PRIVACY POLICY

Introduction

ScriptedCodes LLC ("we," "us," "our") is committed to processing your personal data in accordance with applicable privacy laws, including the California Consumer Privacy Act (CCPA) (California, USA), the General Data Protection Regulation (GDPR) (European Union), and other relevant data protection regulations.

As the Data Controller, ScriptedCodes LLC is responsible for determining the purposes and means of processing your personal data. This means that we manage and control your data, ensuring that it is processed in compliance with legal requirements, securely, and transparently. We may also engage third-party service providers to process your data on our behalf. In such cases, these third-party providers will act as Data Processors, and we ensure that they comply with the same privacy standards as outlined in this Privacy Policy.

Your personal data, which you have provided or will provide to us, and/or which we have obtained through other lawful means (including from third-party sources or public records), may be processed by ScriptedCodes LLC as the Data Controller in connection with the services we offer through the Clean Up AI app. We process your data in a manner that is lawful, fair, and transparent, and only for the purposes described in this Privacy Policy.

Your personal data may be:

  • Collected, recorded, stored, and updated to provide, maintain, and improve our services.

  • Shared with third parties as necessary to provide our services or to comply with legal obligations, with appropriate safeguards.

  • Transferred across borders in compliance with applicable data protection laws, including GDPR and CCPA, where relevant.

This Privacy Policy outlines the types of data we collect, the purposes for which we process it, how we protect your data, and how you can exercise your rights regarding your personal data. We encourage you to review this Privacy Policy regularly, as it may be updated to reflect changes in our practices or legal obligations. By using the App, you agree to the collection and processing of your personal data as described in this Privacy Policy.

2. Personal Data Collection and Methods

2.1. Types of Personal Data We Collect

We may collect the following types of personal data, depending on how you interact with the App:

1. Identity and Contact Information

  • Name, email address, and phone number: We collect this information when you contact us, register for an account, or interact with our customer support. This data is used to communicate with you and provide services.

2. Account and Transaction Information

  • Order Information: When you make purchases through the App, we collect transaction details including the type of purchase, payment information, and billing information, in compliance with payment processing services.

3. User Content

  • Media Content: This includes any photos, images, videos, documents, and other files you upload, share, or create within the App. For instance, you may share photos for duplicate image detection or file organization.

4. Device and Usage Data

  • Device Identifiers: We collect unique identifiers such as the Identifier for Advertisers (IDFA), Identifier for Vendors (IDFV), IP address, device name, operating system version, and other device-related information. These identifiers are collected automatically when you use the App.

  • Usage Logs: This includes data regarding how you use the App, such as the time spent, sections accessed, features interacted with, and other metrics relevant to App performance. This data helps us improve the App and enhance user experience.

5. Geolocation Data

  • Location Information: If you opt-in to location services, we may collect geolocation data to provide location-based features, such as nearby services or to tailor content. You can revoke location access at any time through your device settings.

6. Email Account Information

  • Email Access: With your explicit consent, we may access and process certain data from your email account (e.g., Gmail) to provide services such as email organization, filtering, or deletion of unwanted messages. You have the ability to enable or disable this access at any time via the App settings or your device's privacy settings. Please note, we do not store emails on our servers; all data is processed locally on your device or cloud services (such as iCloud or Google Drive).

7. Advertising Data

  • Advertiser Identifiers: We may collect advertising identifiers (e.g., IDFA, IDFV) to personalize ads and measure ad performance. This data is shared with third-party advertising networks, such as Google AdMob or AppLovin or others not mentioned, to deliver tailored advertisements. You can manage your preferences for personalized ads in your device settings.

8. Cookies and Similar Tracking Technologies

  • Cookies: We use cookies and similar tracking technologies to improve the App's functionality and user experience. Cookies help us track usage patterns, analyze app performance, and provide personalized content. You can manage your cookie preferences through the App or your device settings.

2.2. Methods of Data Collection

We collect personal data through various methods, as outlined below:

1. Direct Collection

  • Information You Provide: When you sign up for the App, contact us, make a purchase, or submit a support request, you provide us with personal information such as your name, email address, and payment details. We collect this information to enable us to communicate with you and provide the App’s services.

  • User Content: When you upload, create, or share media (e.g., photos, videos) within the App, we collect and process this data to provide the requested services, such as organizing, cleaning, or identifying duplicate files.

