IRYS APP
PRIVACY POLICY

Last Update: This Privacy Policy was last modified on 4 June 2025.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you. We use your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for you to access our service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application refers to the Irys Device app - the software application provided by the Company.

Company refers to Silvertone Media Ltd  (also "we", "us", or "our"), a company registered in England and Wales with company number 15459686 and registered office at:

C/O Gravita Oxford LLP First Floor Park Central 40/41 Park End Street Oxford OX1 1JD United Kingdom

Country refers to: United Kingdom

Device means any device that can access the Service, such as a computer, a mobile telephone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Application and the Irys website and associated sites or applications.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.

Third-party Platform refers to any platform (including website, application or social network) through which a User can login or create an account to use the Service.

UK Data Protection Laws refers to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit, page views, app navigation paths, timing, frequency and pattern of your app use).

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• Address
• First name and last name
• Usage Data
• And any other details you provide when creating an account

A third-party payment processor collects and processes financial information on our behalf; we do not collect or retain your payment information.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser or app version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device You use, your mobile device unique ID, the IP address of your mobile device, Your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your app/browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

Information from Third-Party Platforms

The Company may allow you to create an account and log in to use the Service through a Third-party Platform, as indicated when you sign up.

If you decide to register through or otherwise grant us access to a Third-Party Platform, we may collect Personal data that is already associated with your Third-Party Platform's account, such as your name and your email address.

You may also have the option of sharing additional information with the Company through Your Third-Party Platform's account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected while Using the Application

While using our Application, in order to provide features, we may collect, with your prior permission:

• Information regarding your location
• Content: Any posts, images, videos, or comments you share on the platform
• Pictures and other information from your Device's camera and photo library
• Usage Data: How you interact with the app, such as the pages you visit, likes, saves, and search history.
• Device Information: Information about the device and browser you use to access our app (such as IP address, operating system, and device type).
• Camera information, EXIF data and location; this information is not sold to a third party

We use this information to provide features of our Service, to improve and customise our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on your device.

You can enable or disable access to this information at any time through your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including monitoring the usage of our Service.

To manage Your Account: to manage your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with Us through the Service.

To contact you: To contact you by email, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

To ensure community safety and prevent abuse or spam

To manage your requests: To attend and manage your requests to us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.

For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing and your experience.

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyse the use of our Service, and to contact you.
• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• With other users: when you share personal information or otherwise interact in the public areas with other users (i.e. in the form of comments), such information may be viewed by all users and may be publicly distributed outside. 
• To protect the rights, safety, or property of our users or our platform
• With your consent: We may disclose your personal information for any other purpose with your consent.

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Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information.

Deletion of your Personal Data

You have the right to delete or request that we assist in deleting the Personal Data that we have collected about You.

Our Service may give you the ability to delete certain information about you from within the Service.

You may update, amend, or delete your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information that you have provided to Us.

Please note, however, that we may need to retain certain information when we have a legal obligation or a lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Storage & Security of Your Personal Data

The security of Your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. 

While we strive to use commercially acceptable means to protect Your Personal Data from unauthorised access or disclosure, we cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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Your Rights Under UK Data Protection Laws

If you are located in the United Kingdom, your personal data is protected under UK Data Protection Laws. In accordance with these laws, you have the following rights:

• Right of Access – You can request access to the personal data we hold about you.
• Right to Rectification – You may ask us to correct inaccurate or incomplete data.
• Right to Erasure – You can request the deletion of your personal data in certain circumstances.
• Right to Restrict Processing – You may request us to limit the way we use your data.
• Right to Object – You have the right to object to certain types of data processing, such as direct marketing.
• Right to Data Portability – You can request a copy of your data in a structured, commonly used and machine-readable format.
• Right to Withdraw Consent – Where our processing is based on your consent, you may withdraw it at any time.

If you wish to exercise any of these rights, please contact us at privacy@irysphotos.com. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe that we have not handled your personal data appropriately. You can contact the ICO via their website: www.ico.org.uk.

International Data Transfers

Many of our external third parties are based outside the UK so their processing of personal data may involve a transfer of data outside the UK. 

Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards permitted under the UK Data Protection Laws is used.

These may include:

• Transfer to countries or organizations that have officially been deemed to provide an adequate level of protection for personal data by the ICO, which currently includes the EEA (see here for an up-to-date list)
• Transfers to companies which are certified under the UK’s data bridge for UK/US transfers (the Data Privacy Framework)
• Using a specific contract approved by the EU/ICO - the EU Standard Contractual Clauses and the International Data Transfer Addendum. We use this contract for transfers to the US, where the recipient is not certified under the Data Privacy Framework.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. 

Cookies and Similar Technologies

A cookie is a piece of text containing a unique identifier, which is stored on your computer by your web browser or by your mobile device. They are basically a tool that stores information about app use and websites’ visits.

Mobile apps use unique identifiers associated with your device, similar to cookies, such as device identifiers and third-party services for analytics, to collect data such as your geo-location or your network location. This data is used in the same way as cookies, e.g. to analyse and improve services to you.

For simplicity, in this Policy we also refer to all these technologies as “Cookies”.

Strictly Necessary Cookies

These Cookies are necessary for the Application to function and cannot be switched off in our systems, or the Application will not work properly. They are usually only set in response to actions made by you which amount to a request of services, such as setting your privacy preferences, logging in or filling in forms, making payments, uploading photographs, chatting or to localise your experience.

We also use Cookies to help keep the Application and our users safe and secure. These Cookies do things like protect users from spam and fraud by ensuring the safety of your personal data.

We may use persistent Cookies, which will help us to ensure we have identified that the same device is logging in to the correct account. These types of Cookies also help with our anti-spam measures and help us to prevent phishers, scammers, unauthorised login attempts to your account and accessing any hacked accounts. 

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: privacy@irysphotos.com
• By post: Silvertone Media C/O Gravita Oxford LLP First Floor Park Central 40/41 Park End Street Oxford OX1 1JD United Kingdom