Privacy Policy

Effective Date: April 18th, 2024

This User Privacy Policy (hereinafter referred to as the "Policy") is an integral part of the User Agreement and is jointly entered into by the user (hereinafter referred to as "you") and us (hereinafter referred to as "we" or "our").

If you are a minor under the age of 18, you need to read this privacy policy accompanied by your guardian. Please make sure you and your guardian read it carefully, and only use our products and services after obtaining your guardian's consent to all terms of this privacy policy. We absolutely respect the privacy and information of users and will strictly protect your privacy and information. When you use this product and service, we may collect and use your relevant personal information. We hope to explain the processing rules and related matters when we collect and use your personal information through this privacy policy to better protect your rights. Here we make the following explanations and instructions to you:

I. Definitions Unless otherwise agreed, the terms used in this privacy policy usually have the following definitions. If not specifically stated in this privacy policy, the relevant term definitions are consistent with the User Agreement:

1. Personal Information (refer to GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): refers to various information recorded by electronic or other means that can identify a specific natural person's identity or reflect a specific natural person's activity, either alone or in combination with other information. Examples of personal information: personal basic information (including personal name, birthday, gender, address, personal mobile phone number, email address, etc.), personal identification information (including identity document number), personal biometric information (including fingerprints, facial features), network identity identification information (including system account, password, IP address, personal digital certificate, etc.), personal property information (including bank account, password, transaction and consumption records, virtual currency, virtual transactions, redemption codes, etc.), contact information, personal internet records (including website browsing records, software usage records, software list/application list in use), personal commonly used device information (including hardware serial number, hardware model, device MAC address, operating system type, software list, device unique device identification code, etc.), personal location information (including precise location information, latitude and longitude, etc.). The types of personal information we actually collect are subject to the description in this privacy policy.

2. Personal Sensitive Information (refer to GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): refers to personal information that, once disclosed, illegally provided, or misused, may endanger personal and property safety, and is likely to lead to damage to personal reputation, physical and mental health, or discriminatory treatment. Examples of personal sensitive information: your personal property information, personal identification information, personal biometric information, contact information, friend list, group list, precise location information, personal information of children under 14 years old (inclusive), etc. The types of personal sensitive information we actually collect are subject to the description in this privacy policy.

3. Device: refers to a device that can be used to access or use this product and service, such as a computer, tablet, or smartphone.

4. Unique Device Identifier: refers to a string of characters embedded in the device by the device manufacturer, which can uniquely identify the corresponding device (such as IMEI/android ID/IDFA/OpenUDID/GUID/SIM card/IMSI information, etc.).

5. IP Address: refers to the number assigned to each device that accesses the internet, usually based on geographical location.

6. Cookie: refers to a small file containing a string of characters that is sent and stored on your computer, mobile device, or other device when you log in and use a website or other online content (usually encrypted). Cookie and similar technologies are used for purposes similar to cookies, such as web beacons, proxies, and embedded scripts.

7. Account: also known as "user account", refers to the account that you successfully registered for using our product and service in accordance with the User Agreement and relevant laws and regulations.

2. What Kind of Personal Information Do We Process?

When you use the My App services, we may collect a variety of information, including:

- Photos or videos that you upload.

- Your prompt requests and history, as well as generated photos or videos.

- Your subscription plans and payment details, including subscription details, payment amount, order ID, payment time.

- Device information, including IDFA, unique device identifiers, and IP address.

- App analytics and usage data, including data about your activity on our App, including crash data, diagnostic data, your operating system version, the configuration of the app, the time and date of your use of My App.

- Coarse location data, such as country and city.

- Content of your feedback.

- Content of communications with our customer service.

Additional note on facial images:

When you upload photos/facial images to My App, we ensure that such data is transferred securely and encrypted to our server. Our artificial intelligence algorithm analyzes the photos you upload and applies them to the template you choose to generate stylized pictures. It's important to note that no biometric data is collected and processed during this process. Additionally, any photos provided by users and photos generated are not stored on our servers.

We process your facial images on My App server only for the purpose of generating photos as you request. We do not sell your Personal Information to third parties. Once the generation process is completed, the photos you provided will be deleted immediately. We only store anonymous or aggregated data for as long as necessary to fulfill the purposes set out in our Privacy Policy.

3. How Do We Use Your Personal Information?

We may process your Personal Information for the following purposes:

- To provide Services for you in connection with My App Terms of Service.

