Privacy Policy | Limna

Limna App Privacy Policy

This is the Privacy Policy for the application called Limna (“App”), a trading name of the Artfacts.net Ltd. The App is operated by or on behalf of Artfacts.net Ltd (‘we’, ‘us’ or ‘our’). This policy sets out how we collect and use your personal data in connection with the provision of our services to you through the App.

We are committed to protecting and respecting your privacy. Please read the following carefully to understand our views and practices regarding your personal data and how we may treat it. By accepting our services and using the App, you acknowledge you have read and understood this privacy policy. For the purposes of UK and European Economic Area data protection law, (the “Data Protection Law”), the data controller is: ArtFacts.Net Ltd of 1-2 Craven Road, London, England, W5 2UA.

Information collected about you and how we use it

The App will collect and process the following personal data from you:

  • Information you give us This is information you enter directly when you interact with the App. This includes where you:

    • Register to create an account with us.
    • Ask questions or submit a query.
    • Enter into and pay for a subscription or other features on the App.

Find out more

This is information about you that you record by filling in forms and using different App features. It includes information to:

  • Register to create an account with us: you will need to set up an account with us in order to use certain features of the App. We ask for:

Identity information: your name, preferred name and chosen password

Contact information: your email address.

This is so we can create an account in your name, identify you as the account holder when you log in and use the App and contact you where appropriate with specific administrative service messages about your account.

  • Ask questions: if you submit a query regarding the App, we will use the details you provide to investigate and respond.

Identity information: in connection with responding to any questions or enquiries you raise with us.

  • Enter into and pay for a subscription or other features: if you enter into a subscription with us, or pay for a subscription or other features on the app we will require:

Identity information: your name, preferred name and chosen password.

Contact information: your email address.

This information is backed-up to a secure external hosted database and subject to encryption in transit to and from the App.

  • Information we collect about you from your use of the App: we will automatically collect usage information from you each time you visit the App. This includes:

    • Technical information.
    • Information about your engagement with the App.
    • Location data.

Find out more

  • Technical information: we collect the internet protocol (IP) address used to connect your device to the Internet, your device make and model and identifiers, App version, and operating system version. We also receive information about the content of a request as well as the time zone setting, date associated with the request.
  • Information about your engagement with the App: may include the App session data traffic, including date and time, content viewed or searched for, content load response times, download errors, length of session. This is so that we understand how the App is used and in the case of your searches, display to you ranked feedback, editorial content, summary reports and sponsored content relevant to your search terms.
  • Location data: we may also derive your approximate regional location. Delivery of location services will involve reference to one or more of: (a) the coordinates (latitude/longitude) of your location and/or your Identifier for Advertisers (IDFA) code for your Apple device, or a similar device identifier. See Tracking technologies below for more information on the use of tracking technologies and device identifiers on the App.

You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed in the table at the bottom of this privacy policy.

Tracking technologies

The App uses cookies and/or other similar technologies to collect and store certain information. These typically involve pieces of information or code transferred to or accessed from your mobile device to store and sometimes track information about you. Such technologies enable you to be remembered when using that device to interact with online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

The App uses tracking technologies to distinguish you from other users of the App. This helps us to provide you with a personalised experience when you navigate the App and also allows us to improve our content and services. Most browsers and devices automatically accept tracking technologies, but if you prefer, you can change your device privacy settings to enable you to do this. We also give you information about how to disable tracking technologies below. However, you may not be able to take full advantage of our App if you do so.

A number of tracking technologies we use last only for the duration of your App session and expire when you exit the App. Others are used to remember you when you return to the App and will last for longer. We use such technologies on the basis of our legitimate interests (where such technologies are strictly necessary for the operation of the App (and we have considered that these are not overridden by your rights), or otherwise where you have consented to their use.

We will not deploy tracking technologies used to tailor advertising on your device without receipt of your prior permission.

Find out more

We use the following types of tracking technologies:

  • Analytical/performance technologies. They allow us to recognise and count the number of users and to see how they engage with our App content and features. This helps us to identify in our legitimate interests, ways of improving our App, for example by ensuring that users are finding what they are looking for easily.
  • Functionality technologies. These are used to recognise you when you return to our App. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
  • Tracking technologies. Such technologies record your visit to our App, how you navigated the App and the links you have followed. We will use this information subject to your choices and preferences to make our App more relevant to your interests. We may also share this information with third parties for this purpose.

