Effective date: 10 December, 2022
Welcome to 4PM App. Inc. (“Company,” “we,” “us” or “our”), a mobile technology company specializing in deep learning-related products. Our goal is to move forward mobile photography and video creation to the next level using neural networks, deep learning and computer vision technics. We aim to create new ways for people to express their emotions through the camera.
We may collect several types of information, including but not limited to Personal Data, from and about you:
When you Use Delicious, you usually provide to us certain information, including your Personal Data:
If you use iOS device
If you use Android device:
Please note that we always delete all metadata that may be associated with your photos and videos by default (including, for example, geotags) before storing your photos or videos to our systems.
When you Use Delicious, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
If you use iOS device:
We have a process in place to anonymize data specified in this Section 3 fully by erasing identifiers that connect you to stored data. We use this anonymized data for analytical and other business purposes.
The technologies we use for automatic data collection may include:
Third-party analytics. We use third-party analytics tools, such as Google Firebase, Facebook Analytics, AppsFlyer and Amplitude, to help us measure traffic and usage trends for Delicious. These tools collect information sent by your device or Delicious, which includes your pseudonymised user ID and the information about Delicious web pages you visit when following the links available to you on Delicious, your actions in Delicious application and basic information about the type of subscription you have. We collect and use this analytics information in an aggregated manner with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User. For information on how third party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Delicious, please visit the following link or contact us at privacy@Delicious.web.app.
Log file information. Log file information is automatically reported to Delicious each time you Use Delicious. When you Use Delicious, we and our Service Providers may automatically record certain log file information, including your IP address,, referring/exit pages and URLs, number of clicks and how you interact with links on and through Delicious, domain names, landing pages, pages viewed, and other such information. The information allows us to receive more accurate reporting and improve Delicious.
Device identifiers.When you use a mobile device like a tablet or phone to Use Delicious, we access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may identify data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may deliver information to us or to our Service Providers about how you Use Delicious and may help us and others (on our request) produce a report on such Use. Among others we collect the following device identifiers:
Registered Users. If you are a registered User, we collect more Personal Data about you including the following:
For Use of Delicious you may provide us and upload to Delicious your face images (photo or video). In order to make possible for you to Use certain functions of Delicious, we will process (provided by you) human face images (photo or video) through TrueDepth API technologies that will provide us information about such human faces' position, orientation and their topology on your image and/or video frame. We do not have access the your original photos that you upload, such photos are stored on your device only. What we see is only the anonymized information, as described above, about the technical characteristics of the photo (faces’ position, orientation, their topology on your image and/or video frame). For more information about TrueDepth API processing of your photos and videos you may visit the following link. None of the information collected by te TrueDepth API ever leaves the user’s device nor is it persistently stored on the device.
Images (photo or video), that you provide us in or through Delicious, and/or other information related to human faces obtained from your images (photo or video) and/or using TrueDepth API technologies, such as ARKit, are the “Face Data”. The Face Data shall be considered the Personal Data
We collect and store your Face Data for online processing function. We also share and transfer the Face Data off the User devices to our cloud providers (Google Cloud Platform and Amazon Web Services) for the same purpose in which case, the photos: (i) become available to us in an anonymised manner (we get information about your pose, orientation and the topology on your image and/or video frame) and (ii) are automatically deleted within 24 hours after being processed by Delicious. In case of using Magic Avatars feature, the photos are automatically deleted after the AI results are generated.
We do not use your Face Data you provide when you Use Delicious for any reason other than to apply different stylized filters or effects to them unless you have given us your explicit consent to use the photos or videos for a different purpose.
Your photos and videos. We do not use photos or videos you provide when you Use Delicious for any reason other than to apply different stylized filters or effects to them, unless you have given us your explicit consent to use the photos or videos for a different purpose. Please note that to apply different stylized filters or effects to your photos we may upload such photos to the cloud providers we use (Google Cloud Platform and Amazon Web Services), in which case, the photos: (i) become available to us anonymously and (ii) are automatically deleted within 24 hours after being processed by Delicious.
Other information. We may use your information other than photos and videos for the following purposes:
We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 5 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).
For any new purpose of processing we will ask for your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 5 (“data minimization principle”).
Access, modification, correction and erasure. You can send us an email at privacy@Delicious.web.app to request access to, modification, correction, update, erasure or deletion of any Personal Data that you have provided to us and that we have about you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
EEA/UK residents. Individuals residing in the European Economic Area (“EEA”) and the United Kingdom (“UK“) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR“) and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (SI 2020/1586), as may be amended from time to time (“UK GDPR“) (collectively, the “GDPR“), including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see How to Contact Us Section).
Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage you in a dialogue to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Following the provisions of the GDPR, we might also ask you to prove your identity (for example, by requesting your user or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties are violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.
