Privacy Policy

This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) by Bending Spoons S.p.A. (“we” or “us”), the parent company of Splice Video Editor S.r.l., when you use the Filmic mobile applications (namely, Filmic Pro, Double Take by Filmic Pro, Filmic Remote and Filmic First Light, hereinafter “apps”) or otherwise interact with us and this Privacy Policy is presented to you, in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).

If you are a California resident, please see Section 11 (Additional Information for California Consumers) below.

1. Data Controller and Data Protection Officer

The Data Controller is Bending Spoons S.p.A., based in Via Nino Bonnet 10, Milan, MI 20154 (Italy), VAT 08931860962. For any requests regarding the processing of your personal data, please email us at privacy@bendingspoons.com.

Our Data Protection Officer can be contacted by sending an email to dpo@bendingspoons.com for any requests relating to the processing of your personal data or this Privacy Policy.

2. Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing

We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.

Purpose	Legal Basis	Categories of Processed Data
To enable you to use the apps and to provide you with its functionalities, including: access to the device camera(s) for recording videos and taking photos create an account and authenticate your access to the account show information about the apps and your editing or enhancing process	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	Identification and contact information, identifiers and Internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the apps, and unique identifiers) and other information necessary to enable you to use the apps. If you create an account or login with your Facebook, Google or Apple account, we may also receive the following information: first and last name, email address, profile image. By creating an account or logging in with your Facebook, Google or Apple account, you will be enabled to upload in the cloud storage photos and videos (including audio recordings) made through the apps.
To improve our products and services (for example, by conducting statistical analysis or other research activities to optimize our features and provide you with new ones).	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to improve our products and services. As for the collection of personal data by means of analytics tracking technologies, please see Section 12 (In-app Tracking Technologies).	Identification and contact information you provide us (such as name, social media handle, or email address, when requested), identifiers and Internet and network activity information (such as IP address), and information collected or generated to improve the apps’ functionalities (such as device language, information about your interactions with the apps, inferences we generate and other related information about your usage of the apps).
To ensure the quality and the proper functioning of the services by analyzing, preventing or correcting failures and bugs, illicit use or misuse of the services.	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to ensure the quality and the proper functioning of the services.	Identifiers and Internet and network activity information (such as IP address, device model, device type, device orientation and device resources, OS version, crash and error logs, name of the current app screen), inferences we generate and other related information about your usage of the apps.
To comply with our legal obligations, including requests from public authorities.	The legal basis for the processing is compliance with legal obligations to which we may be subject (art. 6(1)(c) of the GDPR).	Any information which may be required by law or under the instructions of public authorities.
To process and respond to customer support communications and to requests for information you may raise with us.	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	Identification and contact information you provide us (such as first and last name, email address) and the content of your communication or request.
To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions).	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations.	Any information necessary to ensure the performance of these purposes.
To analyze your usage information, including your preferences, interests and behaviors when you use our products and services, to: conduct surveys, statistical analysis or other research activities to improve our products and services maintain, optimize, and develop new features find and group users with similar characteristics advertise our products and services towards more users like you and reach out to inactive users with our ads measure the effectiveness of our campaigns and make our advertising more relevant customize information and marketing communications	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR).	Identification and contact information (such as name, email address, when requested), identifiers and Internet and network activity information that we collect (such IP address), information about your interactions with the apps, inferences we generate and other related information about your usage of the apps.
To carry out marketing activities, and send you information and marketing communications about our products and services such as tips, offers, and newsletters through emails and push notifications (only if you grant permission by enabling push notification on your mobile operating system settings).	The legal basis for the processing is your consent (art. 6(1)(a) of the GDPR). Where your consent is not required, for example, where we use your email to send you information about products and services related to or similar to the apps (“Soft Opt-In”), the legal basis is our legitimate interest (art. 6(1)(f) of the GDPR).	Identification and contact information (such as name, email address), identifiers and Internet and network activity information (such as IP address), information we may receive from third-party advertising networks and platforms (such as unique identifiers), information about your interactions with the apps, inferences we generate and other related information about your usage of the apps (such as your responses and your voice in case you take part in our interviews).

3. Data Storage and Protection

Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

Personal data processed for the purposes referred to in Sections 2.a), 2.d), 2.e) and 2.f) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 10 years from the termination of the agreement.

Personal data processed for the purposes referred to in Sections 2.b), 2.c), 2.g) and 2.h) (as to Soft Opt-In) will be kept until you object to such processing. However, should you not exercise your right to object, personal data will be kept for such purposes for no more than 2 years from the termination of the agreement.

Personal data processed for the purposes referred to in Section 2.h) will be kept until you withdraw your consent to such processing. However, should you not withdraw your consent, personal data will be kept for no more than 2 years from the termination of the agreement.

Except for any legal obligation that sets a longer data retention period, at the end of these periods, the personal data processed will be deleted or anonymized.

4. Your Choices with Regard to the Use of Your Personal Data

It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.d), and 2.e). If you do not provide the personal data, you will not be able to enjoy the apps’ services and features.

