Privacy Policy

1. Who we are

JOYTELLECT LTD (company number 17040270) is a company registered in England and Wales. Our registered office is Office 34a Business Centre, 9 Lydden Road, London SW18 4LT, United Kingdom. JoyTellect is the controller of personal data described in this policy unless stated otherwise.

Privacy and data-rights contact: https://joytellect.com/contact/

2. Scope and applications covered

This policy applies to joytellect.com and to JoyTellect Skin Maker, published as “AI Skin Maker & Editor” on the Apple App Store and “Skin Maker & 3D Editor” on Google Play, including renamed or successor versions (together, the “Apps”).

Section 3.5 identifies the processing profile for each platform version. The App Privacy and Data Safety information supplied to Apple and Google is maintained for each released build and is intended to be consistent with this policy. If a build changes its SDKs, permissions, purposes or data flows, we update the affected disclosures before release.

This policy does not govern Apple, Google, Mojang/Microsoft, Unity or another third-party service you choose to use. Those parties process data under their own notices.

3. Data we process

3.1 Data from the website

joytellect.com uses essential hosting and security technologies and may use optional, privacy-respecting analytics to count page views and store-link clicks. Optional analytics are enabled only after consent where required. Hosting and security providers may automatically record an IP address, request time, requested page, referrer and browser/user-agent information in standard server logs to deliver and protect the website.

3.2 Data from our apps

The categories below are processed only where the corresponding SDK or feature is active in the app profile in section 3.5, and subject to your device settings, region and privacy choices:

• Device and app information. Device model, operating-system version, language, region, app version, network type, carrier, IP address, time zone, screen or performance characteristics and installation identifiers.
• Identifiers for attribution and advertising. A resettable advertising identifier (IDFA on Apple devices or advertising ID on Android), vendor/device identifiers, app-instance or installation IDs and campaign attribution data. On iOS, the app and its SDKs do not access IDFA unless ATT status is authorised. On Android, use of the advertising ID is subject to the device setting, consent and applicable law. Apple SKAdNetwork may be used for privacy-preserving campaign measurement.
• Usage and feature data. App launches, sessions, screens or tools used, editing and export events, ad impressions or interactions, campaign events, purchase or subscription status and consent choices. The Apps do not provide user-to-user chat.
• Diagnostics. Crash logs, stack traces, error codes, launch time, frame rate, memory or device state and related technical events. Automated diagnostic records are configured not to contain content you create. Information included in a support message is processed only when you choose to send it.
• Push notifications. If you allow notifications, a push token, app/device information and delivery or interaction status may be processed. You can disable notifications in device settings at any time.
• Purchases and subscriptions. Product identifier, transaction or receipt identifier, entitlement and subscription status, price/currency information supplied by the store and anti-fraud signals. Apple or Google processes payment-card and billing data; JoyTellect does not receive your full card or bank details.
• Support data. Your email address, app/device information, purchase receipt or order ID, and the content and attachments you choose to send when requesting support or exercising a right.
• Media you select. Some creator apps may let you import or export an image or file using the device’s system picker or share sheet. We process only the item you select for the feature you request and do not upload your media library to our servers.

3.3 Content stored locally

Skins, designs, templates, saved projects and other content you create are stored on your device. JoyTellect does not operate user accounts or a cloud-save service for that content and does not receive it merely because you create or save it. If you export or share content, the operating system and destination service process it under their own terms.

3.4 Data we do not seek

We do not ask for a real name, postal address, telephone number, account password, contact list, precise GPS location, health data, biometric data or private messages to provide the apps. We do not intentionally collect special-category or sensitive personal data. Please do not include such information in support requests.

3.5 App-level processing schedule

The following schedule is the disclosure baseline for current releases. The Apps use the common analytics, diagnostics, attribution and push stack described in section 6. LevelPlay and its mediated advertising partners process data only in builds that display ads. Apple or Google processes store purchases. The Apps do not currently require a JoyTellect account, provide user-to-user chat or offer JoyTellect cloud storage for created content.

A feature listed above processes data only when it is actually used. Device permissions for notifications, images or files are requested at the point the related feature is used and can be withdrawn in device settings.

