Privacy policy


The Overly app uses the camera on your smartphone, whilst the app is enabled, to recognise images through the camera and show on-screen dynamic content on top of what you see in the real world – what’s known as ‘augmented reality’.



Overly is an augmented reality platform for third party use.


We use artificial intelligence, computer vision technology and other functionality – including, where you choose to enable it, facial recognition technology – to make this happen.


You can find out more about our app and how it works at


As part of our offering to other businesses, we enable them to offer you augmented reality content via the Overly app as part of their advertising and marketing campaigns.


At Overly we are working to build a service which is useful and fun for our users and in doing that we are absolutely committed to your privacy. The Overly app, the Overly websites and related APIs and tools covered by this policy are constantly evolving as we add new features to improve your experience, but our users’ privacy remains at the heart of what we do. As the Overly app changes, so might the information we use and how we use it. We encourage users to consult this policy whilst using Overly app.


The technology behind Overly is complex, and you can do different things using the Overly app, the Overly websites and related APIs and tools, so we have tried to explain the ways we collect and use your data in a straightforward way so you know what is going on. We welcome any feedback or questions you may have on privacy matters and how we use your data – please contact us at

Who we are

Overly is a technology business headquartered in Riga, Latvia, with partner companies in various countries around the world. For the purposes of European data protection law, Overly SIA (registered in Riga, Latvia, Registration number 40103755658) is the ultimate data controller for personal data collected, processed and used through the app.

What this document tells you

When you use the Overly app, websites, APIs, tools and any other services we may make available, you will share some information with us. When we talk about the Overly “app” or “service”, we mean all the websites, APIs, tools and other products, services and features offered by Overly.


This policy is designed to explain to you what information about you Overly collects in providing the Overly app and service, how that information is used and shared and how you can control what happens with that information.

What information we collect

When you use the Overly app or visit our websites we receive certain information about you, including:

  • digital images of the objects and people you are scanning
  • Overly app scans and other online content you are shown and link to and your interests and preferences suggested by what you’ve scanned and what online content you’ve viewed
  • a unique user ID, which we assign to you, against which we maintain data about you and your use of the Overly app
  • your location (both generally in respect of your locale, e.g. the UK and specifically, exact latitude and longitude coordinates)
  • certain mobile network and device identifiers to help us provide our services including the IP address that your internet network provider may allocate to your mobile or other internet enabled device.

We also receive additional personal information about you which you choose to give us.


When you use our Overly administration tool and/or our APIs, content generated or procured by you might be transferred to the Overly platform (“User Generated Content”).

How we use your information

We use your personal information to provide, monitor and improve the Overly app, website, services and the technology which supports them and to provide you with a great, personalised experience. We will occasionally use your information to contact you, for instance if you send us requests or ask us questions about Overly or if there are technical or operational issues or updates which we think our users need to know about.


We may also send you free newsletters and emails that directly promote the Overly service. When you receive such promotional communications from us, you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. We do need to send you certain communications regarding the Overly service and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Policy.


We provide augmented reality services to brands so that their marketing materials are scannable, providing users with augmented reality content when they scan materials such as magazine adverts or product packaging. Where we do this, we also report to our clients on an aggregated basis (so that no individuals are identified), the location of users scanning their content, how long they spent interacting with the client’s scannable content or our app generally and how they use our app.


We also disclose information in the aggregate to third parties for marketing and strategic development purposes.


This Section Has General Information About Your Personal Information

Where we store your information

The information we collect in relation to you is stored on data centres operated by our third party providers. Our data centres are currently based in Europe. By using Overly service, you consent to the hosting of your personal information on these servers, which may involve the transfer of your personal data outside of the country it was collected. It is important to note that countries have different regulations in relation to personal information, including in relation to rights of access by law enforcement authorities.

Can i find out what personal information overly holds about me?

