Blurpeg Privacy Policy
1. ABOUT THIS POLICY
(a)Blurpeg is provided by Clever Iterations Pty Ltd (ABN 19 695 039 019), New South Wales, Australia (Clever Iterations, we, us or our).
(b)This Privacy Policy explains how:
(i)the Blurpeg app for iPhone, iPad and Android (App) processes photos, images and PDFs on your device;
(ii)we handle personal information that we receive through Apple or Google services, support communications and the Blurpeg website; and
(iii)you can contact us about your personal information or make a privacy complaint.
(c)We are responsible for personal information that we receive and control. Where applicable data-protection law uses the term controller, we are the controller of that information. Apple, Google and other third parties may separately handle information under their own terms and privacy policies.
(d)We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles set out in that Act (the Australian Privacy Principles). Where applicable law in another jurisdiction imposes additional requirements, including the EU and UK General Data Protection Regulations (GDPR and UK GDPR) and the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA), we will comply with those requirements in relation to personal information we hold about individuals located in those jurisdictions.
(e)This Policy applies to Blurpeg. Where this Policy is inconsistent with the Clever Iterations Privacy Policy that applies across our other products, this Policy prevails in relation to Blurpeg.
2. PRIVACY BY DESIGN
(a)Blurpeg is designed so that its core redaction functions operate on your device.
(b)Through the App's core redaction functions, we do not receive:
(i)the photos, images or PDFs that you process in the App (User Content);
(ii)face regions detected by the App;
(iii)manual redaction regions that you add; or
(iv)any redacted image or PDF that you save (each an Output).
(c)The App does not require a Blurpeg account and does not contain advertising or product-analytics SDKs.
(d)The App does not use User Content to train an artificial intelligence or machine-learning model.
(e)The App does not disclose User Content to a third-party artificial intelligence or machine-learning provider.
3. HOW THE APP PROCESSES USER CONTENT
(a)Photos and images. Blurpeg supports photos captured through the App and images selected from your existing photo library.
(b)When you capture a photo through Blurpeg, the App temporarily holds the image in device memory while you review it. The App is designed to save the newly rendered Output only when you choose to save it.
(c)When you select an existing image, the original remains in your photo library and Blurpeg saves a separate Output.
(d)On iPhone and iPad, you may also select a document image from your photo library or Files through the separate manual document-image workflow. On Android, manual redaction regions can be added in the image editor. Vectrari™ Face is not used in the separate iPhone and iPad manual document-image path.
(e)Vectrari™ Face runs on your device and detects where faces may appear (bounding-box or region detection). It does not generate an identification template, face vector, or other biometric identifier capable of uniquely identifying a natural person. It is used for detection only, in the photo workflows that offer face suggestions. Detected regions and manual regions are transient information used to support the current review and redaction session.
(f)Automated face detection can miss a face. You must review the image and may add a manual redaction region before saving.
(g)PDFs. PDF redaction is manual. Blurpeg presents the PDF for page-by-page review and processes the document locally on the device so that you can add redaction regions.
(h)Blurpeg does not automatically detect faces, text, names or other information in a PDF.
(i)Blurpeg writes the PDF Output when you choose to save. When you save, Blurpeg rasterises each page and generates a new image-only PDF containing the selected visual redactions. The original PDF remains in its original location unless you separately delete or replace it.
(j)A PDF may contain metadata, attachments, annotations, forms, scripts, hidden text, hidden layers or other non-visible information. Please review the Blurpeg Terms of Use and the complete Output before relying on or sharing a redacted PDF.
(k)Output files and device storage. For image Outputs, Blurpeg renders the selected redactions into the pixels of a newly encoded image file. Blurpeg is designed so that source location, EXIF and camera metadata are not carried into that Output. For PDF Outputs, Blurpeg is designed so that source metadata is not carried into the newly generated PDF. The PDF Output contains newly created output metadata, such as creation and modification timestamps and a producer value, and the suggested output filename on iPhone and iPad preserves the source file name. Android uses a generic suggested filename. Review the filename before sharing. Your device, photo library or file-storage provider may add its own information to a file after you save it.
(l)Your device, photo library, file-storage provider and backup settings control the storage, synchronisation, backup and sharing of User Content and Outputs after processing.
(m)Blurpeg does not delete originals, backups or copies held outside the App.
4. APP PERMISSIONS
(a)Blurpeg may request access to:
(i)the camera, when you choose to capture a new photo;
(ii)the system photo picker on iPhone, iPad or Android, when you choose an existing image;
(iii)add-only photo-library access on iPhone and iPad, when you ask Blurpeg to save an image Output; and
(iv)the platform's system file-selection or sharing functions, when you choose or save a PDF. Android saves image Outputs through the system media collection without requesting access to your whole photo library.
