PRIVACY POLICY

In order to provide you with this mobile application (the “App” or “Software” or “Services”), Guangzhou Zhongxin Wuxian Technology Co., Ltd.(hereinafter as “we”, “our”, or “us”)needs to collect some privacy information about you. We understand the importance of protecting your privacy. This Privacy Policy (the “Agreement” or “Policy”) explains what information of yours will be collected when you download, install, access, or use the Software, and how such information will be used and shared. It also explains choices you have to control the collection, correction and/or deletion of such information. By using the Software, you consent to the Policy and to the collection, processing, disclosure and use of your information as described in this Policy.

1.Overview

This Policy applies only to information we collect in our App, e-mail and other electronic communications sent through or in connection with our App. This Policy DOES NOT apply to information collected by any third party. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

BY USING THE SERVICE, YOU HEREBY WARRANT AND REPRESENT THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, (II) YOU ARE OVER 16 YEARS OF AGE (OR ARE A PARENT OR GUARDIAN WITH SUCH AUTHORITY TO AGREE TO THIS PRIVACY POLICY FOR THE BENEFIT OF SUCH INDIVIDUAL UNDER 16 YEARS OF AGE).

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN,PLEASEDO NOT USE THE SOFTWARE & SERVICES.

For this Policy “GDPR” shall mean the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. Unless otherwise specified, all references made within this Policy to the European Union (EU) include all current member states to the European Union and the European Economic Area.

2.TYPES OF PERSONAL Information WE COLLECT, FOR WHAT PURPOSES.

2.1 Information may be automatically collected

(1)Technical Information. We may use the API provided by IOS to collect certain technical information, which is regarding your device configuration and identifiers, and your use of the Software and Services, including your configuration and settings of the Software and Services; the type, name and version of operating system; ISP (Internet Service Provider); internet protocol (IP) address; media access control (MAC) address; anonymous user identifiers; device configuration and identifiers; advertising ID; status of the WLAN; application log information.

(2)Social Networks. If you choose to share some videos or other materials of the Software to a app provided by the third party, we will access your application list to verify whether such app exists.

(3)Payment data. We may use the API provided by IOS to collect information about your subscription orders, such as purchase items, subscription time, order status, payment time. We do not collect and we are not responsible for the collection or security of payment details. Payment information is processed and stored using third-party companies (such as Apple). These companies can be contacted through their websites: https://www.apple.com/. Before entering your personal payment details, we suggest that you read and become familiar with the privacy policy of these third-party companies.

2.2 Information you provided or permission you granted to us

(1)Permission to Access to the Camera, Microphone or Video. In order to use certain features of the Software, you may voluntarily grant us the permission to access to the camera and microphone to record a video, or to access to the video for obtaining videos in your mobile device. Only if you confirm the permission, will we gain access to your camera, microphone or video.

(2)Facial Features Information.

a. Collection and processing of your facial features information.

When you use certain features to process your facial videos, we will then use the self-developed SDK to analyze the facial features data, recognize the position and shape of the five sense organs, gender in the videos, and process the video, feedback the special effect videos to you.

If you cease to consent or affirmatively revoke consent for our collection and processing of your facial features information, we will promptly cease all such collection and processing.

b. The purposes we collect your facial features information.

We capture the facial features information only for operating the face recognition functions and providing better special effect videos for you.

c. Storage and sharing of your facial features information.

For such facial videos, facial features information and special effect videos, we will neither store in our server nor share them with any third parties after processing.

(3)Permission to Access to the Storage. To ensure that you may save photos, videos or cache other information normally to your device, you may voluntarily grant us the permission to access to the storage of your device.

(4)_Permission to Access to the Identifier For Advertising( IDFA).

To provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners, we will collect the IDFA of your device after you grant us the permission to access to such data.

(5) Your Content. When using some of our Services, such as editoring graphics, photos, videos, music, you may voluntarily post, upload or share the content( including but not limited to graphics, photos, videos, music) to the Software .

2.3 The purposes we use your information

The main purpose we use your information is to deliver and improve the Service. Read on for a more detailed explanation of the various reasons we use your information:

to operate and update the Software and the Service, and provide you with existing and new functionality and features;

to improve and customize the Software and the Service;

to maintain, test, monitor and improve the quality and operation of the Software;

to take any action in case of a dispute involving you in connection with the Software and the Service.

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

3.WITH WHOM WE SHARE YOUR PERSONAL DATA

We will only disclose your personal data with your knowledge and as stated in this Privacy Policy. This includes disclosures that will enable us to fulfill our obligations to you, and allows us to manage our business operations. Your personal data may be shared as follows:

3.1 We share your personal data with service providers

We will share your information with third parties only in the ways that are described in this Privacy Policy.

We will not rent or sell your personal data to third parties, but in order to help them and us understand the usage patterns of Service for analytical purposes and to offer new features or otherwise tailor or enhance our Service, we may share your information with third parties that provide automatic data processing technologies for the App or providing service to the App.

We will take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with the Service; and (iii) to use the data solely in compliance with the applicable data protection laws, this Privacy Policy and the App Store Review Guidelines.

We do not have power to control or influence these third parties’ tracking technologies or how they may be used. Therefore, if you do not want to share your personal data with any third-party organizations, please contact us by email for more details or do not use such service provided by that third party.

3.2 We may share your personal data for safety, legal purposes and law enforcement

We use and disclose personal data as we believe necessary under applicable law, to enforce our Terms of Service, to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

3.3 We may share your personal data with third parties in case of change of control

As we develop our business, we may buy or sell assets or business offerings. Customer information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

PRIVACY RIGHTS
If you reside in the EU, you may:

Delete your personal data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Service to you) by sending us an email.

When you request to delete your personal data, we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such data and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements, please check section 8 for more details). When we delete any data, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud detection or similar purposes.

Change or correct your personal data: You can edit, change, update or fix some of your personal data by sending us an email.

Object to, or limit, or restrict, use of your personal data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held) by sending us an email.

Access your personal data: You can ask us for a copy of your personal data by sending us an email. You can ask us for a copy of your personal data in machine readable form by sending us an email.

5.PROTECTION OF PERSONAL DATA

We take precautions — including administrative, technical, and physical measures — to safeguard your personal data against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. We use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s data. We also protect user’s privacy by seeking to minimize the amount of sensitive data. We also seek appropriate contractual protection from our partners regarding their treatment of user data. 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.

6.CHILDREN’S PRIVACY

Although our Service is a general audience service, our App is not intended for children under the age of 16 or other statutory minimum age according to the applicable laws and regulations in your country (the “Minimum Age”) . We do not knowingly collect, maintain, or use personal data from children under the Minimum Age, and no part of the Service is directed to children under the Minimum Age. If you learn that your child has provided us with personal data without your consent, you may alert us at [zhongxinweb2021@outlook.com]. If we learn that we have collected any personal data from children under the Minimum Age, we will promptly take steps to delete such information and terminate the Service for the child.

7.CHANGES TO THIS PRIVACY POLICY

We may modify this Agreement at any time. If we decide to make material changes to this Agreement, we will provide notice through our Service, or by other means, to provide you an opportunity to revise changes before they become effective. If you disagree with the changes to this Agreement, you should stop using Service. Your continued use of our Service after we send a notice about our changes to this Agreement means that you are consenting to the updated Agreement.

8.DATA RETENTION

We retain your personal data we collect as described in this Agreement and for as necessary for the provision of the Services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the Services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

If you cease to consent or affirmatively revoke consent for our collection, use, disclosure of your personal information, we( and any third parties with whom we cooperate) will promptly cease all such use, you can request that we erase your personal information and close your account.

9.CONTACT US

You may contact us at any time for details regarding this Agreement. For any questions concerning your personal data please contact us at [zhongxinweb2021@outlook.com].

This Privacy Policy is effective upon acceptance by users or publication by us once update or modification. This Privacy Policy is incorporated into, and is subject to the Terms of Service.