Privacy Policy

Last Updated: August 31, 2023

Please carefully review this Privacy Policy to understand our practices regarding your Personal Data (as defined below) and how we will process it. This Privacy Policy applies to the Vocal Image OÜ apps, websites, and related services (collectively referred to as the "Services"). We will explain how Vocal Image OÜ and its affiliated companies ("we", "us", "our") collect, use, secure, and/or disclose your personal information when you use our Services. The data controller is Vocal Image OÜ, registered at Siidisaba tn 12b-24, 11311, Tallinn, Harju maakond, Estonia. We do not process any special categories of personal data (“sensitive data”).

Vocal Image OÜ as Data Controller
When using our Services, you agree to this Privacy Policy and affirm that you are at least 16 years old. Our Services may request certain personally identifiable information, also known as "Personal Data", to identify you. We strive to limit the collection of personal data to what is necessary for providing our Services, avoiding extraneous collection unless willingly provided by you.
Here is the information we may collect and process:
Information You Provide Directly:

- Account Details: User details provided during the registration for our services, including your name, username, and email address.
- Training Goals and Preferences: Information about your intended use and preferences for our proprietary AI models.
- Usage Information: Data related to your usage of our services, including your interactions and activities within the app.

Information Collected Automatically:

- Device Information: Data automatically collected from your device, such as the device ID, IP address, operating system, and browser type.
- Usage Data: Information about how you interact with our services, including the features you use, actions taken, and your preferences.
- Mobile Device Identifiers: This includes your unique device ID (persistent/non-persistent), IDFA (Identifier for advertisers), and hardware type.
- General Location Information: This is collected to provide you with the correct version of the application.
- Application Data: Information about your interactions with the application, as recorded in server log files, including your user ID, and any audio recordings.

Information Collected Through Third-Party Tools:
- Analytics: We use analytics tools, like AppsFlyer and Mixpanel, to gather data on the usage and performance of our services. For more details, please refer to the privacy policies of these providers.

How We Use Your Information
Vocal Image OÜ uses the collected information primarily to provide and enhance our Services, to engage with you, conduct research, create internal reports, and for marketing purposes. We store data on servers located in the EU via Amazon Web Services and may also use servers in other countries. We automatically record details about your activity through our Services, including but not limited to your usage pattern, in-app purchase history, subscriptions, clicked advertisements, and data generated by your use of our Services. For instance, in some Services, your application progress may be stored with your Apple ID on iCloud for iOS Devices. Our Services may also use tools from third-party providers, allowing these parties to collect and/or analyze non-Personal Data from your devices separately.
Here's how we may use your information:
- Service Operation and Improvement: We use your data to operate, improve, and personalize our Services based on your preferences.
- Communication: We use your information to respond to comments and questions, deliver customer service, provide updates, push notifications, security alerts, support, and administrative messages.
- Marketing and Promotion: We use your data to deliver products and services you request, send promotional materials, and communicate about products and services offered by Vocal Image OÜ and our selected partners.
- Data Linking and Enhancement: We may combine your information with data we obtain from third parties to better understand your preferences and enhance our services.

Our legal basis for using your information is the agreements you enter into with us in relation to the Services (the “Terms of Use”). Only our personnel who need access to your data to deliver our Services or represent us will have access to your information, as outlined in this Policy.
Additionally, we use your data for the following purposes:
- Training AI Models: To improve and train our proprietary AI models using the voice recordings and ratings provided by users. Please note, we do not share users' voice recordings with any third parties.
- Personalization and Improvement of Services: To augment your user experience, offer personalized recommendations, and improve the features and functionality of our app.
Communication and Support: To address inquiries, provide customer support, and communicate updates, promotions, and information pertinent to our services.
Compliance with Laws: To comply with relevant laws, regulations, or legal obligations.