(b)Blurpeg uses these permissions only to provide the function you request.
(c)You can manage camera and photo-library permissions in your device settings. Access granted through a system picker is generally limited to the items you choose, subject to the platform and file provider's operation of that service.
5. INFORMATION WE MAY RECEIVE
(a)Apple and Google services and purchases. If you download Blurpeg or purchase an unlock through the Apple App Store or Google Play, the relevant store may process information about your store account, storefront, transaction, download, device and use of its services under its own terms and privacy policy. The App communicates with the relevant store to retrieve prices, complete purchases and check or restore ownership. Your photos, PDFs and redaction regions are not sent to the store for editing.
(b)We do not receive your payment-card details from Apple or Google. Blurpeg stores local export-allowance and purchase-entitlement information on your device. On Android, this includes a signed purchase receipt used to verify access locally; it is not uploaded to a Clever Iterations purchase server. If you enter a complimentary access code on Android, Blurpeg verifies and stores that signed code locally on your device. Redeeming the code does not contact our servers. Google Play manages purchase confirmation and acknowledgement. A later store check can update access following a refund or revocation.
(c)Apple and Google may provide us with store sales, order, download and aggregate usage reports and, depending on platform settings and services, crash or diagnostic information. Google's billing components may also process technical information about billing operations to operate and support the payment service. Diagnostic information may include technical information such as the App version, device model, operating-system version, error time and information about an App failure.
(d)Support and privacy communications. If you contact us, we may receive:
(i)your name, email address and other contact details;
(ii)the content of your message;
(iii)files or screenshots that you choose to provide; and
(iv)technical information that you provide about your device, operating system or App version.
(e)Please do not send us unredacted confidential or sensitive User Content unless it is necessary for us to address your request and you have authority to provide it.
(f)Blurpeg website. The Blurpeg website does not use client-side analytics, advertising cookies or tracking pixels.
(g)The website's hosting infrastructure may process standard request information, such as your IP address, browser type, requested page, timestamp and security-event information, to deliver and protect the website and maintain operational logs.
(h)Blurpeg's primary website server is a Linode virtual private server located in Sydney, Australia.
6. HOW WE USE INFORMATION
(a)We may use information that we receive to:
(i)provide and support Blurpeg;
(ii)respond to questions, support requests, privacy requests and complaints;
(iii)investigate crashes, faults, misuse and security incidents;
(iv)maintain, secure and improve the App and website;
(v)manage Apple App Store and Google Play distribution, transactions and reporting;
(vi)comply with legal obligations and protect our lawful rights; and
(vii)complete a corporate transaction, subject to appropriate confidentiality and privacy protections.
(b)We do not use information for targeted advertising or cross-app tracking.
(c)We do not sell User Content or other personal information.
(d)Where applicable law requires a legal basis for processing, we rely on one or more of:
(i)performing our agreement with you or taking steps at your request;
(ii)our legitimate interests in operating, securing, supporting and improving Blurpeg, where those interests are not overridden by your rights;
(iii)compliance with a legal obligation; and
(iv)your consent, where we ask for it.
(e)We do not use contact details provided for a support request, privacy request or complaint for direct marketing unless you separately ask to receive product updates or otherwise consent.
7. DISCLOSURE OF INFORMATION
(a)We may disclose personal information that we receive to:
(i)service providers that host or secure the Blurpeg website, provide email and support systems, store business records or provide professional and technical services;
(ii)Apple or Google, where necessary to manage distribution through their stores, support, technical issues or a transaction;
(iii)our professional advisers, insurers and auditors;
(iv)a regulator, law-enforcement body, court or other person where required or authorised by law; and
(v)a buyer, investor or successor in connection with a proposed or completed sale, merger, restructure or transfer of all or part of our business or assets, subject to appropriate confidentiality and privacy protections.
(b)We require service providers that handle personal information for us to protect it and use it only for the services they provide, subject to applicable law.
(c)Apple and Google collect and process information independently when providing their stores, payment and related services. Their respective privacy policies govern that processing: Apple Privacy Policy and Google Privacy Policy.
8. OVERSEAS PROCESSING AND DISCLOSURE
(a)The Blurpeg website is hosted in Australia as described in clause 5(h). Apple, Google and some other service providers that support app-store distribution, email, support, security, professional services or business administration may process or store personal information outside Australia.
(b)Apple and Google are based in the United States and may process personal information there and in other countries in which they operate. Our other service providers are likely to process personal information in Australia and the United States, and in other jurisdictions where our global providers operate.
