This Privacy Policy describes the
privacy practices of Fotobuzz in connection with the Fotobuzz mobile applications (each, an
“App” and collectively the “Apps”) and the
Fotobuzz.me website (the “Site”).
WELCOME TO Fotobuzz’S
PRIVACY POLICY!
If you decide not to read this entire
Privacy Policy, we want you to walk away with a few key points about Fotobuzz’s privacy practices:
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The Apps are photo or video editors that allow users to edit portraits with highly realistic facial
transformations.
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We do not use photographs or videos you provide when you use the Apps for any reason other than to
provide you with the editing functionality of the Apps.
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We use third-party cloud providers — specifically, Google Cloud Platform and aliyun Web
Services — to process and edit photographs and videos.
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You only send to the cloud the photographs or videos that you specifically select for editing.
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Photographs or videos are temporarily cached on the cloud servers during the editing process, and
encrypted using a key stored locally on your mobile device.
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Photographs or videos may remain in the cloud for a maximum limited period of 24 to 48 hours, for
improved performance and lower bandwidth allowing additional changes to recently selected photos or
videos in an optimal manner.
Here’s more on our privacy
practices.
【1】INFORMATION WE COLLECT
1.1. When you use the App and select
photographs or videos for editing, we cache them for processing to render the requested editing service:
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Photographs or videos you select when you use the
Apps, via your camera or camera
roll (if you have granted the Apps the permission to access your camera or camera roll), or via the
in-App internet search functionality. We process only specific photos and videos you choose to
modify using the Apps; and we do not collect your photo or video albums even if you grant us access
to them. We safeguard each photograph or video that you select using an encryption key stored
locally on your device. This means that the only device that can view the photo or video is the
device from which the photograph or video was submitted using the Apps – the user’s
device. Please note that while we do not require or request any metadata attached to the photographs
or videos you select for editing, metadata (including, for example, geotags) may be associated with
your photographs or videos by default. We take steps to delete any metadata that may be associated
with a photograph or video you provide when you use the Apps. Photographs or videos may remain
cached in the cloud for a limited period between 24 to 48 hours after your last edit, so that you
can return to it and make additional changes if you so choose.
1.2. When you use the App and the Site,
we may collect some information, including:
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App usage information and online activity data,
such as information about 1) how
you use the App and interact with it, including the features you use, your preferred language, the
date and time when you first installed the App and the date and time when you launch the app; 2)
sources of referrals to the Site. Our service providers and certain third parties (e.g., online
advertising networks and their clients) also may collect this type of information over time and
across third-party websites and mobile applications. This information may be collected on our Site
using cookies, browser web storage (also known as locally stored objects, or “LSOs”),
web beacons, and similar technologies. We may collect this information directly or through our use
of third-party software development kits (“SDKs”). SDKs may enable third parties to
collect information directly from the App. For more information, please see our
Cookie Policy
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App-related purchase history, if you choose to
purchase an App subscription, we
will not receive such information as billing address, credit card etc. (as we don’t distribute
subscriptions directly), we will only receive confirmation from the relevant application store that
you are a paid subscriber to the App so we can provide Pro services.
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Device data, such as your computer and mobile
device operating system type and
version number, manufacturer and model, push tokens, Google Advertising ID and Apple ID for
Advertising, browser type, screen resolution, IP address (and the associated city/country in which
you are located), and the website you visited before visiting our Site.
Only online identifiers such as the IP
address, Apps Instance ID (that is assigned to an App copy, installed on your device) and Advertising ID are
generally considered as personal data. However, we are not in a position to identify you directly as a data
subject on the basis of such identifiers.
1.3. When you contact us by email, we
may also collect:
【2】HOW WE USE YOUR INFORMATION
2.1. We do not use photographs or
videos you provide when you use the Apps for any reason other than to provide you with the editing
functionality of the Apps.
2.2. We may use information other than
photographs and videos for the following purposes:
To
operate and improve the Apps
and the Site. We use your personal information to operate, maintain, and provide you with the
Apps and the Site. In particular, we will use your personal information to perform our contractual
obligations under our Terms of Use, such as to:
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Enable you to use the Apps’ features and to visit the Site.
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Communicate with you about the Apps, and the Site, including by sending you announcements (if you
chose to “share email address”), updates, and security alerts, which we may send through
a push notification, and responding to your requests, questions, and feedback.
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Provide technical support and maintenance for the Apps.
To
improve, monitor, and
protect our Apps and the Site. It is in our legitimate business interests to improve and keep
our services safe and secure for our users. We do this by:
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Performing statistical analysis on aggregated data relating to the use of the Apps and Site
(including through the use of third-party services).
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Troubleshooting, testing, and researching.
To display
advertisements to
you. If you use the free version of the Apps, we work with advertising partners to display
advertisements within the Apps. These advertisements are delivered by our advertising partners and may be
targeted based on your online activity. Where require under applicable law, we process your personal
information based on your consent for these purposes, which you may withdraw at any time. Otherwise we
process your personal information for advertising purposes where it is in our legitimate interests to do so.
To learn more about your choices in connection with advertisements, please see our
Cookie Policy.
For compliance, fraud
prevention, and safety. We may use and disclose the information we collect (such as device data
and app usage information) where it is in our legitimate business interests to: (a) protect our, your, or
others’ rights, privacy, safety, or property (including by making and defending legal claims); (b)
enforce the terms and conditions that govern the Apps and Site; and (c) protect, investigate, and deter
against fraudulent, harmful, unauthorized, unethical, or illegal activity. We may disclose this information
to government authorities and other third parties as required by applicable law. We cannot disclose the
photos and videos that have been cached for processing as we do not store the encryption keys.
To create anonymous,
aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data
where it is in our legitimate business interests, and use and share it with third parties.
2.3. We will only process personal
information on the basis of our legitimate interests where such interests are not overridden by your
interests or your fundamental rights and freedoms.
【3】HOW WE SHARE YOUR INFORMATION
3.1. We do not disclose user
photographs or videos to third parties (with the exception of temporarily caching an encrypted version with
our cloud providers, Google Cloud Platform and aliyun Web Services, to provide the photo and video editing
features of the Apps). We cannot share the photos and videos cached for processing as we do not store the
encryption keys.
3.2. We may share your non-photograph
and non-video information in the following circumstances:
Affiliates. We may
share information we collect from you with our subsidiaries and affiliates, for purposes consistent with
this Privacy Policy.
Service
providers. We
may share your information with service providers that perform services on our behalf or help us operate the
Apps (such as customer support, hosting, analytics, email delivery, marketing, and database management
services). These third parties may use your information only as directed or authorized by us and in a manner
consistent with this Privacy Policy and are prohibited from using or disclosing your information for any
other purpose.
Advertising
partners.
When third-party cookies and other tracking tools are used, our advertising partners may collect information
from your device to display advertisements on the Apps, and to advertise the Site and Apps (and related
content) elsewhere online.
Third-party platforms
and
social media networks. You may select to post the edited photograph or edited video to your
social media account. We do not control the third-party platforms’ use of your information, which is
governed by that third party’s privacy policy and terms and conditions.
Professional
advisors.
We may disclose your information to professional advisors, such as lawyers and auditors, where necessary in
the course of the professional services that they render to us.
Business
transfers. We
may sell, transfer, or otherwise share some or all of our business or assets, including information, in
connection with a business transaction (or potential business transaction) such as a corporate divestiture,
merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or
dissolution.
【4】COMPLIANCE WITH LAW
We may be required to disclose your
information to comply with applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities, or for the compliance, fraud prevention, and safety
reasons described above. We do not have any access to your photos or videos as they are cached in encrypted
format, and the key resides on the user’s device so we cannot disclose such content.
【5】YOUR CHOICES
Opt out of push
notifications. You may opt out of the push notifications we may send you by changing the
settings on your mobile device.
Device
permissions.
You may revoke any permissions you previously granted to us, such as permission to access your camera,
camera roll, or microphone through the settings on your mobile device.
Personal information
requests. We also offer you choices that affect how we handle the personal information that we
control. Depending on your jurisdiction, you may request the following in relation to your personal
information:
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Information about how we have collected and
used your personal information. We
have made this information available to you without having to request it by including it in this
Privacy Policy.
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Access to a copy of the personal information
that we have collected about you.
Where applicable, we will provide the information in a portable, machine-readable, readily usable
format.
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Correction of personal information that is
inaccurate or out of date.
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Deletion of personal information that we no
longer need to provide the services or
for other lawful purposes.
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Additional rights, such as to object to and
request that we restrict our use of your
personal information.
To make a request, please email us at
[email protected] . We may ask for specific information from
you to help us confirm your identity. California residents can empower an “authorized agent” to
submit requests on their behalf. We will require authorized agents to confirm their identity and authority,
in accordance with applicable laws. You are entitled to exercise the rights described above free from
discrimination.
If you would like to submit a complaint
about our use of your personal information or our response to your requests regarding your personal
information, you may
contact us or submit a complaint to the data
protection regulator in your jurisdiction. If you are in Europe, you can find your data protection regulator
here.
Choosing not to share
your
information. Where we need your information in order to provide the services to you or where we
are required by law to collect your information, if you do not provide this information when requested (or
you later ask to delete it), we may not be able to provide you with our services.
Limits on your
choices. In some instances, your choices may be limited, such as where fulfilling your request
would impair the rights of others, our ability to provide a service you have requested, or our ability to
comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address
your request, you may submit a complaint by contacting us as provided in the “How to Contact Us”
section below. Please note that we may require additional information in order to verify your identity and
process your request.
