Privacy Policy

1. Information we collect

We collect from you the following data:

a. Information you provide us directly. When you use our Services, we collect the information that you provide us directly:

Photos. We may collect the photos, that you take with your camera while using our application and photos, that you upload to our application from your device. Please note, you won’t be able to upload content from your camera unless we can access your device’s camera.

Videos. We may collect the videos, that you take with your camera while using our application and videos, that you upload to our application from your device. Please note, you won’t be able to upload content from your camera unless we can access your device’s camera.

Facial features. We may collect the facial feature data separately from your photos only to provide you with the face-morphing functionality of DuoFace App. Please note, we collect facial feature data that is not biometric data.

b. Usage data. When you use our Services, we may collect information about your activity within our Services, for example, which pages you have viewed and for how long. We also may collect IP addresses, the source of the traffic, information regarding the device and operating system, information about your wireless and mobile network connections, unique device identifiers, IDFA, region, browser type, language, battery level, and time zone.

In the mobile application: We collect usage data with the help of Google Analytics and the Facebook App Event Tracking system. With the use of them, we collect such data as IP-Address, your device model, screen resolution and operation system, session durations, your location. Based on these data, we analyze your needs and interests, evaluate the effectiveness of our campaigns and improve our Website to make its content relevant to you and the Website itself available for smooth viewing with your device.

c. Cookies and similar technologies. Like most online services and mobile applications, we may use cookies — tiny pieces of code that remain in your device after you have visited any websites and online services. When you use that website or application the next time, these pieces enable their owners to provide you with information customized for your needs.

We use cookies for authentication purposes only. When you access the Services or content, DuoFace App uses session cookies, meaning that if you close the Services, cookies expire and no longer have any effect. You shall specifically agree to our use of cookies when you use our Services by clicking the respective button in the notification.

When you use the Services, we may also use technologies like pixels, web beacons, and local storage to collect information about how you use DuoFace App and provide features to you.

d. Web app connection, country and language. Our hosting and content-delivery providers receive your IP address, browser information and requested pages to deliver and secure the service, and may retain operational or security logs. We use the country code supplied by Amazon CloudFront to select the initial language and pricing: Armenian and AMD for Armenia, and English and USD for other countries or when no country is available. You can change the language manually; prices remain based on the country. We do not request GPS location.

Browser storage supports sign-in, sessions and web-app functionality. You can manage or clear stored data in your browser settings. Blocking or clearing browser storage may affect sign-in and other features.

e. Web accounts, subscriptions and support. We process the account details you provide, your selected plan and subscription status. For paid subscriptions, we use payment references, amount, currency and status to activate access and provide billing support. Support messages may include your email, order reference and issue details. Do not send payment credentials to support.

Billing-record details. For web purchases, transaction records include the order and bank transaction references, purchased plan, amount, currency, date and time, payment or refund status and renewal or cancellation confirmations. These are payment records, not the full card number or card security code.

2. How We Use Information

DuoFace does not use your videos, photos and facial features for any reason other than to provide you with the face-morphing functionality of DuoFace. In no way will DuoFace use your videos, photos and facial features for face recognition, as DuoFace does not introduce the face recognition technologies or other technical means for the processing of biometric data for the unique identification or authentication of a user.

We may use the information other than videos, photos or facial features to:

- provide, improve, test, and monitor the effectiveness of our Services;

- perform troubleshooting, diagnose or fix technology problems

- enhance the safety and security of the Services;

- monitor and analyze trends and usage;

- develop and test new features of the Services;

- understand your needs and provide services and advertisements that are relevant to you;

- use the information we’ve collected from cookies and similar technologies to enhance our Services and your experience with them.

Uploaded Content is collected for its display in the library for the user’s repeated use and convenience of the Services usage. Uploaded Content is stored on the device and cloud for a specific period of time and displayed to you exclusively during your use of the Services. By submitting this content for the morphing you expressly agree for its collection and storage as set forth herein. In no way will DuoFace use your Uploaded Content for face recognition, as DuoFace does not introduce the face recognition technologies or other technical means for processing of biometric data for the unique identification or authentication of a user.

If DuoFace decides to change the purposes of processing specified above, we will inform you on such changes prior to use your personal information within the newly set purposes and ask for your separate consent if required by the applicable laws.

For the web app, we also use necessary non-media information to select the initial language, show regional prices, manage accounts, activate subscriptions, administer renewal and cancellation, investigate billing issues, handle refunds and support requests, prevent fraud and meet legal obligations. These purposes do not extend the permitted use of photos, videos or facial features described above.

3. How We Share Information

In order to provide high-quality Services, DuoFace hires people, may enter agreements with independent contractors as well as cooperates with other services providers, companies, and organizations. For those reasons, some of your personal information may be passed to the persons mentioned. First of all, our employees may have access to your data. Then, we may transfer your data to our sub-contractors and affiliates.

DuoFace uses cloud storage providers such as Google Cloud and Amazon Web Services. Provider data-protection information is available at https://cloud.google.com/security/compliance/gdpr/ and https://aws.amazon.com/compliance/gdpr-center/. Information may be processed outside your country, including in the United States, subject to applicable data-transfer requirements.

DuoFace also integrates into the application the following platforms:

- Firebase (https://firebase.google.com/) – Google's mobile platform, helping DuoFace develop a high-quality application.

- Sentry (https://sentry.io) – an error monitoring platform helping DuoFace discover, triage, and prioritize errors in the application in real-time.

- AppsFlyer (https://www.appsflyer.com/) – a mobile attribution and marketing analytics platform helping DuoFace market the application.

- Amplitude (https://amplitude.com/) – behavioral analytics platform for product intelligence helping DuoFace understand user behavior and build engaging experiences;

- Google Analytics (https://analytics.google.com/) - analytics service offered by Google that tracks and reports DuoFace traffic

- Facebook App Event Tracking (https://developers.facebook.com/docs/app-events/) - analytics service offered by Facebook that tracks and reports DuoFace traffic

- Google AdMob (https://admob.google.com/home/) - mobile advertising platform

- AppLovin (https://www.applovin.com/) - mobile advertising platform

- Appodeal (https://appodeal.com/privacy-policy/) - mobile advertising platform

DuoFace does not control third-party platforms, websites, or online services, and DuoFace is not responsible for their actions. These platforms, websites, and online services follow different rules regarding the collection, use, and sharing of your personal information. DuoFace encourages you to read the privacy policies of these platforms, websites, and online services to find out more about how your usage data may be used by these vendors.

International transfers must comply with applicable data-protection law. Where required, we use a valid transfer mechanism and appropriate safeguards. You can contact us for information about the safeguards applicable to your data and how to obtain a copy.

You also have to be aware of the fact that DuoFace may disclose your personal information to enforce and comply with the law. In other words, DuoFace may disclose to officials the information necessary for the investigation or legal process on official request or the official bodies acting within their powers.

Web app providers. Amazon Web Services, including Amazon CloudFront, processes the connection data described in section 1 to deliver the service and provide the country code used for language and regional pricing. Card payments are processed through Ameriabank CJSC (https://ameriabank.am/) or Ardshinbank OJSC (https://ardshinbank.am/). The bank processing your payment and its payment-processing partners handle your card details on the secure payment page. For payments routed through the ArCa payment gateway, Armenian Card (ArCa) also processes the information needed to carry out the payment. DuoFace uses the necessary transaction and subscription records to provide the service and resolve billing issues.

Payment confidentiality. Payment and subscription records are used only to provide and administer the service, handle refunds and disputes, prevent fraud and meet legal obligations. We do not sell them or share them for advertising. We disclose them only to the payment provider and service providers that need them for these purposes, or when legally required. A content or usage-data licence in the Terms of Use does not authorise any other use of payment records.

4. How We Store Information

Data retention. Your data will be stored by DuoFace no longer than is necessary for the purposes for which the data are processed. That is why,

- your photos and videos are stored on the DuoFace server until you finish the editing session, but not longer than within 72 hours after the finishing of the editing session. For the rest of the time your photos and videos used in DuoFace application are stored locally on your mobile device and may be removed any time by either deleting these photos and videos from your mobile device’s file system directly or by deleting DuoFace application;

- your facial feature data is stored on the DuoFace server for a limited period of 30 calendar days after your last use of the DuoFace application;

- anonymous, aggregated or de-identified data will be stored as long as necessary to fulfill the purposes DuoFace has set out in this Privacy Policy.

Data security. DuoFace processes your data using computers and/or other IT-enabled tools. DuoFace takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Web app and billing records. Locally stored web-app media can be removed using the app’s controls or browser site-data settings; clearing local data does not itself delete server records. For direct web payments, transaction evidence is retained for at least three years as required by the acquiring terms, and longer only where applicable law requires it. This financial-record period does not extend the photo/video or facial-feature periods above. Account and support information is retained only as needed for the stated purpose and applicable legal obligations. We use HTTPS for the web app; no internet service can guarantee absolute security.

5. Your Rights Regarding Information

You have a right to access to your personal data processed by DuoFace App and the right to data portability

This means that you can ask DuoFace what personal data of yours is processed. You can also ask for clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from DuoFace your personal data in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means.

You have a right to request from DuoFace to rectify your personal data

This means you can require all the inaccurate personal data concerning you to be corrected. You can also complete the personal data if you feel there is a need to do so.

You have a right to request DuoFace to erase personal data

You can request DuoFace to erase personal data if its processing is no longer necessary to achieve purposes for which it was collected as well as if there are no legal grounds for the processing.

You have a right to restrict the processing of your personal data by DuoFace

In some cases, prescribed by law you will be able to restrict the processing of your personal data, for example, if you contest the accuracy of your personal data being processed or in case DuoFace is not interested in processing your personal data any longer, but you want DuoFace to do this on different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted.

You have a right to withdraw your consent

You can withdraw your consent for the collection and processing of your personal data by DuoFace at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. After we at DuoFace receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.

You have a right to object to processing of your personal data by DuoFace

In some cases, prescribed by the applicable laws you can object to processing of your personal data.

You have a right to object to processing of your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process your data to pursue our or third party’s legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms.

If you make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.

Please note that when processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification. We will no longer process your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process your data for direct marketing purposes.

How to exercise your rights as to your personal data?

Any requests to exercise your rights can be directed to DuoFace through the contact details provided below. These requests are free of charge.

6. Time for Reply and Reaction

DuoFace will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if DuoFace is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. DuoFace will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.

If you have doubts as to our reply or reaction, or absence of such, you have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country.

7. Children’s Privacy

The privacy of children is one of our major concerns.

General age limitation. At DuoFace we can provide you the Services only in case you are aged 13 or older and any use or access to the Service by anyone under thirteen (13) is strictly prohibited and in violation of the Terms and this Policy. If you are under 18 you will need to get your parent’s/guardian’s permission before providing any private information to DuoFace. We reserve the right to request reasonable proof of such permission, and you must provide such proof within a reasonable period of time, but no later than in three (3) business days following such request. Shall we not receive any answer or proof concerning your maturity, we reserve the right to terminate your access to the Services.

Age limitation for EU residents. Due to the requirements of the EU General Data Protection Regulation, you shall be at least 16 years old in order to use our Services. To the extent prohibited by applicable law, we do not allow the use of the Service by EU residents younger than 16 years old, unless with the parent’s/guardian’s permission as provided above.

If we unintentionally collect personal data, find any content with, or related to a child under age 13 (or 16 in the EU), we will delete such information as quickly as possible. Besides, if you are aware of anyone younger than 13 (or 16 in the EU) using our Services, please contact us at support@duoface.app

8. Change to our Privacy Policy

We may change this Privacy Policy from time to time if doing so will be deemed necessary in order to comply with the applicable laws and actual circumstances of the functioning of the Services, so please periodically check this page to ensure that you’re satisfied with any changes. Additional notifications on any amendments will be displayed or otherwise communicated to you when using the Services after the amendments were made. If within one week after such notification has been shown to you, you continue to use the Services, you will be considered as having accepted all the amendments made, unless there is an obligation imposed on DuoFace by applicable law to obtain your explicit consent to the amendments. This can be a case when, for example, the nature of your data processing and purposes for processing change.

9. Contacts

We hope this Privacy Policy helped you understand how your personal information is dealt with at DuoFace. DuoFace will undertake its best effort to make your personal data protected. If you have any questions regarding this Privacy Policy and our Services,

please contact us at support@duoface.app

Data controller and contact: DavKon Tech LLC. TIN: 02872817. Nor Nork 7th Block, 36 Building, Apt. 3, Yerevan 0092, Armenia. Phone: +374 91 550314. Email: support@duoface.app.