You can see our previous Privacy Policy here
Effective date: February 16, 2021
Welcome to Prisma Labs, Inc. (“Company,” “we,” “us” or “our”), a mobile technology company specializing in deep learning-related products. Our goal is to move forward mobile photography and video creation to the next level using neural networks, deep learning and computer vision technics. We aim to create new ways for people to express their emotions through the camera.
This Privacy Policy (this “Privacy Policy”) describes:
This Privacy Policy applies only to information we collect on Prisma Web Services and via email, text, and other electronic communications sent through or in connection with Prisma Web Services.
This Privacy Policy is incorporated by reference into our Prisma Web Terms of Service. So, please make sure that you have read and understand our Prisma Web Terms of Service.
We undertake to build Prisma Web Services and any of their features in such a way that they respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy not only allows you to understand what we do with your Personal Data (as defined below), but also to manage your Personal Data effectively.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By registering with, accessing or using (“Using”, as applicable) Prisma Web Services, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, do not Use Prisma Web Services.
By Using Prisma Web Services you understand and agree that we are providing a platform for you to stylize photos. If you have any questions about this Privacy Policy or Prisma Web Services, please contact us (for contact information, please, see How to Contact Us Section).
This Privacy Policy DOES NOT apply to the information that:
We may collect several types of information, including but not limited to Personal Data, from and about you:
To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”. Please bear in mind that provisions of Section 6 do not apply to your pseudonymized Personal Data.
When you Use Prisma Web Services, we may ask you to provide certain information, including your Personal Data:
You may provide photos (with or without applied Prisma Web stylized filters or effects) for publication or display on third-party websites and other online services, you access through Prisma Web Services (“Post”). You confirm that you have all required rights, approvals and consents from any third parties, if applicable, to use their photos or photos on which other individuals are shown in Prisma Web Services and to Post such photos on third-party websites and other online services. This may be applicable if you: (i) Post, or use photos (via Prisma Web Services), that are not your’s; or (ii) Post, or use photos (via Prisma Web Services) that show other individuals, that require such persons’ and/or individuals’ consent (for more information on the Prisma Web Terms of Service, please visit the following link).
Your photos are Posted and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties, with whom you may choose to share your photos. Therefore, we cannot and do not guarantee that your photos will not be viewed by unauthorized persons.
When you Use Prisma Web Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically under this Privacy Policy may include your Personal Data and information we may maintain or associate with your Personal Data, that we collect in other ways or receive from third parties. It helps us to improve and deliver a better and more personalized Prisma Web Services, including by enabling us to:
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Prisma Web Services are not currently set up to respond to those signals.
If the information covered by this Section 3 is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.
The technologies we use for automatic data collection may include:
Third-party analytics. We use third-party analytics tools, such as Google Analytics, Google Firebase Analytics, Facebook Analytics, AppsFlyer, Amplitude, to help us measure traffic and usage trends for Prisma Web Services. These tools collect information sent by your computer or Prisma Web Services, including the web pages you visit and other information that assists us in improving Prisma Web Services. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Prisma Web Services, please visit the following link.
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We may use both session cookies and persistent cookies to identify that you have logged in to Prisma Web Services and to tell us how and when you interact with Prisma Web Services. We may also use cookies to monitor aggregate Usage and web traffic routing on Prisma Web Services and to customize and improve Prisma Web Services. Unlike persistent cookies, session cookies are deleted when you log off from Prisma Web Services and close your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you disable or refuse cookies, please note that some parts of Prisma Web Services may then be inaccessible or not function properly. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to Prisma Web Services. Some Service Providers that we engage may also place their own cookies on your computer. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such Service Providers.
Log file information. Log file information is automatically reported by your browser each time you make a request to access (i.e. visit) a web page. It can also be provided when the content of the web page is downloaded to your browser or device. When you use Prisma Web Services, our servers automatically record certain log file information, including your web request, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on Prisma Web Services, domain names, landing pages, pages viewed, and other such information. The information allows us to receive more accurate reporting and improve Prisma Web Services.
Device identifiers. When you use your device to access Prisma Web Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your device. A device identifier may be data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may deliver information to us or to a Service Provider about how you browse and Use Prisma Web Services and may help us or others provide reports. Some features of Prisma Web Services may not function properly if use or availability of device identifiers is impaired or disabled. Among others we collect the following device identifiers:
Metadata. Metadata is a technical data that is associated with your photos. For example, metadata can describe how, when and by whom some of your photos was collected and how that content is formatted. You can add or may have metadata added to your photos.
