Privacy Policy

Effective Date: October 23, 2023

Update Date: May 7, 2025

We take your privacy and information security very seriously. We are committed to the careful handling, protection, and responsible use of your personal information.

This Privacy Policy (hereinafter referred to as "this policy") aims to clarify the information we and our affiliates and subsidiaries (hereinafter collectively referred to as "we," "our") collect, as well as how we use and protect your information when you use any mobile application downloadable via the App Store (hereinafter referred to as "services").

1. What Information Do We Collect:

1.1 Device Information

1. To provide you with a better experience when using our application, we collect information about your device and network connection.
2. This information depends on the context of your interactions with us, your choices (including your privacy settings), and the products and features you use. It may include:
   • ▪ SDK/API/JS code versions, IP address, platform, timestamps, application identifiers, application versions, application distribution channels, unique device identifiers, terminal manufacturers, operating system versions, language settings, time zones, and network status (cellular data, Wi-Fi, VPN, etc.), CPU and battery usage, screen resolution, memory usage, storage usage, SIM card carriers, SIM card countries, application publication status on the App Store, ad loading strategies, ad platforms and ad placement IDs, phone height and width, SIM card carrier names, operating system versions, developer mode, and ADB debugging mode.
   • ▪ We store information collected in this manner using device identifiers tied to the devices you use. This allows us to retain your advertising behavior while using the application. We will treat this information as personal information.

1.2 Data Related to Your Use of Services

1. Click counts, landing pages, browsed pages and their order, time spent on specific pages, request date and time, number of applications opened, and some browsed pages
2. Permission status
3. Whether features are functioning properly
4. Package name
5. Timestamps of the first open time
6. Application brand
7. Application network status
8. Firebase Device ID
9. Application model
10. SIM card country
11. System language, etc.
12. Advertisers may store or read cookies
13. This data will only be passed to the following authorized third-party analytics platforms: Adjust, Umeng, Google Analytics, and Google Firebase
14. The above information is only used to improve product experience and will not be sold to any third party. We do not use this information for purposes other than improving product experience and ad performance.

1.3 Monetization and Analytical Information from Other Sources

1.4 Integrated Third-Party SDKs in Our Applications May Access Your Information, Including:

1. Demographic data (e.g., determining your IP address)
2. Anti-fraud data (e.g., click fraud in ads)
3. Data related to your device (e.g., device type, technical information, country)
4. Data used for advertising, marketing, and analysis
5. Advertisers may store or read cookies

The information collected by third-party SDKs is managed by those SDK providers, over which we have no control. These third parties include monetization partners such as Mintegral, Google Ads, Pangle, Tencent Ads, Sigmob, and analytics tool partners like Adjust, Umeng, Google Analytics, and Google Firebase.

1.5 Other Information

We may collect information you voluntarily provide to us. This includes, but is not limited to, your email address, feedback, and answers to questionnaires.

2. How We Use Information:

2.1 To Improve and Optimize Services

2.2 To Provide You with Better Services

We have a legitimate interest in collecting and processing necessary data in order to:

1. Update and develop services
2. Enhance and improve your experience
3. Manage our relationship with you
4. Customize your service experience
5. Respond to your comments and inquiries and provide support
6. Offer promotions in services and other websites and services
7. Send you relevant information (e.g., updates, security alerts, support messages)

2.3 To Provide Services

We process the necessary data to:

1. Allow you to use the services
2. Operate the services
3. Provide and deliver products and services you request
4. Perform advertising and marketing-related activities

2.3.1 To Send You Personalized Advertisements and Marketing Materials

We may use information collected from you, such as advertising identifiers, age, country, region, gender, language, games played, and interaction data with services and other users.

We may also utilize various third-party advertising and marketing partners to assist us and may share the information we collect from you with such third parties for this purpose.

Therefore, we have a legitimate interest in processing the necessary data to:

1. Track the content you access while using the services and your online behavior
2. Deliver, target, and improve our advertisements and marketing materials
3. Transfer the information collected from you to third-party advertising and marketing partners

2.3.2 By Accepting This Policy and Downloading or Continuing to Use the Services

You agree that we and our advertising and marketing partners can collect and use information about you to personalize advertisements and marketing materials and enhance your experience unless you opt-out of this service.

We encourage you to review the privacy policies of our third-party advertising and marketing partners so that you understand how these third parties collect, use, and share your information. We are not responsible for the privacy policies of any third parties, whether accessed through the services or otherwise.

2.4 Ensuring Service Security

Ensuring security during the provision of services is our top priority. We take appropriate security and technical measures to protect your information from unauthorized access, loss, and misuse. To achieve this goal, we also require our vendors to take appropriate security measures when processing personal information on our behalf.

To maintain the security of services, combat fraud, and ensure proper use in other aspects, we have a legitimate interest in processing necessary data to:

1. Analyze and monitor the use of services
2. Prevent cheating, crime, or fraud
3. Take action against users involved in fraud or misconduct

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any communications facilities that we provide. We recommend that you exercise caution when disclosing any information through the services. In particular, please note that any personal identifiable information or personal sensitive data that you share or disclose while using the services may be collected and used by others. Therefore, you should be mindful of the information shared online. Also, note that any questions, answers, comments, or submitted content posted on forums will be publicly visible.

3. Information We Share:

As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you ads, measure your interactions with ads/websites, and better understand traffic usage or user behavior to improve their services. The use of the information we disclose to them will be governed by their privacy policies.

4. Important Permissions We Request:

1. Depending on the context of your interactions with us, we may request certain permissions so that our application can function properly. You can choose to opt-out at any time, but please note that not granting us these permissions may result in our application not operating correctly. The following permissions are requested by us:
   • ▪ Location
     • ▪ Approximate location (based on the network)
   • ▪ Wi-Fi connection information
     • ▪ View Wi-Fi connections
   • ▪ Others
     • ▪ Receive data from the Internet
     • ▪ Full network access permissions
     • ▪ View network connections
     • ▪ Prevent device sleep
     • ▪ Read synchronization settings
     • ▪ Enable and disable synchronization settings
     • ▪ Launch foreground services
     • ▪ Use full-screen intents
     • ▪ Post in the notification bar
     • ▪ Disable key lock when the screen is in black state
     • ▪ Change device settings
     • ▪ Receive broadcasts when the device starts
     • ▪ Access Apple account information
     • ▪ Access Apple account authentication information
     • ▪ Change synchronization settings

5. Legal Basis for Processing Your Personal Data:

We process personal data for the purposes described in this privacy policy. The legal bases for processing personal data include: processing necessary for the performance of a contract with you (e.g., to provide the services you request and to identify and verify your identity); processing necessary for compliance with legal obligations (e.g., compliance with applicable accounting rules and mandatory disclosures to law enforcement); processing necessary for our legitimate interests (e.g., managing our relationship with you, ensuring the security of our services, and informing you about our products and services); and processing based on your consent (e.g., placing certain cookies and sharing your information with third parties for advertising purposes).

In certain cases, to enable us to provide you with all of our services and to allow you to use all of the features of our app, you may need to provide personal data for the above processing.

6. Your Rights:

1. When you use our services, we provide you with the rights described below. If you wish to exercise your rights under applicable law, please contact us at picsloop@126.com. When we receive your personal rights request, please ensure you are prepared to verify your identity. Please note that your personal rights have limitations. We may limit your personal rights in the following ways:
   • ▪ When access is legally required or authorized to be denied;
   • ▪ When granting access would negatively affect the privacy of others;
   • ▪ To protect our rights and property;
   • ▪ As well as if the request is frivolous or burdensome.

6.1 Right to Withdraw Consent

If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. Withdrawing consent does not affect the legality of our processing or any processing carried out by any third party based on your consent prior to withdrawal.

6.2 Right to Access and Rectification

If you request a copy of the personal information we hold about you, we will provide you with a copy free of charge and without undue delay, unless the law allows us to charge a fee. If such access would adversely affect the rights and freedoms of other individuals, we may limit your access. You can also request the correction or updating of any personal information we hold about you unless you can do so directly through the service.