(c)Where required by applicable law, we take reasonable steps to ensure that an overseas recipient protects personal information in a manner consistent with applicable privacy requirements.
9. RETENTION AND DELETION
(a)We do not hold User Content or Outputs processed solely on your device. We cannot access or delete those files. You control them through your device, photo library, file-storage and backup settings.
(b)We retain support communications, diagnostic information and business records only for as long as reasonably necessary for the purposes described in this Policy, including to provide support, investigate an issue, maintain security, comply with law and resolve disputes.
(c)We retain website security and request logs only for as long as reasonably necessary to deliver, secure and troubleshoot the website, and ordinarily for no longer than 14 days, unless a longer period is required by law or needed to investigate a security incident.
(d)When information is no longer required, we take reasonable steps to delete it or de-identify it, subject to applicable legal and technical requirements.
(e)You may request deletion of personal information that we hold by contacting us. We will assess the request under applicable law. We may need to retain some information where required by law or where a lawful exception applies.
10. SECURITY
(a)Blurpeg reduces data-transfer risk by performing its core detection and redaction functions on your device.
(b)We use reasonable administrative, technical and organisational measures to protect personal information that we receive against misuse, interference, loss and unauthorised access, modification or disclosure.
(c)No technical system can guarantee absolute security. You should protect your device and accounts, review each Output before sharing it and use appropriate device, storage and backup controls.
(d)We maintain processes to assess and respond to suspected data breaches affecting personal information that we hold. If a breach must be notified under applicable law, we will notify affected individuals and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme and, where applicable, the relevant EU or UK supervisory authority, as soon as practicable after we become aware of the breach. Where notification to a supervisory authority is required under the GDPR or UK GDPR, we will notify within 72 hours where feasible.
11. CHILDREN
(a)Blurpeg is not directed to children under 13. It is principally intended for adults and organisations that want to reduce identifying detail in photos, images and documents.
(b)A person must be at least 13 years old to use Blurpeg. A person under 18 may use Blurpeg only with the permission and supervision of a parent or legal guardian. If applicable law sets a higher minimum age for digital services or requires verifiable parental consent, that requirement must be met.
(c)A parent, guardian or other authorised adult may use Blurpeg to process User Content that contains a child. Blurpeg does not create an account or persistent identity profile for that child or any other person.
(d)Blurpeg does not decide whether consent or another lawful basis exists to capture, process, retain, publish or share User Content containing a child. The person using Blurpeg remains responsible for those decisions.
(e)If you believe that we have received personal information from a child in circumstances where we should not hold it, please contact us.
12. YOUR PRIVACY RIGHTS
(a)Depending on the law that applies to you, you may have a right to:
(i)ask whether we hold personal information about you and request access to it;
(ii)request correction or deletion;
(iii)object to or request restriction of processing;
(iv)receive certain information in a portable form;
(v)withdraw consent where processing is based on consent; and
(vi)complain to a privacy or data-protection authority.
(b)You may exercise a right by contacting us. We may need to verify your identity before responding. We will respond within the period required by applicable law.
(c)You may deal with us anonymously or using a pseudonym where practicable, although this may limit our ability to investigate or respond to your request.
13. PRIVACY COMPLAINTS
(a)To make a privacy complaint, please contact us and describe the issue. We aim to acknowledge the complaint within 5 business days and provide a substantive response within 30 days, subject to any different period required by applicable law.
(b)If you are not satisfied with our response, you may contact:
(i)the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au;
(ii)the UK Information Commissioner's Office (ICO) at ico.org.uk;
(iii)a supervisory authority in the EU Member State in which you live or work, or in which the alleged infringement occurred; or
(iv)another privacy or data-protection regulator that has jurisdiction in your location.
14. CHANGES TO THIS POLICY
(a)We may update this Policy if Blurpeg's functions, data practices or legal obligations change.
(b)We will publish the updated Policy and its effective date. If a material change affects how we collect, use or disclose personal information, we will, where reasonably practicable, give at least 30 days' notice through the App, our website or app-store release information before the change takes effect. We may give shorter notice where reasonably necessary to address an urgent legal, security or technical issue. We will obtain consent where required by applicable law.
15. CONTACT
(a)For questions about this Policy, to exercise a right, or to make a privacy complaint, please contact us at:
(i)Email: privacy@blurpeg.com (Attention: The Privacy Officer); or
(ii)Post: Suite 74, Ground Floor, 135–153 New South Head Road, Edgecliff NSW 2027, Australia (Attention: The Privacy Officer).
(b)For general support, please contact us at hello@blurpeg.com.
(c)Clever Iterations Pty Ltd, ABN 19 695 039 019, New South Wales, Australia.