Registered Users information. When you register an account with us in order to Use Prisma Web Services (“Account”), we collect the following Personal Data about you:
Your photos. We do not use photos you provide when you Use Prisma Web Services for any reason other than to apply different stylized filters or effects to them, unless you have given us your explicit consent to use the photos for a different purpose.
Other information. We may use your information other than photos for the following purposes:
We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 4 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).
For any new purpose of processing we will ask for your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 4 (“data minimization principle”).
We may sell you Subscription through Prisma Web Services. When you make a purchase through Prisma Web Services, we use a third-party payment processor to process your payments. In connection with the processing of such payments, you provide your payment and transaction information and other Personal Data (for example, it may include your name, payment amount, date of purchase, credit card number, expiration date of your credit card, CVC code, telephone number, email address and postal address for billing and some other payment and transaction information and Personal Data) directly to our third-party processor Stripe (“Payment Processor”), whose use of such information is governed by Stripe Privacy Policy.
Access, modification, correction and erasure. You can send us an email at [email protected] to request access to, modification, correction, update, erasure or deletion of any Personal Data that you have provided to us and that we have about you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
EEA/UK residents. Individuals residing in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain statutory rights in relation to their Personal Data under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR”) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (SI 2020/1586), as may be amended from time to time (“UK GDPR”) (collectively, the “GDPR”), including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).
Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage you in a dialogue to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Following the provisions of the GDPR, we might also ask you to prove your identity (for example, by requesting an ID or other proof) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties are violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.
Please note that we will grant your request within 30 days after receiving it, but it may take up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems - this is due to the size and complexity of the systems we use to store data.
Opting Out of Promotional Emails
You may opt-out of receiving promotional emails from us at any time through any of the following methods:
Bases for Using Your Personal Data. If you reside in the EEA or the UK we are only allowed to use your Personal Data when certain conditions apply. These conditions are called “legal bases” and we typically rely on one of four:
Your California Privacy Rights. If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Data. To learn more about your California privacy rights, visit (i) the following link and (ii) our CCPA Privacy Notice for California Residents.
We may disclose aggregated information about our Users and information that does not identify any individual without any restriction. We may remove parts of data that can identify you and share anonymized data with any persons.
We do not rent or sell your Personal Data, including photos, to any third parties outside the Company or its Affiliates.
Parties with whom we may share your Personal Data. We do not share or transfer your photos to third parties, unless you have given us your explicit consent (with the exception of uploading the photos to our cloud providers Google Cloud Platform and Amazon Web Services and storing and deleting such photos as described in this Privacy Policy).
We use only secure places of storage, such as Google Cloud Platform and Amazon Web Services. Google LLC and Amazon Web Services, Inc. are located in the United States of America. To learn about data protection practices of Google LLC please visit the following link. To learn about data protection practices of Amazon Web Services, Inc. please visit the following link. We may share your Personal Data as well as other collected information (including but not limited to, your photos, information from cookies, log files, device identifiers and Usage data) with businesses that are legally part of the same group of companies that we are part of, including our subsidiaries, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve Prisma (including by providing analytics). Such Affiliates are bound by the rules of this Privacy Policy.
We also may share your Personal Data and other collected information (including your photos) with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only for the purposes for which we disclose it to them (and as directed and authorised by us) (“Service Providers”).
Such Service Providers include (i) cloud providers Google Cloud Platform and Amazon Web Services, that we use to apply photo editing features of Prisma Web to your photos and to store and delete such photos, as described in this Privacy Policy, (ii) third parties that may use your photos collected by us in the ways described in this Privacy Policy and where legally required with your explicit consent, (iii) third-party analytics, as specified in this Privacy Policy, (iv) email delivery services and (v) professional advisors, such as lawyers, auditors and insurers, in the course of the professional services that they render to us.
What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.
Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Prisma Web Services or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information at your own risk. We are not responsible for circumvention of security measures contained in Prisma Web Services. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:
The safety and security of your information also depends on you. You are responsible for maintaining the secrecy of your Account information and for controlling access to emails between you and us at all times. Your privacy settings may also be affected by changes the social media services, though which you may share your photos, make to their services. We are not responsible for the functionality, privacy or security measures of any other organization.
