1. GENERAL INFORMATION
This Privacy Policy governs the processing of personal data of users of the FaceLive application, developed by the development group Sam&Felix on behalf of the company Lowegate.
2. DATA COLLECTED
2.1 Registration Data
- Username
- Email address
- Password (encrypted)
- First and last name
- Registration date
2.2 Location Data
- GPS coordinates (latitude and longitude)
- Position timestamps
- Location accuracy
2.3 Multimedia Content
- Recorded videos (VideoLog)
- Profile images
- Screenshots and photos
- Metadata associated with multimedia files
2.4 Technical Data
- IP address
- Browser User Agent
- Device type
- Operating system
- Access and usage logs
3. PURPOSE OF PROCESSING
- Service Provision: User account management and application functionality
- Geolocation: User mapping and geographic video logging
- Security: Abuse prevention and infrastructure protection
- Improvement: Usage analysis to optimize user experience
- Communications: Sending service-related notifications
- Monetization: Displaying advertisements through Google AdSense
4. LEGAL BASIS
Data processing is based on:
- Data subject consent (art. 6, par. 1, lett. a GDPR)
- Contract performance (art. 6, par. 1, lett. b GDPR)
- Legitimate interest of the controller for security and service improvement
5. DATA SHARING
5.1 Authorized Third Parties
- Google AdSense: For advertising display
- Google Maps: For mapping and geolocation services
- Hosting providers: For service delivery
5.2 Competent Authorities
Data may be disclosed to competent authorities when required by law or to protect the rights and safety of users and third parties.
6. DATA RETENTION
- Account data: Until account deletion
- VideoLog and content: Until manual removal by user
- Location data: 24 months from collection
- Access logs: 12 months
- Security backups: Additional 30 days for data recovery
7. USER RIGHTS
In accordance with GDPR, users have the right to:
- Access: Request information about processed data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request removal of personal data
- Restriction: Limit processing in specific circumstances
- Portability: Obtain data in structured format
- Objection: Object to processing for legitimate reasons
- Withdraw consent: Revoke consent at any time
8. SECURITY MEASURES
- SSL/TLS encryption for communications
- Password hashing with secure algorithms
- Automatic backups and data redundancy
- Access monitoring and suspicious activity detection
- Regular security updates
- Restricted access to personal data
9. DISCLAIMERS
IMPORTANT - LIABILITY LIMITATIONS
Use of the FaceLive application is at your own risk. The development group Sam&Felix and the company Lowegate disclaim all responsibility for:
9.1 Direct and Indirect Damages
- Moral, physical, psychological or economic damages arising from app use
- Loss of data, videos, images or other content
- Privacy violations by third parties
- Improper use of content published by other users
- Consequences arising from user geolocation
9.2 User-Generated Content
- Sam&Felix and Lowegate are not responsible for content uploaded by users
- Users are solely responsible for their VideoLogs, photos and shared data
- Uploading illegal, defamatory or third-party rights violating content is prohibited
- The platform does not perform preventive content checks
9.3 Security and Hacking
- No guarantee of absolute security against cyber attacks
- Possible data breaches despite implemented security measures
- Service interruptions for maintenance or technical problems
9.4 Geolocation Use
- Risks related to geographic position sharing
- Possible consequences for personal safety
- Stalking or harassing behavior by other users
10. LEGAL LIABILITY LIMITATION
Sam&Felix and Lowegate shall not be held liable for:
- Consequential damages or indirect damages of any nature
- Economic losses arising from app use or malfunction
- Third-party rights violations caused by users
- Legal actions taken by third parties against users
- Unauthorized commercial use of content
- Illegal behavior by users on the platform
10.1 Maximum Liability
In any case, the maximum liability of Sam&Felix and Lowegate is limited to €0 (zero euros), as the application is provided free of charge.
10.2 Indemnification
Users agree to hold harmless and indemnify Sam&Felix and Lowegate from any claim, damage, loss, cost or expense arising from app use.
11. COOKIES AND TRACKING
11.1 Technical Cookies
- Session cookies for login and navigation
- Preference cookies for user settings
- Security cookies for CSRF protection
11.2 Third-Party Cookies
- Google AdSense: Cookies for personalized ads
- Google Maps: Cookies for mapping services
- Google Analytics: Cookies for traffic analysis (if implemented)
12. INTERNATIONAL TRANSFERS
Data may be transferred and processed in countries outside the EU, particularly:
- United States: For Google services (AdSense, Maps)
- Countries with EU adequacy decisions
- Countries with appropriate safeguards according to GDPR
13. MINORS
The application is not intended for minors under 16 years old.
We do not knowingly collect data from minors. If a parent or guardian discovers that their child has provided personal data, they must contact us immediately for removal.
14. PRIVACY POLICY CHANGES
We reserve the right to modify this Privacy Policy at any time. Changes will be:
- Published on this page with update date
- Notified to users through the application
- Effective immediately after publication
Continued use of the application after changes constitutes acceptance of the new Privacy Policy.
16. COMPETENT COURT
For any dispute related to this Privacy Policy, the court of Munich (Deutschland) shall have jurisdiction, with application of Italian law and EU Regulation 2016/679 (GDPR).
ACCEPTANCE
Use of the FaceLive application implies full acceptance of this Privacy Policy.
Document valid from August 12, 2025
© 2026 Sam&Felix - Lowegate. All rights reserved.
FaceLive v2.1.2 - Privacy Policy v1.0