Please note that we will process your request within 30 days after receiving it, but it may take up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems - this is due to the size and complexity of the systems we use to store data.
Opting Out of Promotional Emails
IF REQUIRED BY LAW, WE WILL ASK FOR YOUR CONSENT TO SEND YOU PROMOTIONAL AND MARKETING EMAILS. IF YOU WISH TO OPT OUT OF OUR PROMOTIONAL AND MARKETING EMAILS, YOU CAN OPT OUT FROM OUR PROMOTIONAL AND MARKETING EMAIL LIST BY USING ANY OF THE FOLLOWING METHODS:
Bases for Using Your Personal Data. If you reside in the EEA or the UK we are only allowed to use your Personal Data when certain conditions apply. These conditions are called ”legal bases“, and we typically rely on one of four:
Your California Privacy Rights. If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Data. To learn more about your California privacy rights, visit (i) the following link and (ii) our CCPA Privacy Notice for California Residents.
We may disclose aggregated information about our Users and information that does not identify any individual without any restriction. We may remove parts of data that can identify you and share anonymized data with any persons.
We do not rent or sell your Personal Data, including photos and videos, to any third parties outside the Company or its Affiliates (as defined below).
We may also share certain Personal Data as well as other Collected Information with third-party advertising partners. These third-party advertising partners may use tracking technologies and other automatic information collection technologies to collect information about you or your device when you Use Delicious. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites, apps, and other online services websites. Such information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information on how third-party advertising partners collect and process your data and to opt out of such collection and processing, generated by your Use of Delicious, please visit the following link.
Meta API Conversions. We also utilize Meta API service called "API Conversions" which creates a connection between our marketing data and Meta systems. Meta API Conversions, among other things, help us in optimizing ad targeting. According to these purposes, we send your hashed email addresses to Meta API Conversions service.
Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Delicious or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for circumvention of security measures contained in Delicious. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:
The safety and security of your information also depends on you. Your privacy settings may also be affected by changes the social media services, through which you may share your photos and videos.We are not responsible for the functionality, privacy, or security measures of any other organization.
If you want to report a security incident related to Delicious, please contact us at privacy@Delicious.web.app.
Contacting us. You can provide your feedback or report a technical issue by using ”Send Feedback“ button in Delicious settings. The email will be sent from your personal email
to fb@Delicious.web.app, and the message will contain the following diagnostics information that will help us to resolve your issue/address your request:
This information is used to assess your feedback and/or identify the problem if you are reporting one and is NOT USED to identify Users individually.
We retain your Personal Data for as long as we need it for the purposes for which it was obtained or until you ask us to delete it.
Normally, the retention term would be the term of your account existence. It means that we will normally retain your Personal Data until you delete your account or request us to delete your data (by contacting us at privacy@Delicious.web.app). Please note that deletion of Delicious application does not mean deletion of your account!
As to your photos and videos, these are deleted from our systems within 24 hours from their upload. We also may retain your Personal data in connection with your privacy-related requests and communications with us, if any, as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Data, we may continue to retain and use anonymised data previously collected that can no longer be used for personal identification.
The Company is based in the United States. Accordingly, your Personal Data may be transferred to and stored шin the United States or in other countries. If you are an EU / EEA / UK resident, please note that Delicious transfers Personal Data from the EU, EEA and UK to the U.S. and other third countries. When transferring Personal Data of the users from the EU, EEA or the UK outside of the EU, EEA or the UK, we either implement standard contractual clauses or rely on current European Commission adequacy decisions.
As to the location of our servers, we use AWS servers located in the USA for Delicious operation, while our analytics operations are processed both on the servers provided by AWS (located in the USA) and by Google LLC (located in the Republic of Ireland).
In appropriate cases, the Company will enter into standard contractual clauses as approved under the European Commission Decision C(2010)593 or decision 2004/915/EC, as applicable, to permit the transfer of your Personal Data to the United States, Cyprus or another country that has not been deemed to provide adequate level of data protection.
For further information please contact privacy@Delicious.web.app
General age limitation. Delicious is not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to Use Delicious. If you are under 13, do not: (i) Use or provide any information in Delicious or through any of its features, or (ii) provide any information about yourself to us, including your name, address, telephone number or email address. In the event that we learn that we have collected or received any Personal Data from a child under 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us (for contact information, please, see How to Contact Us Section).
Age limitation for EEA residents. Due to requirements of the GDPR, you shall be at least 16 years old in order to Use Delicious. To the extent prohibited by applicable law, we do not allow Use of Delicious by the EEA residents younger than 16 years old. If you are aware of anyone younger than 16 Using Delicious, please contact us (for contact information, please, see How to Contact Us Section) and we will take required steps to delete information provided by such persons.
4PM App. Inc.
1447 2nd Street
Santa Monica, CA, 90401