- To fulfill requests for products, services, functionality, support, and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.

- To provide customized contents and services for you.

- To better understand and analyze how our users use My App.

- To improve and develop our services and conduct product development.

- To measure and understand the effectiveness of the advertisements.

- To train and enhance our AI model.

- For digital marketing purposes and to promote My App.

- To improve information security of My App.

- To prevent fraud or other illegal activities.

II. How We Collect and Use Personal Information

We collect and use personal information that you voluntarily provide during the use of services or that is generated due to the need for products and/or services, in accordance with laws and regulations and following the principles of legitimacy, legality, and necessity. If we intend to use your personal information for other purposes not specified in this privacy policy, or use the collected information for other purposes based on specific purposes, we will promptly inform you in a reasonable manner and obtain your consent again before using it.

The types of personal information we collect and use include two categories:

• First: Information necessary for the core business functions of our products or services: This type of information is essential for the normal operation of products and/or services, and you must authorize us to collect it. If you refuse to provide it, you will not be able to use our products and/or services normally;

• Second: Information that may need to be collected for additional business functions: This information is required for non-core business functions, and you can choose whether to authorize us to collect it. If you refuse to provide it, it will result in the inability to achieve additional business functions or achieve the intended effect, but it will not affect your normal use of the core business functions.

You understand and agree that we hope to provide you with complete products and services, so we will continue to improve our products and services, including technology, which means we may frequently launch new business functions that may require the collection of new personal information or changes in the purpose or method of using personal information. If a function or product/service that requires the collection of your personal information is not explained in this privacy policy, we will separately explain the purpose, content, usage method, and scope of the information collection through updating this policy, page prompts, pop-ups, website announcements, etc., and provide you with a way to choose to agree, and collect it after obtaining your explicit consent. During this process, if you have any doubts about related matters, you can contact us through the methods provided in Article 10 of this privacy policy, and we will respond to you as soon as possible.

In the course of using this product and service, we will generally collect and use your personal information in the following scenarios:

1. During the use of this product and service:

(1) Read/write external storage of the device. We need to obtain the permission to read/write external storage of the device (if you use an Android device, the permissions involved may include "read external storage permission", "read/write SD card content permission", and "modify/delete SD card content permission", the same below), obtaining the above permissions and information is used for the installation and storage of products on the device and the reading of archives and files (including necessary processes and caches, and reading, writing/downloading/saving/modifying pictures or albums, files, crash logs, etc.), to ensure your normal login and use of our services, and maintain the normal and stable operation of the product's basic functions. If you refuse to provide the aforementioned permissions, it may result in your inability to use our related products and services.

(2) Log information, including login logs, item logs, purchase logs, activity logs, upgrade logs, chat logs, product internal friend records, and other log information generated during the use of this product and service. We collect the above information for operational statistical analysis, customer service complaint handling, and other service experience optimization analysis, and to facilitate your viewing of your historical records in the product client; if you refuse to provide the aforementioned permissions, it may result in your inability to use our related products and services.

(3) Interaction information. When you interact with text, pictures, voice, and other means with other users in the product, we may collect and save the content of the information you send to filter inappropriate content such as pornography, violence, politics, abuse, malicious advertising, etc., to purify the network space and maintain a healthy online environment. If you wish to interact with other users via voice or take, upload, and save pictures, after obtaining your authorization and consent, we will access your microphone, camera, album, and read/write external storage permissions. If you refuse to provide the aforementioned permissions, it may result in your inability to use our related products and services, but it will not affect your normal use of other functions of this product and service (unless otherwise specified in this privacy policy), and you can also disable the aforementioned permissions at any time in the system settings.

(4) Application information, device information (unique device identifier, device serial number, device manufacturer, device name, device type and version, device model, device style, device MAC address), network identity identification information (IP address), operating system and process information, network environment information, and service crash records. We collect the above information to verify account information, ensure your account security, and may use your IP address to identify the location where your device accesses the internet, in order to implement specific activity content.

(5) Transaction information, including recharge records, consumption records, and other necessary information related to transactions. When you use certain consumption functions in the product, we will collect the above information to facilitate your query of transaction records, and to protect your transaction security to the greatest extent possible. Recharge records and consumption records are personal sensitive information, and the collection of such information is necessary to achieve the consumption function of the service; otherwise, the transaction cannot be completed.

