App: Ugly Cam
Controller: Chrometis, OÜ
Address: Ahtri tn 12, 15551 Tallinn, Estonia
Registration number: 17340556
Contact: uglycam@chrometis.com
Effective date: 2026-02-11
1. Terms of Use
- This app is intended for users aged 18 or older.
- You must have the right to use any images you edit.
- You may not use the app for unlawful purposes.
- The app is provided "as is" without warranties.
- We may update features and these terms when needed.
2. Privacy Policy (GDPR)
This policy explains how we process personal data under the GDPR. Image processing happens locally on your device. We do not store your photos on our servers.
2.1 Photos
All photo processing happens locally on your device. We do not upload or store your photos on our servers.
2.2 Data we collect
- Advertising ID and device identifiers (Android ad ID / iOS IDFA) for ad delivery and measurement (Google Mobile Ads SDK).
- IP address (used for approximate location).
- App interaction and ad engagement data (impressions, clicks, taps, video views).
- Diagnostics and performance data (crash reports, app launch time, hang rate, energy usage).
- Support data if you contact us (email and message content).
2.3 Purposes
- Deliver and measure ads (AdMob).
- Prevent fraud and protect security.
- Improve stability and performance.
- Provide support when you contact us.
We do not use analytics beyond Google AdMob.
2.4 Legal bases
- Consent (Art. 6(1)(a) GDPR) for personalized advertising where required.
- Legitimate interests (Art. 6(1)(f) GDPR) for non-personalized ads, measurement, and security.
- Contract (Art. 6(1)(b) GDPR) to operate the app and provide requested functionality.
2.5 Personalized vs non-personalized ads
We use Google AdMob. Personalized ads may use your Advertising ID, device information, IP address (approximate location), and ad/app interactions to tailor ads. If personalized ads are enabled and Google has account/usage data, Google may use that activity (such as apps you use, searches, and location signals) to tailor ads.
- Turn off personalized ads in the app (toggle in the Privacy Policy modal).
- Turn off ad personalization in your device settings.
- Contact us at uglycam@chrometis.com.
2.6 Consent (EEA/UK/Switzerland)
For users in the EEA, UK, and Switzerland we use Google's User Messaging Platform (UMP) to collect and manage consent for personalized ads. You can change or withdraw consent at any time using the in-app toggle or your device settings.
2.7 Sharing and subprocessors
We share data with Google AdMob for ad delivery and measurement. Google may process this data as a subprocessor. Primary subprocessor: Google (Google Ireland Limited / Google LLC).
2.8 International transfers
Google may process ad data outside the EEA/UK/Switzerland, including in the United States. Google relies on the EU-U.S. Data Privacy Framework (and the UK Extension / Swiss-U.S. Data Privacy Framework where applicable) and/or Standard Contractual Clauses (SCCs) for transfers.
2.9 Retention
We do not store your photos. Ad-related data retention is handled by Google AdMob according to their policies. Support communications are retained only as long as needed to resolve your request.
2.10 Is data required?
- Required: basic device data for ad delivery and app operation.
- Optional: personalized advertising consent. If you decline, you will still receive non-personalized ads and the app will continue to function.
- If you deny camera or photo library permission, you cannot take or select photos.
2.11 Your rights
You may request access, correction, deletion, restriction, objection, and portability of your data, and you may withdraw consent at any time. Contact us at uglycam@chrometis.com.
2.12 Right to complain
You have the right to lodge a complaint with your local supervisory authority. In Estonia, this is the Estonian Data Protection Inspectorate (AKI).
2.13 Deletion requests
To request deletion of data associated with the app, contact us at uglycam@chrometis.com. We will handle the request and coordinate with relevant processors (e.g., Google) where applicable.
2.14 Security
We use reasonable technical and organizational measures to protect personal data, but no system is fully secure.
2.15 Changes
We may update this policy and will adjust the effective date above.