Privacy Policy

---Everything We Do Is Striving For Your Best Experience.

Overview

Welcome to AI Photo App ("AI Photo App","we", "our",or "us"). We are committed to protecting and respecting your privacy.

This Policy explains our practices regarding the collection, use, disclosure, and protection of information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Privacy policy applies to all users, and others who access the App (“Users”).For the purposes of the GDPR, we are the data controller, unless otherwise stated.

Please read the following privacy policy, for information regarding the ways your personal information may be processed, carefully. When you use the app you acknowledge that you have read, understood, and agree to be bound by these terms.

User service

In the AI Photo App App ("App", "AI Photo App") you can create unique Artworks.

We categorize users of the App as follows: User and Client for privacy purposes. User is a person to whom we provide our App on a free basis.

Client is our user, individual, to whom we provide our App on a paid basis. You own and control the personal data we collect about you. You can choose not to provide certain information or disable and prevent us from collecting, storing, and processing it. Please be aware you will not be able to take advantage of some of AI Photo App’s features in this case.

Please read our Terms of Service and Community Guidelines carefully, from the moment the user agrees, we are the controller of the personal data of users and customers.

This means we determine the amount, purpose, and means of personal data processing when you use the App.

I. What kind of information do we collect?

We may access or collect the following information in order to provide you with a better user experience and better services and to improve our products:

Categories of information may be collected from the following categories of sources:

Directly from you or your agent, such as through your submissions to the Services.

Directly or indirectly from activities through the Services, such as through your interactions with the Services.

From third parties with whom we partner to provide services.

We may access your personal information when you voluntarily choose to use our services, applications or provide us with your personal information.

• Content Information, i.e. photos, pictures and other data that you transfer using the App.

• Product interaction information and any user-generated content.

Face Data Policy

• The face data we collect

We analyze your photo and find out the feature points of the face in the photo (such as eyes, nose, mouth, etc.) for face processing. We do not collect facial data. After the analysis process is completed, all data will be deleted and no data will be saved.

• Purpose and process of collecting face data

To give you a "face changing" effect, we need to find feature points (such as eyes, nose, mouth points).

The complete process is as follows: (1) You will submit the selected photos to our server in an encrypted manner; (2) The server analyzes the face data in your photos and applies it to the template you select; (3) After the synthesis is completed, the server returns the final rendering effect to you through the application; (4) The final composite effect will be temporarily stored in encrypted storage and will be permanently deleted after a certain period of time. After the synthesis process is completed, we will immediately delete the face image you submitted to the server.

• Face data sharing and storage

"We will not share your face data with any third party, nor will we store any face information you submit. The photos you upload will be deleted after the analysis process is completed.".

Collect information:

• Face recognition: For certain theme template editing and short video production services, our application will collect the avatar photos you upload or take. To use the facelift feature in the theme template section, you can voluntarily allow our application to access the camera or album to obtain photos from your mobile device. Our application can only access your camera and album after you confirm your permission. When you use certain facial recognition features, we will automatically capture the positions and shapes of your five senses, analyze facial feature information, store this information on our server for photo processing, and return the renderings to you. We will not store or share such processed photos, facial features, or renderings with any third party.

Information that you voluntarily provide to us

We may collect, store and process some information about you when you use the form available within the “Contact us” section on the Website (hereinafter, “Contact us” form). In particular, if you decide to make a request via the “Contact us” form, the following categories of information are voluntarily provided by you: your name, email address, the text of your message and/or any files that you optionally choose to attach to your request.

Information automatically collected

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps.

We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Analytics information

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information.

We use third-party automatic data processing technologies (such as Google and Facebook) to analyze certain information sent by your device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties process your personal data, that might be processed by their own means (not through our App). Any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Facebook Privacy Policy: https://www.facebook.com/about/privacy/

Google Privacy Policy: https://www.google.com/policies/privacy/

Adjust Privacy Policy: Security and Privacy | Adjust

Firebase Privacy Policy: Fyber – Services Privacy Statement - Digital Turbine

Information other users provide about you

We also receive and analyze content, communications and information that other people provide when they use our Services. This can include information about you, such as when others invite you to use our application, and for doing so they provide us your phone number, name and other information. We require that these users have the legal rights to collect, use and share your data before they provide us with any information.

Regarding the Website: your browser transfers certain data so that it can access the Website, namely:

• the date and time of the request

• the browser type

• the operating system

• the language and version of the browser software.

