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 Legacy mobile application (hereinafter “app”) 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 Corso Como 15, 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 |
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The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR). |
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The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to improve our products and services. |
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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. |
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The legal basis for the processing is compliance with legal obligations to which we may be subject (art. 6(1)(c) of the GDPR). |
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The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR). |
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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. |
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The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR). |
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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 app (“Soft Opt-In”), the legal basis is our legitimate interest (art. 6(1)(f) of the GDPR). |
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The legal basis for the processing is your consent (Article 6(1)(a) of the GDPR). |
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The legal basis applied to the processing is consent of the data subject (Article 6(1)(a) of the GDPR). |
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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 Sections 2.h), 2.i) and 2.j) will be kept until you withdraw your consent to such processing. However, should you not withdraw your consent, personal data will be kept:
for the purposes referred to in Section 2.h), for no more than 2 years from the termination of the agreement, and
for the purposes referred to in Sections 2.i) and 2.j), for no more than 10 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 app’s services and features.
Where we rely on your consent for the purposes referred to in Sections 2.h), 2. i) and 2.j), 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 app’s 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.
You can also manage how you share certain information with us by adjusting the privacy and security settings on your mobile device (such as Limit Ad Tracking or Allow Apps to Request to Track on iOS and iPadOS, or Opt out of Interest-Based Ads or Opt out of Ads Personalization on Android devices). You should refer to the instructions provided by your device’s operating system or its manufacturer to learn how to adjust your settings.
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 app is 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 app 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 app 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 app or participate in a survey or contest); automatically when you use the app (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 app 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 app); 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 app 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 app 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.
Last updated: 16 November 2022
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