Privacy Policy

This privacy policy (the “Privacy Policy”) applies to the processing of personal data (the “Personal Data”) of the users carried out by Toretei S.r.l., an Italian company with legal seat in Via T. Salvini n.25, Rome (Italy) through its application named ReDraw in accordance with Regulation (EU) 2016/679 - General Data Protection Regulation or the “GDPR” - as well as the Italian Legislative Decree 196/2003 (as amended) and other applicable local laws, as amended or replaced time by time (jointly, the “Applicable Privacy Laws”).

Toretei S.r.l. in the Data Controller pursuant to the Applicable Privacy Laws and for any request regarding this Privacy Policy and your rights you can write to:

Toretei S.r.l., Via T. Salvini n.25, Rome (Italy)


Here at Toretei S.r.l. we are committed to protecting and respecting your privacy. We take your privacy seriously and will use your personal information exclusively to provide the services related to the ReDraw use (the “Services”) and only after obtaining your consent to the collection and processing of your personal data (the “Personal Data”) on the terms specified below.

This Privacy Policy explains when, where, how and why we collect personal information about you (the “Data Subject”), how we use the information, the conditions under which we may disclose it to others, your rights in respect of your personal information, as well as how we keep it secure.

This Privacy Policy applies to all visitors, users, and others who access the Services.

When the processing of Personal Data requires your consent, the Data Subject may give his/her consent only if aged at least 16 years (see art. 8 of the GDPR).

The Services are not for children under the age of 16. Toretei S.r.l. does not knowingly collect personal data from children. If you believe we have received personal data from children under the age of 16, please email us at

If the Data Subject is under the age of 16, the consent must be given by a parent or other holder of parental responsibility (in the latter case, the Data Controller shall make every reasonable effort to verify that consent is given or authorized by the holder of parental responsibility).

Should the Data Controller realize that some users are aged below 16 and consents have not been given by parents (or holders of parental responsibility), it shall immediately delete the processed data and close the related account forthwith.

We collect from you the following data:

(a) Information you provide us directly. When you use our Services, we collect the information that you provide us directly:

- Basic Data. We may collect some your basic data such as name, age, email address which are necessary to enable you to use our Services.

- Photos. We may collect the photos that you upload from your mobile device while using our application. Please note, you won’t be able to upload content from your camera roll unless you consent the access to your device’s camera, being in any case excluded any autonomous access.

- Facial features. We may collect the facial feature data separately from your photos only to provide you with the portrait functionality of ReDraw.

Please note that the possible collection of photos and/or facial feature will not be made for facial recognition and will be completely anonymous and will be exclusively made to the end to improve the neural models of Redraw and, therefore, of the Services.

(b) Usage data. When you use our Services, we may collect information about your activity within our Services, for example, which pages you have viewed and for how long. We also may collect IP-addresses, the source of the traffic, information regarding the device and operation system, information about your wireless and mobile network connections, unique device identifiers, browser type, language, battery level, and time zone.

We collect usage data with the help of Google Analytics and Facebook. With the use of Google Analytics and Facebook, we collect such data as IP-Address, your device model, screen resolution and operation system, session durations, app events, your location. Basing on these data, we analyze your needs and interests, evaluate effectiveness of our campaigns and improve our App to make its content relevant to you and the App itself available for smooth viewing with your device.

As indicated above we may collect your photos and/or facial features but only on an anonymous basis and only to the end of improve the neural models of Redraw and, therefore, of the Services. This collection will be exclusively made by Toretei S.r.l.’s team and will not in any case the transfer of such photos and/or facial features to third parties.

(c) Cookies and similar technologies. Like most online services and mobile applications, we may use cookies — tiny pieces of code that remain in your device after you have visited any websites and online services. When you use that website or application for the next time, these pieces enable their owners to provide you with information customized for your needs.

We use cookies for authentication purpose only. When you access the Services or content, ReDraw uses session cookies, meaning that if you close the Services, cookies expire and no longer have any effect. You shall specifically agree to our use of cookies when you use our Services by clicking the respective button in the notification and, in any case, you may block, delete, or disable saving cookies on your device. You can turn the cookies off by choosing the appropriate settings of your browser.

ReDraw does not use your photos and facial features for any reason other than to provide you with the art portrait functionality of ReDraw and, as above indicated, to improve the neural models of Redraw and, therefore, of the Services. In no way ReDraw will use your photos and facial features for face recognition, as ReDraw does not introduce the face recognition technologies or other technical means for the processing of biometric data for the unique identification or authentication of a user.