To ensure your normal use of product features and services, AI Photo App will use the following permissions for other data that we may access

We will also access the following information to provide you with an enhanced user experience and better services, as well as to improve our products. Relevant permission content is dynamically obtained when you use product services and features. You can control whether permissions are turned on or off in system settings, but your selections and settings may affect the normal use of certain features of the product. "The information that may be accessed, collected, or shared may be used for application analysis or advertising analysis or other third-party SDKs. The specific content can be viewed in the privacy policy of" "APPENDIX - ADVERTISING NETWORKS AND PARTNERS" "below.".

• Camera permissions: for shooting functions;

• READ_EXTERNAL_STORAGE/READ_MEDIA_IMAGES permissions: Users to upload their own pictures, generate unique artworks, and save them to their mobile phones.

• Read/write external memory card: uRead the external storage space of the device and save the picture;

• Receive notification messages: used to receive messages;

• Obtain the current network status: remind the user whether the current mobile network is in use or determine whether the user's network is available;

• Advertising ID: Collect the device advertising identifier GAID for personalized advertising content;

We may disclose your personal information in accordance with your wishes or as required by law in the following circumstances:

1) Your prior permission;

2) In accordance with applicable laws, legal procedures, and litigation claims within and outside your country of residence;

3) At the request of public and government agencies;

4) To protect our legitimate rights and interests.

Users with whom you share information

We have no control over the behavior of other users with whom you share information. We cannot and do not control the information you share with other users using the application, service or website (including through forums) or how such information is used or shared by other users. We are not responsible for third parties circumventing our security measures.

II. How do we use this information?

To provide you with a better user experience, we may use your information for the following purposes:

1. General Use of Information.

The information we collect is used to:

1) To meet the purpose of your information provision.

2) Carry out the activities described to you at the time your information was collected or as set forth in the California Consumer Privacy Act (“CCPA”).

3) To provide you with the requested information, products or services.

4) Execute internal and external marketing, including providing targeted advertisements and information.

5) Fulfillment of obligations and enforcement of contractual rights.

6) To improve the Services, for example through testing, research, analysis and development.

7) Respond to requests from law enforcement agencies and government organizations as required by law, court orders, or government regulations.

8) Evaluate or effect a merger, divestiture, reorganization, reorganization, dissolution, sale or other transfer of some or all of our assets, whether on an ongoing basis or as part of a discrete transaction in which the information collected is the transfer of assets.

9) Use information for security purposes; we may use information for account and network security purposes, including protecting our services for the benefit of all users, and pre-screening or scanning uploaded content for potentially illegal content. We may use your information for identity verification, monitoring account and transaction risks, detection and security prevention, fraud monitoring, file backup, customer security services, etc.

10) We store and maintain your information to fulfill our legal obligations; for example, in an emergency, we may record, review, analyze and dispose of your information in accordance with applicable laws.

11) Without prior notice to you, other categories of information will not be used for substantially different purposes.

2. Use the information as appropriate.

Information voluntarily provided to us or lawfully obtained by us is our property and we may use it for any lawful purpose, including selling, renting or transferring the information to publishers, advertisers and data aggregators for marketing purposes.

3. Targeted Advertising and Information.

We may use personal information to more effectively target advertisements and other information. While individuals are online, we may use technical information to associate individuals with their personal information and to attempt to display information and advertisements for products and services that you may respond to. We may use data collected from responses to one type of advertisement or information to target advertisements or other information across different venues.

4. Legal Proceedings.

We may disclose personal information in response to subpoenas, court orders and other legal process required by law.

5. Disclosure and Sale of Information.

We may sell or disclose personal information for business purposes. For example, we may provide your information to service providers or third-party advertisers who perform services on our behalf. For example: identities, inferences drawn from any other information.

6. Cookies and similar technologies

When you use our Services, certain information may be stored locally on your mobile device using "cookies" or similar technologies (such as Google Analytics and web beacons). We use cookies and similar technologies mainly to achieve the following functions or services:

• Ensure safe and efficient operation of products and services

We may set cookies or anonymous identifiers for authentication and security so that we can confirm that you are safe to log into the Services, or that you are not experiencing theft, fraud or illegal activity. These technologies also help us to make our services more efficient and improve login and responsiveness.

• Help you have an easier access experience

Using such technologies can help you avoid repeated steps and processes of filling in personal information and frequent logins.

7.To improve, test and monitor the effectiveness of our App/Website.

We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App/Website.

8.To generate avatars.

Users can upload their own pictures and Generate unique avatars. In order to protect your rights and security, the generated pictures will be automatically deleted after being stored for a certain period of time.

9.To make our service available.

We use functional information and information that is processed automatically to provide you with all requested services.

10.To communicate with you.

We use the contact information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

11.To prevent fraud and spam, to enforce the law.

