Privacy Policy

Last Updated: 22/04/2025

This Privacy Policy describes how MRND Studio ("we," "us," or "our") collects, uses, and discloses information when you use our Untouched application ("App").

We are committed to protecting your privacy. Please read this Privacy Policy carefully to understand our practices regarding your information.

1. Information We Collect

1.1 Personal Information: We collect the following personal information when you create an account: Name, Email address.

1.2 Usage Data. We collect the following data related to your use of the App:

  • Face-touch statistics (number of touches detected)
  • Time data (when face touches occur)
  • App usage patterns and interactions

1.3 Local Device Data: The App creates and stores the following data on your device only:

  • Screenshots taken when face touches are detected

1.4 Voluntary Submissions. You may voluntarily submit:

  • Footage of false positives (when the App incorrectly identifies face touching)
  • Feedback about the App's performance and usage

2. How We Collect Information

2.1 Direct Collection. We collect information directly from you when you:

  • Create an account
  • Use the App
  • Contact our support team
  • Voluntarily submit feedback or false positive footage

2.2 Automated Collection. The App automatically collects:

  • Face-touch data through webcam analysis
  • Usage analytics

2.3 Important Privacy Safeguards: We DO NOT collect, store, or transmit any webcam footage or video without your explicit voluntary submission. All webcam processing occurs locally on your device. Screenshots are stored ONLY on your local device and are not transmitted to us.

When you voluntarily submit footage of false positives (as described in Section 1.4), this constitutes a separate, explicit consent-based submission that you initiate to help improve our service. This voluntary submission is the only circumstance under which any webcam-related data leaves your device.

3. How We Use Your Information

3.1 We use your personal information to:

  • Create and manage your account
  • Process payments and subscriptions
  • Communicate with you about your account or the App
  • Respond to your inquiries and support requests

3.2 We use usage data to:

  • Improve the App's functionality and user experience
  • Analyze trends and user behavior
  • Monitor and enhance the performance of the App
  • Develop new features and improvements

3.3 We use voluntarily submitted footage to:

  • Improve our face-touch detection algorithm
  • Reduce false positives
  • Enhance the overall accuracy of the App

4. Data Storage and Security

4.1 Data Storage: Account information is stored on secure servers. Screenshots are stored locally on your device only. Voluntarily submitted footage is stored on secure servers.

4.2 Data Retention: Account information is retained while your account is active. If you delete your account, we will delete your personal information within 30 days, except where we have a legitimate legal reason to retain specific information (which will be deleted after no more than 12 months). Voluntarily submitted footage will be retained for up to 24 months, after which it will be anonymized or deleted. You may request earlier deletion at any time.

4.3 Data Security. We implement appropriate technical and organizational measures to protect your information, including:

  • Encryption of data in transit and at rest
  • Regular security assessments
  • Limited staff access to personal data
  • Secure authentication protocols

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers. We share information with:

  • Polar and Stripe for payment processing
  • Analytics providers to help us understand app usage

5.2 Legal Requirements: We may disclose your information if required by law, regulation, legal process, or governmental request.

5.3 Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

5.4 Important Limitations. We DO NOT:

  • Sell your personal information to third parties
  • Share your information with advertisers
  • Allow third parties to access your webcam data

6. Your Rights and Choices

6.1 Account Information: You can review and update your account information at any time through the App.

6.2 Communication Preferences. You can opt out of non-essential communications by:

  • Following the unsubscribe instructions in our emails
  • Adjusting notification settings in the App

6.3 Data Access and Portability. You have the right to:

  • Request a copy of your personal information
  • Request correction of inaccurate data
  • Request deletion of your data (subject to legal requirements)
  • Request restriction of processing

6.4 How to Exercise Your Rights: To exercise these rights, please contact us at feedback@untouchedapp.com.

7. Cookies and Tracking Technologies

7.1 The App uses the following tracking technologies:

  • Analytics cookies to understand how users interact with the App
  • Session identifiers to maintain your logged-in status

7.2 Your Choices: You can control cookies through your device settings, but this may impact functionality.

8. International Data Transfers

8.1 Data Location: Your information may be transferred to and processed in countries other than your country of residence.

8.2 Supervisory Authority: As a French company, we operate under the supervision of the Commission Nationale de l'Informatique et des Libertés (CNIL), the French Data Protection Authority.

9. Legal Framework and User Rights

9.1 Governing Law: As a digital product offered by a company established in France, we operate under French law and European Union regulations, particularly the General Data Protection Regulation (GDPR). We apply these protections universally to all our users regardless of their location.

9.2 Legal Basis for Processing. We process your personal data on the following legal bases as defined in the GDPR:

  • Contract: To provide the App services you have requested
  • Consent: For voluntary submissions and certain communications
  • Legitimate interests: To improve our App and services

9.3 Your Rights. All users, regardless of location, are granted the following rights under our framework:

  • Right to access your personal data
  • Right to correction of inaccurate data
  • Right to deletion of your data ("right to be forgotten")
  • Right to restriction of processing
  • Right to data portability
  • Right to object to processing
  • Rights related to automated decision making and profiling

9.4 To exercise these rights, please contact us at feedback@untouchedapp.com.

9.5 California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to delete personal information, and the right to opt-out of the sale of personal information. We do not sell your personal information.

9.6 Minor Users: Users must be at least 16 years old to use the App. We do not knowingly collect information from users under 16 years of age.

10. Changes to This Privacy Policy

10.1 We may update this Privacy Policy from time to time.

10.2 We will notify you of material changes by sending an email to the address associated with your account.

10.3 Your continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

11. Company Information

In accordance with French law, specifically Article 6-III of Law No. 2004-575 of June 21, 2004 (Loi pour la Confiance dans l'Économie Numérique), we provide the following information:

MRND Studio SARL

Registered Capital: 1000€

SIREN Number: 938756715

Registered Office Address: 19, rue des Rémouleurs 03100 Montluçon FRANCE

Email: feedback@untouchedapp.com

Data Protection Registration Number: [CNIL REGISTRATION NUMBER]

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: feedback@untouchedapp.com

Our Data Protection Officer can be contacted at feedback@untouchedapp.com