We may use the information other than photos or facial features to:

- provide, improve, test, and monitor the effectiveness of our Services;

- perform troubleshooting, diagnose or fix technology problems;

- enhance the safety and security of the Services;

- monitor and analyze trends and usage;

- develop and test new features of the Services;

- understand your needs and provide services and advertisements that are relevant to you;

- use the information we have collected from cookies and similar technologies to enhance our Services and your experience with them.

The photo you upload (the “Uploaded Content”) is collected exclusively for its display in the library for the user’s repeated use and convenience of the Services usage. Uploaded Content is stored at the on-line secured data storage of Amazon Cloud and displayed to you exclusively during your use of the Services. By submitting this content for the art portrait you expressly agree for its collection and storage as set forth herein.

If ReDraw decides to change the purposes of processing specified above, we will inform you on such changes prior to use your Personal Data within the newly set purposes and ask for your separate consent if required by the Applicable Privacy Laws.

Toretei S.r.l. does not share your information with other partners.

Toretei S.r.l. manage and storage Personal Data only on secure places of storage of Amazon Cloud. Amazon Cloud is located in the United States of America and complies with the requirements of the EU-US Privacy Shield and is appointed as Data Processor.

Toretei S.r.l., by means of its supplier Amazon Cloud, adopts all technical and organizational measures for preventing the loss, improper use and alteration of Personal Data.

Personal Data processed to fulfill legal obligations and obligations related to the use of the Services will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than 10 (ten) years from the termination of the agreement (i.e. after the cancellation of the Redraw’s account) except for any legal obligation that sets a longer data retention period. At the end of this period, the processed data will be deleted or anonymized.

Personal Data processed for the use of Redraw will be kept for no more than 2 (two) years from their collection except for any legal obligation that sets a longer data retention period. At the end of this period, the processed data will be deleted or anonymized.

The provision of supply Personal Data above is mandatory. Any refusal to provide the requested data could make it impossible to enjoy the Services.

The provision of Personal Data for the purposes indicated above occurs on the basis of the legitimate interest of the Data Controller, pursuant to art. 6(1)(f) of the GDPR. In any case, Data Subjects can at any time exercise the rights referred to in point no. 7 to have such processing ceased.

The provision of Personal Data related to cookies is optional. Any refusal to provide such data will not result in any detrimental consequences within the use of the App.

Personal Data may be disclosed to the following categories of recipients:

public, judicial or police authorities, within the limits established by applicable laws and regulations;
third parties carrying out activities that are related or instrumental to the Data Controller’s activities, as outsourced data processors duly appointed in writing by Toretei S.r.l. in accordance to the Applicable Privacy Laws or acting as autonomous data controllers (such as, by way of example only, suppliers providing IT maintenance and development services, IT or filing services providers, suppliers of mobile marketing services, in case this Notice refers that marketing activities are performed).

The complete and updated list of such entities is available for consultation upon request by sending an email to

Your data will not be disclosed for any reason other than those stated above nor disseminated, unless such disclosure is deemed necessary for the fulfillment of legal obligations and/or regulations.

Toretei S.r.l. may also transfer Personal Data, currently held in United States of America at Amazon Cloud’s servers, to different countries also located outside the European Economic Area (EEA). In such cases, Toretei S.r.l. will make sure that such transfer is based on appropriate safeguards listed in the GDPR, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission concerning the States in which the addressees are based; (c) binding corporate rules adopted by Toretei S.r.l. and approved by the competent authorities or that are parties of agreements with the Toretei S.r.l. in this regard.

Any user, at any time and free of charge, can have and/or exercise the following rights, as specified in the GDPR:

the right to be informed on the purposes and methods of the processing;
the right of access;
the right to obtain a copy of the Personal Data held overseas and obtain information concerning the place in which such data are kept;
the right to ask for updating, rectification or integration of the Personal Data;
the right to request the cancellation, anonymization or blocking of the Personal Data;
the right to restrict the processing;
the right to object to the processing, wholly or partly, also where it is carried out through automated individual decision-making, including profiling;
the right to withdraw the consent to the processing of the Personal Data freely and at any time – in such a case, the processing carried out before withdrawal of consent shall remain valid;
the right to Personal Data portability (i.e. to receive an electronic copy of user’s personal data, if the user would like to port his/her personal data to himself or a different provider), if applicable;
the right to limitation of the processing.

The users also have the right to lodge a complaint before the competent national data protection or judicial authority.

For the exercise of their rights, users may contact the Data Controller, in writing by sending a letter with proof of receipt to the Toretei S.r.l.’s headquarters, or by sending an email to

Toretei S.r.l. may modify, integrate and/or update, in whole or in part, this Privacy Policy.

It is understood that any modification, integration or update will be communicated to you promptly and on time via email or at the time of the start of the App. In this regard, it could be required to you to read the new version of the Privacy Policy and to accept it before continuing to use the App.

Date of last amendment: June 28, 2021

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