Last Updated: 2023-10-27

[Introduction]

Ai4u Software Service Provider (referred to as "we") places a high emphasis on the privacy and protection of user's personal information. We will, in accordance with legal requirements, take appropriate security measures to do our utmost to safeguard your privacy and personal information. In view of this, we have formulated this "Privacy Policy" (referred to as "this Policy" or "this Privacy Policy") to help you fully understand how we collect, use, share, store, and protect your personal information during your use of our products and/or services, as well as how you can manage your personal information for better decision-making.

Before you commence using our products and/or services, we urge you to carefully read and understand this policy, with a particular focus on the terms highlighted in bold/bold underlined, to ensure full comprehension and agreement before you begin. In addition to this policy, in specific situations, we will provide information about the purposes, scope, and methods of information collection through immediate notifications (including pop-ups, page prompts, etc.) and feature update explanations. These immediate notifications and feature update explanations are an integral part of this policy and hold the same legal weight as this policy. We have attempted to explain professional terminology mentioned in this policy in plain and simple terms for your understanding. If you have any questions, opinions, or suggestions regarding the content of this policy, you can contact us through the contact information provided at the end of this policy.

Your agreement to the privacy policy indicates that you have understood the functions provided by the application, as well as the necessary personal information required for the operation of these functions, and you grant the corresponding authorization for collection and use. However, it does not imply that you have separately agreed to activate additional functions, process non-essential personal information, or process sensitive personal information. We will seek your separate consent based on your actual usage for the activation of additional functions, processing non-essential personal information, and processing sensitive personal information.

This Privacy Policy will help you understand the following:

1. Scope of Application

2. Information Collection and Usage

3. Third Parties Involved in Data Usage, Transfer, and Disclosure of Personal Information

4. Your Rights

5. Information Storage

6. Policy Updates

7. Protection of Minors

8. Contact Us

Appendix: Relevant Definitions

I. Scope of Application

This policy applies to the various products and/or services provided to you by Ai4u Software Service Provider through websites, apps, and new forms that may emerge with technological developments. If we or our affiliated companies have separate privacy policies for the products and/or services we provide to you, the corresponding products and/or services will be subject to the respective privacy policy.

Apart from the information collection and usage activities explained in this policy, this policy does not apply to other services provided to you by third parties. The rules for the collection and usage of personal information by other services are subject to separate explanations provided by them.

II. Information Collection and Usage

When you use our products and/or services, we may need or choose to collect and use two types of your personal information as follows:

1. To realize the basic functions of providing our products and/or services to you and fulfill the obligations stipulated by laws and regulations, you are required to authorize us to collect and use necessary information. If you refuse to provide the relevant information, you will not be able to use our products and/or services normally;

2. To enable additional functions in providing our products and/or services to you, you can choose to separately agree or disagree with the information we collect and use. If you refuse to provide this information, you will not be able to use the related additional functions or achieve the intended functional effects, but it will not affect your use of our basic functions.

We want to specifically remind you: We are dedicated to creating diverse products and services to meet your needs. Since we offer a wide range of products and services, and the specific products and services chosen by different users may vary, the basic functions, additional functions, and the types and scope of personal information collected and used will differ. Please refer to the specific product and/or service functionalities for accurate information.

We will provide you with various specific functional scenarios, including:

(1) Account Registration/Log-in

When you use third-party platform accounts (such as Facebook, Apple ID, Google) to log in, you authorize us to access relevant information from your log-in to the third-party account. This is used to link your account with Ai4u Software, allowing you to log in and use related products and/or services directly.

The mentioned information falls under necessary information for this function. If you do not provide this information, you may not be able to register or log in normally.

(2) Browsing/Photo Generation/Sharing/Download

When you use Ai4u Software features, to provide a consistent service, we need to collect device information and log information, which includes your operational and behavioral log information. This includes your browsing history, photo generation, sharing, download records, and access dates. To generate photos, we need to collect facial data for training facial models, which are used to create user portrait photos from photo templates. User facial data is stored for one year to allow users to adjust facial models within that period, and we promise not to share user facial data with third parties.

