privacy

Privacy Policy

This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) by Bending Spoons S.p.A. (“we” or “us”), the parent company of Splice Video Editor S.r.l., when you use the Alight Motion application (“app”) or otherwise interact with us and this Privacy Policy is presented to you, in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).

If you are a California resident, please see Section 11 (Additional Information for California Consumers) below.

1. Data Controller and Data Protection Officer

The Data Controller is Bending Spoons S.p.A., based in Via Nino Bonnet 10, Milan, MI 20154 (Italy), VAT 08931860962. For any requests regarding the processing of your personal data, please email us at privacy@bendingspoons.com.

Our Data Protection Officer can be contacted by sending an email to dpo@bendingspoons.com for any requests relating to the processing of your personal data or this Privacy Policy.

2. Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing

We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.

Purpose	Legal Basis	Data Collected
1. To enable you to use the app and to provide you with its functionalities.	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	> Identification and contact information, identifiers and Internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, and unique identifiers), and other information necessary to enable you to use the app. If the app needs to access your photo and video library, your music library, or your microphone recordings when you use the app, it requires your permission. However, all processing of this data occurs on your device, and we do not collect or have access to such data, except for data which will be strictly necessary to provide you with specific features (such as to upload an Alight Motion project package containing your project files and media to our cloud services, and to share your project with other users). If you create an account or login with your Facebook, Google or Apple account, we will also receive the following information: first and last name, profile photo, and email address.
2. To improve our products and services	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to improve our products and services.	> Identification and contact information you provide us (such as name, social media handle, or email address, when requested), identifiers and Internet and network activity information (such as IP address), and information collected or generated to improve the app’s functionalities (such as device language, information about your interactions with the app, inferences we generate and other related information about your usage of the app). For the purpose of statistical analysis, we may also collect information and metadata related to your images, videos and other media files.
3. To ensure the quality and the proper functioning of the services	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to ensure the quality and the proper functioning of the services.	> Identifiers and Internet and network activity information (such as IP address, device model, device type, OS version, crash and error logs), inferences we generate and other related information about your usage of the app.
4. To comply with our legal obligations	When this activity is required by a specific legal obligation, your personal data may be used to the extent required to comply with the legal obligation itself (Article 6.1.c GDPR).	> Any information which may be required by law or under the instructions of public authorities.
5. To process and respond to customer support communications and to requests for information you may raise with us.	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	> Identification and contact information you provide us (such as first and last name, email address), identifiers, subscription type, OS version, country, and the content of your communication or request.
6. To establish, exercise or defend our rights and those of our employees	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations.	> Any information necessary to ensure the performance of these purposes.
7. To analyze your usage information, including your preferences, interests and behaviors	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR). The collection of personal data by means of profiling and third-party analytics tracking technologies is based on your consent (art. 122 of Italian Privacy Code).	> Identification and contact information (such as name, age or email address, when requested), subscription status, identifiers and Internet and network activity information that we collect (such as IP address), information about your interactions with the app, inferences we generate and other related information about your usage of the app.
8. To carry out marketing activities	The legal basis for the processing is your consent (art. 6(1)(a) of the GDPR). Where your consent is not required, the legal basis is our legitimate interest (art. 6(1)(f) of the GDPR).	> Identification and contact information (such as name, email address), identifiers and Internet and network activity information (such as IP address), information we may receive from third-party advertising networks and platforms (such as unique identifiers, including IDFA or AAID), information about your interactions with the app, inferences we generate and other related information about your usage of the app (such as your responses and your voice in case you take part in our interviews).
9. To install third-party tracking technologies to provide you with personalized ads.	The legal basis for the processing is your consent (Article 6(1)(a) of the GDPR).	> Identifiers and Internet and network activity information (such as IP address, unique identifiers including IDFA or AAID, crash logs and diagnostic information, performance data such as app launch time, hang rate, or energy usage), information about your interactions with the app, and advertising data (such as advertisements seen), your ad tracking choices and consent to receive personalized ads (if granted), and inferences about your interests and preferences. IDFA (on iPhone or iPad) and AAID (on Android devices) are unique device identifiers provided by the operating system of your device.

3. Data Storage and Protection

Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

Personal data processed for the purposes referred to in Section 2.a), 2.b), 2.e), 2.g) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than three (3) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Personal data processed for the purposes referred to in Section 2.c) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than one (1) year from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Personal data processed for the purposes referred to in Section 2.d), will be kept up to for a maximum of five (5) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.

