Effective date: 10 April 2024
This Privacy Policy describes the privacy practices of TICKBOOM PTE. LTD. (the “Company”, “we”, “us”, or “our”) and how we handle personal information that we collect through our mobile application TickBoom.ai: B2B Fashion App (the “app” or the “application”), our website located at https://tickboom.ai (the “Site”) and through any other applications, websites or services that we own or control and that link to this Privacy Policy (collectively, “TickBoom”). TickBoom consists of an AI-enabled platform serving fashion designers and businesses, including AI-generated product photography and fashion model creation. This Privacy Policy governs the Personal Data (as defined below) collected from or processed about you when you use the services provided by TickBoom, including by downloading, installing, registering with, accessing or otherwise using the application (collectively referred to herein as “Use”).
We provide this Privacy Policy to explain our practices for collecting, using, processing, and disclosing the Personal Data we process about TickBoom users (“users”, “you”, or “your”, as applicable), and to tell you about the rights you may have in relation to your Personal Data and choices you may be able to make in relation to it. By “Personal Data”, we mean information that is (i) associated with an identified or identifiable natural person, and (ii) protected as personal data under applicable data protection laws.
A brief note on how we generate artificial intelligence fashion models (“AI Models”), backgrounds, product descriptions, and related content:
TickBoom primarily uses a fine-tuned version of Stable Diffusion, a text-to-image generative artificial intelligence foundation model, which allows users to generate customized artificial intelligence photos from existing photos or videos. For our product descriptions, social captions and other features, we use an API of ChatGPT, a large language foundation model created by OpenAI, L.L.C. For information about how ChatGPT works, you can review the product overview at http://chat.openai.com.
We do our best to moderate the Stable Diffusion and ChatGPT models, but it is still possible that you may encounter content that you view as inappropriate for you.
We also encourage you to get acquainted with our Terms of Service (www.tickboom.ai/terms-of-service) to understand how we provide our services to you.
We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains what we do with your Personal Data (as defined below) and allows you to manage your Personal Data effectively.
Please read this Privacy Policy carefully to understand our privacy practices. The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it. If you do not want us to process your Personal Data as it is described in this Privacy Policy, please do not Use TickBoom.
By Using TickBoom, you understand and agree that we are providing you with tools for editing and adjusting text, audio, photos, images, videos, graphs, and other information, materials or content, works of authorship of any kind, and information or other materials that are posted, generated, provided or otherwise made available through TickBoom.
If you have any questions about this Privacy Policy or TickBoom, please contact us at privacy@tickboom.ai (for additional contact information, please see Section 13 of this Privacy Policy, “How to Contact Us”).
This Privacy Policy DOES NOT apply to information that:
We may collect Personal Data from and about you:
You may provide Personal Data to us directly, or to Service Providers acting on our behalf, when you Use TickBoom. The Personal Data you provide depends on which features of TickBoom you Use and how you interact with the app.
When you Use TickBoom, we may automatically collect certain data about you. This data is needed for the operation of TickBoom and, among others, may be used for in-app analytics or marketing purposes. The data we collect automatically includes:
If you use an iOS device:
If you use an Android device:
Such automatically collected data helps us operate TickBoom and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and to understand how you use TickBoom and what you like and dislike the most.
The technologies we use for automatic data collection may include:
We use third-party analytics tools, such as Google Firebase, Meta, AppsFlyer and Amplitude, to help us measure traffic and usage trends for TickBoom. These tools collect information via third-party analytics software development kits incorporated into TickBoom, which includes your pseudonymized user ID and the information about TickBoom web pages you visit when following the links available to you on TickBoom, your actions in TickBoom 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 be used to identify any particular 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 TickBoom, please contact us at privacy@tickboom.ai.
We process your photos and videos to provide you with the features of the TickBoom application that you choose to Use. In doing so, when you upload photos or videos containing faces to TickBoom, we process these photos and videos using technology that identifies data that is in these photos and videos and provides us with information, including information that estimates the location of parts and areas of the face (“Facial Data”). The following describes how we process, share, and retain your photos, videos, Facial Data and other elements of your photos or videos in connection with various features of the TickBoom app. Please note, however, that we may retain your data for longer time periods than set forth below where required to do so by law.