You have the right to request a copy of the personal information Overly holds about you and to have any inaccuracies corrected. We need to establish your identity as we do not want to release information to the wrong person, so we may ask for documents that prove your identity. Please address requests and questions about this to

How we share your information

We may share information about you in the following ways:

  • With third parties. We may share your information with the following third parties:
    • With organisations who provide services or technology to us.We may share information about you with service providers who perform services on our behalf – for instance our data centre providers who host the Overly technology and data and partners that provide services to us. These third-party providers have access to your data only for the purpose of performing services on our behalf.
    • We provide augmented reality services to brands so that their marketing materials are scannable, showing users augmented reality content when they scan the materials. Where we do this, we also report to our clients on an aggregated basis where users accessing their augmented reality content are located, how long they spent interacting with the client’s Overly content or our app generally and how they use the Overly app.
    • We also disclose information in the aggregate (so that no individuals are identified) to third parties for marketing and strategic development purposes.
  • With third parties for legal reasons. We may share information about you if we believe that disclosing the information is needed to:
    • comply with any valid legal process, governmental request, or applicable law, rule, or regulation
    • investigate, remedy, or enforce potential breaches of our Terms of Use
    • protect the rights, property, and safety of us, our users, or others
    • detect and resolve any fraud or security concerns
  • With our affiliates. We may share your information with entities within the Overly family of companies
  • With third parties if Overly is acquired or its legal structure undergoes a reorganisation or all or a big chunk of our business is transferred to another company or companies.. In that circumstance we may share your information with that company before and after the transaction closes so that we can still provide you with a great service.

How old do i have to be to use overly?

Overly services are intended for users who are at least 13 years old. Overly does not knowingly collect personal information from children under 13.

How long will overly keep my personal information?

We will hold your personal information on our systems for as long as is necessary to provide access to our app and websites and will not hold onto it once we have processed a request by you to delete your account. By emailing, you can have all account data deleted – if you do this a red flag goes on the database and, while Overly cannot use the personal information, it stays on the system for a period for administration purposes before being deleted automatically.


If we are subject to a legally binding requirement to retain user information for a specific period, this may (subject to the law in question) override your ability to require deletion.


Please remember that other Overly users may have content and information you have made available through Overly, for instance through screen shots or other image capture and we do not control how they use or how long they keep that content.

The security of your information

In addition, we take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your personal information) from unauthorised access, use or disclosure. We use encryption methods when storing and transmitting. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Mobile devices

When you download or use the app on your mobile device, information may be accessed from or stored to your mobile device. This is used in a similar way to a web browser cookie, such as by enabling the apps to ‘remember’ you or provide you with the content you have requested.


Your web browser on your device or your mobile device’s operating system may also provide Overly with information about your mobile device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address and apps ID (a unique identifier relating to the particular copy of the Apps you are running). In the future we may use mobile device identifiers for advertising use which perform a similar role to cookies, like the IDFA used by Apple devices and the Advertising ID used by Android devices.

Changes to overly privacy policy

This Privacy Policy may be updated from time to time so please check from time to time. The date of the most recent revisions will appear at the beginning of this policy. If you do not agree to these changes, please do not continue to use the Overly app, websites or our other services to submit personal information to Overly.

Cookie policy

What are cookies?

Cookies represent information in the form of a very small text file that is placed on an internet user’s hard drive. It is generated by a web page server, which is basically the computer that operates a web site. The information the cookie contains is set by the server and it can be used by that server whenever the user visits the site. A cookie can be thought of as an internet user’s identification card, which tells a web site when the user has returned.

What information can we gather if you accept cookies?

Once approved, we will assign your device a cookie, which may collect information about how you use the site. Information we can gather information such as your IP address, your operating system, your browser type and language, the date and time of your visit, the search term that led you to the site, your geographic region, the type of content you view, etc.


We use cookies and other tracking technologies (like Google Analytics, Hotjar, and Hubspot) to help us recognize your visit and track users’ and interaction with our services. We also use cookies to collect non-personal information, help smooth the upload process, remember you on future visits, better understand how users engage with the site so we can enhance the user experience, and maintain volume on video playback. We use Google Analytics to improve our site and user experience.

Manage your cookies

If you do not wish to have cookies placed on your computer, you can set your browser to refuse cookies but should be aware that certain features of our website may not function properly without them. You can also visit the Digital Advertising Alliance and the Network Advertising Initiative pages to opt-out of cookies. To opt-out of Google Analytics visit this site:

Removing cookies from your device

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.


Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).

Managing site-specific cookies

For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser

Blocking cookies

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit a site/page. And some services and functionalities may not work properly at all (e.g. profile logging-in).

Managing our analytics cookies

You can manage your preferences concerning cookies from Europa Analytics on the dedicated Europa Analytics page.

Find out more and manage your cookies preferences at


Contacting Overly about this Privacy Policy


If you any questions or comments about this Privacy Policy please contact: