Enigmatic Saola LTD (“the Company”, “we”, “us”, or “our”), a company registered at HaKeren 1, Ra’anana, Israel, places great importance on protecting the privacy of everyone who uses our software (“You”). This Privacy Policy (“Policy”) forms integral part of our Software (as defined below) terms in the End User License Agreement (“Terms”) and governs the manner in which information, including Personal Data (meaning any information that identifies or could reasonably identify a specific individual (“Personal Data”)), related to your use of the ClearBG software application (“Software”) and its associated services, is processed. Our approach to data handling is designed to align with applicable privacy frameworks, including the General Data Protection Regulation (GDPR) (“GDPR”) and the California Consumer Privacy Act (CCPA) (“CCPA”), where applicable.
Capitalized terms used but not defined in this Policy carry the meanings given to them in our Terms. Any Personal Data you provide us is provided on a voluntary basis and, where required by applicable law, based on your consent.
You acknowledge that you are not legally obligated to permit us to process, including collecting your Personal Data, and that any such processing is based on your consent. However, declining to do so may limit access to certain features of the Software.
Data We Collect
During your interaction with our Software, including access or use the Software, we may process the following categories of information:
1. Non-Identifiable Data. This means information that does not identify you as an individual and cannot reasonably be linked to an identifiable individual. This includes technical and operational data that cannot be traced back to a specific individual, such as operating system version, device configuration, preferred language, and aggregated performance metrics. This data is collected automatically to support the proper functioning and improvement of the Software.
2. Personal Data. This includes information that could, directly or indirectly, identify you — for example, IP addresses, queries submitted through the Software’s interface, images you upload through the Software (to the extent such images contain Personal Data, for example a person’s face), or other digital identifiers. We process such data for the following purposes:
- To ensure the Software operates as designed and delivers its core functionality.
- To handle support inquiries and respond to user feedback.
- To maintain the integrity and security of the Software and detect fraudulent activity.
- To meet our legal obligations and manage user consent records.
How We Process Your Data
The Company, together with its authorized service providers, may collect online identifiers (such as IP addresses) as well as contextual and technical data generated through your use of the Software. This information is used to support analytics, operational continuity, and ongoing improvement of our services.
In addition, to the Software enabling you to upload images, we may process any Personal Data included in such images that you choose to provide through the Software, solely to provide the requested functionality, such as background removal and/or background replacement.
GDPR — Legal Basis for Processing
Where GDPR applies, we process data based on one or more of the following legal bases when processing Personal Data:
- Contractual Necessity: Processing required to provide the services you have requested from us.
- Legitimate Interests: Processing is necessary to secure, maintain, and enhance the Software.
- Consent: Processing that depends on your having given us clear, specific permission for a defined purpose.
Categories of Personal Data Collected and Disclosed
Over the preceding twelve-month period, we may have shared the following categories of Personal Data with third parties for legitimate business purposes:
- Category A — Identifiers: Such as IP addresses and other network-based identifiers.
- Category F — Internet or Electronic Network Activity: Including interactions with the Software and search queries processed through it.
- Category H — Visual: Including images uploaded by you, which may include images of individuals.
These disclosures were made to the following categories of third party recipients:
- Infrastructure and Hosting Providers: Engaged to maintain the availability and stability of our services.
- Analytics Partners: Who assist us in measuring and improving Software performance.
- Affiliated Entities and Revenue Partners: For internal reporting, fraud prevention, and revenue attribution purposes. To manage preferences related to interest-based advertising, you may use external tools, such as opt-out tools offered by the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI).
Data Sharing
We do not sell your Personal Data. However, Personal Data may be shared, including disclosure in limited circumstances, such as:
- To service providers operating under appropriate confidentiality and data protection obligations.
- When disclosure is required by law, court order, or a legitimate government authority.
- In connection with a merger, acquisition, or transfer of business assets, where the receiving entity assumes equivalent privacy obligations.
- With your prior explicit consent.
Data Security
We apply industry-standard technical and organizational safeguards to protect your Personal Data against unauthorized access, loss, alteration, or disclosure. While we take these obligations seriously, no digital system can guarantee absolute security. If you become aware of any potential vulnerability or unauthorized access, please notify us promptly at [email protected].
Your Privacy Rights
Subject to applicable law and your jurisdiction, you may be entitled to exercise the following rights with respect to your Personal Data:
- Request access to the Personal Data we hold about you.
- Request correction or deletion of inaccurate or outdated Personal Data.
- Request deletion of your Personal Data, subject to legal retention obligations.
- Restrict or object to specific processing activities.
- Withdraw consent where processing is consent-based, without affecting prior processing.
- Lodge a complaint with a relevant data protection supervisory authority.
To the extent the CCPA applies: you have the right not to be discriminated against for exercising any of your privacy rights. This includes protection against denial of goods or services, differential pricing, or any other adverse treatment. You may also have the right to request that your Personal Data not be sold, where applicable.
Requests will be handled in accordance with applicable legal requirements, and we may request additional information to verify your identity.
We may require identity verification before processing certain requests. If you believe you hold additional rights not listed above, please contact us to discuss. To exercise any of your rights, reach us at [email protected].
Data Retention
Personal Data is kept only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law, regulation, or dispute resolution obligations. Where data is no longer needed for identifiable purposes, it may be anonymized or aggregated and will no longer constitute Personal Data under this Policy.
Children’s Privacy
The Software is not directed at individuals under the age of 16. If you have reason to believe that a child has submitted Personal Data through our Software, please contact us at [email protected], and we will take appropriate steps to investigate and, where confirmed, delete such data in accordance with applicable law.
Updates to This Policy
We reserve the right to revise this Policy at any time to reflect changes in law, our operational practices, or the features of our Software. The “Last Updated” date at the top of this document indicates when the most recent version took effect. Continued use of the Software after any revision constitutes your acceptance of the updated Policy.
Contact Us
For any questions or concerns about this Policy or our data practices, please reach out to us at: [email protected].