1. Customer Service

When you initiate a complaint, appeal, or consultation, or apply for account cancellation, in order to verify your user identity and ensure account and system security, we may need you to provide account information first and match it with the personal information you previously provided. At the same time, in order to facilitate contact with you or help you solve problems or send gifts, we may also need you to provide your name, mobile phone number, email, and other contact information and personal information. Additionally, we will collect your communication information (including text/picture/audio/video/communication records) and other necessary information related to your needs. The above information is personal sensitive information, and we collect it to investigate facts and help you solve problems. If you refuse to provide the above information, we may be unable to promptly feedback the results of your complaints, appeals, or consultations.

In order to better understand customer needs and optimize services, our customer service staff may contact you by phone to understand the product usage situation, ask for your opinions, or conduct follow-up activities. If you do not want to receive such phone calls, you can contact us through the methods provided in Article 10 of this privacy policy, and we will no longer contact you by phone.

1. Cookie and Similar Technologies

In order to improve related services, we may use cookies and similar technologies to store and track user-related data at certain times. The use of the above is limited to: estimating traffic, statistical analysis of user preferences, and other commercial, market analysis, or academic purposes. Cookies and similar technologies may be used by third parties, such as advertising services that require identifiable data, information, etc. as evaluation indicators and data. These data are only used for analysis purposes, to evaluate the effectiveness of advertisements and other promotional and promotional activities in our products or services, and to improve them.

1. According to relevant laws and regulations, as well as national standards, in the following situations, we may collect, use, share, transfer, and publicly disclose your personal information without obtaining your prior consent:

(1) Related to our fulfillment of legal obligations;

(2) Directly related to national security, national defense;

(3) Directly related to public safety, public health, or significant public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;

(5) In order to protect your or other individuals' life, property, reputation, etc. and it is difficult to obtain your consent;

(6) The personal information you have voluntarily disclosed to the public;

(7) Collecting personal information from publicly available sources, such as legal news reports, government information disclosure, etc.;

(8) Necessary for the conclusion or performance of a contract to which you are a party;

(9) Necessary for maintaining the safe and stable operation of the services we provide, such as discovering and handling product or service failures;

(10) Necessary for legitimate news reporting;

(11) Necessary for academic research in the public interest, and the results of the research or descriptions are publicly available, and the personal information contained in the results is de-identified;

(12) Other situations as stipulated by laws and regulations.

Please note that when we share, transfer, or publicly disclose de-identified personal information, and the data recipient cannot restore or re-identify the information subject, it does not constitute sharing, transfer, or public disclosure of personal information. For such data, we do not need to notify you separately and obtain your consent.

IV. How We Store and Protect Your Personal Information

1. Information Storage

(1) Storage Location: In accordance with laws and regulations, we will only store the personal information collected about you within the territory of the People's Republic of China. Currently, there is no scenario where your personal information is stored across borders or provided to overseas entities. If cross-border data transmission is necessary, we will inform you separately (including the purpose of data export, recipient, usage method and scope, content, security measures, security risks, etc.) and obtain your explicit consent. We will ensure that the data recipient has sufficient data protection capabilities to protect your personal information.

(2) Storage Period: We retain your personal information for the shortest period necessary to achieve the purposes of our products and services. For example, when you use our registration and membership functions, we need to collect your mobile phone number and retain it during the period you use the function to provide the service and ensure your account and system security. Additionally, we may retain your relevant information for the necessary period specified by relevant laws (e.g., the "E-Commerce Law" stipulates that the retention period for goods and service information and transaction information shall not be less than three years from the date of transaction completion).

(3) After the above storage period is exceeded, we will delete or anonymize (de-identify) your personal information.

1. Information Protection (1) The security of your personal information is of utmost importance to us. We will strictly comply with relevant laws and regulations, adopting industry-recognized reasonable and feasible measures to protect your personal information. This includes preventing unauthorized access, disclosure, use, modification, and avoiding damage or loss of information.

(2) When requiring users to provide information related to their personal identity, we should disclose our privacy policy to users in a clear and visible manner in advance and take necessary measures to protect user information.

(3) Except as explicitly stipulated in this privacy policy, without user permission, we shall not provide, disclose, or share users' registration information, such as name, personal identification number, contact information, home address, etc., with any third party, except in the following situations: authorized disclosure by the user or user's guardian; disclosure required by relevant laws or mandatory regulations; provision required by judicial or administrative authorities based on legal procedures; when filing a lawsuit or arbitration to protect one's legitimate rights; provision of user's personal identity information upon the legitimate request of the user's guardian.