Where we rely on your consent for the purposes referred to in Section 2.h), your provision of personal data is optional, and you have the right to withdraw your consent at any time. If you do not provide the personal data, you will still be able to enjoy the apps’ services and features.

Where we rely on our legitimate interest for the purpose referred to in Sections 2.b), 2.c), 2.f), 2.g) and 2.h), you may, at any time, exercise your right to object to such processing as explained in Section 7 (Your Rights) below.

5. Sharing Your Personal Data

We may share or disclose your personal data to the following categories of recipients:

Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners, suppliers of mobile marketing services, and advertising networks and platforms).
If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers, and may be one of the assets that is transferred to another owner.
Public, judicial or police authorities, within the limits established by applicable laws.

Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

6. Transfers of Personal Data Outside the European Economic Area

We may transfer personal data from the European Economic Area (“EEA”), the UK or Switzerland to other countries outside the EEA. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Laws, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission; or (c) binding corporate rules.

More information on the appropriate warranties are available for consultation by sending an email to privacy@bendingspoons.com.

7. Your Rights

At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Applicable Privacy Laws:

Right of access. You have the right to obtain information about the processing of your personal data and to access it.
Right to rectification. You have the right to ask for the updating, rectification or integration of your personal data.
Right to erasure. You have the right to request the deletion of your personal data.
Right to restriction of processing. You have the right to request the restriction of the processing of your personal data.
Right to data portability. You have the right to obtain a portable electronic copy of your personal data.
Right to object. Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation. In particular, you are entitled to object to the processing of your personal data for direct marketing purposes, including profiling.
Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent, although the processing carried out before your withdrawal of consent will remain valid.

You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

To exercise your rights, or if you have any other questions about privacy or data protection at Bending Spoons, you can contact us by sending an email to privacy@bendingspoons.com. We may take reasonable steps to verify your identity prior to responding to your request.

8. Children’s Personal Data

The apps are not intended for anyone under the age of 16. We do not knowingly collect personal data from children. If you believe we have received personal data from children under the age of 16, please email us at privacy@bendingspoons.com. If we learn that a user is under the age of 16, we will take reasonable steps to delete any processed data and close such user’s account.

9. Third-party Websites and Services

The apps may include links to other websites or services operated by third parties. The activities described in this Privacy Policy do not apply to data processed by such third-party websites and services. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.

10. Changes to this Privacy Policy

We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws. If we make modifications, we will notify you by revising the date at the bottom of this Privacy Policy and, under certain circumstances, we may also notify you by additional means such as pop-up or push notifications within the apps or our website, or email.

11. Additional Information for California Consumers

This section provides additional disclosures required by the California Consumer Privacy Act (“CCPA”).

a) Additional Information Related to Collection, Use, and Disclosure of Personal Information

We collect personal information from several sources: directly from you (for example, when you make purchases within the apps or participate in a survey or contest); automatically when you use the apps (for example, device information); and from other sources (for example, mobile measurement partners). We also generate inferences about you based on your use of the apps and other information we collect.

In the preceding 12 months, we have collected the following categories of personal information: identifiers; internet or other electronic network activity information; characteristics of protected classifications under California or U.S. federal law (such as gender if you participate in a survey); commercial information (such as purchases you make in the apps); approximate geolocation information (such as country); audio and visual information; inferences; and other information that relates to or is reasonably capable of being associated with you. For details about the personal information we collect, please see Section 2 (Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing) above. We collect personal information for the business and commercial purposes listed in the chart in Section 2 above.

We may share your personal information with the categories of third parties as described in Section 5 above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes: identifiers, internet and electronic network activity information, characteristics of protected classifications under California or U.S. federal law; commercial information; approximate geolocation information; and other information that we have inferred about you or that relates to or is reasonably capable of being associated with you.

We do not sell your personal information. We do allow our advertising partners to collect certain device identifiers and electronic network activity via our apps to show ads that are based on your interests. If you prefer to limit this activity, your device may include a feature (such as “Limit Ad Tracking” on iOS, or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for interest-based advertising purposes.

b) Rights of California Consumers

Subject to certain limitations, the CCPA provides California consumers the right to:

Request more details about the categories and specific pieces of personal information that we process.
Request the deletion of their personal information.
Opt out of “sales” of personal information that may be occurring.
Not to be discriminated against for exercising these rights.

If you’re a California consumer, to exercise these rights, or if you have any other questions about privacy or data protection at Bending Spoons, you can contact us by sending an email to privacy@bendingspoons.com. We may take steps to verify your request by asking you to provide information that matches information we have on file about you. California consumers can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on their behalf and may also still ask them to verify their identity with us directly.

12. In-app Tracking Technologies

When we refer to “tracking technology/technologies” in this Policy, we mean any technology that stores or accesses information on the user’s device, including SDK, tracking pixel, HTML5 local storage, local shared object, and fingerprinting technique.

Tracking technologies are usually classified by purpose (Technical, Analytics, Profiling) and by publisher (First-party, Third-party).

This classification is important because different legal requirements apply based on how the tracking technologies are classified.