2. Automatic Collection

  • Device and Usage Data: As you interact with the App, we automatically collect device-related information (such as device identifiers, IP address, operating system version, and usage logs). This data is collected via automated technologies such as analytics tools and tracking technologies, and is used to analyze usage patterns and improve App functionality.

  • Cookies and Tracking Technologies: We use cookies to track user preferences and optimize App performance. Cookies are small data files stored on your device that enable us to personalize your experience within the App and gather anonymized data about your interactions with the App.

3. Third-Party Data Collection

  • Third-Party Platforms: We may receive data from third-party platforms (such as Google Play or Apple App Store) when you download or use the App. This data may include app installation details, device information, and usage metrics.

  • Advertising Networks: When you interact with advertisements within the App, data may be shared with third-party advertising networks like Google AdMob, AppLovin MAX, or other similar services. These networks use identifiers like IDFA and IDFV to deliver targeted advertisements based on your interests and device usage.

2.3. User Consent and Control

Your privacy is important to us, and we are committed to providing clear choices regarding the data we collect. Here are the ways you can control the data we collect:

1. Consent for Data Collection

  • Opt-In Features: For certain features (such as accessing your email account, photo gallery, or location services), we require your explicit consent. We will request your permission through a pop-up consent notice when these features are enabled for the first time. You can grant or deny permission, and you may also manage your preferences at any time in your device settings.

2. Managing Permissions

  • Email and Photo Access: You have the right to enable or disable access to your email account or photo gallery at any time. If you choose to disable these features, some functionalities of the App may be limited, but you will still be able to use other aspects of the App.

  • Location Services: If you enable location services, we may collect and use your geolocation data. You can disable this feature at any time through your device’s settings, which will stop us from collecting location data moving forward.

  • Ad Personalization: You may also opt out of personalized ads by adjusting the settings on your device or through the advertising settings within the App.

3. Data Retention

  • We will retain your personal data only for as long as necessary to provide the services you request, fulfill legal obligations, and manage any disputes. Once the purpose for which the data was collected is fulfilled, we will delete or anonymize it, in accordance with applicable law.

4. User Rights

  • Right to Access: You have the right to request access to the personal data we hold about you.

  • Right to Rectification: You may request that we correct any inaccurate or incomplete personal data we have about you.

  • Right to Deletion: You may request the deletion of your personal data, subject to certain legal exceptions.

  • Right to Restrict Processing: You can request that we restrict the processing of your personal data under certain circumstances.

  • Right to Object: You may object to the processing of your personal data for marketing purposes or based on our legitimate interests.

To exercise any of these rights, please contact us through the contact details provided in the Contact Us section of this Privacy Policy.

2.4. Data Protection and Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure servers, and regular security audits. However, no method of data transmission over the internet is completely secure, and we cannot guarantee the absolute security of your personal data.

2.5. No Storage of Personal Content on Servers

As a part of our privacy commitment, we do not store your personal content (such as emails, photos, videos, or documents) on our servers. All personal data is processed locally on your device or within your own cloud services (e.g., iCloud, Google Drive). This ensures that you maintain full control over your content, and we do not retain any personal media unless specifically required for providing services like email management or file organization.

2.6. Third-Party Services and Advertisers

We may share some of your data with third-party service providers and advertising partners, such as Google, Apple, Firebase, and others not mentioned to facilitate certain features within the App (e.g., ad delivery, analytics). These third parties may collect and use your data in accordance with their own privacy policies. For example, advertising networks may collect advertiser identifiers (e.g., IDFA, IDFV) for personalized advertising purposes. You can review the privacy policies of these third parties to understand how your data is used in these contexts.

By using the Clean Up AI app, you consent to the collection and processing of your personal data as described in this section.

3. Data Processing Principles

At ScriptedCodes LLC, we are committed to processing your personal data responsibly, securely, and in accordance with applicable data protection laws. This section outlines the principles and legal grounds by which we collect, store, and process your data.

3.1. Lawfulness, Fairness, and Transparency

We are committed to processing your personal data in a lawful, fair, and transparent manner. This means:

  • Lawfulness: We only process your personal data when we have a legal basis for doing so, such as your consent, the performance of a contract, compliance with legal obligations, or legitimate interests.

  • Fairness: We collect and use your data in ways that are fair to you and align with your reasonable expectations.

  • Transparency: We provide clear and easily accessible information about how and why we collect and use your data, as well as how you can manage your privacy preferences.

3.2. Purpose Limitation

We will only process your personal data for specific, legitimate purposes, as outlined in this Privacy Policy. Your data will not be used for any purpose that is incompatible with those specified purposes. These purposes include, but are not limited to:

  • Providing, maintaining, and improving our services (e.g., Clean Up AI).