1. User Account Use and Management

To ensure the security of user accounts, we have the right to verify the authenticity and validity of the identity information provided during user registration and should actively take reasonable technical and management measures to ensure the security and effectiveness of user accounts. Users are obligated to properly keep their accounts and passwords and to use them correctly and safely. If either party fails to fulfill the above obligations, resulting in the loss of account passwords, account theft, etc., which causes damage to the civil rights of users and others, they shall bear legal responsibility.

We understand your concern about personal information and do our utmost to ensure your rights to query, correct, delete, and withdraw authorization for your personal information, providing you with the full ability to protect your privacy and security. Your rights include:

1. You have the right to query your personal information

You can query the relevant personal information you have provided to us according to the instructions (or settings) of the products and services we provide. This includes:

(1) Account Information: You can log into your personal profile page at any time through the relevant page to access your personal profile information in the product, including: avatar, nickname, etc.;

(2) Other Information: If you encounter operational problems during access and need to obtain other personal information content that cannot be known previously, you can contact us through the methods provided in this privacy policy.

1. You have the right to correct your personal information

When you find that the personal information you provided to us has registration errors, is incomplete, or needs updating, you can contact us through the methods provided in this privacy policy and submit a correction application.

(1) For some of your personal information, such as avatar, nickname, etc., we provide operational settings on the relevant function pages of the product, where you can directly correct/modify.

(2) If you encounter difficulties in exercising the above rights, or if other services that currently cannot provide you with online self-correction/modification, you can contact us through the methods provided in this privacy policy to request us to correct or modify your data. After verifying your identity and ensuring that the correction/modification does not affect the objectivity and accuracy of the information, we can correct or modify incorrect or incomplete information, except as otherwise provided by laws and regulations.

1. You have the right to delete your personal information

(1) For some of your personal information, you can contact us through the methods provided in this privacy policy to submit a deletion request. Once the personal information deletion request is approved, we will delete or anonymize such information unless otherwise provided by laws and regulations.

(2) In the following situations, you can directly request us to delete your personal information, except for information that has been anonymized or as otherwise provided by laws and regulations:

① When our processing of personal information violates laws and regulations;

② When we collect and use your personal information without your consent;

③ When our processing of personal information violates our agreement with you;

④ When you cancel your user account;

⑤ When we terminate services and operations.

1. You have the right to withdraw your authorization

As mentioned earlier, we provide some functions of our products and services that require obtaining your device-related permissions (including: album, camera, microphone, etc., specific to the product's actual acquisition functions). You can revoke (or stop) the authorization of the above permissions at any time after authorization. For example, you can close your authorization for mobile phone albums through "Settings-Privacy-Photos" on iOS devices. You can also revoke your consent to this privacy policy through the product's corresponding function page or by canceling your account, and permanently revoke our authorization to continue collecting your personal information. You need to understand that when you revoke your authorization, we will not be able to continue providing you with the specific functions and/or services corresponding to the revoked authorization. However, your decision to revoke your authorization will not affect the personal information processing that has been carried out based on your authorization prior to the revocation.

1. You have the right to cancel your account

You can contact us through the methods provided in this privacy policy to apply for account cancellation. After canceling your account, you will no longer be able to log in and use our products and services; all rights and interests that have been generated but not yet consumed during the use of our products and services, as well as future overdue benefits, will be cleared; the content, information, data, and records under the account will be deleted or anonymized (except as otherwise provided by laws and regulations or as required by regulatory authorities, such as the "Cybersecurity Law of the People's Republic of China" which stipulates that network operation logs shall be retained for at least six months). After the account is canceled, it cannot be recovered.

VI. Protection of Minors

1. We attach great importance to the information security and protection of minors. We encourage parents or other guardians (hereinafter referred to as "guardians") to guide minors in using our services. If you are a minor under the age of fourteen, please notify your guardian to read this policy together and seek their consent and guidance before using our products and services and submitting personal information.

2. For personal information of minors collected with the consent of the guardian, we will only use or publicly disclose this information as permitted by law, with the explicit consent of the guardian, or as necessary to protect minors.
3. If you are the legal guardian of a minor, please pay attention to whether the minor you are guarding uses our products and services with your authorization and consent. If the guardian explicitly refuses us to provide services to minors in the above manner, we will promptly delete the relevant personal information of minors that we have collected, stored, and used in accordance with legal requirements and stop providing services to the minor.

