PRIVACY POLICY

Last Updated: August 30, 2024

1. Preamble

  1. This Privacy Policy (the "Policy"), together with the User Agreement, governs your use of our Services. It details our practices regarding the collection, use, disclosure, processing, transfer, and storage of the information you provide. By using, browsing, accessing, or purchasing from our Services, you agree to comply with this Policy and consent to the handling of your information as described. We will only use your information in ways outlined in this Policy. Any capitalized terms not defined in this Policy will have the meanings provided in the User Agreement.
  2. We may update this Policy periodically to reflect changes in our practices and ensure compliance with applicable laws. Upon making updates, we will amend the "Last Updated" date at the top of the Policy. We encourage you to periodically review this page to remain informed of any changes.
  3. Please review this Policy carefully. If you disagree with any of its provisions, we advise against using or accessing our Services.

2. What Personal Information Do We Collect

In this Policy, "personal information" refers to any data that identifies or can identify an individual. When you use our Services, we may collect the personal information outlined below.

  1. You may provide personal information when creating an account or using our Services, such as:
    1. Registration Details: such as your email address, phone number or other contact information, password, user identifier and language.
    2. Profile Information: such as an avatar or profile picture, gender, birthday, nickname or username, or country.
    3. User-Generated Content: such as comments, texts, messages, pictures, images, videos, sounds, code, your device's camera and microphone or other data or materials that you upload and distribute when you use our Services.
    4. Payment Information: such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number, or other payment information where required for payment.
    5. Location Information: We may collect GPS data (adjustable via device settings) and general location based on your SIM card (not precise).
    6. Correspondence: such as information used to verify with your account or to resolve your feedback or complaints.
    7. Customer Support Information: we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.
    8. Social Media: the information you provide through social media when registering via a third-party social media, such as Facebook, Google, Instagram, Twitter, or when linking your account to a third-party social media account.
  2. We may also gather your personal information automatically for certain situations, including:
    1. Information from Other Sources: We may obtain additional information from third parties, such as social media networks, when you grant us access. By accessing our Services through these networks, you authorize us to collect and use this information in accordance with our Privacy Policy.
    2. Device Information: Includes your device's brand, model, OS, screen resolution, system version, Bluetooth settings, language, internet connection, installed apps, running background apps, advertising ID, IP address, and other device identifiers.
    3. Mobile Advertising Identifiers: Such as Apple's IDFA or Google's AAID, used for advertising purposes to provide targeted ads.
    4. Metadata: Associated with your User-Generated Content, describing details like when, how, and by whom it was created, including hashtags and captions.
    5. Cookies & Tracking: We use cookies and similar technologies to track your interactions with our Services, such as account activation, content viewed, ads clicked, URLs visited, notifications received, IP address, country code, and user ID.

3. How We Use the Collected Information

We use the personal information we collect for various purposes to provide, maintain, and improve our services. Specifically, we use your information as follows:

  1. Service Delivery: we require certain information from you, particularly when you provide images or videos containing facial data and use features related to facial recognition or analysis. By doing so, you acknowledge and agree that we may collect and use facial geometry or other facial data (the "Facial Data") from the images, videos, and other media you provide to generate the requested image or effects. We store these images, videos, and generated effect data on our servers. The Facial Data is utilized solely to deliver and enhance the services provided to you, and is not used for personal identification or authentication purposes. Without this information, we may be unable to provide the requested services.
  2. Personalization: To personalize your experience by tailoring content, recommendations, and advertisements to your preferences and interests. This helps us to offer a more relevant and engaging experience.
  3. Improvement of Services: To analyze usage patterns and user feedback in order to improve our Services, develop new features, and optimize performance. This may involve using aggregated and anonymized data to understand trends and enhance service quality.
  4. Communication: To communicate with you about your account, our Services, and any updates or changes that may affect you. This includes sending you notifications, and promotional materials.
  5. Security and Compliance: To ensure the security of our services and to comply with legal obligations. This includes monitoring for and preventing fraudulent or unauthorized activities, enforcing our terms and conditions, and protecting our rights and the rights of others.
  6. Research and Development: To conduct research and development activities aimed at advancing our technology and service offerings. This includes utilizing data to explore new possibilities and enhance existing functionalities, and train our AI models.

4. Transfer of Personal Information

The personal information we collect may be transferred to, stored, and processed in countries outside of your jurisdiction, including but not limited to the countries where our affiliates or service providers are located. By using our Service or providing us with your personal information, you consent to the transfer, storage, and processing of your information in such countries, which may have different data protection laws than those in your country of residence. We take appropriate steps to ensure that your personal information is treated securely and in accordance with this Policy and applicable data protection laws.