6.3 Right to Deletion ("Right to be Forgotten")

You may request that we delete personal information we hold about you if: it is no longer relevant to the purposes for which it was collected or processed; it was collected based on your prior consent but that consent has since been withdrawn; or it was collected in connection with processing activities you oppose, and there is no other legitimate basis for processing.

6.4 Right to Restriction

You have the right to restrict our processing of your personal information when one of the following applies:

• You contest the accuracy of your personal information we process. We will restrict our processing of your personal information during the time necessary for us to verify the accuracy of that information, which may lead to partial or complete service interruptions;
• The processing is unlawful, and you oppose the deletion of your personal information and request restriction of its use;
• We no longer need your personal information for processing purposes, but you need it to establish, exercise or defend legal claims; or
• You have objected to processing, pending verification of whether our legitimate grounds override your rights.

We will only process your restricted personal information in the following cases: with your consent; to establish, exercise, or defend legal claims;

6.5 Right to Object to Processing

If we are processing your personal information based on your consent, contract, or legitimate interests, you can object to our processing at any time under applicable law. We may continue to process your personal information where necessary for the defense of legal claims, or any other exception under applicable law.

6.6 Right to Data Portability

If we process your personal information based on a contract with you or your consent, or if such processing is carried out through automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format and, where technically feasible, request us to transmit your personal information directly to another controller, unless exercising this right adversely affects the rights and freedoms of others.

6.7 Notification to Third Parties

If we share your personal information with third parties, we will notify those third parties of any requests to correct, delete, or restrict your personal information unless this proves impossible or involves disproportionate effort. We will identify those third parties per your request.

6.8 Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to decisions based solely on automated processing of your personal information (including profiling) that produce legal effects concerning you or similarly significantly affect you, unless exceptions apply under applicable law.

6.9 Right to Lodge a Complaint

If you believe we have violated your privacy rights, please contact us via email at picsloop@126.com so that we can address your concerns. You also have the right to lodge a complaint with the relevant regulatory authority in your area, particularly where you are resident, work, or where the infringement occurred.

7. Children's Privacy Protection

This service is not directed at anyone under the age of 13. We do not intentionally collect personal identifiable information from children under 13. If we discover that a child under 13 has provided us with personal information, we will immediately delete that information from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we can take necessary measures.

8. Changes to the Policy

Any information collected is subject to the policy in effect at the time of collection. However, we may occasionally revise this policy. If such changes occur, we will provide additional notifications in appropriate ways. Your continued use of our app or services means you accept these changes.

9. Facial Information Processing

9.1 What Facial Information Do We Collect?

We collect facial images or video frames uploaded by users (e.g., selfies or photos of others) to support AI-driven interactive features, such as facial mapping, animation generation, and scene reconstruction.

This information is used solely for effect processing in image editing. Stored user image information will be regularly deleted.

9.2 Why Do We Collect Facial Information?

Facial information is used to achieve the following AI functions:

• Personalized virtual avatars: facial recognition for customizing digital identity
• Face-swapping in generated videos/images: replacing the user's face with that of other characters in the output
• Realistic animation effects: simulating emotions, expressions, or actions
• Scene composition: integrating facial images into virtual environments

9.3 Is Facial Information Shared with Third Parties?

Yes. Facial information is processed through the following third-party AI interfaces:

• Alibaba Cloud AI (Website: https://ai.aliyun.com/) for facial recognition and image generation

Third parties will access data only as necessary, and their privacy policies will govern the processing of facial information.

9.4 Will third parties store users' facial information?

Third parties will not store users' facial information; they will only process and apply effects to the images provided by users.

9.5 How Long is Facial Information Retained?

Facial information will be stored while the user's account is active or until the user requests deletion. Once deleted, the data will be permanently removed from our servers and processing systems.

10. Contact Us

If you have any questions or concerns regarding the policy, you can contact us via email at picsloop@126.com.