This information is necessary for this function. If you do not provide this information, you may not be able to use the mentioned functions normally. We will request your photo album permissions when you use the download function.

(3) Information Upload

When Ai4u Software generates content based on the original portraits you upload, we will process the original portrait information you actively upload. This type of information is necessary for providing this service. We will follow legal requirements to encrypt this type of information strictly during the collection, transmission, and storage processes to ensure its security. We only provide image processing services and do not extract identifiable information for identification purposes. After the service is completed, the system will automatically delete this information and not retain it. When you upload this type of information, we will request your camera and photo album permissions.

(4) Ordering and Payment

When you purchase our products and/or services, such as creating facial models or downloading generated photos, we need to collect the following personal information, depending on the service type: transaction service information, transaction amount, order time, order number, order status, payment method, and payment status. We collect this information to help you complete transactions smoothly, safeguard your transaction security, check order information, and provide customer service. This information is necessary for this function, and if you do not provide it, you may not be able to participate in the activities mentioned.

(5) Customer Service and Dispute Resolution

When you contact us or file a dispute resolution application, to safeguard your account and system security, we require you to provide necessary personal information for verifying your membership identity. To contact you, quickly help you solve problems, or record the handling plan and results of related issues, we may save your communication, call/communication records, and related content (including account information, other information you provide to prove relevant facts, or contact information you provide). If you inquire about specific orders, complaints, or provide suggestions, we will use your account information and order information.

(6) Providing Security Assurance

To enhance the security of the services we and our affiliated companies and partners provide, protect personal safety, property security, account security, transaction security, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, malicious programs, and other security risks, more accurately identify violations of laws, regulations, or Ai4u Software's relevant agreements and rules, we embed application security SDK developed by our affiliated companies in the application to collect your device information, service log information, and may use or integrate your membership information, transaction information, device information, service log information, and information authorized or shared by our affiliated companies or partners according to the law (among which, we may collect MAC addresses, IMEIs, and other device identifiers for risk checks during application background operation). This is done to comprehensively assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary record-keeping, auditing, analysis, and disposal measures as required by law.

(7) Other Additional Services

(1) Services Based on System Permissions

To provide you with more convenient and higher-quality products and/or services, and to improve your experience, we may collect and use your personal information by enabling system permissions in the services we provide to you. If you do not agree to enable relevant permissions, it will not affect your use of the basic services of Ai4u Software, but you may not be able to enjoy the user experience these services bring to you. You can decide to enable or disable these permissions at any time.

Please note that enabling any permission authorizes us to collect and use relevant personal information to provide corresponding services. Once you disable a permission, it means that you are revoking the authorization, and we will no longer collect and use relevant personal information based on that permission, nor can we continue to provide the services associated with that permission. Your decision to disable permissions will not affect information collected and used based on your previous authorization.

(2) Cookie and Similar Technologies Services

Cookie and similar device information identification technologies are commonly used on the internet. When you use our services, we may use these technologies to send one or more Cookies or anonymous identifiers (hereinafter referred to as "Cookies") to your device to collect, identify, and store information related to your use of this product. We promise not to use Cookies for any purposes other than those mentioned in this Privacy Policy. We use Cookies mainly to ensure the safety and efficient operation of the product and/or service. This allows us to confirm the security status of your account and transactions, investigate crashes, and related exceptions. It also helps you avoid repetitive form filling and inputting of search content.

Most browsers provide users with the function to clear browser cache data. You can perform the corresponding data clearing operation, or adjust the acceptance or rejection of our Cookies. These changes may cause you to be unable to use services or features that depend on Cookies.

(8) Other Rules for Collecting and Using Personal Information

If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing it to us.

If we use information for purposes not mentioned in this policy, or if we use information collected for specific purposes for other purposes, we will obtain your consent in advance.

III. Partners Involved in Data Usage and Transfer, and Disclosure of Personal Information

(1) Partners Involved in Data Usage

1. Basic Principles

When cooperating with partners, we adhere to the following principles:

1) Principle of Legality, Fairness, and Minimal Necessity: Data processing should have a legal basis, a legitimate purpose, and be limited to the minimum necessary for achieving the processing purpose.

