Privacy Policy (Summary)
Latest Release, Update, and Effective Date: Month 3, Day 1, 2024.
We hold your privacy and personal information protection in the highest regard. When using MIX2 Portrait Master (hereinafter referred to as "Portrait Master"), we may collect and use relevant information about you. Please read carefully, fully understand, and agree to accept all the contents of the Privacy Policy before commencing usage, particularly those terms highlighted in bold.
The Privacy Policy summary primarily informs you about the types and service scenarios in which we may collect and use your personal information within necessary limits, as well as the fundamental rules governing how we process your personal data. For a comprehensive understanding of all scenarios where we might collect and use your personal information and for our complete set of rules regarding the processing of such information, please refer to the full text of the Privacy Policy attached in the annex.
I. How we collect and use your personal information
1. Editing and beautification. When you perform network data requests (such as downloading materials or connecting to iCloud for photo downloads and uploads), we may need to collect your device ID, IDFA, device model, local language, and time zone information to identify the device being used.
2. Feedback. When you provide feedback or inquire through the in-app feedback function, we may collect your device ID, IDFA, device model, local language, and time zone information to better understand your mobile device situation.
3. In-app purchases. Upon purchasing the VIP service of Portrait Master, we will gather corresponding order information, including transaction order numbers, device IDs, transaction IDs, order types, payment methods, payment statuses, order titles, order amounts, currencies used for payment, order creation timestamps, order payment timestamps, whether the order is official, user IDs, and local languages.
4. Security assurance. To troubleshoot product malfunctions and ensure account and payment security, we may collect your device ID, IDFA, IP address, device model, and operational log information.
5. Questionnaire survey. In questionnaire surveys, you may be asked to provide your WeChat ID, mobile phone number, or QQ number to gather specific opinions from you and provide responses to your suggestions.
6. The specific items of your information collected and utilized by the various business functionalities of the product are listed; please refer to the List of Personal Information Collection and Usage. The itemized list of device permissions potentially accessed for implementing relevant business functions is provided; please refer to the System Permissions Request and Usage Checklist.
II. How we share your personal information
Please understand that we are unable to provide you with all services independently, necessitating the involvement of other service providers to jointly provide these services to you. As a result, it is required for us to share or entrust the processing of certain parts of your personal information with third parties. You can review the situation where third-party SDKs collect and utilize your personal information by referring to the Third-Party Sharing List of Personal Information.
III. How you manage your personal information
You can manage your personal information in multiple ways, such as accessing and correcting your profile, as well as deactivating your account. However, please be aware that we may not be able to fully accommodate your requests due to legal obligations that we are required to fulfill.
IV. How to contact us
If you have any questions, comments or suggestions about the Privacy Policy or matters related to your personal information, you can contact us by sending an email to inFace @camera360.cn or by mailing a registered letter to Floor 13, Building 1, No. 1268, Middle Section of Tianfu Avenue, Chengdu Hi-Tech Zone, China (Sichuan) Pilot Free Trade Zone.
We will respond within 15 days. If you are dissatisfied with our reply, you also have the option to seek resolution by initiating civil litigation at the People's Court located in the defendant's place of residence.
The following is the full Privacy Policy for Portrait Master.
Privacy Policy
Latest update date: Month X, Day X, 2024.
The Policy will assist you in understanding the following aspects that may be involved during your use of MIX2 Portrait Master (hereinafter referred to as "Portrait Master"):
1. How we collect and use your personal information
2. How we share, transfer, and disclose your personal information
3. How we protect your personal information
4. Your rights
5. How we process personal information of minors
6. Storage of personal information
7. Applicable laws and jurisdiction
8. How to update the Policy
9. How to contact us
Portrait Master is acutely aware of the importance of personal information to you and commits to making every effort to protect the security and reliability of your personal data. We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: The principles of consistent power and responsibility, clear purpose, confirmation before collection and utilization, collection to the minimum extent as required, ensuring security, subject participation, openness and transparency, and so on. Meanwhile, Portrait Master pledges that we will adopt appropriate security protection measures in accordance with mature industry security standards to safeguard your personal information.
Please thoroughly read and understand the Privacy Policy before using our products or services. When you enter this product for the first time, we will prompt you with a pop-up window to read the Privacy Policy and ask you to choose whether to accept it. If you choose to consent, Portrait Master will strictly collect and use your personal information according to the purposes outlined in the Policy, as detailed in "I. How we collect and use your personal information". If you choose not to consent, Portrait Master will not automatically collect or report your personal information.
I. How we collect and use your personal information
Personal information refers to all kinds of information that is recorded by electronic or other means and can be used alone or in combination with other information to identify a specific natural person or reflect activities of a specific natural person.
Portrait Master collects and uses your personal information solely for the following purposes described in the Policy:
(I) Business function one: Editing and beautification.