We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

III. How do we share your information?

We will not rent or sell your personal data to third parties, but we may share information you obtain through tools such as cookies, log files and device identifiers with third-party organizations that provide automatic data processing technology for this website. We do not control or influence these third parties' tracking technologies or how they are used.

Please note that while we only work with third parties to ensure that we take the necessary technical and organizational measures to protect your data, we cannot guarantee the security of any information directly transmitted from the website to such third parties. We will not be liable for any accidental loss or unauthorized access to your data due to the fault of third parties.

AI Photo App only shares personally identifiable information with third parties when you allow it to be shared, or as necessary to complete operations within the software or services, or as required by law. Here are some situations where this might happen:

To help improve or promote our services:

We may share information and aggregate data we collect on usage and user behavior with third parties, to help improve or promote AI Photo App, but we do it in such a way that no individual user can be identified or linked to any specific action or information.

AI Photo App allows third-party companies to collect certain information information from users of AI Photo App. These companies may utilize cookies, pixels or other technologies to collect and use non-personally identifiable information (e.g., hashed data, click streaming information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other website in order to provide advertisements about goods and services likely to be of greater interest to you. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative atwww.networkadvertising.org/choices . Even so, you always have the option to uninstall the software if you no longer want to be a AI Photo App user.

To provide you with services:

We may provide information to service providers who help us operate AI Photo App. For example, we may use third parties to help host our site, send e-mail or SMS related to the operation of AI Photo App, removing repetitive information from our user lists, to any process payments or to provide search results. These service providers can technically access your personal information for use for a limited time but when this occurs, it is reasonable to apply the contractual and technical protections of limiting the use of this information to help us provide the AI Photo App service.

To offer services in association with other companies:

We may provide services in conjunction with other companies. If you opt in for these services, we may share your information to facilitate this service. However, we will identify the partners and display the privacy policy before you use such services.

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

We may contain links to third party sites/services. You also may visit the Website following a link from a third party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

· as required by law;

· when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

· if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;

· in some cases, we may share your information with our affiliates, subsidiaries, contractors, business partners or other third parties who perform services on our behalf.

Ⅳ. Data storage

Storage of Personal Information. We store personal information on servers with security measures designed to prevent loss, misuse and alteration of the information under our control. We also maintain physical and procedural safeguards designed to protect personal information. Notwithstanding these measures, we cannot guarantee that its security measures will prevent unlawful access, theft or alteration of personal information.

The length of time we retain personal information is for the purpose of providing our services or achieving the original or directly related purpose of collecting such information, or for other commercial purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements The law requires us to retain certain types of information (such as time limits) for a period of time. "If your personal information is no longer needed for legal or commercial purposes for processing it, we typically destroy or anonymize it.".

If there is a retention of personal data information, the following principles will be followed.

1. Personal data shall be processed and stored as required for the purpose for which it was collected.

so:

1) Personal data collected for the purpose of fulfilling our contract with you will be retained until such contact has been fully fulfilled.

2) Personal data collected for the realization of the legitimate interests of the company shall be retained for the period necessary to achieve the purpose. Users can find specific information on the legitimate interests pursued by the Company in the relevant sections of this document or by contacting the Company.

2. As long as the user consents to such processing, the company may be permitted to retain personal data for a longer period of time as long as such consent is not withdrawn. In addition, companies may be obliged to retain personal data for longer periods of time when required to comply with legal obligations or as ordered by authorities.

3. Once the retention period has expired, the personal data will be deleted. Therefore, the rights of access, deletion, rectification and data portability cannot be enforced after the expiration of the retention period.

4. Log data

Our servers automatically record information generated when you connect to the Services ("Log Data"). Our log data is anonymous, so it does not include information such as your IP address, user ID, phone number, cookie information, browser type, operating system or device model, location, carrier or internet service provider information.

V. AGE LIMINTATION USE OF THE SERVICE

In order to access and/or use the Website, you must be eighteen (18) years of age or older.

All users who are minors in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by their parent or guardian to access and/or use the Website, so if you are between the ages of thirteen (13) and seventeen (17) years and you wish to access and/or use the Website, before doing so you must: (a) assure and confirm (if needed) that your parent or guardian have read and agreed (get your parent or guardian’s consent) to this Agreement prior to your access and/or use the Website; (b) have the power to enter a binding contract with us and not be barred from doing so under any applicable laws.

Parents and guardians must directly supervise any access and/or use of the Website by minors.

VI. Security

The security of your personal information is highly important. We will try our best to make sure the data is protected from any fraud. For this reason, we have a secure environment to collect, store and track the information using latest technologies.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

VII. Third-Party

We use various third-party services to help provide our services, such as hosting services, including Google Cloud Platform, analytics services, such as Google Analytics and Google Firebase, bug reporting services, such as Instabug and transactional SMS Serve.