4. Why we use data and our legal bases

• Provide the app and purchases (contract). Run requested editing, preview, local import/export, receipt validation, entitlements, subscriptions and customer-support features.
• Consent. Use or access information on your device for analytics, attribution or advertising where consent is legally required; access IDFA for tracking; send push notifications; and show personalised advertising. You may withdraw consent at any time without affecting processing already carried out lawfully.
• Legitimate interests. Maintain app stability and security, diagnose crashes, prevent fraud and abuse, measure aggregate product performance and administer our business, where those interests are not overridden by your rights. We apply an opt-out or consent basis instead where law requires it.
• Legal obligations and claims. Keep accounting records, respond to lawful requests, enforce our rights and establish, exercise or defend legal claims.

5. Advertising, attribution and consent

The Apps may be supported by contextual or personalised advertising. JoyTellect uses Unity LevelPlay (formerly ironSource) as the principal mediation platform. LevelPlay may request an advertisement from one of its mediated advertising partners. Those partners are not selected by JoyTellect for every impression and can change over time.

• Where consent is required for storage/access on a device, analytics, attribution or personalised advertising, the consent-dependent components do not initialise or transmit data until the required choice has been recorded. Components strictly necessary to display the privacy interface, prevent fraud, secure the app or serve permitted contextual advertising may operate without advertising consent where law allows.
• The in-app consent interface identifies the relevant processing purposes and available advertising partners and records or transmits the user’s choice. In regions where a reusable consent interface is required, it can be reopened through the app’s Privacy Choices control.
• On iOS, the App Tracking Transparency prompt controls access to IDFA and tracking across apps and websites owned by other companies. Refusing ATT does not prevent contextual ads or privacy-preserving SKAdNetwork measurement.
• AppsFlyer receives in-app events used for campaign attribution and measurement. Configured campaign partners may receive limited postbacks, such as an install or conversion event, in accordance with your choices and applicable law.
• You can change advertising or tracking choices through Privacy Choices in the app, through applicable device settings, or by contacting us. A withdrawal prevents future consent-based processing by components we control after the choice is received; it does not invalidate processing already carried out lawfully.

The current LevelPlay advertising-partner information is available through the consent interface shown in the affected app and Unity’s privacy information.

6. Service providers and other recipients

We disclose only the data reasonably needed for the purposes above. A provider may act as our processor/service provider, as an independent controller/business, or in both roles depending on the service and jurisdiction. Advertising partners may determine their own advertising and fraud-prevention purposes. Where processing is carried out on our behalf or under our control, we require protection no less protective than this policy and applicable law.

Google privacy |

Adjust is not an active data-processing provider in the current processing profile. Legacy Adjust components, if present in a transition build, are disabled and must not initialise or make network requests. Adjust will not be reactivated unless the affected policy, store disclosures and consent configuration are updated before release.

We may also disclose data to professional advisers, auditors, insurers, law enforcement or regulators where necessary, or in connection with a merger, financing, reorganisation or sale of all or part of our business, subject to appropriate safeguards and notice where required.

7. International data transfers

We operate globally and our providers may process data in the United Kingdom, EEA, United States, Israel and other countries. Where UK or EEA personal data is transferred to a country without an applicable adequacy decision, we use an approved transfer mechanism, such as the EU Standard Contractual Clauses and, for UK transfers, the UK International Data Transfer Addendum or International Data Transfer Agreement. We also carry out transfer-risk assessments and use supplementary safeguards where appropriate. You may request information about a relevant safeguard by contacting us.

8. How long we keep data

Retention varies by app, provider, configuration and legal requirement. The periods below are the intended maximums or criteria unless a shorter period applies. We may retain a limited record longer where necessary for security, fraud prevention, litigation or a legal obligation.

9. Your choices and controls

• iOS tracking. Settings → Privacy & Security → Tracking.
• Android advertising ID. Use the advertising/privacy controls in Android or Google settings to delete or reset the advertising ID and manage ad personalisation.
• Consent choices. Open Privacy Choices in the app settings to withdraw or change a consent choice. If the control is not displayed because the app does not use consent-based processing in your region, contact support for assistance.
• Push notifications. Disable notifications for the app in device settings.
• Local content. Delete the content in the app, clear the app’s local data, or uninstall the app. Keep your own exported copy if you want to retain it.
• Support and rights requests. Use https://joytellect.com/contact/. Because there is no JoyTellect account, we may ask for the app name, platform, installation/advertising identifier or purchase order ID needed to locate a record. Do not send more information than requested.