Below you will find the types of tracking technologies as classified with some practical examples.

By purpose

Technical tracking technologies

Technical tracking technologies are used for the purpose of transmitting messages over an electronic communication network or to provide a service specifically requested by the user.

Thus, technical tracking technologies are essential for the correct functioning of the app and to provide the service offered to and requested by the user.

For example, technical tracking technologies can be used to monitor sessions, store specific server access information related to the user configuration, facilitate the use of online content, or keep track of items in a shopping cart or information used to fill in a form.

Technical tracking technologies do not need your consent.

Analytics tracking technologies

Analytics tracking technologies may be used to assess the effectiveness of an information society service provided by a publisher, evaluate and improve the design of an app, or help measure its traffic.

In other words, analytics tracking technologies may be used to track the traffic and performance of an app, by collecting aggregate data on the number of users and how they interact with the app to improve its services.

For example, analytics tracking technologies may collect information about how users access an app, including the number of users, possibly grouped by geographical area, time slot, how long users stay on the app, what parts of the app they interact with, or the number of users who used a particular feature.

Analytics tracking technologies need your explicit consent. However, analytics tracking technologies are equated to technical trackers and, thus, do not need your consent if:

they are only used to produce aggregated statistics that are performed by way of the controller’s own resources and do not turn into activities that go beyond statistical counting and enable business-related decision-making; or
the third parties do not match the analytics trackers' data with any other information and do not forward such data to other third parties.

Profiling tracking technologies

Profiling tracking technologies may be used to evaluate certain personal aspects relating to users and trace specific actions or recurring behavioral patterns in the use of the offered functionalities back to specific, identified or identifiable individuals for the purpose of grouping them within homogeneous, multi-sized clusters. This is aimed to enable the company to analyze and predict personal aspects concerning the users, provide them with increasingly customized services beyond what is strictly necessary for the delivery of the service, and also send targeted advertising messages in line with the preferences expressed by the user during their in-app activities.

In other words, profiling tracking technologies may be used to convey behavioral advertising, measure the effectiveness of ads, or to customize the services offered in line with the user’s monitored behavior.

For example, profiling tracking technologies can be used to create user profiles and offer content in line with the user’s interests, send targeted ads or messages, conduct statistical analysis or other research activities to improve our products and services and measure the effectiveness of our campaigns.

Profiling tracking technologies need your explicit consent.

By publisher

First-party tracking technologies

First-party tracking technologies are installed and managed directly by the owner of the app which will process the collected data for its own purposes.

Third-party tracking technologies

Third-party tracking technologies are installed and managed by different apps or developers either for our purposes or for the third party’s own purposes.

The data collected by these third parties is governed by their own specific privacy policies and terms and conditions over which we have no control. Thus, for further information about this data processing activities, please refer to the privacy policy of such third parties as indicated in the following section ("Types of tracking technologies used by the app”).

Third-party non-anonymized analytics and/or profiling trackers need your consent. You can manage this consent at any time by accessing the “Privacy Settings” area within the app.

Types of tracking technologies used in the app

This app installs the following types of tracking technologies:

Name	Purpose	Retention period	Publisher (i.e., first-party or third-party)	Description	Third-party Privacy Policy (where applicable)
Filmic SDK (technical)	Technical	3 years. See Section 3 (Data storage and protection) for more details.	First-party	Our internal software development kit (SDK). It is essential for the app to function correctly.	N/A
Filmic SDK (statistical analytics)	Technical	3 years	First-party	Our internal software development kit (SDK). It allows us to produce aggregated statistics.	N/A
Firebase Crashlytics	Technical	3 years. See Section 3 (Data storage and protection) for more details.	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy
Firebase Dynamic Links	Technical	3 years. See Section 3 (Data storage and protection) for more details.	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy
FirebaseAuth	Technical	3 years. See Section 3 (Data storage and protection) for more details.	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy
Firebase	Analytics	3 years	Third-party	Firebase is a tool provided by Google which is essential for the app to work properly. When analytics features are enabled, it can help us to improve app’s traffic and performance.	https://policies.google.com/privacy
Filmic SDK (profiling)	Profiling	3 years	First-party	Our internal profiling software development kit (SDK). It allows us to provide customized services.	N/A
Adjust	Profiling	3 years	Third-party	Adjust is a mobile attribution tool. It helps us to measure the effectiveness of our ads.	https://www.adjust.com/terms/privacy-policy/
Firebase	Profiling	3 years	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy

Tracking technologies settings

You can activate or disable (in whole or in part) profiling and third-party analytics tracking technologies at any time through the “Privacy Settings” area of the app.

In case of withdrawal of consent, your data will no longer be collected through those trackers but we will continue processing the data collected before the withdrawal.

You cannot deactivate first-party analytics tracking technologies since they are equated to technical trackers and, thus, are not based on your consent. However, you can opt out of the further processing of your data collected by means of such trackers by sending an email to privacy@bendingspoons.com.

With regards to your rights under applicable Data Protection Laws, please refer to Section 7 (Your Rights) above.

Last updated: July 22, 2023

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