【6】Additional Notes on Face Data
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Collection. We collect face data during
your photo processing, specifically when you upload pictures that wish to apply effects to. Our
system automatically checks for the presence of a face to ensure the application of the correct
and better photo effect.
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Use. Face data is used solely for the
purpose of delivering the photo effects as requested by you. If the photo contains a face, our
system utilizes this data to customize the applied effects and ensure the final product meets
our standards of quality and user expectations.
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Disclosure. We do not disclose face data to
any external parties. The face data collected is solely for internal processing within the app
to deliver the requested service to you. All user data, including processed results from
uploaded photos, are now stored on our secure Amazon AWS servers located in Ohio, USA. This
ensures higher data security and compliance with global data protection regulations.
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Share. There is no sharing of face data
with any third parties. All user content, including photos that contain faces, are processed
exclusively within our app and are not made available to any third-party services or entities.
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Retention. Uploaded photos are not stored
in server. Once the processing is complete, the original uploaded image is immediately
destroyed. We retain only the processed results, and these are visible within the user's
personal account where the user retains full control to delete them at any time. To enhance user
experience and convenience for future uploads, we cache the processed results locally within App
sandbox. This allows you to quickly access and, if desired, re-upload previously processed
photos without the need to store these photos on our servers.
【7】OTHER SITES, MOBILE APPLICATIONS, AND SERVICES
The App may contain links to other
websites, mobile applications, and other online services operated by third parties. These links are not an
endorsement of, or representation that we are affiliated with, any third party. In addition, our content may
be included on web pages or in mobile applications or online services that are not associated with us. We do
not control third party websites, mobile applications, or online services, and we are not responsible for
their actions. Other websites, mobile applications, and online services follow different rules regarding the
collection, use, and sharing of your personal information. We encourage you to read the privacy policies of
the other websites, mobile applications, and online services you use.
【8】SECURITY PRACTICES
We use commercially reasonable security
practices to help keep the information collected through our services secure. However, Fotobuzz cannot
guarantee the security of any information you provide, as bad actors, for example, may try to access,
disclosure, alter, or destroy your information.
Please do your part to help us. You are
responsible for maintaining the confidentiality of your information, and for controlling access to
communications between you and Fotobuzz, at all times. We are not responsible for the functionality,
privacy, or security measures of any other organization.
【9】RETENTION
We configure Google Cloud Platform and
aliyun Web Services to delete photographs and videos, and the information associated with those photographs
and videos, within 24 to 48 hours after the photograph or video was last edited using the Apps. This allows
you to revisit photographs or videos to make additional modifications during that time.
With respect to non-photograph and
non-video information that we may collect, we will retain such information only for as long as necessary to
fulfill the purposes we have set out in this Privacy Policy.
【10】CROSS-BORDER DATA TRANSFERS
If we transfer your personal
information internationally, these countries may not provide the same protections as the data protection
laws where you are based. Where we transfer information internationally, we:
We do this using a variety of
protections, as appropriate for each data transfer. For example, we use:
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Standard Contractual Clauses (or an alternative legal tool, such as the UK Government-approved
International Data Transfer Agreement or Addendum) to require the third party to protect your data
and to provide you with EU- and UK-level rights and protections;
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Technical protections, such as automated deletion, encryption, and pseudonymization;
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Policies and processes to challenge disproportionate or unlawful government authority requests.
Note, our technical support team may
also access your information, such as App usage information, in locations outside of your state, province,
or country.
【11】CHILDREN
Our Apps and Site are not directed at
children under the age of 13. This explains why we do not consciously collect data from subjects under the
age of 13. If you are less than 13 years old, do not use our Apps and Site. If you are a parent or the
guardian of a person under the age of 13, please do not allow such person to use our Apps and Site. In
certain cases, this age may be higher than 13 due to local regulatory requirements.
【12】CHANGES TO THE PRIVACY POLICY
We reserve the right to modify this
Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by
updating the date of this Privacy Policy and posting it on the App and Site. We may, and if required by law
will, provide notification of changes in another way that we believe is reasonably likely to reach you, such
as through the Apps.
Any modifications to this Privacy
Policy will be effective upon our posting the new terms to the Site and/or upon implementation of the new
changes on the Apps and Site (or as otherwise indicated at the time of posting). In all cases, your
continued use of our services after the posting of any modified Privacy Policy indicates your acceptance of
the terms of the modified Privacy Policy.
【13】HOW TO CONTACT US
If you have any comments or questions
regarding this Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a
complaint about how your personal data is being processed by Fotobuzz, you can contact our Data Protection
Officer DPO at
[email protected] .
ADONADS TECHNOLOGY CO LIMITED
FLAT RM A1, 11/F WINNER BUILDING，36 MAN YUE STREET HUNG HOM，KL，HONG KONG