Contacting you. By Using Prisma Web Services you consent to receive electronic communications from us (e.g., via email, by posting notices on Prisma Web, the Site and in your Account). These communications may include notices about Prisma Web Services, Subscription, your Account (e.g., Account verification, changes/updates to features of Prisma Web Services and their scope, prices of Subscription, technical and security notices, updates to this Privacy Policy and Prisma Web Terms of Service) and promotional and marketing materials. IF YOU WISH TO OPT OUT OF OUR PROMOTIONAL EMAILS, YOU CAN UNSUBSCRIBE FROM OUR PROMOTIONAL EMAIL LIST BY USING ANY METHOD IN THE OPTING OUT OF PROMOTIONAL EMAILS SECTION.
We will retain your Personal Data as long as your Account is active or needed to provide you Prisma Web Services, and only for as long as it serves purposes of processing identified in Section 4. At any time, you can instruct us to delete your Personal Data by contacting us (for contact information, please, see How to Contact Us Section).
We reserve the right to use your certain Personal Data and other collected information in any aggregated and anonymized form after you have deleted your User Account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
Your photos with applied styles through Prisma Web Services are automatically uploaded to our servers and are stored there in duplicate to the photos stored on your computer. If you remove data from your User Account, you will no longer see it in Prisma Web Services, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical reasons.
The Company is based in the United States. Accordingly, your Personal Data may be transferred to and stored on servers in the United States. Your Personal Data also may be transferred in any country where Google Cloud Platform and Amazon Web Services have/use servers. As the Company has a development and marketing team based in Russia, your Personal Data also may be transferred to and stored on servers in Russia.
The data protection and privacy laws of the United States, Russia and other counties may not be as comprehensive or offer the same protections as the laws in your country. For example, personal data transferred to the United States and Russia may be subject to lawful access requests by legal authorities. You nevertheless consent to the transfer of your Personal Data to the United States, Russia and other countries where the Company is located, or is providing products or services, or from where its Affiliates and Service Providers provide their products and services to the Company and its Affiliates.
In appropriate cases, the Company will enter into standard contractual clauses as approved under the European Commission Decision C(2010)593 or decision 2004/915/EC, as applicable, to permit the transfer of your Personal Data to the United States, Russia or another country that has not been deemed to provide adequate level of data protection.
General age limitation. Prisma Web Services are not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to Use Prisma Web Services. If you are under 13, do not (i) Use or provide any information on Prisma Web Services or through any of their features, or (ii) provide any information about yourself to us, including your name, address, telephone number or email address. In the event that we learn that we have collected or received any Personal Data from a child under 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us (for contact information, please, see How to Contact Us Section).
Age limitation for EEA residents. Due to requirements of the EEA GDPR you shall be at least 16 years old in order to Use Prisma Web Services. To the extent prohibited by applicable law, we do not allow Use of Prisma Web Services by the EEA residents younger than 16 years old. If you are aware of anyone younger than 16 Using Prisma Web Services, please contact us (for contact information, please, see How to Contact Us Section) and we will take required steps to delete information provided by such persons.
We are not responsible for the practices employed by any websites or services linked to or from Prisma Web Services, including the information or content contained within them. Where we have a link to a website or service, linked to or from Prisma Web Services, we encourage you to read the privacy policy stated on that website or service before providing information on or through it.
General contact details. If you have any questions about this Privacy Policy or Prisma Web Services, please contact us via email at [email protected] or our mailing address:
Prisma Labs, Inc.
Suite D2028
440 N Wolfe Rd
Sunnyvale, CA 94085
Appointed EEA/UK representative. If you are a resident of the EEA or the UK and you have any questions about this Privacy Policy or Prisma Web Services, please contact us via email on [email protected] or our EEA/UK representative mailing address:
DPOEU LTD
Office 902
Oval Krinou 3
Ayios Athanasios
4103 Limassol, Cyprus
Email: [email protected]
Data protection officer. If you are a resident of the EEA, the UK or Switzerland and you wish to exercise your rights under Section 6, or you have any questions about this Privacy Policy or Prisma Web Services, you can contact our data protection officer via email at [email protected].
The Company may modify or update this Privacy Policy from time to time, so please review it periodically. The date this Privacy Policy was last revised, is identified at the top of the page. Your continued Use of Prisma Web Services after we make changes to this Privacy Policy is deemed to be acceptance by you of those changes, so please check the policy periodically for updates. In some cases, we may require you to expressly accept our new privacy policy in order to continue Using Prisma Web Services (for example, if we expand types of Personal Data collected from you or introduce new purposes of collection and processing of your Personal Data).