Personal data processed for the purposes referred to in Section 2.f) will be kept up to ten (10) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Personal data processed for the purposes referred to in Section 2.h) will be kept up to two (2) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

For the purposes referred to in Section 2.i), you can find more information about the retention period of your data by visiting the third parties’ privacy policies linked in Section 12 (In-app Tracking Technologies).

At the end of these specified periods, unless any legal obligations require a longer data retention, the processed personal data will be either deleted or anonymized.

4. Your Choices with Regard to the Use of Your Personal Data

It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.d), and 2.e). If you do not provide the personal data, you will not be able to enjoy the app’s services and features.

Where we rely on your consent for the purposes referred to in Section 2.h) and 2.i), your provision of personal data is optional, and you have the right to withdraw your consent at any time. If you do not provide the personal data, you will still be able to enjoy the app’s services and features.

Where we rely on our legitimate interest for the purpose referred to in Sections 2.b), 2.c), 2.f), 2.g) and 2.h), you may, at any time, exercise your right to object to such processing as explained in Section 7 (Your Rights) below.

You can also manage how you share certain information with us by adjusting the privacy and security settings on your mobile device.

5. Recipients of Your Personal Data

We may share or disclose your personal data to the following categories of recipients:

Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers.
If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers.
If you choose to participate in a contest, sweepstakes or promotion we offer, information and content you submit in connection with the contest or promotion may be shared publicly as part of our marketing and advertising efforts.
Public, judicial or police authorities, within the limits established by applicable laws.

Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

According to Section 2.i), if you give your consent to install tracking technologies, you will allow third parties mentioned therein to collect personal data about you in order to show you customized and personalized advertising.

6. Transfers of Personal Data Outside the European Economic Area

We may transfer personal data from the European Economic Area (“EEA”), the UK or Switzerland to other countries outside the EEA. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Laws.

7. Your Rights

At any time and free of charge, you can exercise the following rights:

Right of access.
Right to rectification.
Right to erasure.
Right to restriction of processing.
Right to data portability.
Right to object.
Right to withdraw your consent.

You also have the right to lodge a complaint before the competent national Data Protection Authority.

8. Children’s Personal Data

The app is not intended for anyone under the age of 16. We do not knowingly collect personal data from children.

9. Third-party Websites and Services

The app may include links to other websites or services operated by third parties. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.

10. Changes to this Privacy Policy

We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws.

11. Additional Information for California Consumers

This section provides additional disclosures required by the California Consumer Privacy Act (“CCPA”).

a) Additional Information Related to Collection, Use, and Disclosure of Personal Information

We collect personal information from several sources: directly from you, automatically when you use the app, and from other sources. In the preceding 12 months, we have collected identifiers; internet or other electronic network activity information; commercial information; approximate geolocation information; audio and visual information; inferences; and other information that relates to or is reasonably capable of being associated with you.

b) Rights of California Consumers

Subject to certain limitations, CCPA provides California consumers the right to:

Request more details about the categories and specific pieces of personal information that we process.
Request the deletion of their personal information.
Opt out of “sales” of personal information.

12. In-app Tracking Technologies

When we refer to “tracking technology/technologies” in this Policy, we mean any technology that stores or accesses information on the user’s device.

Types of tracking technologies used in the app

Tracking Technology	Purpose	Retention	Publisher	Description	Privacy Policy Link
Alight Motion SDK (technical)	Technical	3 years	First-party	It is essential for the app to function correctly.	N/A
Firebase Crashlytics	Technical	3 years	Third-party	Essential for the app to correctly interact with the backend.	Google Privacy Policy
AppLovin	Technical Profiling	Defined by the Third Party	Allows us to show you advertising, and customize it according to your preferences.	AppLovin Privacy Policy
Adjust	Profiling	3 years	Third-party	A mobile attribution tool for measuring the effectiveness of our ads.	Adjust Privacy Policy
IronSource SDK	Technical Profiling	Defined by the Third Party	Allows us to show you advertising and customize it according to your preferences.	IronSource Privacy Policy

Tracking technologies settings

You can activate or disable profiling and third-party analytics tracking technologies at any time through the “Privacy Settings” within the app.

Last updated: April 16, 2025