  • Communicating with you about your account, services, or new features.

  • Ensuring the security and integrity of our services and infrastructure.

  • Meeting our legal obligations, including compliance with applicable data protection laws.

3.3. Data Minimization

We will only collect the minimum amount of personal data that is necessary to fulfill the purposes outlined in this Privacy Policy. This principle ensures that:

  • We avoid collecting unnecessary or excessive data that is not relevant to the service we provide.

  • We regularly assess our data collection practices to ensure they remain in line with the principle of data minimization.

3.4. Accuracy

We take reasonable steps to ensure that the personal data we collect is accurate, complete, and up-to-date. To help us keep your data accurate, we encourage you to update your information when necessary. If we become aware that any of the personal data we hold is inaccurate or incomplete, we will take steps to correct it as soon as possible.

3.5. Storage Limitation

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws. Once the purpose for which the data was collected is fulfilled, we will either delete or anonymize your personal data in compliance with legal and regulatory requirements.

For example, if we are processing your personal data under a contractual obligation, we will retain it for the duration of the contract and for a reasonable period thereafter to meet legal, regulatory, or business requirements.

3.6. Integrity and Confidentiality

We implement appropriate technical and organizational measures to ensure that your personal data is protected against unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Encryption: We use industry-standard encryption protocols to protect your data both in transit (e.g., during transmission over the internet) and at rest (e.g., stored on our servers).

  • Firewalls and Anti-virus Protection: Our systems are safeguarded with firewalls and anti-virus software to prevent unauthorized access and protect against malware and other security threats.

  • Access Control: We limit access to your personal data to authorized personnel only. Our employees and contractors are required to follow strict confidentiality obligations to ensure the integrity of your data.

  • Information Security Management System (ISMS): We maintain an ISMS, which includes security policies, procedures, and controls, to continuously monitor and improve the security of your data.

3.7. Accountability and Compliance

We are responsible for ensuring that your personal data is processed in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the New York SHIELD Act. To demonstrate accountability, we:

  • Regularly audit and assess our data processing activities to ensure compliance (annually, or as required).

  • Provide ongoing training to employees handling personal data on privacy and data security best practices.

  • Document our data processing activities and maintain records as required by applicable laws.

  • Ensure that our third-party service providers, contractors, or partners who process your personal data are compliant with applicable privacy regulations.

3.8. Data Subject Rights

You have specific rights regarding your personal data, and we are committed to respecting these rights in line with applicable data protection laws. These rights may include:

  • Access: The right to request information about the personal data we hold about you.

  • Correction: The right to request corrections to inaccurate or incomplete personal data.

  • Deletion: The right to request the deletion of your personal data under certain conditions, such as when the data is no longer necessary for the purposes for which it was collected.

  • Restriction: The right to restrict the processing of your personal data in certain situations.

  • Objection: The right to object to certain types of processing, including direct marketing.

  • Data Portability: The right to request a copy of your personal data in a structured, commonly used format for transfer to another controller.

You can exercise your rights by contacting us at contact@scriptedcodes.com. We will respond to your request within the timeframes required by applicable law, typically within 30 days.

3.9. Legal Grounds for Processing

The legal grounds on which we process your personal data are as follows:

  • Performance of a Contract: We process your personal data when it is necessary to fulfill our contractual obligations to you, including providing the services you request, processing payments, and delivering the functionality of Clean Up AI.

  • Legal Obligation: We may process your data to comply with legal obligations, such as tax laws, financial reporting, and responding to legal requests or law enforcement authorities.

  • Consent: We may process your personal data based on your explicit consent, such as when you opt-in for marketing communications or optional app features. You have the right to withdraw your consent at any time.

  • Legitimate Interests: We process personal data based on our legitimate interests, provided that these interests do not override your rights and freedoms. Examples of legitimate interests include improving the app’s functionality, ensuring security, and conducting internal audits.

  • Vital Interests: In exceptional cases, we may process personal data to protect your or another person’s vital interests, such as in emergency situations where your data is necessary for safety or urgent health-related decisions.

3.10. Security Measures

We implement robust security measures to protect your personal data from unauthorized access, loss, misuse, or disclosure. These measures include both technical and organizational safeguards, such as:

  • Encryption: We use industry-standard encryption protocols to protect your personal data during transmission (e.g., over the internet) and at rest (e.g., stored on our servers).

