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Privacy Policy

Last updated: 21 November 2023
At Reblum, your privacy is important to us. We treat your personal data responsibly and make great efforts to provide lawful and transparent processing of your personal data.

Who we are

When we refer to Reblum, we mean Reblum LTD, a legal entity registered under the laws of the United Kingdom, company number 15146084, having its principal place of business at 61 Bridge street, Kington, Herefordshire, United Kingdom, HR5 3DJ (“we”, “Company”).

Except as otherwise stated herein, Company is a data controller of personal data processed in accordance with this Privacy Policy. This means that we decide what data should be processed, how and why. In limited cases described below, we may act as a data processor, acting under your instructions as the data controller.

We developed this Privacy Policy to inform you (“you” or “User”) how your personal data may be processed when you provide it through your use of our website https://reblum.app/ (“Website”) or social media pages, and through your downloading, accessing, and/or use of our software product presented on our Website (“Software”).

This Privacy Policy is the integral part of our End User License Agreement (“EULA”). Please make sure you read it carefully. Unless defined otherwise by this Privacy Policy, all terms and definitions used herein shall have the meaning defined in the EULA. If you do not agree with the data practices described in this Privacy Policy, you should not use the Website or Software.

The Privacy Policy contains information about the purposes for which we use and how we may process your personal data, with whom we may share it, where your personal data is stored, and the measures we take to protect its security. There is also a description of your rights with respect to your personal data, and how you can contact us about our privacy practices.

If you have any questions about the Privacy Policy, the processing of your personal data by Reblum, or the exercise of your rights as a personal data subject, send us a request through the contact details below in this Privacy Policy.

Age of our Users

Please note, our Reblum Services are not directed at Users under the age of legal majority (children). We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will take steps to delete such information.

Detailed description of how we process your data

In the tables below you will find a detailed information about:

  • what is our role in data processing;
  • what personal data we process;
  • what are the purposes of such processing;
  • what are legal basis for such processing (where we act as the controller);
  • what is the retention period of your data.

The data we process is personal information about you provided to us when you use our Website and Software and when other sources provide it to us, as further described below. 

When you visit the Website, we may automatically collect some data related to you. Please refer to our Cookies Policy, which explains how we use cookies and similar technologies, what data we collect with the use of them, and for what purpose we use your personal data. The Cookies Policy forms an indispensable part of our Privacy Policy, as long as we process your personal data with the help of cookies and similar technologies.

Except for the purposes indicated below, we may also process data to perform legal duties, responsibilities, and obligations and to comply with laws and regulations that apply to us. For example, we could store data about emails and names of subscribers to our newsletters, as well as their choices and consent - to make sure we comply with laws on e-communication. 

The information below is classified by the purpose of data processing:

Execution and performance of the agreement

Role of Reblum: controller
Which Service it relates to: Software
Processing we perform Data we process Legal basis for the processing
  • To run the Software and implement the Software’s functionality
  • To process images User upload to the Software
The data is both processed and stored:
  • device information such as:
    • IP address;
    • Device type;
    • Type and version of operating system used;
    • RAM;
    • GPU;
    • SWAP memory size;
    • Display resolution (actual and virtual);
    • Device CPU;
    • GPU memory size;
    • hash of the computer identifier.
  • Image processing data:
    • size and format of the image;
    • time of Software activity;
    • loading time for processing;
    • timings for opening and saving the image.
 Entering into and performance of a contract (Article 6.1(b) UK GDPR).

Data retention period:
We will retain your data during the term of EULA and for up to 12 months afterwards.

 

Registration of your account

Role of Reblum: controller
Which Service it relates to: Website
Processing we perform Data we process Legal basis for the processing
  • To create, authorize in and maintain information in the User’s account
The data is both processed and stored:
  • Email address;
  • When authorizing via email address, we send a one-time password to this email;
  • If you register or sign in to your account through a third-party service (such as Facebook, using a Google Account, or Apple), we will have access to some of your account information from that service, including identifiers such as your name and other internal service identifiers or information in this account.
  • Subscription Plan information (type, Subscription term, status);
  • Device type; 
  • Hash of the linked device identifier;
  • Time of Software activity;
  • Device CPU.
 Entering into and performance of a contract (Article 6.1(b) UK GDPR).

Data retention period:
We will store the data during the term of EULA and for up to 12 months afterwards.

 

Identification of your devices used to install Software under EULA,  User verification and fraud prevention

Role of Reblum: controller
Which Service it relates to: Software
Processing we perform Data we process Legal basis for the processing
  • To link the User’s device, on which the Software is downloaded and accessed, with User’s account
  • To verify User 
  • To analyze User’s data to prevent the fraud and for statistical purposes
The data is both processed and stored:
  • Email address.
  • Country of residence
  • Device information such as: 
    • IP address;
    • Device type;
    • Type and version of operating system used;
    • RAM;
    • GPU;
    • SWAP memory size;
    • Display resolution (actual and virtual); 
    • Device CPU; 
    • GPU memory size;
    • hash of the device operating system identifier.
  • User’s payment system token
Entering into and performance of a contract(Article 6.1(b) UK GDPR);
Legitimate interest (Article 6.1(f) UK GDPR).