Geolocation Data
With your express consent, we or our partners may collect precise location-based information (GPS) to provide content specifically tailored to your region (such as area-based content packages). This information also helps us align your device location with certain points of interest for the purpose of interest-based advertising as detailed elsewhere in this Policy. Please note, participation in this aspect of the Service is not mandatory for all our applications. You have the right to opt-out from sharing your location by switching it off at the device level through your settings at any time.
Information We Obtain from Third Parties
We may receive information about you from our analytics service providers who collect data through our Services in accordance with their own privacy policies. A comprehensive list of the third parties that operate in our Services is provided in Appendix A.
Customer Inquiries
When you reach out to our customer service team, we may use your email address to communicate with you regarding your usage and experience with Vocal Image OÜ applications, and to notify you about company news and promotions. Should you decide to stop receiving certain email notifications, you can opt-out at any time by following the unsubscribe link located at the bottom of each communication or by emailing us at the contact address provided in this policy.
Tracking and Data Collection Technologies
We, along with our marketing, outsourcing partners, affiliates, or analytics service providers, utilize technologies such as cookies, beacons, scripts, and tags to recognize a user's device and "remember" your visit details, such as preferences or username and password. These technologies may link to your personal information, like your user ID, to enhance the quality of our Services, personalize recommendations based on your interests, and simplify the usage of our Service. You reserve the right to disable cookies at any time.
Website Services
During your browsing session on our Sites, we may automatically log certain information such as your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the referring website addresses. This information helps us monitor, develop, and analyze your use of the Service. We may utilize your email address to contact you regarding your experience with the Services and to keep you informed about Vocal Image OÜ news and promotions.
Mobile Applications
When you use any of the Vocal Image OÜ applications on a mobile platform, we may record specific information and data. This includes your application usage, access, session times, in-app purchases, unique device ID (persistent/non-persistent), hardware type, your operating system's version ("OS"), your device name, and your location (based on your Internet Protocol ("IP") address). This information aids us in troubleshooting, understanding usage trends, and improving and optimizing our Services for your user experience. It may also be used for interest-based advertising as described elsewhere in this Policy. Occasionally, we may send push notifications through our mobile applications about application updates, new content availability, and other service-related aspects that may be of importance to you. You have the right to opt-out from receiving these types of communications by disabling them at the device level through your settings.

Rights of Data Subjects
You, as a user of our Services, have several rights regarding your personal data:
- Right to Access and Rectification: You have the right to access your personal data that we hold and correct any inaccuracies without undue delay.
- Right to Erasure: Under specific circumstances, you can request the erasure of your personal data without undue delay.
- Right to Restrict Processing: You can ask to limit the processing of your personal data under certain conditions.
- Data Portability: If the processing of data is based on your consent or a contract, and is carried out by automated means, you can request to receive the personal data you've provided to us in a machine-readable format, or have it transferred directly to another data controller when technically feasible.
- Right to Object: If your personal data is being processed under certain provisions of the law, you have the right to object at any time on grounds relating to your specific situation.
- Automated Decision-Making and Profiling: Under applicable law, you have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal or significant effects on you.
- Right to Withdraw Consent: If the processing of your personal data is based on your consent, you can withdraw that consent at any time. This will not affect any processing that took place prior to the withdrawal.

To exercise any of these rights, please contact us at support@vocalimage.app. You may also lodge a complaint with the appropriate data protection authority within the European Economic Area for unresolved issues.
Accessing, Correcting, and Deleting Your Information
Upon request, we will inform you if we hold any of your personal data. If your personal data changes, or if you no longer desire our Services, you may correct, update, delete inaccuracies, or erase your personal information by changing your account settings or by reaching out to us. We will respond to your request within a reasonable timeframe.
Opting Out of Marketing
You have the option to opt-out of receiving promotional emails from us by following the instructions in those emails or by emailing us with the contact information provided in this policy. Please note that even if you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relationship.