1. This product allows for use without registration. When you perform network data requests (such as downloading materials or connecting to iCloud for photo downloads and uploads), we may need to collect your device ID, IDFA, device model, local language, and time zone information to identify the device being used.
2. When you use features such as Supreme Skin Quality, Facial Feature Adjustments, Fun Stickers, and Varied Backgrounds, to ensure optimal facial image processing results, we will collect technical data from facial photos using facial recognition technology, including the number of detected faces, the size of facial areas, estimated age and gender based on facial recognition. The above data are derived computationally and do not represent factual attributes but rather calculated estimates. They are not linked to specific users, and we do not collect or store your real facial recognition features. We will store the data listed in this article on our own servers and will not share it with any third parties.
3. Simultaneously, you may be required to grant the following permissions:
Album permissions: To read and store photos.
Network permissions: To download materials and iCloud photos.
(II) Business function two: Feedback. When you send us feedback or make inquiries through the in-app feedback feature, we may collect your device ID, IDFA, device model, local language, and timezone information to understand your mobile device's condition and address issues such as crashes, lags, and abnormal display bugs in for targeted solutions.
At the same time, in order to conveniently communicate with you and help resolve problems, we need you to provide at least one form of contact information, either your WeChat ID, mobile phone number, or QQ number. If you refuse to provide the above information, we may be unable to promptly inform you of the relevant processing results.
(III) Business function three: In-app purchases. Upon purchasing the VIP service of Portrait Master, we will gather corresponding order information, including transaction order numbers, device IDs, transaction IDs, order types, payment methods, payment statuses, order titles, order amounts, currencies used for payment, order creation timestamps, order payment timestamps, whether the order is official, user IDs, and local languages.
(IV) Business function four: Security assurance. To troubleshoot product malfunctions and ensure account and payment security, we may collect your device ID, IDFA, IP address, device model, and operational log information.
(V) Business function five: Questionnaire survey. To give you a better understanding of Portrait Master's products and related services, we may push notifications within the product regarding our products, services, marketing information, or conduct relevant questionnaire surveys for you. In questionnaire surveys, you may be asked to provide your WeChat ID, mobile phone number, or QQ number to gather specific opinions from you and provide responses to your suggestions.
In case we intend to use the information for other purposes not stated in the Policy, we will seek your prior consent.
In case we intend to use the information collected for specific purposes for other purposes, we will seek your prior consent.
II. How we share, transfer, and disclose your personal information
(I) Share
We will not share your personal information with any company, organization, or individual other than Chengdu Pinguo Technology Co., Ltd., except under the following circumstances:
1. Share with your explicit consent: We will share your personal information with other parties with your explicit consent.
2. We may share your personal information with the public in accordance with laws and regulations, dispute resolution requirements, or mandatory required by government administrative or judicial authorities.
3. To the extent required or permitted by law, we may share your personal information with a third party in order to protect the interests, property or safety of Pinguo or Pinguo's users or the public.
4. Share with our affiliated companies: Your personal information may be shared with affiliated companies of Chengdu Pinguo Technology Co., Ltd. We will only share necessary personal information collected under the Policy and such sharing will always be bound by the purposes stated in the Privacy Policy. Affiliated companies intending to change the purpose of processing personal information will seek your renewed authorization and consent.
Our affiliated companies include: Beijing Pinguo Technology Co., Ltd., Chengdu Jiapin Zhiyun Technology Co., Ltd.
5. Share with authorized partners: For the purpose stated in the Policy, some of our services will be provided by the authorized partners. We may share certain pieces of your personal information with our partners to ensure the completion of the services provided to you. We will only share your personal information for legal, just, necessary, specific and clear purposes, and will only share the personal information necessary for the provision of the service. Our partners have no right to use the shared personal information for any other purpose.
Currently, our authorized partners include the following type:
Technical support partners. To accomplish specific functionalities, we integrate third-party SDKs for technical support. For instance, to help us analyze product user distribution and statistical data, we may provide the following personal information to such partners. Over time, Portrait Master may choose to work with some of these partners or change partners, hence the list of partners may be subject to adjustments.
| Third-Party SDK Names | Description of Use Scenarios | Types of Personal Information Shared |
| Fabric | Used for crash log collection | Unique device identifier, geographical position information |
| GrowingIO | Used for data statistics and analysis | Software usage and click records, unique device identifier, geographical position information |
| Firebase | Used for data statistics and analysis | Software usage and click records, unique device identifier, geographical position information |
| Appsflyer | Used for data statistics and analysis | Unique device identifier, IP address |
(II) Transfer
We will not transfer your personal information to any company, organization, or individual except for the following circumstances:
1. Transfer with your explicit consent: We will transfer your personal information to other parties with your explicit consent;
2. When the transfer of personal information is involved in a merger, acquisition, or bankruptcy liquidation, we will require the new company or organization to obtain your personal information to continue to be bound by the Privacy Policy. Otherwise, we will require the company or organization to seek your authorization and consent again.