  • Firewalls and Antivirus: We deploy firewalls and antivirus software to safeguard our networks and systems from external threats.

  • Access Control: We use access control mechanisms to ensure that only authorized personnel can access your personal data. Access to sensitive data is granted only on a need-to-know basis and is monitored.

  • Penetration Testing: We periodically conduct penetration tests and security audits to identify and fix potential vulnerabilities in our systems.

We take all reasonable steps to ensure that your data is secure and that our services meet or exceed industry standards for data protection.

3.11. Logging and Monitoring

We maintain detailed logs of system activity, including access to and modifications of personal data. This helps us to:

  • Monitor the security of our systems and data.

  • Audit and track actions taken within our systems for compliance purposes.

  • Detect and respond to potential security threats or breaches in a timely manner.

Logs are retained and monitored for a period determined by our internal data retention policies and in accordance with legal requirements. Access to logs is strictly controlled and limited to authorized personnel only.

3.12. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. The retention periods for personal data may vary based on the type of data and its use. Once the retention period expires, we securely delete or anonymize the data.

Specific retention periods include:

  • Service-related data: Retained as long as the user maintains an active relationship with us and for a period after, to comply with legal or audit requirements.

  • Marketing data: Personal data used for marketing purposes will be retained until you withdraw your consent or opt-out of marketing communications.

  • Transactional data: Data related to transactions, such as payment information, will be retained for as long as required by law for auditing or financial reporting purposes.

3.13. Data Transfer and Cross-Border Data Transfers

Since we operate globally, your personal data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your country. We ensure that such transfers are carried out in compliance with applicable data protection laws.

In cases where data is transferred outside of the European Economic Area (EEA), we may use Standard Contractual Clauses (SCCs), which are legally binding agreements that ensure an adequate level of protection for personal data transferred internationally.

By using Clean Up AI, you consent to the transfer, storage, and processing of your personal data in the United States or other locations, in compliance with applicable laws.

3.14. Non-Disclosure and Confidentiality Agreements

To safeguard your personal data, we require all employees, contractors, and third-party service providers to sign non-disclosure agreements (NDAs) to ensure that personal data remains confidential and is not shared without appropriate authorization.

We take steps to ensure that our third-party vendors and subprocessors also adhere to the same privacy and security standards as outlined in this Privacy Policy. This includes conducting regular assessments and audits to verify compliance.

4. Age Limitation

At ScriptedCodes LLC, we are committed to protecting the privacy and safety of children. As such, we do not permit the use of our application, Clean Up AI, by individuals under the age of 16.

We do not knowingly collect or process personal data from users under the age of 16. If we become aware that a user under the age of 16 has provided us with personal information, we will take immediate steps to delete that data.

If you believe that someone under the age of 16 has shared personal information with us, please contact us at contact@scriptedcodes.com.

For users between the ages of 16 and 18, we require consent from a parent or legal guardian to use our services. If you are a parent or guardian and believe your child under 18 has used our services without proper consent, please reach out to us so we can address the issue appropriately.

5. Transferring Personal Data to Third Parties

At ScriptedCodes LLC, we take the privacy and security of your personal data seriously. As part of our operations, we may transfer your personal data to third parties, both within the United States and internationally, in accordance with applicable data protection laws.

Your personal data may be transferred for the following purposes:

  • Storage and Archiving: To securely store your data and ensure that we can retain it for necessary periods as required by law or for business purposes.

  • Business Operations: To enable the efficient operation of our services, such as technical support, billing, and processing payments.

  • Customer Support: To provide after-sales support for services or address inquiries and issues related to our products and services.

  • Customer Relationship Management (CRM): To manage communications with users, conduct marketing and customer outreach, and maintain an ongoing relationship with you.

5.1. Third-Party Service Providers

To help us deliver our services, we may share your personal data with third-party service providers who assist us in various business functions. These service providers are required to maintain strict confidentiality and are prohibited from using your data for any purpose other than providing services to us.

Some of the third-party service providers we may share your personal data with include:

  • Cloud Hosting Providers: For data storage and hosting purposes, we may use cloud infrastructure providers based in the United States or abroad.

  • Analytics and Tracking: We use services like Google Firebase, Adjust, and other analytics platforms to monitor app performance, user behavior, and improve the user experience. These third parties may collect certain data on our behalf, such as device information, usage data, and performance metrics.

  • Advertising and Marketing Platforms: We may share data with third-party services like Facebook SDK for analytics, advertising, and marketing purposes to better tailor our communications and improve the services we offer.