Your AI Models are stored on our servers or those of our Service Providers and are available to you within the TickBoom app at any time, via any device from which you log into the TickBoom application, until you decide to either delete the AI Models or delete your TickBoom account. Please be aware that deleting the TickBoom application from your device does not result in the deletion of your TickBoom account.
Notwithstanding anything to the contrary elsewhere in this Privacy Policy:
Personal Data may be processed by both automated and non-automated means and may be stored on our premises and on our Service Providers’ servers. We adopt appropriate technical and organizational measures designed to prevent the loss, improper use and alteration of your Personal Data. For example, we adopt measures to protect your images. However, transmissions of data over the internet are never 100% secure.
Personal Data processed for the purposes of provision of the app, app improvement, customer support, or profiling will be kept for no more than three (3) years from the date of your last interaction with the app or from the date of the expiration of your subscription. If you access the app after your subscription expires, the retention period starts from the date of this most recent interaction with the app.
With specific reference to images, videos, and audio recordings that you upload, as well as Facial Data processed to generate AI Models, the following retention policy applies:
With reference to AI Models, the following retention policy applies:
Upon the applicable expiration date, images, videos, audio recordings, as well as Facial Data processed to generate AI Models and any AI Models themselves, are automatically deleted from our servers and those of our Service Providers.
Personal Data processed for troubleshooting purposes will be kept only as long as necessary to fulfill such purposes, and in any case for no more than one (1) year from the date of your last interaction with the app or from the date of the expiration of your subscription. If you access the app after your subscription expires, this retention period starts from the date of this most recent interaction with the app.
Personal Data processed for compliance purposes will be kept up to five (5) years from the date of your last interaction with the app or from the date of the expiration of your subscription. If you access the app after your subscription expires, this retention period starts from the date of this most recent interaction with the app.
Personal Data processed for purposes of the establishment, exercise or defense of legal claims will be kept up to ten (10) years from the date of your last interaction with the app or from the date of the expiration of your subscription. If you access the app after your subscription expires, this retention period starts from the date of this most recent interaction with the app.
Personal Data processed for marketing purposes will be kept up to two (2) years from the date of your last interaction with the app or from the date of the expiration of your subscription. If you access the app after your subscription expires, this retention period starts from the date of this most recent interaction with the app.
Regarding Personal Data processed for targeted advertising purposes, you can find more information about the retention period of your data by reviewing the privacy policies of the third parties referred to in Section 8 (“Sharing of Collected Information”).
At the end of each of the data retention periods specified in this Section 5, subject to any legal obligation that specifies a longer data retention period, the Personal Data processed will be deleted or anonymized.
We use your Personal Data for a variety of purposes depending on the categories of Personal Data and the ways in which you Use or interact with the TickBoom app, including the following:
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 6 or collect any Personal Data that is not required for the mentioned purposes in accordance with the purpose limitation principle.
For any new purpose of processing that is not compatible with any of the purposes mentioned above, we will ask for your separate explicit consent.
To the extent necessary for any of the processing 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 and store only such amounts and types of your Personal Data that are strictly required for the purposes mentioned in this Section 6 in accordance with the data minimization and storage limitation principles.
Access, modification, correction and erasure. You can send us an email at privacy@tickboom.ai to request access to, or modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. 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 Section 13 of this Privacy Policy, “How to Contact Us”).
Residents of California, Illinois, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy laws, including the rights specified below. You can exercise these rights by contacting us (for contact information, please see Section 13 of this Privacy Policy, “How to Contact Us”).
Please keep in mind that in case of a vague request to exercise any of the aforementioned rights we may engage with you in a dialogue to ask for more details if needed to complete your request. In case this is impossible, we reserve the right to refuse your request.
Following the provisions of the applicable law, 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 any third party is violated by your request, and that the mentioned rights are exercised by an actual Personal Data subject or an authorized person.
Please note that we will process your request within one month of receiving it. We may extend this period by two months where necessary, considering the complexity and number of the requests. If we extend the response period, we will let you know within one month of your request. We will not discriminate against you for exercising your rights under the law.
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:
We do not rent or sell your Personal Data, including photos, videos and Facial Data, to any third parties outside the Company or its Affiliates (as defined below).
Parties with whom we may share your Personal Data.
We may share your Personal Data with businesses that are legally part of the same group of companies that we are part of, including our subsidiaries (“Affiliates”). The Affiliates function as our data processors and may perform data processing on our behalf (e.g., providing technical support or conducting analytics). Such Affiliates are bound by appropriate contractual safeguards in place.
