We are committed to providing privacy to our website users and users of our products. This Privacy Policy explains how WNDR11 LTD ("WNDR11", "we", "us", or "our") collects, uses, stores, protects, and discloses Personal Data when you use our website, mobile application "Imagin8" ("Mobile App"), and our products, offers, features, tools, and resources provided through those platforms (collectively, the "Online Products").
The controller of your Personal Data collected via our Online Products, where WNDR11 determines the purposes and means of processing, is WNDR11 LTD, located at Akropoleos, 59 - 61, 3rd floor, Office 301, 2012, Nicosia, Cyprus ("WNDR11" or "we").
WNDR11 LTD is a company incorporated in Cyprus under registration number HE411801.
This Privacy Policy is based on applicable European data-protection legislation, including the General Data Protection Regulation (EU GDPR), and applicable data-protection laws. Where applicable, we also take into account US privacy laws, including the California Consumer Privacy Act (CCPA).
Information that can be used to identify or contact you is Personal Data. We collect Personal Data from you when you use our Website or Online Products, as further described in this Privacy Policy.
We may automatically collect information such as browser type, IP address, error logs, operating system, device information, application usage information, diagnostic information, and other similar technical data. Aggregated data may be used to monitor trends, administer the Online Products, and understand how the Online Products are used.
When you use an image-processing or AI-powered feature, you may choose to provide a photograph. A photograph may contain your face or the face of another person. The face-related information processed for this feature is the visual information contained in the photograph you submit.
We do not ask you to provide a separate facial scan and do not intentionally create or maintain a separate database of facial biometric identifiers, face templates, or face embeddings from photographs as part of this feature.
Under applicable data-protection law, a photograph is not automatically biometric data merely because it contains a face. Biometric data is generally relevant where a specific technical process is used to uniquely identify or authenticate a person. We nevertheless treat photographs containing faces as sensitive user content and apply the safeguards described in this section.
We use submitted photographs and face-related visual information only to provide the feature for which you submitted them. We do not use them for advertising, behavioral profiling, or marketing.
We use Personal Data for the purposes described below:
Depending on the circumstances, our legal basis may include performance of a contract, your consent, compliance with a legal obligation, or our legitimate interests, including providing, securing, maintaining, and improving the Online Products.
Where processing is based on consent, you may withdraw your consent at any time with future effect. Withdrawal does not affect processing that occurred before withdrawal.
Certain features of the Mobile App use the OpenAI API to process photographs and provide AI-generated results.
When you choose to use an AI-powered feature, the photograph you submit for that feature is transmitted for processing. The photograph may contain your face or another person's face. Depending on the feature, related instructions, prompts, or technical information necessary to process the image may also be transmitted.
The photograph is transmitted to our backend infrastructure. A temporary copy may be stored in Amazon Web Services (AWS) S3 while the request is being processed. Our backend then sends the required image data to OpenAI through the OpenAI API.
OpenAI is a third-party service provider used to provide the requested AI processing. We do not send submitted photographs to OpenAI for our own advertising, marketing, or user profiling.
Before the Mobile App sends a photograph to the third-party AI service, the Mobile App presents a separate in-app disclosure identifying the photograph as the data being sent, identifying OpenAI as the recipient, explaining that the transfer is necessary to provide the requested AI feature, and asking the user to continue.
Acceptance of this Privacy Policy or our Terms of Service does not, by itself, replace this feature-specific permission.
Our use of the OpenAI API is subject to OpenAI's applicable business and API data terms. OpenAI states that, by default, API inputs and outputs are not used to train or improve its models unless the customer explicitly opts in to data sharing.
OpenAI may retain API inputs and outputs for up to 30 days for service operation and abuse monitoring, subject to applicable exceptions and service-specific arrangements. Eligible organizations may be able to use Zero Data Retention controls for qualifying API endpoints.