10. UK and EEA data-protection rights

Subject to legal conditions and exceptions, you may have rights to access personal data, correct inaccurate data, erase data, restrict processing, object to processing based on legitimate interests or direct marketing, receive certain data in a portable format, and withdraw consent. You may also complain to the UK Information Commissioner’s Office (ICO) or your local EEA supervisory authority.

To exercise a right, use https://joytellect.com/contact/. We normally respond within one month. We may request proportionate information to verify the request. If we cannot match a pseudonymous identifier to data held by a provider, we will explain what controls or provider request process is available.

ICO complaints: ico.org.uk/make-a-complaint/

10.1 Addendum for EEA residents (EU GDPR representative)

If you are a resident of the European Union, the EU General Data Protection Regulation (EU GDPR) applies to the processing of your personal data.

JOYTELLECT LTD, a company organised and existing under the laws of England and Wales (the Data Controller), has appointed its affiliated EU entity as its designated representative in the European Union in accordance with Article 27 of the EU GDPR.

If you have any questions about how we handle your personal data, or if you wish to exercise your data subject rights (such as the right to access, delete, or restrict your data), you can contact our EU Representative directly:

EU Representative Name: JMH DEVELOPERS OÜ

Postal Address: Vesivärava tn 50-212, Kesklinna linnaosa, Tallinn 10152, Harju maakond, Estonia

Dedicated Email Address: support@jmhdevelopers.com

Our EU Representative is authorized to act on our behalf and serve as a direct point of contact for EU users regarding all matters related to EU GDPR compliance.

11. California and other US state rights

Depending on where you live and whether a law applies to JoyTellect, you may have rights to know/access, correct, delete, obtain a portable copy, opt out of targeted advertising or the sale/sharing of personal information, limit certain uses of sensitive personal information, and appeal a refusal. We will not discriminate against you for exercising a right.

We do not sell personal information for money. However, disclosure of device identifiers, usage/ad data or approximate location to LevelPlay, mediated advertising partners or attribution partners for personalised or cross-context behavioural advertising may be considered a “sale”, “sharing” or targeted advertising under some US state laws.

• To opt out, use Privacy Choices in the app or submit a request through https://joytellect.com/contact/ identifying the app, platform and device/installation identifier. We will disable eligible future processing and transmit available opt-out signals to providers we control.
• Our website does not use browser data for cross-context behavioural advertising. Where technically applicable, we treat recognised opt-out preference signals as a request to opt out of eligible sale, sharing or targeted-advertising processing.
• We do not knowingly sell or share personal information of users under 16. If you believe this has occurred, contact us and we will investigate and apply an opt-out or delete data as appropriate.
• For requests to know, correct or delete, email us. We may verify the request using information already associated with the device or transaction. You may use an authorised agent where law permits.

12. Children and teenagers

The Apps are general-audience products and are not enrolled in the App Store Kids Category or Google Play Designed for Families programme. They are not intended for children under 13, and we do not knowingly collect personal data from a child under 13 without legally valid parental authorisation. Users below the age of legal majority should use the Apps only with a parent or guardian’s involvement.

An app-store age rating describes content suitability and does not mean that an app is directed to children. We recognise that a general-audience creator tool may nevertheless be accessed by a child or teenager. The Apps do not require a JoyTellect account, do not include user-to-user chat, and store created content locally. We do not knowingly use personal information of users under 16 for personalised or cross-context behavioural advertising. Where we learn that a user is a child or receive a legally relevant platform/device signal, we apply required age-based restrictions, avoid personalised advertising and delete personal data where required. Parents or guardians may contact us to request review or deletion.

13. Security

We use reasonable technical and organisational measures appropriate to the nature and risk of the data, including access controls, encryption in transit for data sent from the apps, data minimisation, provider review and incident-response procedures. No transmission or storage method is completely secure. If a breach creates a legal notification duty, we will notify affected users and regulators as required.

14. Changes to this policy

We may update this policy when our apps, providers or legal obligations change. The date on the cover shows the latest version. If a change materially affects your rights or relies on a new consent, we will provide additional notice in the affected app and request consent where required. Earlier versions may be requested from support.

15. Contact

Contact: https://joytellect.com/contact/