Privacy policy

1. Who is responsible for your data

The data controller is Romain Pamart EI (Pam's Factory), email: pams.factory@gmail.com.

We have not appointed a data protection officer. For any question about your data or to exercise your rights, write to pams.factory@gmail.com.

2. What data we process, why, and on which legal basis

We do not collect your payment card details (they are handled by Google Play or Apple), your contacts, your location or the content of photos you do not put in a synced project. We do not use your photos for any other purpose than showing them to you: no advertising profile, no training of artificial intelligence models. What you choose to share with the community is also shown to the other users and reviewed as described in section 5.

3. Free trial and device fingerprint

The 7-day free trial is offered once per account and once per device. To check the device, the app sends the identifier of its installation, from which our server computes a fingerprint that cannot be reversed (SHA-256 with a secret key). Only this fingerprint is stored, with the account that started the trial. When you delete your account, the fingerprint is kept without any link to you, so that the device cannot start a new trial.

4. Cloud sync

During the free trial and with Ruban Pro, your projects and templates, the photos and images they use (JPEG, PNG, or a compact encoding of RAW data), their thumbnails, your film recipes and your LUTs are copied to your account so that you can find them on your other devices. They are only accessible to you, through your account, unless you choose to share an item with the community (section 5).

Once an account is back to the free version (end of the trial, refund), its cloud copies are deleted 30 days after the end of the trial (or after Ruban Pro was removed, if later). The projects on your devices are not affected.

5. The community

Sharing a film recipe or a template with the other users is optional, item by item. Once published, what you share and the public name you chose are visible to every signed-in user: keep personal data out of them. Your email address and the name of your account are never shown. When a template is submitted, its images are re-encoded and their metadata, location included, is removed.

Before a template or a recipe with an example photo is published, its images are sent to Google Cloud Vision, which estimates whether they may contain adult or violent content. Depending on the case, this result helps our moderators or is enough for the item to be published or refused automatically; you can always ask for a person to review a refusal. Moderators see what you submit, your public name, your account identifier and your history in the community, but not your email address or your purchases. The administrators of Ruban can also see your account details and the storage your account uses.

When you report an item, its author does not learn who reported it. Reports and the decisions taken on them are kept for 400 days after the decision; your identifier is removed from your reports when you delete your account.

If you withdraw an item, it leaves the catalogue, and the example photo of a recipe is deleted. If you delete your account, everything you shared is withdrawn and no longer linked to you, and the example photos of your recipes are deleted. The images of a template that was published stay stored, because projects made from it use them; write to us if you want them deleted. We keep what is needed to handle a dispute or answer the authorities, to whom we report illegal content when the law requires it.

6. Purchases

Ruban Pro is bought through Google Play or the App Store, which process the payment as independent controllers under their own privacy policies. They send us a proof of purchase, which our server checks with them before unlocking Ruban Pro on your account. We keep a record of each purchase for 10 years, as required by French accounting law (Commercial Code, art. L123-22); when you delete your account, this record is kept without any link to you.

7. Statistics and crash reports

Usage statistics (Google Analytics for Firebase) are only collected if you agree, in the consent form displayed at first launch. You can change your choice at any time in Settings › Privacy. We use them in aggregate form only (for example: how many people applied a film this week).

Crash reports (Firebase Crashlytics) contain technical information about the crash and the device, not the content of your projects. They are kept 90 days.

8. Advertising in the free version

The free version shows ads served by Google AdMob; the trial and Ruban Pro show none. In the European Economic Area, the United Kingdom and Switzerland, a consent form (Google User Messaging Platform, IAB TCF framework) asks you, at first launch, whether ads may be personalised and whether information may be stored on or read from your device. Without consent, only non-personalised or limited ads are shown. On iOS, the app also asks for your permission before accessing the advertising identifier (App Tracking Transparency).

You can change your choice at any time in Settings › Privacy › Ad privacy choices, and reset or delete the advertising identifier in the settings of your device. How Google uses data for advertising: policies.google.com/technologies/ads.

9. This website

This website does not use cookies, analytics or advertising. The account deletion page uses Firebase Authentication to sign you in: your session is stored in your browser only while you use it and is removed when you sign out. Our hosting provider keeps technical logs (IP address, browser, pages requested) for security, for 30 days.

10. Who receives your data

Your data is only accessible to Pam's Factory, to the people it appoints to moderate the community, and to the following recipients, within the limits of their task:

• Google (Google Ireland Limited and Google LLC), as processor: Firebase Authentication, Cloud Firestore, Cloud Storage, Cloud Run, Firebase Hosting, Firebase Cloud Messaging, Google Analytics for Firebase, Firebase Crashlytics, Cloud Vision (scan of the images submitted to the community), under the Google Cloud and Firebase data processing terms.
• Google AdMob for the ads of the free version, as independent controller for personalised advertising, under Google's privacy policy.
• Google Play and Apple (App Store) for purchases and payments, as independent controllers.
• The other users of Ruban: only what you choose to share with the community, with your public name.

We never sell or rent your data. We may disclose it to the authorities when the law requires it.

11. Transfers outside the European Union

Our server and our database are hosted in the European Union (Google Cloud, Belgium). The photos and thumbnails of synced projects and the images shared with the community are stored in the United States (Google Cloud Storage, Iowa), and Google may process some data in other countries for its services. These transfers are covered by the EU-U.S. Data Privacy Framework, under which Google LLC is certified, and by the standard contractual clauses of the European Commission (Decision 2021/914) included in Google's data processing terms, with additional security measures such as encryption in transit and at rest. You can ask us for a copy of these safeguards.

12. How long we keep your data

13. Security

Data is encrypted in transit (HTTPS) and at rest. Access to your synced content is restricted to your account by security rules checked by our servers; purchase tokens and device identifiers are only stored as fingerprints. Access to our administration tools is limited to Pam's Factory and to the people it appoints to moderate the community, and logged.

14. Your rights

You have the right to access your data, to have it corrected or deleted, to restrict its processing, to receive it in a portable format, to object to processing based on our legitimate interest, and to withdraw your consent at any time (without affecting the processing carried out before). Under French law, you can also give instructions about what happens to your data after your death.

Most of these rights can be exercised directly in the app (Settings), or by writing to pams.factory@gmail.com. We answer within one month; we may ask you to prove your identity, for example by writing from the email address of your account.

If you think your rights are not respected, you can lodge a complaint with the French data protection authority, the CNIL (3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, www.cnil.fr), or with the authority of your country of residence.

15. Deleting your account

You can delete your account at any time in the app (Settings › Delete my account) or on this page. Your account, your profile and your synced content are deleted immediately; purchase records and the device fingerprint are kept without any link to you, as explained above. What you shared with the community is withdrawn and no longer linked to you (section 5).

16. Minimum age

Ruban is intended for people aged 16 or over. We do not knowingly collect data from younger children; if you think a child has created an account, write to us and we will delete it.

17. Changes

We may update this policy, for example when a feature changes. The date at the top shows the latest version; we will tell you in the app before any important change takes effect.

18. Contact

Romain Pamart EI (Pam's Factory), pams.factory@gmail.com.