KIXDAY

Privacy Policy

1. Introduction

KIXDAY is a sneaker battle app by ShoeTracker.ai (the “App”), owned and operated by ADS Delivery OOD, a company incorporated under the laws of Bulgaria, company number 208549000, with its registered seat at 192A Cherni Vrah Blvd., 1407 Sofia, Bulgaria (“ADS”, “we”, “us” or “our”).

KIXDAY has no user accounts in this version. Viewing a battle and voting on it are available to anyone who holds the battle link.

When you use the App, we may process information that constitutes personal data under Regulation (EU) 2016/679 (“GDPR”) and personal information under other applicable data-protection laws. This Privacy Policy explains how we collect, use, disclose, store and protect that information, and describes the rights available to individuals whose data we process.

For privacy-related enquiries, please contact us at info@shoetracker.ai.

2. Data Protection Role

ADS Delivery OOD acts as Data Controller for the personal data processed through KIXDAY, including in relation to the administration, security and operation of the App.

3. What Personal Data We Process

Depending on which features you use, we may process the following categories of personal data:

Using the App without an account does not mean that you are anonymous to us. When you vote, an identifier stored in your browser and a salted hash of your IP address are processed so that duplicate votes and abuse can be prevented.

The App is not designed to collect special categories of personal data, such as biometric, health, political or religious information, and ADS does not intentionally solicit such data.

ADS does not perform facial recognition or biometric processing. The App does not access a device microphone, does not record audio and does not record video from a device camera; the camera, where you choose to enable it, is used only to capture a still image that you then choose to submit. Photograph the shoe, not people. Images showing people, faces or personal data are prohibited by the Community Rules.

4. How We Use Personal Data and Legal Bases for Processing

We process personal data only where there is an appropriate lawful basis under applicable data-protection law. We may rely on the following legal bases:

Certain personal data may be necessary to provide a requested feature. If such information is not provided, the relevant functionality may not be available.

5. Recipients and Service Providers

We may disclose personal data only where necessary to provide, operate, secure and support the App, or where required by law. The service providers currently engaged are:

We may also disclose personal data to professional advisers, such as lawyers and accountants, where reasonably necessary and subject to appropriate confidentiality obligations, and to public authorities where disclosure is required by applicable law, regulation, court order or a lawful request from a competent authority. Providers may be added, replaced or removed as the App develops, and this Policy will be updated accordingly.

We do not sell personal data to third parties and do not disclose personal data for targeted advertising.

6. Image Processing and Your Content

When you submit an image, it is transmitted to Replicate, which separates the sneaker from its background and returns the cut-out. ADS requests deletion of the prediction from the provider’s systems right after processing. ADS does not independently verify that each such request is carried out.

Automated screening may be applied to submitted content for safety and moderation purposes. Such tools are applied on a best-efforts basis and are not capable of identifying every item of prohibited content. They supplement, and do not replace, the Report button and the removal mechanisms described in the Terms of Service.

KIXDAY does not identify the sneaker model from your image. Brand and model names are typed by you.

ADS does not use images you upload, or the outputs generated from them, to train or fine-tune AI models. Any future change to this would require a prior update to this Privacy Policy and any consent or other lawful basis required by applicable law before it took effect.

You retain your rights in the images and other content you upload. ADS receives a limited licence to process, store, display and serve such content only as necessary to provide and operate the App, as described in the Terms of Service.

The share video (about nine seconds, without audio) and preview image are generated on your device from the cut-out images. Nothing is posted automatically; you decide whether and where to share.

Battles are unlisted links and are not shown in a public feed. However, a battle, its cut-outs and your handle are accessible to anyone who holds the link, and your Locker page is public for your handle. When a link is shared, the cut-out is exposed through a public URL used for link previews, which messaging and social-media apps may cache. Where content is shared to an external platform or messaging service, or downloaded by a recipient, ADS cannot recall or delete those copies.

KIXDAY does not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. Automated screening may result in an individual image being refused or removed; this affects that item of content only.

7. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, and records expire automatically as follows:

Certain records may be retained longer where required for legal compliance, security, fraud prevention, dispute resolution or another lawful purpose.

You can delete your own battles and Cards from the browser that holds your creator key. You can also request deletion by emailing info@shoetracker.ai with the battle link. Where content has been delivered through a content-delivery network, cached in a link preview or shared to an external service, copies held in those caches, or by recipients, may persist after the original has been removed from our storage.

8. International Data Transfers

Personal data may be processed by our service providers outside the European Union / European Economic Area (EEA), including in the United States. Certain infrastructure and network providers may also process data through global networks or in other jurisdictions depending on routing and service availability.

Where a recipient is covered by an adequacy decision of the European Commission, including where applicable a United States recipient participating in the EU-US Data Privacy Framework, ADS may rely on that adequacy decision. Where personal data is transferred to a third country for which no adequacy decision applies, ADS relies on recognised transfer mechanisms, including the European Commission’s Standard Contractual Clauses (“SCCs”), together with additional safeguards where appropriate.

Further information about the safeguards applied to international transfers may be requested by contacting us at info@shoetracker.ai.

9. Your Privacy Rights

Depending on your jurisdiction and subject to applicable law, you may have rights in relation to your personal data, including:

You may also have the right to lodge a complaint with the competent data protection authority, including the Bulgarian Commission for Personal Data Protection where applicable.

To exercise these rights, contact us at info@shoetracker.ai and include the relevant battle link where you can. Because the App has no accounts, we may need to verify that you are the person who created the content, or ask you for the link to it, before we act on a request, in order to protect other users. We will respond within the period required by applicable law.

10. Security Measures

ADS implements appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure, including encryption in transit, access controls, rate limiting and anti-abuse controls.

Media that forms part of a battle, Card or Locker page is served from addresses that are not listed in a public feed but that are accessible to anyone who holds the link. Such media is not protected by a login, and you should share those links only with people you intend to see the content.

No online service can guarantee absolute security. Where required by applicable law, ADS will notify the relevant supervisory authority and affected individuals of a personal data breach.

11. Cookies and Similar Technologies

KIXDAY uses cookies and browser storage where necessary to operate and secure the App. These include the creator key stored in your browser, which lets you delete your own content, and the random voter identifier stored in a cookie, which allows one vote per browser and supports abuse prevention. These technologies are necessary for the App to function and are not subject to consent.

If analytics or other non-essential technologies are introduced, they will be used only where permitted by applicable law and, where required, with your consent. We do not use cookies for targeted advertising.

Clearing your browser’s site data removes the creator key and the voter identifier. Without the creator key you can still request deletion of your content by email.

12. Children’s Privacy

KIXDAY is intended for users aged 16 and over, or the applicable minimum age in your jurisdiction where higher.

In the United States, we do not knowingly collect personal information online from children under the age of 13.

Before creating content you are asked to confirm that you are 16 or older. Such a confirmation is a self-declaration; ADS does not collect a date of birth and does not verify age against any external source.

If we become aware that personal data relating to a child has been collected or processed in circumstances that do not comply with applicable law or our applicable age requirements, we will take reasonable steps to delete or otherwise appropriately handle that information.

A parent or legal guardian who has concerns about the processing of a child’s personal data may contact us at info@shoetracker.ai.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the App, our data-processing practices, legal requirements or other relevant developments.

Where changes are material, we will notify users through the App, by a notice on our website or by another appropriate method. The “Last updated” date at the top of this Privacy Policy indicates when it was most recently revised.

Where applicable law requires consent to a change in processing, we will obtain such consent as required.

14. Contact Us

If you have any questions about this Privacy Policy, the processing of your personal data or the exercise of your privacy rights, you may contact us at:

ADS Delivery OOD
UIC: 208549000
192A Cherni Vrah Blvd., 1407 Sofia, Bulgaria
Privacy enquiries: info@shoetracker.ai, subject line: Privacy Request