Privacy Policy

Privacy Policy

Last updated: September 25, 2025

Moka IT Engineering Kft ("Company," "we," "our," or "us") operates the Shotly mobile application ("App").

This Privacy Policy explains how we collect, use, and protect your information when you use our App.

By using Shotly, you agree to the collection and use of information in accordance with this Privacy Policy.

Information We Collect

  • Device Information: device type, operating system, and unique device identifiers.
  • Purchase Information: details of in-app purchases made through the Apple App Store.
  • Log Data: IP address, app usage statistics, crash logs, and other diagnostic data.

We do not collect your name, email address, phone number, or store face images on our servers.

How We Use Your Information

We use the information we collect to:

  • Provide and operate the App.
  • Process in-app purchases.
  • Improve app performance, stability, and security.
  • Analyze usage trends for internal purposes.
  • Prevent fraud, abuse, and ensure security.
  • Comply with legal obligations.

Legal Bases (GDPR)

  • Contract performance (Art. 6(1)(b)) - to provide the App and process purchases.
  • Legitimate interests (Art. 6(1)(f)) - for security, fraud prevention, and service improvement.
  • Legal compliance (Art. 6(1)(c)) - to meet tax, accounting, and legal requirements.
  • Consent (Art. 6(1)(a)) - for marketing communications (where applicable).

We do not use your uploads or generated images for AI model training.

Data Storage and Retention

  • Your information is stored on secure servers located in the United States.
  • We keep technical and purchase data for as long as necessary to operate the App.
  • User uploads & generated images: kept until you delete them. You can delete media at any time from your account.
  • Account data & billing records: retained as required by law (e.g., accounting/tax) and for legitimate interests (dispute handling).
  • Logs: retained for security/operations for a limited period, then either anonymized or deleted.

Third-Party Processing Retention (Fal.AI)

For image generation, we use Fal.AI as a processor. According to their standard practice, artifacts related to a generation job are retained for up to 10 days for reliability and abuse monitoring, after which they are deleted by Fal.AI. This retention is independent of your in-product deletion.

Third-Party Services

We use the following third-party services to provide and improve our App:

Fal.AI

Purpose: AI image processing and generation Data shared: Photos you upload, generation prompts Retention: Processing artifacts retained for up to 10 days, then deleted Privacy Policy: https://fal.ai/privacy

Superwall

Purpose: Subscription and payment management Data shared: Device information, purchase data, subscription status Privacy Policy: https://superwall.com/privacy

Supabase

Purpose: Backend infrastructure and data storage Data shared: User ID, session data, generation metadata Privacy Policy: https://supabase.com/privacy

Apple In-App Purchases

Purpose: Payment processing Data shared: Handled by Apple (we do not store payment details) Privacy Policy: https://www.apple.com/legal/privacy/

These services process data on our behalf and are required to protect your information in accordance with their privacy policies.

We do not sell your personal data.

Sharing & Disclosure

We may share your information:

  • With your consent.
  • To comply with law, legal process, or enforce our Terms.
  • In connection with a business transfer (e.g., merger, acquisition); you'll be notified of material changes.
  • With service providers under data processing agreements (as listed in Third-Party Services).

International Transfers

Data may be processed outside your country. Where transfers leave the EEA/UK/Switzerland, we use appropriate safeguards (e.g., EU Standard Contractual Clauses and complementary measures). You can contact us for copies of the relevant safeguards.

Your Rights (EEA/UK/Switzerland & Applied Globally)

You have the right to:

  • Access your data.
  • Rectify inaccurate data.
  • Delete your data ("right to be forgotten").
  • Restrict or object to processing (including objection to marketing).
  • Data portability: receive data in a common format.
  • Withdraw consent at any time (e.g., marketing, non-essential cookies).

To exercise your rights, email danielmoka@mokaie.com. We will respond within 30 days (extendable per GDPR where necessary).

You may lodge a complaint with the Hungarian Data Protection Authority (NAIH): https://www.naih.hu/ | 1055 Budapest, Falk Miksa utca 9-11. | +36 (1) 391-1400

Data Deletion & Portability

You can delete images and your account within the App, or request deletion via email.

  • Self-service deletion (recommended): In your account, use the delete function to remove all uploaded and generated media from our active storage.
  • By request: Email danielmoka@mokaie.com to request deletion of specific items or your entire account. We will respond within 30 days and complete deletion without undue delay, subject to legal obligations (e.g., billing records).
  • Third-party retention: Fal.AI retains processing artifacts for up to 10 days and then deletes them. We do not control this window, but your deletion request applies immediately to our systems.

We will also, on request, export your personal data in a portable format where technically feasible.

Security

We use reasonable technical and organizational measures (e.g., encryption in transit, access controls, backups). No method is 100% secure; report potential issues to danielmoka@mokaie.com.

Children's Privacy

Shotly is available to users aged 4 and above.

We do not knowingly collect personal data from children. If you believe a child's data is present, contact us for deletion.

Communications & Marketing

  • Transactional communications (account, billing, essential updates) - required to run the Service.
  • Marketing communications - sent only with consent; unsubscribe anytime via link or by emailing us.

Changes to This Policy

We may update this Privacy Policy from time to time. We will post the new version with a new "Last updated" date and, for material changes, provide additional notice (e.g., email or in-app).

Contact Us

Moka IT Engineering Kft 5600 Békéscsaba, Orosházi út 17/8, Hungary Email: danielmoka@mokaie.com