Data retention period:
We will retain these data during the term of EULA and for up to 12 months afterwards. 

 

Software maintenance

Role of Reblum: controller
Which Service it relates to: Software
Processing we perform Data we process Legal basis for the processing
  • Proactively monitor Software health and fix issues (troubleshooting).
  • Analyze the Software to optimize User experience.
  • Test and develop new features and functions.
The data is both processed and stored:
  • IP address;
  • Device type;
  • Type and version of operating system used;
  • RAM;
  • GPU;
  • SWAP memory size;
  • Display resolution (actual and virtual);  
  • Device CPU; 
  • GPU memory size;
  • hash of the device operating system identifier.
 Legitimate interest (Article 6.1(f) UK GDPR).

Data retention period:
Data may be processed and stored until the issue is resolved.

 

Communication with User within informational and technical support, as well as improvement of the Reblum Service

Role of Reblum: controller
Which Service it relates to: Software and Website
Processing we perform Data we process Legal basis for the processing
  • Answer Users’ support requests regarding bugs, Software and Website usage, feature requests etc.
  • Analyze your feedback on the functioning of the Software and use them for the future improvement of the Software.
The data is both processed and stored:
  • Email address;
  • User name;
    • Content of your requests, feedback, or other messages, as well as attached User content where it is applicable.
Performance of a contract(Article 6.1(b) UK GDPR);
Legitimate interest (Article 6.1(f) UK GDPR).

Data retention period:
We will store the data from when the support request or feedback was received, until we resolve the matter. We intend to store your personal data for up to 12 months afterwards, to make sure the future requests regarding product usage are properly satisfied, taking into account the history of the requests and feedbacks.

 

To administer our relationship with the User

Role of Reblum: controller
Which Service it relates to: Software and Website
Processing we perform Data we process Legal basis for the processing
Administer our relationship with the User, i.e. send information about our terms, billing information, notifications about payments and other information that the User needs The data is both processed and stored:
  • Email address;
  • Subscription Plan information.
  • Billing contact data (email address, full name).
  • Please pay attention that we do not collect your payment credentials (bank credentials, cards numbers and dates of issuance etc.). Such information may be collected exclusively by third-party payment providers with the respective licenses and security measures with regard to your payment credentials, as it is prescribed in our EULA. We receive only transaction ID and date of transaction from the third-party providers, just to make sure that the transaction is successful or rejected and such transaction relates to you.
 Entering into and performance of a contract (Article 6.1(b) UK GDPR).

Data retention period:
We will store the data during the term of EULA and during the period specified by applicable law.

 

To process the User Content

Role of Reblum: processor
Which Service it relates to: Software
Processing we perform Data we process Legal basis for the processing
Get access to the image you upload to the Software for editing.
    The data processed on the User’s device (and not stored on our servers):
  • User Content such as images, which could include natural persons.
    • The data processed and stored:
  • IP address;
  • image size and format;
  • loading time for editing images;
  • time of opening and saving the image.
 Not applicable (data is provided to perform obligations before the User under the EULA)

Data retention period:
We will store the data from the moment you upload the image to the Software and until you stop editing it by closing the Software or by uploading the new image for editing.
We will store the data from the moment you upload the image to the Software and during the term of EULA.

 

To improve the AI algorithms used as a basis for the Software 

Role of Reblum: processor
Which Service it relates to: Software
Processing we perform Data we process Legal basis for the processing
  • Analyze sent User’s content, and use it for the future improvement of the AI algorithms used as a basis for the Software.
 The data is both processed and stored:
  • User Content sent via bug report form in the Software.
 Consent (Article 6.1(a) UK GDPR).

Data retention period:
Since we use this data to improve the operation (training) of the AI algorithms, we will store this data in a database that is necessary for the proper operation of the Software for the entire period of existence and operation of the Software.
However, we guarantee that we will remove your content from our team's devices after analyzing it which is necessary in order to improve the performance of our Software.

 

To send our marketing information to the User

Role of Reblum: controller
Processing we perform Data we process Legal basis for the processing
Send to Users information about our services, new features and functions, newsletters, promotions etc.

Administer the Users’ responses and survey answers. 

Generate analytical and statistical data based on the Customer responses. 		The data is both processed and stored:

Any data you choose to provide us. It may include:
  • Email.
  • Your responses and surveys answers.
 Consent (Article 6.1(a) UK GDPR) Legitimate interest (Article 6.1(f) UK GDPR)

Data retention period:
We may store your personal data mentioned above from the moment you provide consent to processing and until you withdraw your consent.
We may store your personal data during the term of EULA and for up to 12 months after the termination of EULA.

