Privacy Policy

Last Updated: October 26, 2024

Important: This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use Our Service. By using the Service, You acknowledge and agree to the processing of Your personal information as set out in this Privacy Policy. Please also read our Terms of Service.

Contact Us / Data Controller

For the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws, the Data Controller is:

WAVE DESIGN STUDIO S.R.L.
VIRTUTII NR. 19D ET. 4, SECTORUL 6
Bucharest, Romania

If you have any questions regarding this Privacy Policy, how we process your personal information, or wish to exercise your privacy rights, please contact us:

If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), WAVE DESIGN STUDIO S.R.L. acts as the Data Controller.

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

2. What Personal Information Do We Collect?

We collect information about You in various ways when You use our Services. This includes:

A. Information You Provide to Us

We receive and store information You directly provide to Us. This happens when You:

The types of Personal Data You might provide include:

B. User Generated Content

When You upload wallpapers or other content to our Service, this content may contain personal information if You include it. Uploaded content may be visible to other users depending on the Service's features. Please be mindful of the information You share publicly. Refer to our Terms of Service regarding ownership and licensing of User Generated Content.

C. Information We Collect Automatically

When You access or use Our Services, we automatically collect certain information about Your Device and Your usage:

We use Cookies and similar Tracking Technologies (like SDKs in our Apps) to collect some of this information. See Section 6 below.

D. Information We Collect from Other Sources

3. How Do We Use Your Personal Data?

We use Your Personal Data for various purposes, based on different legal grounds (as required by GDPR and other laws):

4. How We Share Your Personal Information

We do not sell Your Personal Data for monetary consideration in the traditional sense. However, we may share Your information with third parties in the following circumstances, which might be considered a "sale" or "sharing" under certain laws like the CCPA/CPRA when related to cross-context behavioral advertising:

5. International Data Transfers

Your information, including Personal Data, is processed at the Company's operating offices in Romania and potentially in other locations where our Service Providers or Affiliates operate. This means Your information may be transferred to and maintained on computers located outside of Your state, province, country, or other governmental jurisdiction where data protection laws may differ (e.g., transfers from the EEA/UK to the United States).

We take steps to ensure that Your data is treated securely and in accordance with this Privacy Policy. When transferring Personal Data outside the EEA, UK, or other jurisdictions requiring specific safeguards, we rely on appropriate mechanisms such as:

By using the Service and submitting Your information, You consent to these transfers, provided appropriate safeguards are in place.

6. Cookies, SDKs, and Tracking Technologies

We use Cookies (on our Website) and Software Development Kits (SDKs) and similar tracking technologies (within our Applications) to track activity, store certain information, and improve and analyze Our Service. These technologies include pixels, beacons, tags, and scripts.

Types of Technologies Used:

Your Choices Regarding Cookies and Tracking:

For more detailed information, please refer to any specific Cookie Policy we may publish on our Website.

7. Advertising and Your Choices

Our Applications are typically supported by advertising. We partner with third-party ad networks (listed in Section 4) to display ads.

These ads may be contextual (based on the app content) or personalized/interest-based (based on Your inferred interests from Your activity across apps and websites over time, using Your device's advertising identifier).

Personalized Advertising Choices:

Opting out does not mean You won't see ads, but they may be less relevant to You.

8. Uploaded Images, Videos and Facial Data (AI Features)

Some of our apps allow you to upload Your own images or videos to use as wallpapers or as source material for AI-generated content (like avatars or images).

9. Payments

We may offer paid products (e.g., subscriptions for ad-free versions or premium features) within the Service. We use third-party payment processors to handle transactions.

10. Data Retention

We retain Your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.

When data is no longer needed, we will securely delete or anonymize it.

11. Data Security

The security of Your Personal Data is very important to Us. We implement reasonable technical, administrative, and physical security measures designed to protect Your information from unauthorized access, use, alteration, or disclosure. This includes using encryption protocols and software where appropriate.

However, no method of transmission over the Internet or electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

12. Children's Privacy

Our Services are not directed to children under the age of 16. We do not knowingly collect Personal Data from children under 16. If You are under 16, please do not use the Service or provide any Personal Data to Us.

ANY PERSON WHO USES OUR SERVICE REPRESENTS TO US THAT THEY ARE 16 YEARS OF AGE OR OLDER.

If We become aware that We have collected Personal Data from a child under 16 without verification of parental consent, We take steps to remove that information from Our servers. If You believe We might have any information from or about a child under 16, please contact Us immediately at [email protected] 

13. Your Privacy Rights

Depending on Your location, You may have certain rights regarding Your Personal Data. These may include the right to access, correct, delete, restrict processing, data portability, object to processing, and withdraw consent. Specific rights for residents of the EEA/UK, California, Virginia, Nevada, and South Korea are detailed below.

To exercise Your rights, please contact Us using the details in the "Contact Us" section. We may need to verify Your identity before processing Your request. We will respond within the timeframes required by applicable law.

