HitPaw Photo Enhancer 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. Logging in

When you visit or use our products, you may have the option to create an account or choose to log in and register through a third-party account (such as Google account, Apple account, Facebook account, WeChat account) in order to fully utilize all the features of the product. When creating an account, you may provide the following partial or complete information: username, email, phone number, social media accounts, country or region, etc. When registering or sharing through a third-party account, you may provide the following partial or complete information to us: publicly available personal information from the third-party account (nickname, profile picture, etc.), username, email address, etc. This information is used for account creation and user self-presentation. Additionally, when you encounter issues such as account loss, this information will help facilitate the process of recovering your account in a more convenient manner.

b. 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.

c. Using our products

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.

• Basic information: we will collect your activity information, such as the date and time you log in, features you keep using, features with most clicks, pages frequently visited and stay duration, and how you use our products.
• Device information: We collect information about your device, including hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), and mobile network information.

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.

d. Transaction and payment

When you make a purchase and payment transaction for our product through our website or within the product, we collect the billing information that you submit by yourselves: name and email address, country/region, zip code, first six and last four digits of your credit card account, credit card expiration date, billing address, type of product you purchase, amount you pay in your currency, subscription ID, subscription-related URLs (such as purchase confirmation page URL, subscription cancellation URL, invoice PDF URL).

We will use the transaction and payment information to process billing, renewals, and any subsequent refund services related to your order. The relevant information will also be used for internal financial record-keeping purposes.

We do not collect or process the data about your payment instruments such as credit card numbers, banking account numbers or Pay Pal accounts.

e.Providing you with features for photo enhancement

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.

f.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, we may show you ads for Hitpaw products and services that we think may interest you. If you want to cancel the aforementioned purpose, you can contact us through customer service or online forms on our websites.

From time to time, we may contact our customers directly by mail, email, or telephone to inform you about upgrades, new products, promotions, or special offers that you told us you were interested in receiving. If you want to cancel the aforementioned purpose, you can contact us through customer service or online forms on our websites.

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

We will determine different retention periods according to the type of information, the purpose for which we use the information, and the period required to fulfill the purposes described in the Policy, unless a longer keeping time is required or permitted by applicable law.

We take reasonable measures to help protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration or destruction. And please help us keep your account and personal information safe by using sophisticated passwords. Please be aware that the systems and communication networks you use to access our product may be subject to security issues in other steps beyond our control. Please understand that in the Internet industry, due to the limitations and rapid development of technology and the possible existence of malicious attacks, even if we do our best to strengthen security measures, it is not always possible to guarantee 100% security of information.

Given the global reach of our business and to provide you with continuous services on a global scale, we may transfer the data we collect about you to secure servers or data centers located outside the country/region where the data was initially collected (including the United States, European Economic Area (EEA), or Japan) for storage and/or processing. When we transfer your data to countries/regions outside the country where the data was initially collected, we will protect the data in accordance with the explanations provided in this privacy policy and comply with applicable legal requirements to ensure adequate data protection.

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 providing us with data analysis, data storage, payment processing. 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.

You agree that, in the event of merging, separating, acquiring or liquidating, your personal information may be transferred as part of such transaction. And we will ensure the confidentiality of such information at the time of transfer, and ensure that you will be informed of the name and contact information of the recipient. And we will require the new recipient of your personal information to remain subject to this personal information protection policy, or we will require the recipient to ask for your authorized consent again. If we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time.

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.

We are 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.