This Privacy Notice for Felix Parey ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@felixparey.com.
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. This includes diagnostic and usage data (like crash reports and session duration) if you choose to share this through your device's operating system settings. For Drawing Competition users, we also process drawings you create in the app if you have not opted out of image uploading. Learn more about information we collect.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we collect any information from third parties? We do not collect information from third-party sources, other than diagnostic data which may be provided via the mobile platform operator (e.g., Apple) if you have opted-in to sharing.
How do we process your information? We process your information to provide, improve, and administer our Services (including troubleshooting and analyzing usage patterns from diagnostic data), communicate with you, for security and fraud prevention, and to comply with law. For Drawing Competition, unless you opt out, we also process your drawings to train machine learning models and may use them for commercial purposes including selling or licensing to third parties. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties (e.g., service providers involved in business transfers, if any). We do not sell or share your personal information with third parties for their marketing purposes. However, for Drawing Competition, unless you opt out, we may sell or license your drawings to third parties for commercial purposes. Learn more about when and with whom we share your personal information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. You can manage sharing of diagnostic data via your device's operating system settings. For Drawing Competition, you can opt out of image uploading and commercial use through the in-app settings.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
In Short: We collect personal information that you voluntarily provide to us, but we do not require identifiable information like name or email to use our core Services.
We collect personal information that you voluntarily provide to us *if* you contact us directly (e.g., via email) or express an interest in obtaining information about us or our products and Services. We do not require registration or collection of direct identifiers like name or email address to use our mobile application.
In Short: Diagnostic and usage data is collected automatically *if* you opt-in via your device settings. This data helps us improve our app.
We automatically collect certain information when you use the Services. This information does not reveal your specific identity (like your name or contact information unless you provide it separately, e.g., via email) but includes device, diagnostic, and usage information.
Specifically, if you choose to enable sharing of diagnostic and usage data through your mobile device's operating system settings (e.g., Apple's "Share iPhone & Watch Analytics" or similar options), we may receive information related to your use of our application(s). This data collection is facilitated by the platform provider (e.g., Apple) based on your consent given through the device settings. The information we may receive includes:
This diagnostic and usage information is primarily needed to maintain the security and operation of our Services, to identify and fix bugs, understand usage patterns, improve app performance and features, and for internal analytics and reporting purposes.
All personal information that you *voluntarily* provide to us (e.g., if you contact us via email) must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In Short: If you use Drawing Competition, images you create may be uploaded to iCloud and, unless you opt out, may be used for machine learning training or commercial purposes.
When you use the Drawing Competition application, you create drawings that are classified by an on-device artificial intelligence system. These drawings and associated classification data are processed as follows:
By using the Drawing Competition application with image upload enabled (the default setting), you grant us a perpetual, irrevocable, worldwide, royalty-free, non-exclusive, transferable, and sublicensable license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform, display, and commercially utilize the images you create for the purposes described above.
We do not process sensitive personal information.
In Short: We process your information to provide, improve, and administer our Services, communicate with you (if you contact us), for security and fraud prevention, app diagnostics and improvement, and to comply with law. For Drawing Competition, we also process images for machine learning training and potential commercial use unless you opt out.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent (including consent provided via OS settings for diagnostics), to comply with laws, to provide you with services, to protect your rights, or to fulfill our legitimate business interests (like app improvement).
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). Consent for diagnostic data sharing may be managed via your device's OS settings. You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example (list remains the same as previous version):
In Short: We may share information in specific situations described in this section and/or with specific third parties like service providers assisting with business transfers, if applicable. For Drawing Competition, we may sell or license user-created images unless you opt out.
We do not sell or share your personal information with third parties for their marketing purposes. We may share diagnostic or usage data with service providers solely for the purpose of assisting us with app analytics or diagnostics, under strict confidentiality agreements, if applicable.
Drawing Competition Image Sharing: Unless you have opted out through the in-app settings, drawings you create in the Drawing Competition application may be shared, sold, or licensed to third parties for commercial purposes, including but not limited to machine learning training data, dataset compilation, or integration into other products or services. This sharing is independent of your use of the application and may continue after you stop using the app unless you request deletion of your images by contacting us.
We may also need to share your personal information in the following situations:
Note that diagnostic data shared via your device's OS settings is initially handled by the platform provider (e.g., Apple) according to their privacy policies and your settings.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice (like app improvement and diagnostics) unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). For diagnostic and usage data collected via OS opt-in, we retain it only as long as needed for analysis, troubleshooting, and app improvement purposes, often in aggregated or anonymized form.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: Depending on your region, you have rights regarding access, correction, deletion, and portability of your personal information. You can manage diagnostic data sharing via OS settings.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information (e.g., processing based on legitimate interests). You can make such a request concerning information we hold by contacting us using the details in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
Regarding diagnostic and usage data collected via your device's OS settings, you typically control the sharing and can withdraw consent directly through those settings on your device.
We will consider and act upon any request regarding data we directly control in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. For consent provided via OS settings (e.g., for diagnostic data), withdrawal is typically managed through those same device settings. For any consent provided directly to us (e.g., if you contacted us), you can withdraw that consent by contacting us using the details in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent (such as legitimate interests for troubleshooting).
If you have questions or comments about your privacy rights, you may email us at privacy@felixparey.com.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online Browse activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
In Short: If you are a resident of certain US states, you may have specific rights regarding your personal information, including access, correction, deletion, and opting out of sales or sharing (though we do not sell or share personal information as defined by these laws).
We have collected the following categories of personal information in the past twelve (12) months, primarily through diagnostic and usage data shared via OS opt-in:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Online identifiers (like device identifiers), Internet Protocol (IP) address (potentially anonymized/truncated by platform provider). Note: We do not collect real name, postal address, email, etc., unless you voluntarily provide it (e.g., by contacting support). | YES (from diagnostics) |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | NO (unless provided voluntarily, e.g., contacting support) |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Interactions with our Services (e.g., features used, session duration), diagnostic information (crash logs), device event information. | YES (from diagnostics) |
| G. Geolocation data | Device location (We do not typically receive precise location. Coarse location might be inferred from IP address or included in some diagnostic reports provided by the platform.) | YES |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details, job title, work history (only if you apply for a job or contact us in a professional capacity) | NO (unless provided voluntarily) |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | We do not typically create profiles or draw inferences about preferences or characteristics from diagnostic data. | NO |
| L. Sensitive personal Information | NO |
We may also collect other personal information outside of these categories through instances where you interact with us directly (e.g., contacting support) as described below:
Learn more about the sources of personal information we collect in Section 1: "WHAT INFORMATION DO WE COLLECT?"
Learn more about how we use your personal information in Section 2: "HOW DO WE PROCESS YOUR INFORMATION?" and how we share it in Section 4: "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider, solely for purposes like assisting with diagnostics or analytics, or as needed for business transfers or legal requirements. Learn more in Section 4: "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We use personal information (primarily diagnostic data) for our own business purposes, such as internal research for technological development, app stabilization, and demonstration. This is not considered "selling" or "sharing" under most US state privacy laws.
We have not sold or "shared" (as defined under CPRA) personal information to third parties for cross-context behavioral advertising or monetary value in the preceding twelve (12) months. We will not sell or share personal information in the future.
Depending on your state of residence, you have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights may include:
Depending upon the state where you live, you may also have the following rights (list remains the same as previous version):
To exercise these rights regarding information we may hold (e.g., if you contacted us directly), you can contact us by submitting a data subject access request, by emailing us at privacy@felixparey.com, or by referring to the contact details at the bottom of this document. To manage diagnostic data sharing, please use your device's OS settings.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Upon receiving your request regarding data we may hold, we will need to verify your identity. We will only use personal information provided in your request for verification. If we cannot verify your identity from the information already maintained by us (which may be minimal), we may request additional information for verification and security/fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@felixparey.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California Civil Code Section 1798.83 (Shine The Light law) permits users who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.
In Short: You may have additional rights based on the country you reside in.
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose (e.g., diagnostic data via OS opt-in), it may affect our ability to diagnose issues or improve services based on usage patterns, but core functionality should remain. If you contact us, failure to provide necessary information may affect our ability to respond.
At any time, you have the right to request access to or correction of your personal information that we hold. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
At any time, you have the right to request access to or correction of your personal information that we hold. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and reflect changes in our practices.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification (if we have your contact information). We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at privacy@felixparey.com or contact us by post at:
Felix Parey
Kösters Hof 11
Rostock, Mecklenburg-Vorpommern 18059
Germany
Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you (primarily data you provided voluntarily, e.g., if you contacted support), details about how we have processed it, correct inaccuracies, or delete your personal information. To make such a request regarding data we may hold, please fill out and submit a data subject access request or contact us via email/post. To manage diagnostic data sharing, please use your device's OS settings.