*
More details about the Facebook pixel, the Conversions API and its functionality can also be found in the Facebook help area.

Your rights when we process your personal data

To exercise your rights listed below, you can send a request to the Company to support@reblum.app. In order to properly protect your data, the Company may take additional measures to identify you when processing your request. We will provide you with a response to your request no later than 1 month from the date of its receipt, except as provided by law. If there is a valid reason this term can be extended for another 2 months, and we will inform you about such extension and the reasons in advance.

UK GDPR and other countries’ privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the United Kingdom’s Information Commissioner’s Office (“ICO”).

In short, you have the following rights with respect to your personal data when we are the controller of such data:

  1. Right of access. You may ask to access and obtain a copy, if required, of the data about you that we collected. However, where an exemption applies, we may refuse to provide all or some of the requested information about you.
  2. Right to rectification. You may ask to correct or complete your personal information if you find it inaccurate or incomplete.
  3. Right to erasure. You may ask to delete the data we retain, when your personal data is no longer needed for our processing or if you want to withdraw your consent you previously provided to us. 
  4. Right to restriction of the processing. You may request to restrict the use of your data in cases determined by law, such as when you have objected to our use. But we will first verify whether we have overriding legitimate grounds to use it.
  5. Right to data portability. You may ask to transfer your data to a third party in a structured, commonly used, and machine-readable format, in circumstances where the data is processed with your consent or by automated means.
  6. Right to object. You may object to our processing of your data in some cases, for example, when we process your data on the basis of our legitimate interest.
  7. Right to unsubscribe from our marketing communications. You may unsubscribe from receiving our marketing information by clicking on the “unsubscribe” button located in our e-mails, or by sending us email at support@reblum.app. Please note, that you cannot opt-out of receiving e-mails on administrative matter related to managing your account or using the Reblum Services.
  8. Right to file a complaint about the processing. You can complain to the ICO if you are unhappy with how we have processed your personal data. Please do not hesitate to contact us by any means indicated below before you file a complaint with ICO.

Information Commissioner’s Office contacts:

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Helpline number: 0303 123 1113
Website: https://ico.org.uk/global/contact-us/ 

Please note that the rights described above do not extend to the processing of your non-personal data.

How we share your data

To ensure proper functioning of the Reblum Service, we may share your personal data with service providers that help us operate, provide, support and enhance our Reblum Services. For example, we may share your personal data with payment service providers, analytics services, marketing communications services, services for registration and logging in the User account etc. 

If a service provider needs to access your data, they do so under appropriate security and confidentiality measures designed to protect your data. Our subcontractors and any other third parties will provide the same or equal protection of your personal data as stated in this Privacy Policy. 

We are not in the business of selling any of your data, including personal data, to other third parties or advertisers. 

In exceptional circumstances, we may disclose data with law enforcement agencies, courts, fraud prevention agencies, or other third parties, where we think it is necessary to comply with applicable laws or regulations or to defend our legal rights (where possible, we will notify you of this type of disclosure).

For a detailed list of providers and services (processors) we use, don't hesitate to get in touch with us using the contacts listed in the last section of this Privacy Policy.

How we secure your data 

  1. Confidentiality. All personnel are subject to full confidentiality; and any subcontractors and subprocessors are required to sign a confidentiality agreement if full confidentiality is not a part of the main agreement between the parties. Also, any access by authorised personnel is logged. We use verified contractors that might have access to the data as specified in this Privacy Policy and with whom relevant data processing agreements are concluded.
  2. Isolation. Access to personal data is restricted to individually authorised personnel. Authorised personnel are granted minimum access on a need-to-have basis.
  3. Account protection. The Company provides Users with a secure and encrypted connection when transferring personal data and logging in to the account on the Website, for example, by using HTTPS.

We take appropriate security measures to protect your personal data from accidental loss or destruction, from unlawful processing or access to it. We maintain administrative and technical safeguards for an appropriate level of security in respect of all personal data we process. These safeguards include, without limitation, the following:

Disclaimer. While taking the necessary steps to secure your data, we have no choice but to admit that no method of transmission over the Internet or method of electronic storage is 100% secure. If it happens that any of your personal data is under the breach and if there is a high risk of violating your rights as a data subject, we would inform you and the respective data protection authorities as to the accidents without undue delay. We will also do our best to minimise any such risks.

Changes to this Privacy Policy 

We may amend or update these Privacy Policies from time to time. If we decide to do so, and the amendments will substantially affect your rights and legitimate interests, we will notify you of any changes via email and/or a notice within our Services. We will also indicate the “Last updated” date at the top of this document.

Contact Information

If you have any questions about the Privacy Policy or your data we process, do not hesitate to contact us:

Reblum LTD,

61 Bridge street, Kington, Herefordshire, 
United Kingdom, HR5 3DJ
Email: support@reblum.app