VII. Suspension and Termination of Services

1. Users who publish illegal information, seriously violate social morality, or engage in other behaviors that violate prohibitive provisions of the law have the right to immediately terminate the provision of services to the user.

2. Users who engage in improper behavior while receiving services have the right to terminate the provision of services to the user.

VIII. Updates and Access to This Privacy Policy

1. In order to provide you with better services, we will update the terms of this privacy policy according to the update of the product and the relevant requirements of laws and regulations. These updates constitute part of this privacy policy. Without your explicit consent, we will not reduce the rights you are entitled to under this privacy policy. If such updates result in a substantial reduction or significant change in your rights under this privacy policy, we will notify you by prominently displaying a prompt or sending you a push message or by other means. If you continue to use our services, it means that you have fully read, understood, and agreed to be bound by the revised privacy policy.

2. Major changes include but are not limited to:

(1) Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

(2) Significant changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy mergers, etc.;

(3) Changes in the main objects of personal information sharing, transfer, or public disclosure;

(4) Significant changes in your rights to participate in personal information processing and the manner of their exercise;

(5) Changes in the contact information and complaint channels of personnel responsible for handling personal information security;

(6) When the personal information security impact assessment report indicates a high risk.

1. You can access the content of this privacy policy through the relevant function pages of this product and the official website. If you have any questions about the above access functions, you can contact us through the methods provided in this privacy policy.

IX. Applicable Law and Dispute Resolution

1. The establishment, performance, interpretation, and dispute resolution of this User Privacy Policy shall be governed by the laws of the People's Republic of China, excluding the application of all conflict of laws.

2. If there is any dispute between the parties regarding the content of this User Privacy Policy or issues related to personal information protection encountered while using our services, the parties shall resolve it through friendly negotiation; if negotiation fails, either party shall file a lawsuit with the People's Court of Chengdu High-tech Zone.

3. The titles of all terms of this agreement are for convenience of reading only and have no actual meaning and cannot be used as a basis for interpreting the meaning of this agreement.

4. If any part of the terms of this agreement is invalid for any reason, the remaining terms shall remain valid and binding on all parties.

X. Special Provisions on Facial Data

1. Collection of Facial Data

   We may collect users' facial data, which will only be used for generating images to provide specific services and functions. Facial data is considered personal biometric information, and we promise to take strict security measures to protect this information.

2. Use of Facial Data

   The collected facial data will only be used for the following purposes:

   • Provide services and functions requested by the user;
   • Improve user experience and service quality;
   • Comply with legal and regulatory requirements.

3. Sharing of Facial Data

   We will not share users' facial data with any third parties, except:

   • With the user's explicit consent;
   • When required by laws, regulations, or judicial decisions;
   • To protect the interests of users or the public, prevent or handle illegal activities.

4. Storage of Facial Data

   Users' facial data will be stored within the territory of the People's Republic of China and will only be retained during the provision of services. After the service ends, we will delete or anonymize the facial data.

5. Retention Period of Facial Data

   The retention period of facial data will comply with relevant laws and regulations, and when the service no longer requires these data, we will delete or anonymize them.

6. Protection Measures for Facial Data

   We take industry-standard security measures to protect users' facial data, including but not limited to data encryption, access control, and security audits.

XI. Contact Us

1. If you have any questions about the content of this User Privacy Policy or encounter issues related to personal information protection while using our services, you can contact us through any of the following methods:

(1) You can contact customer service or submit feedback online through the relevant function pages in the product;

(2) You can send an email to our email address (contact+aitools@douwantech.com) to contact us.

1. We will respond to your opinions and suggestions as soon as possible within 15 working days after receiving them and verifying your user identity. In special or complex situations, our response time may be correspondingly extended. In addition, you understand and acknowledge that in the following situations related to personal information, we may not be able to respond to your request:

(1) Related to national security, national defense;

(2) Related to public safety, public health, or significant public interests;

(3) Related to criminal investigation, prosecution, trial, and execution of judgments;

(4) There is sufficient evidence to show that you have malicious intentions or abuse your rights;

(5) Responding to your request may cause serious harm to your or other individuals' or organizations' legitimate rights and interests;

(6) Involves trade secrets;

(7) Other situations as stipulated by laws and regulations.