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.

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 processed results generated on our cloud, will be automatically deleted from our systems within three (3) working days. The data is processed solely for the purpose of providing the specific feature you request, and we do not retain such data on a long-term basis or use it to build any facial recognition database.

e. Personalized Recommendations & Tracking Permissions

To provide more accurate personalized recommendations and optimize user experience, our app allows users to voluntarily click on a questionnaire icon and fill in certain information (such as gender, age, and email address). When using the AI Video or AI Style features, content templates that match the user’s preferences will be prioritized. The information collected will be used solely to provide personalized recommendation content and will not be used for any other purpose. Data collection is a one-time process based on voluntary provision by the user, with no mandatory requirements. The entire process strictly complies with applicable privacy protection regulations, and users who choose not to provide this information will not be affected in their normal use of the app. All information provided by the user will be stored on our servers only for as long as necessary to fulfill the personalized recommendation functionality. If a user wishes to delete the personal information they have submitted, they may contact us via email, and we will promptly delete the information. After deletion, personalized recommendations based on such information will no longer be provided. We will not share the information provided through this method with any third party, unless expressly authorized by the user or required by law.

You acknowledge and agree that, with your authorization, our app may collect and process certain information related to your device through third-party services, including but not limited to device model, operating system version, device language settings, advertising identifiers (such as IDFA and Android ID), and event data related to app usage. Such data will be pseudonymized and used for personalized content recommendations and suggestions for optimization.

When you first use features that may involve personalized content recommendations or related functions, the system will display an authorization request, and you may choose to “Allow” or “Deny.” If you deny authorization, we will only display non-personalized content recommendations and will not engage in cross-app or cross-website tracking.

You may change this app’s tracking permission settings at any time in iOS via Settings > Privacy & Security > Tracking, or in Android via Settings > AI Marvels > Permission > Remove Permissions.

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, 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

To ensure the proper functioning of our products and the safe and stable operation of the application, and because some features rely on support from third-party services, we may share certain personal information with specific third-party service providers. These third parties provide support such as data analysis, payment processing, video/image generation services, and the implementation of other features. The scope of sharing is limited to the data necessary to achieve these functionalities. Third parties are required to strictly comply with this Privacy Policy and must not use your personal information for any other purposes.

Third-Party Information Sharing List

We may share your data with our affiliated companies to support product functionalities, provide services, or for internal business management purposes. In the event of a corporate reorganization or transaction, such as a merger, division, acquisition, or bankruptcy, your data may be transferred as part of such transactions. During any data transfer, we will ensure the confidentiality of the information and, where possible, inform you of the recipient’s name and contact information. We will also require the recipient to continue complying with this Privacy Policy, or, if necessary, to obtain your consent again. If we process your personal data based on your consent, you have the right to withdraw such consent at any time. Upon withdrawal, we will stop processing your personal data based on that consent, except as otherwise required by law or contract.

Except as described above, we will not share or sell your personal information to any other third parties.

We may disclose your information as required by law, for example, in response to subpoenas, court orders, law enforcement requests, or government investigations, to protect the rights and legitimate interests of the platform, our company, our users, or the public.

When you first use this product, you are required to read and agree to this Privacy Policy. By doing so, you consent to the sharing of certain personal information with third-party service providers when using features that involve third-party AI services to achieve product functionality. If you do not agree, please refrain from using the relevant features. Subsequent use of different models does not require separate consent each time.

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.