdiction/state to another, therefore, you may want to consider these differences when submitting your user privacy request.
Besides the rights referred to above, U.S. State Privacy Laws specifically mention the following additional data privacy rights you have:
The Right to Opt Out of the processing of the personal data for purposes of (a) targeted advertising, sometimes also referred to as “cross-contextual behavioral advertising” or “interest-based advertising”; (b) the “sale” or “sharing” of your personal data; (c) profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you. The specified Right to Opt Outis exercised with due regard to the context of our interaction with you as with the user of our Website and accompanying data processing activities. To learn the details on how you can exercise your Right to Opt Out, please refer to the subsection Instructions on Online Tracking Opt Out below.
The Right to Non-Discrimination. This right means that you will not receive discriminatory treatment for exercising your privacy right(s). Inter alia, we will not deny you the Website services, charge different prices or rates, or provide a different level or quality of services for you if you choose to exercise your user privacy right(s).
The Right to Appeal. If we deny and refuse to take an action on your initial user privacy request, you may have the right to appeal that decision under some U.S. State Privacy Laws. See the subsection How to Appeal Initial Decision Regarding Privacy Request below for more details.
HOW TO EXERCISE YOUR PRIVACY RIGHTS
Depending on the specific user privacy right you choose to exercise, different methods may be available to you.
In particular, when appropriate technical capabilities are accessible to you within the Website and/or in your device settings, some rights (e.g. the Right to Correct Inaccuracies, the Right to Data Deletion, the Right to Opt Out) can be exercised by you independently without our assistance and the need to submit us the corresponding request. For instance, in certain circumstances the Website may provide you with a possibility to change, update, correct inaccuracies or delete certain pieces of your personal data via your Website account settings.
Instructions on Online Tracking Opt Out.
Further, there are a number of ways you can exercise the Right to Opt Out of data processing for the purposes of activities that under U.S. State Privacy Laws may qualify as targeted advertising; “sale” (under broad interpretation) or “sharing” of personal data; profiling. Follow the instructions below to stop online tracking activities across third party apps and websites and sharing your data with third parties for personalized ads.
Blocking Advertising ID use in your mobile device settings. Your mobile device settings enable you to make choices about the collection, use or transfer of your Advertising ID to third parties for the purposes of targeted advertising and/or ad measurement. To manage your activity tracking permissions and the use of your Advertising ID, please follow the relevant instructions in Section VIII of our Privacy Policy >>.
Advertising Industry Opt Out Tools. Even if you block the access to and use of your Advertising ID, you might still see personalized ads from other companies and ad networks. You have an opportunity to send your opt out request to some of such other companies and ad networks who participate in self-regulatory programs using special Advertising Industry Opt Out Tools. See Section VIII of our Privacy Policy to know which Advertising Industry Opt Out Tools you may choose to use >>.
Ad and Analytics Platforms Opt Out Mechanisms. Some third party ad platforms and analytics service providers have their own privacy management tools that allow you opt out and/or make your privacy choices directly. Here there are some examples:
Therefore, we recommend you to check the privacy options of our service providers (processors) regularly. The up to date list of our service providers (processors) is presented in Section IV of Privacy Policy >>.
Submission of a user privacy request to exercise privacy right(s)
To exercise any user privacy right that cannot be managed by you independently, please contact us anytime through our contact form with the corresponding privacy request. When submitting your request, please include in its text the phrase “Exercising my rights to maintain confidentiality in … State”, replacing '...' with the name of the state of your residence. We will make every effort to satisfy any request you make to exercise any of your privacy rights.
AUTHENTICATION OF USER PRIVACY REQUESTS. INSTRUCTIONS ON HOW TO APPEAL OUR INITIAL DECISION REGARDING YOUR PRIVACY REQUEST
When you submit any user privacy request via our contact form in order to exercise your privacy right(s), the relevant procedure of request authentication shall be put in place. The details and rules for such authentication procedure are provided below.
We shall comply with your user privacy request only if we are able to authenticate you as the user of our Website and as a Covered U.S. Individual Resident. Therefore, when submitting a verifiable user privacy request, you should be ready to:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or such person’s authorized agent, which (depending on the circumstances) may include: name, address, city, state, zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming their authority to represent your interests or a power of attorney, signed by you.
- Describe your privacy request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not be able to respond to your privacy request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you for additional information or documents to verify your identity before taking any action with your privacy request. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scam request.
We ensure that personal information provided in a verifiable user privacy request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.
We try to respond to a verifiable user privacy request within forty-five (45) days of its receipt. If we require more time and it is reasonably necessary, we may extend the response period. In this case we will inform you of the reason and the applicable extension period in writing.
How to Appeal Initial Decision Regarding Privacy Request.
In cases when we have a reasonable basis, we may choose to decline to take an action regarding the user privacy request. For example, this may happen when we are unable to authenticate a request, or when the request is manifestly unfounded or fraudulent. In this particular case we’ll inform you of the justification for declining to take action within a reasonable period of time after receiving your initial request.
If we decline to take action with respect to your initial request, you may be entitled to appeal our decision under some U.S. State Privacy Laws. To do so, you will need to provide us with the missing information and explanations reasonably necessary to address your request effectively. Within the term prescribed by the applicable U.S. State Privacy Law we’ll inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for our decision.
CHANGES TO THIS NOTICE. FINAL PROVISIONS
We may update this Notice from time to time. To stay informed of updates, please review the latest published version of Notice regularly.
If you reasonably believe that certain U.S. State Privacy Law provides you with additional rights or options not outlined or referred to in this Notice, please contact us through our contact form. We will do our best to address all your concerns and reply to your request effectively.