Privacy Policy

itondo s.à.r.l. (we) are committed to protecting and respecting your privacy.

Scope of policy

This policy applies to your use of:
  • itondo app 1.0 mobile application software (App) available via or directly through the website of any app store provider (App Site), once you have downloaded or streamed a copy of the App onto your mobile device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless our Terms of Use state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information we may collect from you

We may collect and process the following data about you:
  • Information you give us (Submitted information): You may give us information about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail). This includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, share data via an App’s social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of our Sites, or when you are a business and become an itondo partner and make use of the itondo partner services. The information you give us may include your name, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information.
  • Information we collect about you and your device. Each time you visit our Site or use our Apps we may automatically collect details of your use of our App or your visits to our Site (including, but not limited to, traffic data, location data, weblogs and other communication data) and the resources that you access (Log Information).
  • Location information. We may also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you do not wish to use this particular feature, you must not download or use our App.
  • Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
If you contact us, we may keep a record of that correspondence.


We use cookies to distinguish you from other users of the App, App Site, app store provider or Services Sites. This helps us to provide you with a good experience when you use the App or browse any of the Sites and also allows us to improve the App and our Sites. For detailed information on the cookies, see our Terms of Service.

Uses made of the information

We use information held about you in the following ways:
  • to allow you to register with us to create an account or profile within the Services;
  • to operate, maintain and improve our Services;
  • to conduct market research analyses, including, without limitation, to analyse user characteristics and usage patterns in order to better understand how our Services are used and market them more effectively;
  • o communicate with you concerning your account or, with your explicit consent or as permitted by law, to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, campaigns, or contests;
  • to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Services;
  • to respond to customer service and technical support inquiries, troubleshoot problems, investigate incidents, and handle complaints;
  • to provide the Services to you and our customers;
  • to complete payment and billing transactions;
  • to comply with applicable laws, regulations, legal processes or enforceable government requests;
  • to send notices, such as communications about your account or profile, changes to our Terms of Service, this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies;
  • to enable user-to-user communications and other in-Service communications and interaction;v
  • to protect against harm to the rights, property or safety of itondo s.à.r.l., its users or the public as required or permitted by law.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to business users, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 users clicked on their artwork image on any given day). We may also use such aggregate information to help business users reach the kind of audience they want to target (for example, users who searched for green paintings). We may make use of the personal data we have collected from you to enable us to comply with our business users’ wishes by displaying their artwork images to that target audience.

Disclosure of your information

We may disclose some or all of the data we collect from you when you download or use the App or our Sites to third parties.
We may disclose your personal information to third parties:
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If itondo s.à.r.l. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
  • In order to:
    • enforce or apply the EULA, our Terms of Service, and other agreements or to investigate potential breaches; or
    • protect the rights, property or safety of itondo s.à.r.l., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where We store your personal data

itondo s.à.r.l. is incorporated in the Grand-Duchy of Luxembourg and our business operations are primarily conducted in Luxembourg. We operate our company and administer this Privacy Policy under applicable laws and regulations of the Grand-Duchy of Luxembourg and the European Union. If you use our App and/or Services from outside of Luxembourg, you are thereby consenting for your personal data to be transferred to, stored in and be processed in the Grand-Duchy of Luxembourg and/or other countries within the European Union by us and/or third parties in the manner described in this Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal data represents your agreement to such transfer, storage and processing of your personal data. Furthermore, you acknowledge that the privacy laws of the Grand-Duchy of Luxembourg and the European Union, or other countries within the European Union, may differ from the laws in the country where you are located and may not provide you the same rights or protections for your personal data as those laws.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Sites or the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
Certain Services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Your rights

You have the right to access your personal data and you have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing at any time by contacting us at
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Changes to privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
If you disagree with our modifications, you should stop using the App or the Services.

Protection of Children’s Privacy

If you reside in the United States, the following applies: We are committed to providing special protection for the privacy of children who may use our App or Services. The App or Services is not intended for nor directed to children under the age of 17 and we do not knowingly collect, use or retain personal data from such children. If we discover that we have inadvertently collected personal data from children under the age of 17, we will take all reasonable measures to delete any records of such personal data that come to our attention.
If you reside in a country within the European Economic Area (EEA), the following applies: We do not knowingly collect personal data from children. We strongly recommend that the parents and legal guardians of children using our App or Services actively monitor their children’s use of the same. If we find children under 17, or under the equivalent minimum age in the relevant jurisdiction, using our App or Services, we will endeavour to ensure that consent is obtained from their parents or legal guardians for processing of the children’s personal data. If this consent cannot be obtained, we will delete the account and all associated personal data. If we discover that we have inadvertently collected personal data from children under the age of 17, we will delete the account and all associated personal data of such children. The parents or legal guardians can review, edit, request the deletion, or prevent further collection or use of their children’s personal data or make inquiries regarding this privacy policy by sending an email to


Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to