Introduction

Welcome to Others’ Eyes OÜ (“We” or “Others’ Eyes”). We are committed to safeguarding your privacy and ensuring compliance with the applicable data protection laws. Please take a moment to read this Privacy Policy carefully before using our website or app.

Data controller

The controller of your personal data is Others’ Eyes, who is responsible for ensuring that your personal data is processed in accordance with this Privacy Policy and applicable data protection laws.

Details of the controller:

Legal entity incorporated under the laws of Estonia with a registry code 16596874
Address: Koldrohu tee 3, 12014 Tallinn, Estonia
E-mail: privacy@otherseyes.com

Changes to this Privacy Policy

The Others’ Eyes team may update this Privacy Policy as needed. If we update this Privacy Policy, we will notify you via our website http://www.otherseyes.com. In the event of substantial updates, we will also notify you by email address that you have communicated to us.  

1. What Personal Data Do We Collect?

In this Privacy Policy, “personal data” is defined as any information relating to an identified or identifiable natural person. We usually collect personal data directly from our clients when they interact with us, including in the course of using our services.

When you use or engage with our services, we may collect and process the following personal data:

• Your image on the photos that you choose to upload to our app, and the AI-generated descriptions regarding these photos;
• The parameters you choose for the AI-powered processing of your image;
• The AI-generated feedback to your image which may include descriptive items regarding you;
• Data regarding analytics on the website upon using and engaging with our services.

2. How Do We Use Your Information and On Which Legal Bases?

We may process your personal data for the following purposes and on the legal bases:

2.1. When you register on our site or app, we may process your personal data as necessary to establish a contractual relationship with you in the course of our ordinary business activities. For these purposes, the legal basis for the processing of your personal data is to enable us to take steps at your request prior to entering into a contract between us.

2.2. When you use our services, we may process your personal data, including your image, as necessary to provide you our services. For these purposes, the legal basis for the processing of your personal data is our contract with you.

2.3. When you use our services, we may process your personal data, such as data regarding analytics as necessary to improve and develop our services, including for security purposes, and to carry out marketing analytics. Inter alia, we may process your facial image in order to solve errors in image processing, but we do not use the images as training data. For these purposes (or for the anonymization underdone with these purposes in mind, if applicable), the legal basis for the processing of your personal data is our legitimate interest to enable us to advertise our services, improve and develop our services in order to enhance the functioning of our services, ensure the technical availability and security of our services.

2.4. We may process your personal data as necessary to comply with our legal obligations deriving from applicable law. For these purposes, the legal basis for the processing of your personal data is the respective legal provision obliging us to process the relevant data. Such legal obligations may derive, for instance, from accounting and tax laws.

2.5. If you subscribe to receive our marketing communications from us by consenting to receiving such communications, we may use your e-mail address for the purpose of sending you updates, offers and other marketing material about us and our services. For these purposes, the legal basis for the processing of your personal data is your consent. You may disagree with such use of your e-mail by withdrawing your consent at any time in accordance with Chapter 5 of this Privacy Policy or by clicking “unsubscribe” in the marketing communication you receive from us.

2.6. If necessary, we may process your personal data on the basis of our legitimate interest to establish, exercise or defend legal claims arising out of or in relation to the contract between us and you.  

3. Retention of Your Personal Data

We process and retain your personal data only for as long as necessary for the fulfilment of the specific purposes of personal data processing described in this Privacy Policy, including to comply with legal requirements applicable to us.

Most of your personal data will be retained until the end of the contractual relationship with us, i.e., until your registered account is active. However, we may retain certain personal data for longer periods, if this is necessary to achieve our legitimate interests or where this is required by law.

Your facial image will normally be stored for one day. If we need to solve any errors that occurred during the provision of our service to you, then we may store the facial image for up to two weeks in order to solve the issue.

When the retention of your data is no longer necessary to achieve the purposes of the processing, your data will be permanently removed, unless you instruct us otherwise, and we agree on the terms on longer storage of your data.  

4. We Do Not Disclose Your Information to Outside Parties Except as Per Your Request

Except in cases of merger or acquisition, your information will not be sold, exchanged, transferred, or given to other companies without your consent. We only share information with trusted third parties who help operate our platform, always under relevant agreements ensuring the confidentiality and security of personal data. We may disclose your information to comply with the law, enforce our policies, or protect rights, property, or safety. Non-personally identifiable visitor information may be shared with third parties for marketing or advertising purposes.

We may transfer your personal data outside of the European Economic Area. If we do so, we use adequate safeguards to protect your personal data, such as the standard contractual clauses for transfers established by the European Commission. You can get more information about the transfers of your personal data by contacting us at privacy@otherseyes.com.  

5. Your Rights as a Data Subject

By contacting us at privacy@otherseyes.com you may exercise your privacy rights as the data subject, including the following:

• You may request access your personal data;
• To the extent allowed under applicable law, you may request us to correct, update, change or remove your personal data at any time;
• If you request the erasure of your personal data, please note that certain information is strictly necessary in order to fulfil the purposes defined in this Privacy Policy and may also be required by law. If personal data is erased under your request, we will only retain such copies of the information as are necessary for us to protect our or third parties’ legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us. Thus, you may not erase such personal data;
• The right to withdraw consent regarding processing of personal data, where the legal basis for processing is your consent;
• The right to data portability (insofar as it does not infringe our legitimate interests to protect our trade secrets or any other confidential information);
• In some cases you may have a right to request restriction of processing of your personal data or to object to processing of your personal data; and
• To the extent permitted under applicable law, you may request more information about our legitimate interest and why we think our legitimate interest overrides your rights and interests as a data subject. Prior applies where the legal basis for the processing of your personal data is our legitimate interest.

If you think there is a problem with the way we are handling your personal data, you have a right to file in a complaint to your national data protection authority in the European Union and the European Economic Area. List and contact details of relevant supervisory authorities can be found here.  

6. How We Protect Your Information

We employ various security measures to safeguard your personal data during submission or access. Our secure server and Secure Socket Layer (SSL) technology encrypt sensitive information. After a transaction, we do not store sensitive data on our servers. Notwithstanding the prior, please note that while we take reasonable steps to protect the security of your personal data, no system completely eliminates all potential security risks.

7. What Is Our Use of Cookies?

We use cookies and local storage devices for security, site performance, and member experience. You may configure your browser and mobile settings to block cookies, but this may limit access to certain features. Our cookie usage includes:

• Strictly Necessary Cookies:These are essential for service delivery.
• Performance-related Cookies:These include analytics to assess how our app or site performs and to ensure a smooth experience. These cookies are stored on your device and used only on the basis of your consent.
• Third-party Cookies:These relate to functionality, such as Facebook login. These cookies are stored on your device and used only on the basis of your consent.

The length of time a cookie will be retained on your device depends on whether it is a persistent or session cookie. Session cookies are temporary cookies that stay on your device until you leave our site. Persistent cookies will be retained on your device after you have finished using our website or services until they expire or are manually deleted.

Please note that some features may rely on third-party cookies. The third-party placing cookies on your device is responsible for their data processing, and we recommend reviewing their privacy policies.  

Contact Us

If you have questions or concerns regarding our Privacy Policy or your data, please contact us at privacy@otherseyes.com.

We are committed to maintaining compliance with relevant privacy laws and regulations, ensuring ongoing data protection, and respecting your rights to access, correct, or delete your personal data.