A. EEA and UK Residents (GDPR / UK GDPR)

If You are in the European Economic Area (EEA) or the United Kingdom (UK), You have the following rights:

To exercise these rights, please contact Us. Contact details for the Romanian DPA (ANSPDCP) are:

B. California Residents (CCPA / CPRA)

If You are a California resident, You have the following rights under the CCPA/CPRA:

Exercising Your CCPA/CPRA Rights: To exercise rights other than Opt-Out, contact Us via email at [email protected] or through our in-app contact form. We will need to verify Your identity. You may designate an authorized agent to make requests on Your behalf, subject to verification requirements.

"Do Not Track" Signals: Our Service does not currently respond to "Do Not Track" (DNT) signals from web browsers. However, You can manage tracking via cookie settings and ad personalization opt-outs as described elsewhere.

California "Shine the Light" Law: California residents can request information once a year about sharing their Personal Data with third parties for those third parties' direct marketing purposes. We currently do not share personal data with third parties for their *own* direct marketing purposes in this manner. If You have questions, contact Us.

Minors Under 18: California residents under 18 who are registered users may request removal of content they publicly posted. Contact Us with specific details. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

C. Virginia Residents (VCDPA)

If you are a Virginia resident, you have the following rights under the VCDPA:

Exercising Your VCDPA Rights: To exercise these rights, please contact Us via email at [email protected] or through our in-app contact form. To opt-out of targeted advertising or sales (if applicable), use the methods described under CCPA (in-app settings or email). We will respond within 30 days (extendable once by 30 days). If we deny your request, you have the right to appeal by contacting us within a reasonable period, stating "Virginia Rights Appeal" in the subject line.

D. Nevada Residents

Nevada residents have the right to opt-out of the "sale" of certain "covered information" for monetary consideration to a person for that person to license or sell such information to additional persons. "Covered information" includes name, address, email, phone number, SSN, or an identifier allowing a specific person to be contacted. We do not currently engage in such sales.

However, if you are a Nevada resident, you may submit a request to opt-out of any potential future sales under Nevada law by contacting us at [email protected] with the subject line "Nevada Do Not Sell Request" and providing your name and email address. For App users you can use the Stop Tracking me functionality in the App's settings

E. South Korea Residents (PIPA)

If You are a resident of South Korea, specific provisions under the Personal Information Protection Act (PIPA) apply:

Appendix - Key Third Parties (South Korea PIPA Compliance): We entrust the processing of personal information or provide it to the following third parties as necessary for our Service:

Third Party / Service Provider Purpose of Processing / Service Provided Personal Information Provided/Entrusted Retention and Usage Period
KUSTOMIX MOB SRL (Affiliate) Operational support, development, analysis Identifiers, Account Info, Usage Data, Device Info (as needed for support) Duration of service provision / As per main retention policy
Google (Firebase, Google Analytics) Service analytics, performance monitoring, crash reporting Device Info, Usage Data, Advertising IDs, IP Address Duration of service provision / As per Google's policies & our retention needs
Singular Labs, Inc. Mobile attribution and marketing analytics Device Info, Usage Data, Advertising IDs, IP Address Duration of service provision / As per Singular's policies & our retention needs
Google (AdMob, Ad Manager) Advertising serving and measurement Device Info, Usage Data, Advertising IDs, IP Address, Rough Geolocation Until user opts-out or withdraws consent / As per Google's policies
Meta (Facebook Audience Network) Advertising serving and measurement Device Info, Usage Data, Advertising IDs, IP Address, Rough Geolocation Until user opts-out or withdraws consent / As per Meta's policies
Pangle (Bytedance Pte. Ltd.) Advertising serving and measurement Device Info, Usage Data, Advertising IDs, IP Address, Rough Geolocation Until user opts-out or withdraws consent / As per Pangle's policies
Mintegral International Limited Advertising serving and measurement Device Info, Usage Data, Advertising IDs, IP Address, Rough Geolocation Until user opts-out or withdraws consent / As per Mintegral's policies
Liftoff Monetize, Inc. (formerly Vungle) Advertising serving and measurement Device Info, Usage Data, Advertising IDs, IP Address, Rough Geolocation Until user opts-out or withdraws consent / As per Liftoff's policies
Smaato, Inc. Advertising serving and measurement Device Info, Usage Data, Advertising IDs, IP Address, Rough Geolocation Until user opts-out or withdraws consent / As per Smaato's policies
Adapty Inc. Subscription and IAP management/analytics User ID, Device Info, Purchase/Subscription Tokens (from Stores), Usage Data related to purchases Duration of service provision / As per Adapty's policies & our retention needs
Apple App Store Payments Payment processing for iOS IAPs Transaction details (handled by Apple) As per Apple's policies
Google Play Billing Payment processing for Android IAPs Transaction details (handled by Google) As per Google's policies

Note: Retention periods are generally tied to the duration needed for the service or until consent is withdrawn/opt-out exercised, subject to legal retention requirements. Please refer to the respective third-party privacy policies for their detailed data handling practices.

14. Links to Other Websites

Our Service may contain links to other websites or services that are not operated by Us. If You click on 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.

15. 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 and within our Applications.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective, and update the "Last updated" date at the top of this Privacy Policy.

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.

16. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us: