AI Marvels App Privacy Policy

This product is provided by HITPAW CO.,LIMITED (hereinafter referred to as "we" or " the Company", whose registered address is at RM B3,19/F TUNG LEE COMM BLDG 91-97 JERVOIS ST SHEUNG WAN HONG KONG, Data Protection Officer can be reached at [email protected]). We attach great importance to protecting the privacy of our users (or "you"), and we are committed to respecting and protecting the personal information we collect.

The data controller is HITPAW CO., LIMITED and its affiliated companies(including but not limited to TENORSHARE（HONGKONG）LIMITED , AFIRSTSOFT CO.,LTD)

HITPAW has appointed an EU representative in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of Personal Data (the “GDPR”). You can contact the designated EU representative of HITPAW by reaching [email protected].

This Privacy Policy explains how we collect, use, store, share and otherwise process your personal information when you use our products. This Privacy Policy will help you understand the followings:

Ⅰ. How we collect and handle your information, and what information we collect from you

Ⅱ. How we store ，protect and transmit your information

Ⅲ. How we share, transfer and disclose your personal information

Ⅳ. How you shall manage your personal information

Ⅴ. How we handle the personal information of minors and children

Ⅵ. Permissions of users in different regions for their personal information

Ⅶ. How the Policy will be updated

Ⅷ. How to contact us

Ⅰ. How we collect and handle your information, and what information we collect from you

1. The personal information we may need to collect and use about you regarding your use of our product includes the following two circumstances:

a. In order to provide you with the basic features of our product, we may need your permission to collect and use the necessary information. In the event that you refuse to provide the corresponding information, you will not be able to have proper access to or use our product.

b. In order to provide you with additional features of our product, you may have the option of accepting or refusing to provide us with certain information about yourself, and the type and scope of personal information collected for the basic features and additional features may differ. If you refuse to provide us with such information, you will not be able to use the additional features or reach the desired results, but this will not prevent you from using the basic features.

2. The specific scenarios in which we collect and use your information for functional purposes:

a. Customer service and dispute handling

When you contact us or submit a request for resolution of an ongoing sale, after-sales, or dispute, we may require you to provide the necessary personal information to verify your identity in order to ensure the security of both your account and our system. In order to easily reach you, help you with the problems in a timely manner, or to keep records of the solutions and results of such problems. We may archive your records of your communications, correspondence/calls and related content (including account information, address, email address, other contact information and other information you provide to prove the relevant facts) with us. We may also use other information about you to provide customer service and to improve the quality of said service, including information you provide when you contact customer service and information you send to us in response to a survey.

b. Using our product

When you are using the products, in order to provide and improve our services, we will collect your basic information, device information, and we may match the corresponding functions based on such information collected, and may change the design of the products, revise the features or develop new ones based on the analysis of such data.This information is collected anonymously, and we cannot identify you through this information.

We collect information about your use of the product and how you use it, including but not limited to startup data, feature usage, interface clicks, login information, operation log information, access dates and times, duration of product usage, file sizes and formats you work with, crash data, and installation data. Additionally, during installation, we collect installation information such as device type, device hardware model, device operating system, version used, and product serial number, etc.

Please note that when you switch the software to run in the background, due to certain device models and system reasons, the information collection behavior resulting from your previous use of the product-related features may not cease immediately. There could be a brief period during which background information collection continues.

We process Product Usage Data and Product Installation Data so that we can facilitate, evaluate, and verify your use of our products and services. We will also use the Product Usage Data for our own internal statistical and analytical purposes, and to evaluate and enhance users' experience of the Products by identifying customer preferences and analyzing crash data. If you want to cancel the aforementioned purpose, you can contact us through customer service or online forms on our websites.

c. Transaction and payment

When you make a payment for our product through the App Store/Google Play, the App Store/Google Play collects various payment information from you. The specific information collected depends on the policies of the App Store/Google Play. In the end, we obtain the following information from the App Store/Google Play: your Apple/Google ID and email, country/region, the first six and last four digits of your credit card account, credit card expiration date, billing address, the type of product you purchased, the amount you paid in your currency, subscription ID, and URLs related to the subscription (such as purchase confirmation page URL, subscription cancellation URL, and invoice PDF URL).

We will use the transaction and payment information to determine your subscription, grant you access to use our product, and keep records for our internal financial purposes.

We will not collect or process data related to your payment tools, such as credit card numbers, bank account numbers, or PayPal accounts.

d. To provide you with product features

When you use the video Filter, AI portrait, AI Style, colorize, FaceDance, Cosplay, Time Machine, AI Hug baby predictor, Magic Brush Live photo, AI Tattoo and Beauty of our product, we need to access your device's storage and network permissions. We obtain these permissions to retrieve photos and videos from your device. You are free to make your selection, after which the photos and videos will be uploaded to our cloud for processing. The cloud will then return the finished product to you, and you can freely choose to save or store the photos locally.

When you use our Face Swap and facial restoration features, we need to access your device's storage and network permissions. We obtain these permissions to retrieve photos and videos from your device. You are free to select the photos and videos, which will then be uploaded to our cloud for processing. To achieve satisfactory results with these two features, only videos and photos containing faces can be selected. The cloud will then return the finished product to you, and you can freely choose to save or store it locally.

The images and videos you upload to our cloud, as well as the finished products processed in our cloud, will be automatically deleted from our system within three working days. Data is only processed when using specific features, and we do not store any facial data.When you are enhancing photos with our products, we need to get access to your device’s storage and network. We need such permissions to get access to your photos on your device, you are free to choose the photos that we can access(Only choose photos with faces when using face retouching to achieve retouching to your satisfaction, and only choose photos of portrait when using portrait cartooning to produce an edited portrait to your satisfaction), and you are also free to delete the process images or save them on your device locally. We can provide the best user experience for these features with facial data. The data will only be processed when the particular feature is used and we do not store the facial data.

e.Other contents

You may provide feedback or reviews about our products on the software store's comment section or other public platforms. We will use the comment data to improve our products. We may use the comments (with your relevant information) you post for marketing purpose to provide the consumers and potential consumers with our product information, and for others to better understand and use our products.

During your usage of our product, you may provide us with your information through data collection forms or other means. We will use the provided information in accordance with the agreed-upon terms, following legal and regulatory requirements. We will not use the information for any other purpose.

3. On one hand, we need the access to the aforementioned permissions and information of you to provide you with specific services. Also, we need them for internal statistics and analysis, to analyze your use of our websites and products and understand how they are used. By doing such, we are expected to improve our products and services, as well as the user experience. If you declined to such access or disagree to our collecting of such information, you will not be able to use such features, and we will give responses to your requests and needs in a timely manner. You will not be able to use the specific service, but it will not affect your regular use of our other services.

Ⅱ. How we store, protect and transfer your information

Unless otherwise required or permitted by applicable laws for longer retention periods, we will determine different retention periods for different types of information based on the nature of the information, the purposes for which we use the information, and the duration necessary to achieve the purposes described in this policy. For example, when processing your information to provide you with services, we will retain your account information, billing information, and similar content for as long as you have an account with us.

We employ reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. Please use complex passwords to assist us in ensuring the security of your account and personal information. Please be aware that the systems and communication networks you use when accessing our products may be subject to security vulnerabilities beyond our control. Understand that in the internet industry, due to technological limitations, rapid advancements, and potential malicious attacks, despite our best efforts to strengthen security measures, it is not possible to guarantee 100% security of information at all times.

Given the global nature of our business operations, we may transfer the data we collect about you to secure servers or data centers located in countries/regions outside the country where the data was initially collected (including the United States, the European Economic Area ("EEA"), or Japan) for storage and/or processing, The purpose of transferring this information across borders is:

• To transfer your payment information to payment processing companies located outside the European Union for transaction processing.
• To use third-party tracking tools (such as Bugsplat, Google Analytics) to track how users use product features. Product usage data may be sent to and stored in third-party servers located outside the European Union. Such tracking tools may share tracking data or analytics reports with TENPRSHARE for the aforementioned purposes. Our tracking tools anonymize your personal data.
• To store personal data on servers leased from service providers.

When transferring your data to countries/regions outside the country where the data was initially collected, we will protect the data in accordance with the instructions in this privacy policy and comply with applicable legal requirements to provide adequate protection for such data.

III. How we share, transfer and disclose your personal information

In order to ensure the implementation of our product-related features and the safe and stable performance of our apps, and because some features of our products cannot be executed by us alone, we may share or entrust some of your personal information with third parties such as our partners in order to ensure the smooth implementation of our product features. You agree that we may share your personal information with affiliates that support our features, and with third parties that we integrate or access, for the purpose of providing the services to you. The support provided by these third parties includes offering us data analysis, payment processing, and the realization of other functionalities. Our affiliates of our features are not authorized to use your personal information for purposes other than those set forth in this Privacy Policy and the purposes set forth herein. They shall obtain your authorized consent separately if they wish to change the purposes for which personal information is processed.

We may share your data with our affiliated companies, and in the event of a merger, division, acquisition, or bankruptcy liquidation, your data may be transferred as part of such transaction. We will ensure the confidentiality of such information during the transfer, inform you of the name and contact information of the recipient, and require the new entity holding your personal information to continue abiding by this personal information protection policy. Otherwise, we will request the recipient to seek your authorization and consent again. If we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.

Except for the aforementioned circumstances, we will not share or transfer your personal information with any third party. The entire process of using our Face Swap feature is conducted through our servers, ensuring that no third party has access to your facial information.

We may disclose all of your information for subsequent reasons: in response to a subpoena, court order, legal process, law enforcement request, legal claim, or government investigation, to protect and defend the rights, interests, and safety of the platform, our affiliates, users, or the public.

Ⅳ. How you shall manage your personal information

You have the right to access, correct, and delete the information we collect about you. If you are unable to do so, or have any questions about Personal Information we have collected and/or shared about you, or would like to withdraw your consent for our processing (i.e. entirely delete your account) please contact us at: [email protected]

We will act on the user’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.

Ⅴ. How we handle the personal information of minors

If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian (collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also recommend minors to obtain guardians’ prior consent and guidance before submitting personal information in your use of our services. If you are the legal guardian of a minor, please ensure that the minor in your custody is using our products or services with your authorized consent. If you have questions about the personal information of a minor in your custody, please contact us through the means set forth in this Privacy Policy.

AI Marvels App is not directed to children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable, unless we have a legal obligation to retain it. Please contact us if you believe we have any information from or about a child under the age of 13: [email protected].

Ⅵ. Permissions of users in different regions for their personal information

The GDPR，Law Concerning Protection of Personal Data of Japan and other applicable data protection laws provide certain rights for data subjects. Broadly speaking you have, or may have, the right (as more fully provided in applicable data protection laws):

• The right to be informed：The User has the right to be provided with clear, transparent and easily understandable information about how Hitpaw collects and uses personal data and its rights. This is the reason why Hitpaw is providing the User with the information in this privacy policy.
• The right of access：The User has the right to obtain access to its Personal Data (if Hitpaw is processing it), and other certain information (similar to that provided in this privacy policy).
• The right to rectification ：The User is entitled to have its personal data corrected if it’s inaccurate or incomplete.
• The right to erasure：This ‘the right to be forgotten’ enables the User to request the deletion or removal of its personal data where there’s no compelling reason for Hitpaw to keep using it.
• The right to withdraw consent：The User has the right to withdraw a previously provided consent to processing of your personal information.
• The right to object to processing ：The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its personal data.
• The right to restrict processing：Under certain circumstances, the User has the rights to ‘block’ or suppress further use of its personal data.
• The right to data portability：to receive its Personal Data provided to Hitpaw in a structured, commonly used and machine readable format and has the right to transmit those data to another controller.
• The right to lodge a complaint：to complain about our processing of your personal information to a local supervisory authority.