Privacy Policy
Last updated: 31 March 2026
Screenshot Explainer ("the App") is operated by Winners Media Limited ("we", "us", "our"), a company registered in the United Kingdom. We are committed to protecting your privacy and handling your data transparently.
This policy explains what data we collect, how we use it, and your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Data Controller
Winners Media Limited is the data controller. For data protection enquiries, contact us at:
Email: privacy@winnersmedia.co.uk
2. What Data We Collect
Account Information
- Email address (when you create an account or sign in with Google, Facebook, or Apple)
- Name (if provided by your social sign-in provider)
Screenshots
- Screenshots you upload are sent to a third-party AI service (Google Gemini) for analysis
- Screenshots are not stored unless you explicitly choose to save them to your history
- If saved, screenshots are stored in your private account and can be deleted at any time
Subscription Data
- Subscription status and purchase history (managed by Apple via the App Store and RevenueCat)
- We do not have access to your payment card details
Usage Data
- Number of analyses performed (stored locally on your device for rate limiting)
- We do not track your location, browsing habits, or use advertising identifiers
Biometric Authentication (Face ID / Touch ID)
- The App offers optional Face ID or Touch ID login for convenience
- Biometric data is processed entirely on your device by Apple's Secure Enclave
- We never access, collect, store, or transmit your biometric data
- You can enable or disable biometric login at any time in the App's Settings
3. How We Use Your Data
- To provide the service: Your screenshots are sent to Google Gemini API for AI-powered analysis. This is the core function of the App.
- To manage your account: Your email is used for authentication and account recovery.
- To manage subscriptions: RevenueCat processes your subscription status.
- To save your history: Only if you choose to save a screenshot, it is stored in your account on our servers.
4. Lawful Basis for Processing
- Consent: You actively choose to upload each screenshot for analysis. You can withdraw consent at any time by not uploading screenshots.
- Contract: Processing your account and subscription data is necessary to provide the service you have subscribed to.
- Legitimate interest: Rate limiting and abuse prevention to protect our service.
5. Third-Party Services
We share data with the following third parties, all of which have their own privacy policies:
Important: We do not sell, rent, or share your personal data with any third parties for advertising or marketing purposes. Your data is only shared with the services listed above to operate the App.
6. Data Storage and Security
- Account data and saved screenshots are stored on Supabase servers in the EU (eu-west-1)
- Data is encrypted in transit (TLS) and at rest
- Row Level Security ensures you can only access your own data
- Screenshots sent for AI analysis are transmitted securely and are not retained by the AI provider
7. Data Retention
- Account data: Retained until you delete your account
- Saved screenshots: Retained until you delete them from your history, or until you delete your account
- Unsaved screenshots: Not stored. They exist only in your device's memory during the analysis session
- Usage counters: Stored locally on your device only. Reset when you uninstall the App
8. Your Rights (UK GDPR)
You have the following rights regarding your personal data:
- Right of access: You can view your data within the App (History and Settings screens)
- Right to erasure: You can delete individual screenshots from your history. To delete your entire account, contact us at the email below
- Right to data portability: You can request a copy of your data by contacting us
- Right to rectification: You can update your account information in Settings
- Right to restrict processing: You can stop using the App at any time. Contact us to restrict processing of existing data
- Right to object: You can object to processing by contacting us
- Right to withdraw consent: You can stop uploading screenshots at any time
To exercise any of these rights, email privacy@winnersmedia.co.uk. We will respond within 30 days.
9. Children's Privacy
The App is not intended for children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
10. International Transfers
Your data may be processed by Google (Gemini API) in the United States. Google operates under Standard Contractual Clauses approved by the European Commission for such transfers. Supabase stores data in the EU.
11. Changes to This Policy
We may update this policy from time to time. We will notify you of significant changes via the App or by email. The "Last updated" date at the top reflects the most recent revision.
12. Complaints
If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
ico.org.uk/make-a-complaint
13. Contact
For any privacy-related questions:
Email: privacy@winnersmedia.co.uk
Company: Winners Media Limited
Country: United Kingdom