Data Security and Retention Periods
Vocal Image OÜ prioritizes the security of your personal data. We strive to protect your information from unauthorized access, loss, misuse, disclosure, and alteration by implementing appropriate organizational, technical, and physical measures. Our protective procedures consider the type of personal data and the potential risks associated with its disclosure.
Data Retention
We retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy. We must keep your personal data to comply with legal obligations, resolve disputes, and enforce our legal agreements and policies. We also retain usage information for internal analytics purposes, typically for a shorter period unless needed for service enhancement or due to legal requirements. Your personal data obtained through our services will be deleted when no longer necessary for these purposes, or upon your request within 14 days. Following deletion, you cannot exercise rights of access, erasure, rectification, or data portability.
Our Policy Regarding Children
We acknowledge the importance of extra privacy protections for children. Our services are intended for users aged 16 years and above. We do not knowingly collect or solicit personal information from, or direct or target interest-based advertising to, anyone under 16. If we become aware of having collected personal information from a child under 16, we will delete it as quickly as possible. If you believe we might have information from or about a child under 16, please contact us.

Subcontracting and Exporting Personal Data
Your information, including personal data, may be transferred to affiliated entities or third parties across borders and from your jurisdiction to others worldwide. These jurisdictions may not have the same data protection laws as yours, and we ensure appropriate safeguards are in place for such transfers. The use and disclosure of your information, including personal data, will be in accordance with this Policy.
Third Party Services
Our Services may integrate tracking and data collection tools from our service providers, such as Firebase, Mixpanel, Meta and Appsflyer (see Appendix A for a complete list). These third parties may use cookies, APIs, and SDKs to collect and analyze user and device-related data on our behalf. They may access and collect information about you, such as your device identifier, locale, geolocation, IP address, application usage, and your interactions with advertising. Please consult the privacy policies of these third-party service providers to learn more about their data collection, usage practices, and use of cookies and other tracking technologies.
Disclosure of Your Information to Third Parties
Vocal Image OÜ will not share your personal information except as approved by you or as described below:
- We may engage other companies and individuals to perform services on our behalf, such as data analysis and customer support. These agents may access your personal information to perform these services.
- We may release your information as permitted by law, to comply with a subpoena, investigate fraud, respond to government requests, or protect our or others' rights and safety.
- In case of a merger, asset sale, or acquisition, we may share your information with the other company. You will be notified via email and/or notice on our Sites of any ownership change or uses of your personal information.
- We may share anonymous or aggregate information with advertisers, publishers, business partners, sponsors, and other third parties.

Links to Other Sites
Our website and application may contain links to other sites, which are subject to their own privacy policies. We are not responsible for the content or privacy practices of these sites. We encourage you to review the privacy policies of these websites before disclosing information.
Changes to This Privacy Policy
This Privacy Policy may change periodically, and we encourage you to review it regularly. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy. If substantial changes are made, we will notify you prominently on our Services before they take effect and update the "effective date" at the top of this Privacy Policy.

Contact Information
Vocal Image OÜ (registration code 16152143) is registered at Harju maakond, Tallinn, Siidisaba tn 12b-24, 11311, Estonia. If you have any questions or concerns about our Privacy Policy, please contact us at: support@vocalimage.app

APPENDIX A: Analytics and Other Service Providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider's privacy notice.
Firebase:
Firebase is an analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
AppsFlyer
Appsflyer is an analytics service that provides attribution and marketing analytics for mobile applications. You can learn more about their data collection and use practices by visiting their Privacy Policy: https://www.appsflyer.com/legal/privacy-policy/
Meta
Meta is a company that owns and operates Facebook, Instagram, and WhatsApp, among other products and services. You can find more information about their data collection and use practices in their Privacy Policy: https://www.facebook.com/privacy/policy/
Mixpanel
Mixpanel is an analytics service that provides advanced analytics and user behavior tracking for websites and mobile applications. You can find more information about their data collection and use practices in their Privacy Policy: https://mixpanel.com/legal/privacy-policy