5. How We Share Your Information with Third Parties

We may share your personal information with third parties under certain circumstances, as outlined below:

  1. Service Providers: We may disclose your information to third-party service providers who perform services on our behalf, such as payment processing, data analysis, and customer support. This includes integrations with advanced technologies like GPT-4 and DALL-E, which provide natural language processing and image generation services.
  2. Business Transfers: In the event of a merger, acquisition, or any form of business reorganization, we may transfer your personal information to the relevant third parties involved in the transaction. We will ensure that the receiving party adheres to comparable privacy and security standards.
  3. Legal Requirements: We may disclose your information to comply with legal obligations, such as responding to lawful requests or orders from public authorities, including to meet national security or law enforcement requirements. Additionally, we may disclose information to protect our legal rights, enforce our terms and conditions, or respond to legal claims.
  4. With Your Consent: We may share your personal information with third parties when you provide explicit consent for such disclosure.
  5. Affiliates: We may share your information with our affiliates for business purposes, including improving our services and providing you with relevant information. Our affiliates are bound by this privacy policy and are committed to protecting your personal information.
  6. Anonymous or Aggregated Data: We may share non-personally identifiable information, such as aggregated data or de-identified information, with third parties for research, marketing, or analytical purposes.

6. How Do We Protect Your Personal Information

  1. We are committed to safeguarding the confidentiality and security of your personal information through robust physical, technical, and administrative measures. Additionally, we require that our service providers implement equivalent safeguards to protect your data. Despite these efforts, we cannot guarantee absolute security against loss, misuse, unauthorized access, or alterations to your information.
  2. You also play a crucial role in securing your personal information. When creating an account, choose a strong, complex password, and keep it confidential. Do not leave your device unattended, and ensure that any wireless connections you use to access our services are secure and trusted. If you suspect any unauthorized access or use of your account, please notify us immediately.

7. Retention of Your Information

We retain your personal information for specific periods based on the purpose for which it was collected and applicable legal requirements. Here's how we manage the retention of your information:

  1. Purpose-Based Retention: We retain your personal information as long as necessary to fulfill the purposes for which it was collected, including providing our services, managing your account, and responding to inquiries. This period is determined based on the nature of the data and the services provided.
  2. Legal and Regulatory Requirements: We may retain your personal information to comply with legal and regulatory obligations, such as tax, accounting, and auditing requirements. The retention period for such data is determined by relevant laws and regulations.
  3. Operational Needs: We retain certain information to address operational needs, such as improving our services, conducting research, and ensuring system security. This data is kept only as long as necessary for these operational purposes.
  4. Data Deletion and Anonymization: Once the retention period expires, we securely delete or anonymize your personal information. Deletion is performed in a manner that ensures the data cannot be reconstructed or retrieved, while anonymization renders the data non-identifiable and not linked to you.
  5. Review and Updates: We periodically review our data retention practices to ensure compliance with this policy and applicable laws. We update our practices as needed to reflect changes in legal requirements and operational needs.

8. Children's Personal Information

We are dedicated to safeguarding children's privacy. We do not intentionally collect personal information from individuals under the age of 13 (or the equivalent minimum age in your jurisdiction). If we become aware that we have collected such information without proper consent, we will take steps to delete that information as quickly as possible. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us using the details in the "How to Contact Us" section. We will take appropriate action to address the issue, including deleting the information if necessary.

9. Your Rights About Your Personal Information

Depending on your location and applicable laws, you may have various rights regarding your personal information, including but not limited to:

  1. Access: You can request a copy of the personal information we hold about you.
  2. Correction: You may ask us to correct or update inaccurate or incomplete personal information.
  3. Deletion: You can request the deletion of your personal information, subject to legal and regulatory requirements.
  4. Restriction: You may request that we restrict the processing of your personal information under certain conditions.
  5. Objection: You have the right to object to the processing of your personal information for certain purposes, including direct marketing.
  6. Portability: You can request to receive your personal information in a structured, commonly used, and machine-readable format, and to transfer it to another organization.
  7. Consent Withdrawal: If we process your personal information based on your consent, you may withdraw your consent at any time.
  8. Complaint: You have the right to lodge a complaint with a data protection authority if you believe our processing of your personal information violates applicable laws.

10. How to Contact Us

If you have any questions, comments or suggestions about this Policy or personal information, please contact us at【】.