5.2. Sharing Personal Data for Legal and Regulatory Purposes

We may share your personal data with third parties, including public authorities or legal institutions, in the following situations:

  • Compliance with Legal Obligations: If required by law, regulation, or legal process, we may disclose personal data to government authorities, regulatory bodies, or law enforcement agencies.

  • Legal Defense and Claims: In the event of a legal dispute, we may share personal data with legal advisors or other parties for the purposes of establishing, exercising, or defending legal claims.

5.3. Cross-Border Transfers

As we operate internationally, your personal data may be transferred and processed in countries outside your country of residence. In particular, your data may be transferred to and stored on servers located in the United States, Europe, or other regions.

In these cases, we ensure that appropriate safeguards are in place to protect your data, such as:

  • Implementing Standard Contractual Clauses (SCCs) for transfers outside the European Economic Area (EEA), where applicable.

  • Ensuring compliance with other relevant data protection regulations.

5.4. Third-Party Websites and Services

Please note that our app may include links to third-party websites or services that are not operated by ScriptedCodes LLC. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party services you interact with.

6. Your Rights as the Data Subject

As a user of Clean Up AI, you have rights concerning your personal data under applicable data protection laws, including the General Data Protection Regulation (GDPR) for users in the European Union (EU) or United Kingdom (UK), and the California Consumer Privacy Act (CCPA) for users in California, USA. Depending on your location, other data protection laws may also apply.

ScriptedCodes LLC is committed to safeguarding your privacy and ensuring that you can exercise your data protection rights. Below is a summary of the rights available to you under these laws.

Your Rights Under the GDPR (For EU/UK Users)

If you are located in the European Union (EU) or United Kingdom (UK), you have the following rights under the General Data Protection Regulation (GDPR):

  1. Right of Access: You have the right to request information about whether we are processing your personal data. If so, you can request access to your personal data and details on the processing activities.

  2. Right to Rectification: If you believe that any personal data we hold about you is inaccurate or incomplete, you can request that we correct or update it.

  3. Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where applicable).

  4. Right to Restrict Processing: You can request that we limit the processing of your personal data under certain conditions, such as when the accuracy of the data is contested or if you object to the processing.

  5. Right to Data Portability: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format, and to transfer that data to another service provider where technically feasible.

  6. Right to Object to Processing: You have the right to object to our processing of your personal data, including for direct marketing purposes, or when we process it based on legitimate interests.

  7. Right to Not Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing (including profiling) that have significant legal or similar effects on you.

Your Rights Under the CCPA (For California Users)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act (CCPA):

  1. Right to Know: You have the right to request information about the personal data we have collected about you, including the categories and specific pieces of data.

  2. Right to Delete: You can request the deletion of your personal data that we have collected, subject to certain exceptions (e.g., if we need to retain it for legal or contractual obligations).

  3. Right to Opt-Out: If applicable, you have the right to opt-out of the sale of your personal data to third parties.

  4. Right to Non-Discrimination: You will not face discrimination for exercising your CCPA rights. This means you will not be denied services or provided a different level of service because you choose to exercise your rights under the CCPA.

How to Exercise Your Rights

To exercise your rights under the GDPR or CCPA, please submit a request via email to contact@scriptedcodes.com or by using the Data Subject Application Form. The application should specify which rights you wish to exercise, such as access, deletion, or rectification.

For us to verify your identity and respond to your request, we may ask you to provide additional information, such as:

  • Your full name, email address, and any other relevant identifiers

  • Any supporting documentation (e.g., proof of identity) to ensure we can verify your request

  • If you are acting on behalf of someone else, you will need to provide proof of your authorization to do so.

We will process your request within 30 days of receiving your request, as required by the GDPR. If we need more time to fulfill your request, we will notify you of the delay and provide a new timeframe. If your request is denied, we will explain the reasons for the denial.

Filing Complaints

If you believe that ScriptedCodes LLC or any third party with whom we have shared your data is violating your data protection rights, you have the right to lodge a complaint with the relevant data protection authority. For users in the EU/UK, you may contact the Data Protection Authority (DPA) in your country. For California residents, you may contact the California Attorney General's Office.

Changes to This Privacy Policy

This Privacy Policy may be revised periodically, and any changes will be posted on our website or within the app. If you continue to use Clean Up AI after such changes are made, you will be deemed to have accepted the updated Privacy Policy.

Company Title: ScriptedCodes LLC

E-mail: contact@scriptedcodes.com