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PRIVACY POLICY

Welcome to Orbo AI

A product of Modaviti e-Marketing Private Limited (“us”, “we”, or “our”) operates https://www.orbo.ai/, https://supertouch.ai/, https://superscan.ai/, https://superenhance.ai and SuperTouch mobile app(hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to Orbo.ai, superenhance.ai, supertouch.ai, superscan.ai and its subdomains and Supertouch mobile app and explains how we collect, safeguard and disclose information that results from your use of our Service.

This Privacy Policy ("Policy") describes how Orbo.ai, superenhance.ai, supertouch.ai, superscan.ai and its subdomains and Supertouch mobile app collects, uses, stores, and protects personal information when you use our website or application that utilizes facial recognition technology. We are committed to protecting your privacy and ensuring the security of your personal information. By using our Service, you agree to the collection and use of your personal information as described in this Policy.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy, constitute your agreement with us (“agreement”).

Definitions

SERVICE means the Orbo.ai, superenhance.ai, supertouch.ai, superscan.ai and its subdomains and Supertouch mobile app operated by Modaviti e-Marketing Private Limited.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information We Collect:

1.1. Personal Information: When you use our Service, we may collect and process personal information, such as facial images, that you voluntarily provide or that is captured through the use of our Service.

1.2. Usage Information: We may collect certain information about your use of the Service, including your photo, skin type, and skin tone.

2. Use of Personal Information

2.1. Facial Recognition: We use facial recognition technology to analyze and process facial images for the purpose of providing the intended features and functionality of the Service.

2.2. Service Improvement: We may use the collected information to improve and optimize the performance of our Service, enhance the user experience, and develop new features and functionalities.

2.3. Communication: We may use your personal information to communicate with you, respond to your inquiries, provide technical support, and send you important updates or notifications related to the Service.

2.4. Legal Compliance: We may use and disclose your personal information as required by applicable laws, regulations, or legal processes.

Usage Data:

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

Face Data in Supertouch Mobile App:

Neither your facial photo/video nor your facial feature vectors will be stored in our database in any form whatsoever. All facial effects, hair color, styling and skin analysis is done on your device and we do not store any information in our database. We do not transfer user's facial information from user's mobile app to our back-end servers.

Location Data:

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data:

We use cookies to improve and personalize its Sites and Services and/or measure its audience. Cookies are files saved to your local storage when browsing on the internet and in particular on our Sites. A cookie is not used to gather your personal data without your knowledge but instead to record information on site browsing which can be read directly by us on your subsequent visits.

You can choose to decline acceptance of all cookies, but your ability to browse certain pages of our Sites may be reduced. The cookies used by us are intended to enable or facilitate communication, to enable the Services requested by users to be supplied, to recognize users when they re-visit the site, to secure payments which users may make, or other preferences necessary for the service requested to be supplied and to enable us to carry out analyses on hit rates and browsing experience so as to improve content, to track email open rates, click rates, and bounce-back rates at individual levels.

By default, cookies are not installed automatically (except for those cookies needed to run our Sites and Services, and you are informed of their installation by a clickable banner with a text description). In accordance with the regulations that apply, we will require your authorization before implanting any other kind of cookie to your local storage. To avoid being bothered by these routine requests for authorization and to enjoy uninterrupted browsing, you can configure your device to accept our cookies, or we can remember your refusal or acceptance of certain cookies. By default, browsers accept all cookies.

When you access third party sites on our Sites, or when you are reading integration or social media links, cookies can be created by the companies disseminating these links. These third parties may be able to use cookies in the context of our Services (partners or other third parties supplying content or services available on the our site) and are responsible for the cookies they install, and it is their conditions on cookies which apply. We assume no liability regarding the possible use of cookies by third parties. For more information, you are advised to check the cookie policy directly on these third-party sites concerning their use of cookies.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

0.1. Session Cookies: We use Session Cookies to operate our Service.

0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

0.3. Security Cookies: We use Security Cookies for security purposes.

0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Modaviti e-Marketing Private Limited uses the collected data for various purposes:

0.1. to provide and maintain our Service;

0.2. to notify you about changes to our Service;

0.3. to allow you to participate in interactive features of our Service when you choose to do so;

0.4. to provide customer support;

0.5. to gather analysis or valuable information so that we can improve our Service;

0.6. to monitor the usage of our Service;

0.7. to detect, prevent and address technical issues;

0.8. to fulfil any other purpose for which you provide it;

0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

0.11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

0.12. in any other way we may describe when you provide the information;

0.13. for any other purpose with your consent.

