Last Updated May 24, 2018

Andor Communications Private Limited ("we" or "us" or "our") respects the privacy of our users ("user" or "you"). We are very delighted that you have shown interest in our app, LightX Express, LightX Photo Editor and Retouch mobile application (the "Service").. Data protection is of a particularly high priority for the management of the Andor Communications Private Limited. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "Application"). Please read this Privacy Policy carefully.

Andor Communications Pvt. Ltd built the LightX Express, LightX Photo Editor and Retouch app.The use of the LightX Express, LightX Photo Editor and Retouch app is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our app, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, device id, advertiser id or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Andor Communications Private Limited. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Andor Communications Private Limited has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this application. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by email.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

1. Definitions

The data protection declaration of the Andor Communications Private Limited is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Andor Communications Private Limited

19/103, East End Apartment, Mayur Vihar Phase1

110091 Delhi

India

Phone: +91-9810265170

Email: support@lightxapp.com

Website: https://lightxapp.com

3. Collection of general data and information

The Application LightX Express, LightX Photo Editor and Retouch of the Andor Communications Private Limited collects a series of general data and information when a data subject or automated system calls up the Application. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches In LightX Express, LightX Photo Editor and Retouch application (so-called referrers), (4) the sub-screens, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Andor Communications Private Limited does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of In LightX Express, LightX Photo Editor and Retouch application correctly, (2) optimize the content of In LightX Express, LightX Photo Editor and Retouch application as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Andor Communications Private Limited analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

4. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

5. Rights of the data subject
6. Data protection provisions about the application and use of Facebook Audience Network

In LightX Express, LightX Photo Editor and Retouch application, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

Audience Network is a network of publisher-owned apps and sites where you can show your ads.

People spend a lot of their time on Facebook and Instagram. But they are also spending time on other apps and sites. Audience Network helps advertisers reach more of the people they care about in the other places where they're spending their time.

In a Facebook ad campaign study, conversion rates were 8x higher among people who saw ads across Facebook, Instagram and Audience Network than people who only saw the ads on Facebook.

Audience Network ads use the same targeting, auction, delivery and measurement systems as Facebook ads.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our application by the data subject€"and for the entire duration of their stay on our Internet application, which specific screens of our app was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

7. Data protection provisions about the application and use of Google Analytics (with anonymization function)

In LightX Express, LightX Photo Editor and Retouch application, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing In LightX Express, LightX Photo Editor and Retouch applications from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on In LightX Express, LightX Photo Editor and Retouch application. Google uses the collected data and information, inter alia, to evaluate the use of In LightX Express, LightX Photo Editor and Retouch application and to provide online reports, which show the activities on In LightX Express, LightX Photo Editor and Retouch applications, and to provide other services concerning the use of In LightX Express, LightX Photo Editor and Retouch application for us.

First-party Cookies

Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites and/or apps that use Google Analytics. Customers may customize cookies and the data collected with features like cookie settings, User-ID, Data Import, and Measurement Protocol. Learn more

Google Analytics customers who have for instance, enabled the analytics.js or gtag.js collection method can control whether or not they use cookies to store a pseudonymous or random client identifier. If the customer decides to set a cookie, the information stored in the local first-party cookie is reduced to a random identifier (e.g., 12345.67890).

For customers who use the Google Analytics for Apps SDK, we collect an App Instance Identifier, which is a number that is randomly generated when the user installs an app for the first time.

Advertising identifiers

Where customers use Google Analytics Advertising Features, Google advertising cookies are collected and used to enable features like Remarketing on the Google Display Network. These features are subject to the users' Ads Settings, the Policy requirements for Google Analytics Advertising Features and Google's EU User Consent policy, which requires customers to obtain consent for cookies where legally required—including consent for personalized ads. For more information about how Google uses advertising cookies, visit the Google Advertising Privacy FAQ. It is possible to implement Google Analytics without affecting normal data collection where Advertising features are disabled until consent is obtained.

IP Address

Google Analytics uses IP addresses to derive the geolocation of a visitor, and to protect the service and provide security to our customers. Customers may apply IP masking so that Google Analytics uses only a portion of an IP address collected, rather than the entire address. In addition, customers can override IPs at will using our IP Override feature.Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

8. Data protection provisions about the application and use of FireBase

In LightX Express, LightX Photo Editor and Retouch data on its real-time database which sync data among users data in no time.