Our Affiliates are:
We also may share your Personal Data and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only based on our instructions (“Service Providers”).
Such Service Providers include:
For the avoidance of doubt, we do not share or transfer your photos, videos or other content with or to third parties, except storing your photos, videos and other content with our cloud providers Amazon Web Services (U.S.A.), Alibaba Cloud and Tencent Cloud to provide online processing and storage functions. We use only secure places of storage, such as Amazon Web Services (U.S.A.), Alibaba Cloud and Tencent Cloud.
What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred.
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 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 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 TickBoom 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 the circumvention of security measures contained in TickBoom. 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 depend on you. Your privacy settings may also be affected by changes to other social media services through which you may share your videos. We are not responsible for the functionality, privacy, or security measures of any other organization.
Security breaches: If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email (if it was provided) and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy, we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.
If you want to report a security incident related to TickBoom, please contact us at privacy@tickboom.ai.
Contacting us: You can provide your feedback or report a technical issue by using the ”Send Feedback“ button in TickBoom settings. The email will be sent from your email to feedback@tickboom.ai, 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.
Contacting you: If you are using TickBoom, you may receive electronic communications from us (e.g., by posting in-app notices in TickBoom, push notifications or emails). These communications may include notices about TickBoom or its in-app subscriptions: e.g., changes/updates to features of TickBoom and their scope, prices of in-app subscriptions, technical and security notices, as well as updates to this Privacy Policy and TickBoom Terms of Use. Upon your consent, we will also share with you our marketing materials about new products, features or offers from TickBoom and its affiliates.
The Company is incorporated in Singapore and uses servers located in the United States (as further explained below). Accordingly, your Personal Data may be transferred to and stored in the United States.
Where required under the EEA GDPR, in case of transfers of Personal Data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your Personal Data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.
Where required under the UK GDPR, in case of transfers of Personal Data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your Personal Data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your Personal Data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.
We use Amazon Web Services servers located in the USA for TickBoom operations, while our analytics operations are processed on [both] the servers provided by Amazon Web Services (located in the USA).
For further information, please contact privacy@tickboom.ai.
General age limitation. TickBoom 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 TickBoom. If you are under 13, do not: (i) Use or provide any information in TickBoom 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 Section 13 of this Privacy Policy, “How to Contact Us”).
Age limitation for EEA residents. Due to requirements of the GDPR, you must be at least 16 years old in order to Use TickBoom. To the extent prohibited by applicable law, we do not allow Use of TickBoom by the EEA residents younger than 16 years old. If you are aware of anyone younger than 16 Using TickBoom, please contact us (for contact information, please see Section 13 of this Privacy Policy, “How to Contact Us”), and we will take the required steps to delete the information provided by such persons.
We are not responsible for the practices employed by any websites or services linked to or from TickBoom, including the information or content contained within them. Where we have a link to a website or service, linked to or from TickBoom, we encourage you to read the privacy policy stated on that website or service before providing information on or through it.
General contact details. If you have any questions about this Privacy Policy or TickBoom, please contact us via email at privacy@tickboom.ai or our mailing address:
TICKBOOM PTE. LTD.
10 Anson Road, #22-02 International Plaza, Singapore 079903
Appointed EEA/UK representative. If you are a resident of the EEA or the UK and you have any questions about this Privacy Policy or TickBoom, please contact us via email at privacy@tickboom.ai
Data protection officer. If you are a resident of the EEA or the UK and you wish to exercise your rights under Section 7, or you have any questions about this Privacy Policy or TickBoom, you can contact our data protection officer via email at privacy@tickboom.ai.
The date this Privacy Policy was last revised is indicated at the top of the page. The Company may modify or update this Privacy Policy from time to time. Some changes do not require your consent: for example, when we add a new purpose of processing that is compatible with the existing purposes, or the new processing activity that falls under the users’ reasonable expectations. However, if the changes made may pose a risk to your rights and freedoms (e.g., by including a new purpose of the processing that is not compatible with the existing purposes of processing, a new legal basis, a new category of Personal Data to be collected or a new data subject, all of which are not reasonably expected by the users), we will ask for your consent to those changes separately from this Policy. If you did not receive a request for your consent to the changes or you refused to give consent, those changes will not apply to you. That fact can negatively affect some TickBoom services provided to you in the event those services inevitably include consent to the changes.