Data Retention:

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Aggregated and De-Identified Information:

We may aggregate and anonymize personal information to create non-personally identifiable information for statistical analysis, research, or marketing purposes. This information cannot be used to identify you personally.

 Sharing of Personal Information:

0.1. We do not sell, rent, or trade your personal information with third parties for their marketing purposes.

0.2. We may share your personal information with trusted third-party service providers who assist us in operating our Service, conducting business activities, or providing services on our behalf. These service providers are contractually obligated to maintain the confidentiality and security of your personal information.

0.3. We may disclose your personal information if required to do so by law or if we believe that such disclosure is necessary to protect our rights, comply with a judicial proceeding, court order, or legal process, or respond to a government or regulatory request.

 International Data Transfers:

Your personal information may be transferred to and processed in countries other than your own. We will take appropriate measures to ensure that such international transfers comply with applicable data protection laws and provide adequate protection for your personal information.

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Modaviti e-Marketing Private Limited will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data:

We may disclose personal information that we collect, or you provide:

0.1. Disclosure for Law Enforcement:

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

0.2. Business Transaction:

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

0.3. Other cases. We may disclose your information also:

0.3.1. to our subsidiaries and affiliates;

0.3.2. to contractors, service providers, and other third parties we use to support our business; refer to clause no 17.

0.3.3. to fulfil the purpose for which you provide it;

0.3.4. for the purpose of including your company’s logo on our website;

0.3.5. for any other purpose disclosed by us when you provide the information;

0.3.6. with your consent in any other cases;

0.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Security of Data:

Within the framework of its Services, we attribute the very highest importance to the security and integrity of information and personal data. We observe reasonable procedures to prevent unauthorized access to, and the misuse of, information including personal data. We use appropriate business systems and procedures to protect and safeguard information including personal data. We also use security and managerial procedures and industry standard technical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

Thus and in accordance with the GDPR and CCPA, We undertake all pertinent precautions in order to preserve the security of the data and, in particular, to protect them against any accidental or unlawful destruction, accidental loss, corruption, unauthorized circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorized persons.

To this end, we implement industry standard security measures to protect personal data from unauthorized disclosure.

The security of your data is important to us but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR):

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed about Personal data, we hold information about you and if you want it to be removed from our systems, please email us at support@orbo.ai.

In certain circumstances, you have the following data protection rights:

0.1. the right to access, update or to delete the information we have on you;

0.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

0.3. the right to object. You have the right to object to our processing of your Personal Data;

0.4. the right of restriction. You have the right to request that we restrict the processing of your personal information;

0.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;

0.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Choice and Rights:

We want you to be in control of how your personal information is used by us. In accordance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, the and the California Consumer Privacy Act (CCPA), you can do this in the following ways:

You can ask us for a copy of the personal information we hold about you.

You have the right to know whether your personal information is sold or disclosed and to whom.

You have the right to say no to the sale of your personal information.

You can inform us of any changes to your personal information, or you can ask us to correct any of the personal information we hold about you. You are also able at any time to modify your personal information by accessing your account settings on our Sites.

In certain situations, you can ask us to erase, block, or restrict the processing of the personal information we hold about you or object to particular ways in which we are using your personal information.

In certain situations, you can also ask us to send the personal information you have given us to a third party.

Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time subject to applicable law. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information subject to applicable law.

We rely on you to ensure that your personal information is complete, accurate, and current. Please do inform us promptly of any changes to or inaccuracies of your personal information by contacting support@orbo.ai We may require your application to be accompanied by a photocopy of proof of identity or authority.

Please note, you are entitled to ask us to provide you with information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

0.1. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

0.2. To stop selling your personal information. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

Please note, if you ask us to delete your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

Service Providers:

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics:

We may use third-party Service Providers to monitor and analyse the use of our Service.

CI/CD tools:

We may use third-party Service Providers to automate the development process of our Service.

Behavioural Remarketing:

We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Payments:

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g., payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Consent:

By using our Service, you represent and warrant that you have obtained any necessary consents and permissions, including the informed consent of individuals whose facial images you provide or upload to the Service.

Links to Other Sites:

Our Service may contain links to other sites that are not operated by us. If you click a third- party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy:

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy:

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: support@orbo.ai.