Privacy Policy

Data We Collect and Why

We collect and process your data to provide and improve our services. We only collect the data necessary for these purposes:

• Photos and Biometric Data: When you use our Application, we collect the photo you upload and process it to estimate your age. This process involves the collection of biometric data, then the extraction and processing of biometric data (a biometric template derived from the facial image), which is processed exclusively for the purpose of age estimation.
  You have the option to provide feedback on our age estimate, including your actual age. This information is voluntarily provided and is used exclusively to improve the accuracy of our AI-based age estimation algorithm. This data is stored separately and is pseudonymized or aggregated to ensure it is not linked to your personal identity.
• Technical Data: We may collect non-personal technical information, such as your device type, operating system, and IP address, to ensure the Application functions correctly and to troubleshoot technical issues.

Legal Basis for Processing Your Data

We process your data based on your explicit consent by affirmatively clicking an "I Agree" button or similar clear action before uploading your photo, you explicitly consent to the collection and processing of your biometric data for the purposes outlined in this Privacy Policy. This consent is specific, informed, and freely given. You have the right to withdraw your consent at any time, in accordance with the Section below.

How We Use Your Data

Your data is used strictly for the following purposes:

• Service Provision: To provide the core functionality of the Application–estimating your age from a photo.
• Algorithm Improvement: To analyze and improve the accuracy of our AI-based age estimation algorithm. This is a crucial part of our research and development.
• Application Maintenance: To ensure the Application's stability, security, and performance.
• Prohibited Use Prevention: To monitor for and prevent any prohibited uses as outlined in our Terms of Use, including but not limited to the creation of competing solutions or unauthorized internal business use of the Application.

Data Sharing and Transfer

Application does not collect and disclose Users personal information except trusted third parties which provide face detection and age prediction services and third parties providing user requested sharing services. We may share your data with trusted third-party service providers who act as Data Processors on our behalf. These service providers assist us in operating our Application, including (e.g. cloud hosting etc) but only to the extent necessary to perform their functions. Any such third parties are bound by Data Processing Agreements (DPAs) and strict confidentiality and data protection agreements ensuring full GDPR compliance. Data Transfers Outside the EU/EEA: If we transfer your personal data outside the European Union or European Economic Area, we ensure that appropriate safeguards are in place, such as the use of Standard Contractual Clauses (SCCs) approved by the European Commission, to guarantee your data receives a level of protection essentially equivalent to that guaranteed within the EU.

Data Retention

We retain your data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. Photos and biometric data are processed and then immediately deleted from our servers once the age estimation is complete. If you have explicitly provided feedback for algorithm improvement, the data is stored separately and anonymously (meaning the data is permanently stripped of any identifiers and cannot be re-linked to you for the sole purpose of algorithm improvement.

Third party websites and services

Application may include links to other websites or services. We are not in control of these third party sites or services. These third party sites or services may have separate terms and policies. We do not have any responsibilities or liabilities for the content or activities of these linked third party sites or services

Your Rights Under GDPR and AI Regulation

As a data subject, you have the following rights:

• The Right to Be Informed: You have the right to know what data we collect and how we use it.
• The Right to Access: You can request access to your personal data.
• The Right to Rectification: You can request that inaccurate or incomplete data be corrected.
• The Right to Erasure (Right to Be Forgotten):You can request the deletion of your personal data.
• The Right to Restrict Processing: You can request that we limit the processing of your data.
• The Right to Data Portability: You can request to receive a copy of your data in a structured, commonly used, and machine-readable format.
• The Right to Withdraw Consent: You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You also have the right to lodge a complaint with a supervisory authority, particularly in the Member State of habitual residence, place of work, or the place of the alleged infringement. In Lithuania, this is the State Data Protection Inspectorate

To exercise these rights, please contact us at dpo@neurotechnology.com.

Children's Privacy

This Application is not intended for children under the age of 18. We do not knowingly collect personal information from individuals under 18. If we become aware that we have inadvertently collected such data, we will take immediate steps to delete it.

Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Lithuania, without regard to its conflict of law provisions. Any disputes relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Lithuania. The data controller responsible for the processing of your personal data under this Privacy Policy is Neurotechnology.

Changes to this privacy policy

We reserve the right to update this Privacy Policy at any time. We will notify you of any changes by updating the "Effective Date" at the top of this document. We encourage you to review this policy periodically to stay informed.