The operating company of Firebase is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Firebase SDK has been integrated, the app on the information technology system of the data subject automatically downloads a display of the corresponding Firebase SDK of Google through the respective component. During the course of this technical procedure, Google is made aware of what specific sub-page of In LightX Express, LightX Photo Editor and Retouch application was visited by the data subject. More detailed information about Firebase is available under https://firebase.google.com/support/privacy/

If the data subject is logged in at the same time to FireBase, Google recognizes with each call-up to In LightX Express, LightX Photo Editor and Retouch application by the data subject and for the entire duration of his or her stay on LightX Express, LightX Photo Editor and Retouch application, which specific sub-pages of our app screen were visited by the data subject. This information is collected through the FireBase SDK.

Further information and the data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.

9. Data protection provisions about the application and use of Crashlytics

On this application, the controller has integrated components of Crashlytics by Google.Crashlytics, a business division of Google Inc., (herein referred to as "Crashlytics") offers a suite of services to provide mobile application developers with information about the functioning of publicly released and beta versions of their mobile applications. The Crashlytics Privacy Policy ("Privacy Policy") governs the Crashlytics crash reporting and beta testing solution and www.crashlytics.com as well as our other websites (collectively, the "Services"). Effective November 20, 2015. https://try.crashlytics.com/terms/privacy-policy.pdf

The operating company of Crashlytics by Google is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

Crashlyticsservices automatically collect certain information that does not personally identify End Users who access or use mobile applications that use the Services. This information includes, but is not limited to, device state information, unique device identifiers, device hardware and OS information, information relating to how an application functions, and the physical location of a device at the time of a crash.

Further information and the applicable data protection provisions of Crashlytics may be retrieved under DoubleClick by Google https://www.google.com/intl/en/policies/.

10. Data protection provisions about the application and use of YouTube

In LightX Express, LightX Photo Editor and Retouch application, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of In LightX Express, LightX Photo Editor and Retouch application was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of In LightX Express, LightX Photo Editor and Retouch application was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited In LightX Express, LightX Photo Editor and Retouch application, if the data subject at the time of the call to In LightX Express, LightX Photo Editor and Retouch application is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to In LightX Express, LightX Photo Editor and Retouch application is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

11. Data protection provisions about the application and use of Google Admob

On this app, the controller has integrated components of Admob by Google. Admob is a trademark of Google, under which predominantly special online marketing solutions are marketed to advertising agencies and publishers.

The operating company of Admob by Google is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

AdMob by Google helps us monetize your mobile app through in-app advertising. Ads can be displayed as banner ads, interstitial ads, video ads, or native ads—which are seamlessly added to platform native UI components. On Android, you can additionally display in-app purchase ads, which allow users to purchase advertised products from within your app.

AdMob uses the Google Mobile Ads SDK. The Google Mobile Ads SDK helps app developers gain insights about their users, drive more in-app purchases, and maximize ad revenue. In order to do so, the default integration of the Mobile Ads SDK collects information such as device information, publisher-provided location information, and general in-app purchase information such as item purchase price and currency.

Further information and the applicable data protection provisions of DoubleClick may be retrieved under DoubleClick by Google https://www.google.com/intl/en/policies/.

12. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

13. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

15. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

16. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

Link to third party applications

LightX Express, LightX Photo Editor and Retouch provides option to share edited images using third party social applications such as Facebook, Google+, Twitter etc. Such applications are governed by their respective privacy policies, which are beyond our control. Once you share your image using these applications, use of any information provided by you is governed by the privacy policy of these Application. If you can't find the privacy policy of any of these sites via a link from the Application's homepage, you should contact the Application directly for more information.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device's camera, storage, sensors, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data

Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notification

We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Application, you have the right to request removal of unwanted data that you publicly post on the Application. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Application, but please be aware that the data may not be completely or comprehensively removed from our systems.

Sale or Bankruptcy

If we reorganise or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy. We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.


Change in Privacy Policy

However internet is an ever evolving medium and thus we may change our privacy policy from time to time to incorporate any necessary changes. If under any such update we make any material change to the way we treat your information, we will inform you of such change via posting a notice on relevant areas of the Services such as AppStore. Any updated version of this Privacy Policy will be effective as of the date set forth therein.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

By email: support@lightxapp.com, support@andor.mobi