(III) Public disclosure
We will publicly disclose your personal information only in the following circumstances:
1. Your explicit consent is obtained.
2. Disclosure based on law: We may publicly disclose your personal information under the mandatory requirements of laws, legal procedures, lawsuits or government authorities.
(IV) Exceptions
Subject to the relevant laws and regulations, under the following circumstances, we may collect, share, transfer, or publicly disclose your personal information without your consent or authorization.
1. Directly related to national security, defense security, or other national interests;
2. Directly related to major public interests such as public safety, public health, or public awareness;
3. Directly related to crime investigation, prosecution, trial and execution of the judgment, etc.;
4. Necessary for the maintenance of significant legal rights and interests concerning your life, property, reputation, or those of other individuals, yet difficult to obtain their consent;
5. Necessary for signing and performing contracts based on your requirements;
6. Necessary for maintaining the safe and stable operation of the products or services provided, such as detecting and troubleshooting faults in the products or services;
7. Necessary for conducting statistical or academic research in the public interest, where any personal information included in the results of such research is anonymized when disseminated for academic research or descriptive purposes;
8. In connection with the personal information gathered from legally publicized information such as legitimate news reports, government information disclosures and other channels;
9. Other circumstances stipulated by applicable laws and regulations.
III. How we protect your personal information
(I) We have used security measures that meet industry standards to protect the personal information you provide from unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and practical measures to protect your personal information. For example, when exchanging data (such as credit card information) between your browser and the "services", the transmission is protected by SSL encryption; we provide HTTPS secure access for the complementary web services accompanying our products; we employ trusted protective mechanisms to guard against malicious attacks on data; we implement access control measures to ensure that only authorized personnel can access to personal information; and we conduct security and privacy protection training courses to enhance our employees' awareness of the importance of safeguarding personal information.
(II) Given that the Internet is not an absolutely safe environment, and communication methods such as emails, instant messaging, and interactions with other Portrait Master users are typically unencrypted. We strongly recommend that you do not send personal information in these ways. You are supposed to use a relatively complex password in order to assist us in ensuring the security of your account.
(III) The Internet environment is not 100% secure, so we will try our best to ensure or guarantee the security of any information you send us.
(IV) In case of any unfortunate personal information security incident, we will promptly inform you according to the requirements of laws and regulations of the basic information and possible impacts of the security incident, the treatment measures taken or will be taken, suggestions regarding risk prevention and reduction on your own, remedial measures offered to you, etc. We will promptly notify you of the related information by email, telephone, push notification, etc. When it is difficult to notify the subject of personal information one by one, we will release corresponding announcements through reasonable and effective methods. Meanwhile, we will report the disposal of such security incidents according to the requirements of the regulatory authorities.
IV. Your rights
In accordance with relevant laws, regulations and standards of China, as well as prevailing practices in other countries and regions, we guarantee that you will exercise the following rights over your personal information:
(I) Deleting your personal information
1. You can submit a request to us to delete your personal information via the contact methods outlined in the Policy "IX. How to contact us" under the following circumstances:
(1) If our processing of personal information contravenes laws or regulations;
(2) If we collect or use your personal information without obtaining your consent;
(3) If our processing of personal information violates the agreement made with you;
(4) If you cease using our products or services, or you have deactivated your account;
(5) If we cease providing products or services to you.
2. When we decide to fulfill your deletion request, we will simultaneously notify any entities that have obtained your personal information from us, requesting them to promptly delete such information, unless otherwise required by applicable laws and regulations or these entities have independently obtained your authorization. When you delete the information from our service, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup is updated.
(II) Revoking your authorization
If you wish to change the authorization of related permissions (e.g., photo album/storage), you can modify these settings on your hardware device. For iOS systems, this can be done through the path: Settings - Portrait Master. For Android systems, navigate through Settings - Apps - App Management - Portrait Master - Permissions.
However, please understand and acknowledge that when you revoke certain authorizations, it may lead to the unavailability of corresponding product features. Consequently, we will be unable to continue providing you with the specific functions and/or services associated with the revocation consent or authorization. Additionally, please note that your decision to revoke authorization does not affect the processing of personal information based on your previous authorization before the revocation took place.
To revoke your authorization for us to collect and process your personal information according to the Privacy Policy, you can follow the path: Home - My - Settings - Revoke Authorization of the Privacy Policy. When you withdraw your consent, we may no longer be able to provide you with the corresponding services and will cease further collection or processing of your personal information. However, please note that your decision to withdraw consent does not impact the processing of your personal information that was based on your prior consent and authorization.