For current information, see OpenAI Business Data Privacy, the OpenAI Data Processing Addendum, and OpenAI's applicable API documentation.
Photos submitted for AI processing are not intended to be permanently stored by WNDR11. A temporary copy may be stored in AWS S3 while the request is being processed.
WNDR11 deletes the temporary photo from its own AWS storage after the processing request is completed. We do not retain the submitted photograph in our application database for ongoing use, advertising, profiling, or unrelated purposes.
If a request fails, temporary files are subject to deletion and are not retained for an unrelated purpose. Our temporary storage exists only to support the requested processing.
After the photograph has been transmitted to OpenAI, retention by OpenAI is governed by OpenAI's applicable API data retention practices. Accordingly, deletion from WNDR11's AWS infrastructure does not necessarily mean that the same data is immediately deleted from OpenAI's systems.
WNDR11 does not intentionally retain face templates, facial embeddings, or other separately stored facial biometric identifiers generated from these photographs.
Our Online Products may contain links to or features of third-party websites. Third-party websites and services are not controlled by WNDR11 and are subject to their own privacy policies.
We may use social-network plug-ins or integrations such as Facebook, Twitter, Instagram, and TikTok to allow users to share content or connect with social networks. When such functionality is used, the applicable third-party provider may receive information as described in its own privacy policy.
The Mobile App may also allow connection to third-party applications or devices, such as trackers. If you connect such a service, the third-party provider may receive or provide information according to the applicable service terms and privacy policy.
Unless required by law or otherwise described in this Privacy Policy, we do not sell your Personal Data. We may share Personal Data with third parties where necessary to provide our services, where the third party acts as a processor on our behalf, where you have given consent, or where disclosure is otherwise permitted or required by applicable law.
Service providers processing Personal Data on our behalf are selected with appropriate regard to data protection and are contractually required, where applicable, to process Personal Data only for authorized purposes.
Some service providers may be located outside the European Economic Area. Where required, WNDR11 uses appropriate safeguards for international transfers, including Standard Contractual Clauses or other lawful transfer mechanisms.
We may disclose Personal Data to public authorities or law-enforcement officials where legally required. We may also disclose information to protect our rights, safety, the rights of third parties, prevent fraud or illegal activity, or enforce our agreements.
Your Personal Data will only be used for the purposes described in this Privacy Policy or for a purpose explicitly disclosed when the data is collected, unless otherwise permitted or required by applicable law.
Personal Data is retained for as long as reasonably necessary to provide the Online Products, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, protect our rights, and conduct legitimate business activities.
Different categories of Personal Data may have different retention periods. In particular, photos submitted for AI processing are treated as temporary processing data as described in Section 5. Other account, billing, legal, security, and operational information may be retained for longer where necessary.
You may contact us for information about retention periods applicable to particular categories of Personal Data.
Depending on applicable law, you may have the following rights:
You may exercise applicable rights by contacting us at the email address below. We may need to verify your identity before completing a request.
You have the right, where applicable, to lodge a complaint with a competent data-protection supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or the place of an alleged infringement.
We use reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage can be guaranteed to be completely secure.
Our Online Products are not intended for children where use is prohibited by applicable law. We do not knowingly collect Personal Data from children in violation of applicable law. If you believe that a child has provided Personal Data to us, please contact us so that we can take appropriate action.
We do not use automated processing of your Personal Data to make decisions producing legal effects or similarly significant effects concerning you, except where explicitly disclosed and permitted by applicable law.
This Privacy Policy may be amended from time to time. Changes will be made available through updates to this page. The "Last updated" and "Effective date" above will be updated when appropriate. Where required by law, we will provide additional notice or obtain consent.
If you have any concerns, queries, or questions regarding this Privacy Policy or our processing of Personal Data, please contact:
WNDR11 LTD
Akropoleos, 59 - 61, 3rd floor, Office 301
2012, Nicosia, Cyprus
Company registration number: HE411801
Email: support@wndr11.cy