Disabling tracking technologies

If you want to disable tracking technologies used on the App, you can change your device privacy settings to reject tracking technologies. Where you have not set your permissions, we may also separately prompt you regarding our use of tracking technologies through the App. You can find more information about the individual tracking technologies we use and the purposes for which we use them below.

Tracking technology Data collected Purpose
App ID App ID Necessary in our legitimate interest for remembering you as the same user as you navigate / engage with the App.
Authentication token Authentication token Necessary in our legitimate interest for identifying you as a particular user as you navigate / engage with the App.
Google Firebase Cloud Messaging App ID and version With your consent, this enables the sending of in-app push messages to the devices of users who activate push messaging using a pseudonymised ID which does not directly identify the user to Google. Push messaging is capable of being deactivated or reactivated at any time in the settings of the user's mobile device. Where messaging is deactivated IDs are retained for 180 days and then deleted. Google Firebase privacy policy here.
Google Firebase Crashlytics Device ID, stack traces, app state, OS information Error diagnosis service used with your consent to improve the stability of the App. In the event of an App crash, data of the app condition along with the operating system of the mobile device running the App and an App ID which does not directly identify the user, is transmitted to Google servers. Google Firebase privacy policy here.
Google Firebase Core Firebase user agent, which includes device, OS, app bundle ID and developer platform The user agent is never linked to a user or device identifier and is used by the Firebase team to determine platform and version adoption in order to better inform Firebase feature decisions. Google Firebase privacy policy here.
Google Analytics App instance ID, anonymised IP address, screen views, session information This enables us to analyse the browsing behaviour of our users. By analysing the obtained data, we are able to compile information about the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. Google Firebase privacy policy here.
Google Firebase A/B Testing None but see notes A/B Testing does not collect data, but uses data collected from Google Analytics to create and administer experiment groups. Google Firebase privacy policy here.
Google Firebase Performance Monitoring IP address to geographically segment performance data, app performance metrics (launch time, network request latency), CPU/memory usage, device, OS and app information Performance monitoring so that we can optimise the app and ensure it works well for users. Google Firebase privacy policy here.
Google Firebase Remote Config Firebase user agent, which includes device, OS, app bundle ID and developer platform, device country code, language code, time zone, OS version, Apple app ID, bundle ID. Remote Config enables us to change the behaviour and appearance of the App without requiring users to download an update. Google Firebase privacy policy here.
Apple Push Notification Service Push Notification Token If you opt in to receiving push notifications, this token allows us to send them to you. Apple privacy policy here.
Appsflyer This helps us to perform marketing performance analysis. Appsflyer privacy policy here.

Communications and notifications

Where permitted in our legitimate interest we may communicate specific administrative service messages about your account. We will not otherwise send communications (including promotional messaging) unless in response to a specific enquiry made by you to us, where in connection with our legal obligations or in any other case, only where we have first obtained your express consent.

Push notifications are facilitated by Apple’s Push Notification Service. You will be able to choose whether to receive push notifications or not. We store a token for each user that enables push notifications.

Who we give your information to

We may make personal information available to:

  • A member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for their own purpose, we will only transfer the information to them for that purpose with your prior consent.

  • Selected third parties.

Find out more

Our selected third parties may include:

  • Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes supporting the services we offer through the App, in particular those providing data hosting services, providing fulfilment services, distributing any communications we send, facilitating feedback on our services and providing App support and development services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only access your information to the extent necessary to perform their support functions. For example:

    • marketing performance analysis (including AppsFlyer which may process your information in Israel, the US and elsewhere – Privacy Policy); and

    • marketing communications mobile measurement and deep linking platform (including Branch which may process your information in the US – Privacy Policy).

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual). For example, Google Analytics.

  • Online advertiser partners. Where you have given your consent to the use of relevant tracking technologies, we may work with social media platforms and digital advertising platforms to show you advertising for our services on other websites and social media platforms. For instance, if you show an interest or buy a product or subscription on our App, we may advertise that or other products we think may be of interest and you may see them on other websites and on your Facebook or other social media feeds.