(III) Personal information subject's acquisition of personal information copies
If you require a copy of your personal information, you can contact us through the means provided at the end of the Privacy Policy. After verifying your identity, we will provide you with a copy of your personal information within our service (including basic profile data and account information), subject to exceptions as otherwise stipulated by laws and regulations or as otherwise agreed upon in the Policy.
(IV) Constraining automatic decision-making by information systems
In certain service functions, we may make decisions based solely on automatic decision-making mechanisms within information systems, such as algorithms, without human intervention. If such decisions significantly affect your legitimate rights and interests, you are entitled to request explanations from us, and we will also provide proper remedies.
(V) Responding to your above requests
1. To ensure security, you may be required to provide a written request or prove your identity in other ways. We may verify your identity before replying to your requests. And we will give a reply within thirty days.
2. For your reasonable requests, we generally do not charge fees. However, in cases of repeated requests exceeding a reasonable limit, we reserve the right to charge a cost-based fee accordingly. We may reject the requests that repeatedly occur without justified reason, require too many technical measures (for example, it is required to develop new systems or fundamentally change the existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on back-up tapes).
3. Under the following circumstances, as mandated by laws and regulations, we will be unable to respond to your requests:
(1) Directly related to national security or defense security;
(2) Directly related to public safety, public health, or major public interests;
(3) Directly related to criminal investigations, prosecution, trial, and execution of judgments;
(4) Related to the fulfillment of legal obligations imposed on the controller of personal information;
(5) There is substantial evidence indicating your subjective malicious intent or abuse of rights;
(6) Responding to your request would cause serious harm to your or other individuals' or organizations' legitimate rights and interests;
(7) Involving commercial secrets.
V. How we process personal information of minors
(I) Our products, websites, and services are primarily designed for and targeted towards adults. The minors are not allowed to create their own user accounts without the consent of their parents or guardians. If you are under the age of 14, please ensure that you read the Policy accompanied by your guardian before using our products and/or services, and only proceed to use our services and provide us with your personal information after obtaining clear and explicit consent from your guardian.
(II) In cases where personal information of minors is collected with parental consent, we will only use or disclose such information when it is legally permissible, explicitly agreed upon by the parents or guardians, or necessary for the protection of the minor.
(III) If your guardian does not consent to your use of our services or provision of personal information according to the Policy, you must immediately cease using our services and promptly inform us.
VI. Storage of personal information
Storage location: In accordance with relevant laws and regulations, the personal information we collected within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China.
Storage period: We commit to storing your personal information for the shortest period necessary to meet legal requirements or fulfill the essential functions and services of our products. For instance, we will continuously store your account information until you choose to revoke, delete, or deactivate your account. For personal information exceeding its storage period, we will promptly delete it or perform anonymization, except where you exercise your right to deletion, account deactivation, or where there are other provisions specified by law.
VII. Applicable laws and jurisdiction
The Privacy Policy shall be governed by the laws of the Mainland region of the People's Republic of China. Any disputes arising under the Privacy Policy shall be under the jurisdiction of the court at the place where the defendant is domiciled.
VIII. How to update the Policy
(I) Our Privacy Policy may undergo changes or revisions. We will not compromise your rights hereunder without your express consent. We will post any changes to the Policy on this page. For significant changes, we will notify you through methods such as email, phone calls, and push notifications.
(II) Major changes referred to in the Policy include, but are not limited to:
1. Changes to the purposes of our processing of personal information, types of personal information processed, and ways in which personal information is used;
2. Significant changes to your rights concerning the processing of personal information and the methods to exercise those rights;
3. Instances where a personal information security impact assessment report indicates high risks exist.
IX. How to contact us
Our company, [Chengdu Pinguo Technology Co., Ltd.], is established within the territory of the People's Republic of China, with its registered address at Floor 13, Building 1, No. 1268, Middle Section of Tianfu Avenue, Chengdu Hi-Tech Zone, China (Sichuan) Pilot Free Trade Zone.
If you have any questions, comments, suggestions, or complaints regarding the Policy or our service content, we have provided multiple feedback channels for your convenience to get in touch with us:
Email complaint channel: In order to better protect your rights, we have set up an email address, inFace @camera360.cn. You can reach out to us through this email;
Personal information protection team: inFace @camera360.cn. You can also send it by registered mail to: Floor 13, Building 1, No. 1268, Middle Section of Tianfu Avenue, Chengdu Hi-Tech Zone, China (Sichuan) Pilot Free Trade Zone (Recipient: Portrait Master).
We will provide you with a response on the processing results within 15 days after receiving your inquiry. If you are dissatisfied with our reply, you also have the option to seek resolution by initiating civil litigation at the People's Court located in the defendant's place of residence.