1. Advertiser Cookies and Web Beacons. Publishers who advertise on the Internet may use their own cookies, web beacons and other technologies to collect information about you. We do not control publishers' use of such technologies. We may place cookies on your computer or device from publishers or advertisers with whom we contract. This Privacy Policy does not apply to the practices of publishers or other companies that we do not own or control, nor does it apply to people we do not employ or manage.

2. Links. Publisher's website may contain hypertext links to third-party websites. We are not responsible for the privacy practices or content of such other sites.

3. Non-publisher affiliates. We may disclose or transfer personal information to entities wholly owned or controlled by us in our sole discretion.

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

Advertising networks and their partners

Amazon Developer

Privacy Policy: AWS Privacy

Google AdMob and their partners

https://www.google.com/policies/privacy/

https://support.google.com/admob/answer/9012903

https://support.google.com/ads/answer/2662922?hl=en

AppLovin

Privacy Policy: https://www.applovin.com/privacy

Facebook Audience Network

Privacy Policy: https://www.facebook.com/about/privacy/

Fyber

Privacy Policy: https://www.fyber.com/services-privacy-statement/

Pangle

Privacy Policy: Partner Data Privacy Policy | Pangle

Smaato and their vendors

Privacy Policy: Privacy Policy | Smaato For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list

Unity Ads

Privacy Policy: https://unity3d.com/legal/privacy-policy

Criteo

Privacy Policy: Privacy Policy | Criteo

Inmobi

Privacy Policy: Privacy Policy

Vungle

Privacy Policy page: https://vungle.com/privacy/

Mintegral

Privacy Policy: Privacy Policy - Mintegral

VIII. EU privacy rights

You, as subjects of personal data, have the following rights:

Right to access: You can request an explanation of the processing of your personal data.

Right to rectification: You can change the information if it is inaccurate or incomplete.

Right to erasure: You can send us a request to delete your personal data from our systems.

Right to data portability: You can request all the data that you provided to us, as well as request to transfer data to another controller.

Right to object: You can object to the processing of your data.

Right to restriction: You may partially or wholly prohibit us from processing your personal data.

Right to withdraw consent: You can withdraw your consent at any time.

Right to lodge a complaint: If your request was not satisfied, you can file a complaint to the regulatory body.

To exercise your rights, write us an email summerdaysc@outlook.com

IX.INFORMATION FOR RESIDENTS OF CALIFORNIA: YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act ("CCPA") may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy regarding our use of your personal information. The CCPA Notice applies to "Consumers" as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights.

Access to Information and Data Portability Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

1)The categories of personal information we have collected about you.

2)The categories of sources from which we collected your personal information.

3)The business or commercial purposes for our collecting or selling your personal information.

4)The categories of third parties to whom we have shared your personal information.

5)The specific pieces of personal information we have collected about you.

6)A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.

7)A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain:

• the categories of your personal information we have sold.

• the categories of third parties to which we sold personal information, by categories of personal information sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

Exercising Your Rights

To make a request for access, portability or deletion according to your rights under CCPA, mail your request for the attention of the Privacy / Legal Department to summerdaysc@outlook.com

The Verifiable Consumer Request must:

1)Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

2)Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer's personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

X. Children's Policy

Our services are not directed at children. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us immediately and we will take reasonable steps to ensure that such information is removed from our files.

XI. Privacy notice update

We will notify you in advance if there is any change to our privacy policy so that you have the opportunity to decide whether you will stay or not.

XII. ◆ Payment terms ◆

The following subscription terms are only for Android AI Photo App users:

Subscriptions:

Title: One Week Subscription

Length of Subscription: 1 Week

Price:$6.99/Week

Title: One Year Subscription

Length of Subscription: 1 Year

Price: $39.99/Year

In-app products:

Title: 50 avatars

Price: $5.99

Title: 100 avatars

Price: $9.99

Title: 200 avatars

Price: $13.99

Recurring billing. Cancel anytime.

Payment will be charged to Google Pay Account at confirmation of purchase.

Subscription automatically renews unless auto-renew is turned off at least 24-hours before the end of the current. Account will be charged for renewal within 24-hours prior to the end of the current period, and identify the cost of the renewal. You can enjoy advanced features after subscribing.

Subscriptions may be managed by the user and auto-renewal may be turned off by going to the user's Account Settings after purchase.

Any unused portion of a free trial period, if offered, will be forfeited when the user purchases a subscription to that publication, where applicable.

XIII. How to contact us?

If you have any questions about our Privacy policy, please feel free to contact us at summerdaysc@outlook.com