  • Error and performance monitoring providers. For example:

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
  • If ArtFacts.Net Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of ArtFacts.Net Ltd, our end users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and to prevent cybercrime.

Where we store your information

The information provided by you that we collect is hosted on secure servers located within Europe (in particular the European Economic Area (“EEA”) and the UK) and, may specifically be hosted and or processed on secure servers in the context of the country you reside and where the App is provided, (where required by law).

To the extent any access to your personal information or transfer of such information is anticipated outside the UK or EEA in the context of supporting the operation of the services provided through the App, we will take steps to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy finding or mechanism, and that it is treated securely and in accordance with this privacy policy.

Find out more

We may transfer your personal information outside the UK and EEA:

  • In order to support the operation of the services provided by the App.
  • Where we are legally required to do so.
  • In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

This includes Google’s Firebase services, in respect of pseudonymised App usage data (that does not directly identify users to Google) may be transmitted to Google servers in the USA. Google Firebase client processing terms include approved standard contractual clauses for protection of any personal data transfers.

Where we transfer your personal information to a jurisdiction not subject to a relevant legal transfer adequacy finding, we will take steps to ensure an appropriate legal adequacy safeguard is in place which usually means, use of specific approved contracts that rely upon standard contractual clauses for the protection of personal data.

For further information on transfers outside of the UK and EEA and/or the specific safeguard methods adopted, please contact hello@limna.ai.

Payment processing

It is possible to make payments on the App via your Apple ID settings . You will be providing any payment card information directly to Apple which authorised payment. Information which you supply to them is not within our control and is subject to Apple’s privacy policy and terms and conditions.

Child safety

Protecting the safety of children when they use the Internet is important to us. The App is intended for use only by persons who are at least 18 years of age. By using the App, you confirm to us that you meet this requirement. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using the App or sending us personal information.

How we protect your information

Personal information you provide to us is stored on secure servers. Where you have chosen a password, which enables you to access our App you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Our App may, from time to time, contain links to external sites. When you engage with sponsored content on the App that will take you to a third party site we will notify you that you are about to leave the App. We are not responsible for the privacy policies or the content of such sites.

The App does not use personal data to make automated decisions in any way that has any legal effect or significantly affects you.

How we protect your information

We retain personal data for as long as you use the App and have an account with us. We may also retain aggregate information for research purposes and to help us develop and improve our products and services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data,
  • to request that your provided personal data be moved to a third party, and
  • where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us as set out below

You may opt out at any time from allowing further access by us to your location data by altering the privacy settings of your device. You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device.

You can also exercise the rights listed above at any time by contacting us at hello@limna.ai.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see https://edpb.europa.eu/about-edpb/about-edpb/members_en). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 14 April 2022.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be sent to hello@limna.ai.

Purpose and lawful basis for processing of personal data

This table sets out:

  • What personal data we process
  • What we use that data for
  • The lawful basis for the processing

It forms part of our privacy policy above which you should also read.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user of the App (a) Identity
(b) Contact
Performance of our terms with you.
To manage our relationship with you which will include: (a) Notifying you about to our terms or privacy policy (b) Responding to your questions and queries (a) Identity
(b) Contact
(a) Performance of our terms with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how users engage with the App and our services).
To administer and protect our business and this App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation
To deliver relevant content to you (a) Identity
(b) Contact
(c) Usage
(d) Technical
Necessary for our legitimate interests (to study how users engage with our services, to develop them, to grow our business and to inform our business strategy).
To use data analytics, crash reporting and push messaging and linking tools to improve our website, products/services. (a) Technical
(b) Usage
(a) Necessary for our legitimate interests (to define types of users for our services, to keep our website updated and relevant, to develop our business and to inform our business strategy)
(b) Consent (where applicable to the particular method of collection (e.g. tracking technologies).
To make our App and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. (a) Technical
(b) Usage
Your consent.
To share aggregated and anonymised analytics with advertising partners and other organisations about how people use the App. You cannot be identified from this information. (a) Technical
(b) Usage
Necessary for our legitimate interests (growing our business and informing our marketing strategy).
To perform our contract with you for the entry into and purchase of a subscription or other features. (a) Identity
(b) Contact
(a) Performance of our terms with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how users engage with the App and our services).