2) Principle of User Informed Consent and Maximum Decision-Making Authority: We fully respect the user's right to be informed and to make decisions about the processing of their personal information during the data processing process.

3) Principle of Maximizing Security Assurance: We will take necessary measures to ensure the security of the processed personal information. We will carefully assess the purposes for which partners use the data, conduct comprehensive evaluations of the security capabilities of these partners, and require them to comply with the relevant requirements of cooperation agreements.

2. Scope of Partners

If our affiliated companies or third parties provide services in specific functions and scenarios, the scope of partners includes our affiliated companies and third parties.

3. Delegation of Processing

We may delegate authorized partners to process your personal information in order for them to represent us in providing certain services or fulfilling functions. We will only entrust them with your information for lawful, legitimate, necessary, specific, and clear purposes as stated in this policy. Authorized partners can only access information needed to fulfill their responsibilities, and we will require them, through agreements, not to use this information for any purposes beyond the scope of delegation. If authorized partners use your information for purposes not entrusted by us, they will obtain your separate consent.

4. Joint Processing

In scenarios involving joint processing of personal information, we will sign relevant agreements with partners in accordance with legal requirements, and specify their respective rights and obligations to ensure compliance with legal regulations and data security during the use of personal information.

5. Collaboration Scenarios

1) Security and Statistical Analysis

A. Ensuring Usage Security: We place high importance on the security of our products and/or services. To protect the legitimate rights and interests of users from unlawful infringements, our partners may use necessary device, account, and log information.

B. Analyzing Product Situations: To analyze the stability of Ai4u Software products and/or services, partners providing analytical services may need to use information about service usage, device identification, overall application installation and usage conditions, and other information.

4) Other Collaboration Scenarios

In addition to the aforementioned collaboration scenarios, we may also entrust information to other partners supporting our business, including those authorized to provide technical infrastructure services, analyze the usage of our services, or provide other customer services. In order to ensure the stable operation of our client, the realization of its functions, and to allow you to use and enjoy more services and functions, our application may embed authorized partner's SDK or similar applications. We will subject authorized partner access to information via application interfaces (API) and SDK to strict security testing. We will also stipulate strict data protection measures with authorized partners, requiring them to process personal information in accordance with this policy and any other relevant confidentiality and security measures. This is apart from cases where authorized partners have obtained your consent. We will subject authorized partners accessing information via application interfaces (API) and software development kits (SDK) to strict security testing and stipulate strict data protection measures with authorized partners, ensuring that they process personal information in accordance with this policy and any other relevant confidentiality and security measures.

(2) Transfer

If, for reasons such as merger, division, dissolution, or bankruptcy declaration, we need to transfer personal information, we will inform you of the name or identity and contact information of the receiving party. The receiving party will continue to comply with this policy and other legal obligations. If the receiving party changes the original purposes or methods of processing, we will obtain your consent again.

(3) Public Disclosure

We will only publicly disclose your personal information in the following cases:

1. When based on your active choices and other individual consent, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations, or seriously violated the Ai4u Software platform's relevant agreements and rules, or if it is necessary to protect the personal and property safety of Ai4u Software platform users or the public, we may disclose your personal information, including relevant violations and measures taken by the platform.

(4) Cessation of Operation

If we cease the operation of products and/or services, we will promptly stop collecting your personal information. We will send you notices individually or in the form of announcements regarding the cessation of operation and delete or anonymize the personal information we hold that is related to the closed products and/or services.

(5) Circumstances Exempt from Obtaining Your Authorization

Please understand that, according to laws, regulations, and national standards, there are situations where partners may use your personal information, or we may transfer or disclose your personal information without obtaining your authorization in the following cases:

1. When necessary for the conclusion or performance of a contract at your request.

2. When necessary for the performance of legal duties or legal obligations: We may share your personal information as required by laws and regulations, litigation, dispute resolution, or other legal obligations, as well as for the protection of personal safety, health, and property during public health emergencies or emergencies.

4. In the reasonable scope, processing of your publicly disclosed personal information or other personal information that has been legally disclosed (such as personal information disclosed through legal news reports, government information disclosures, and other channels).

6. In other circumstances as stipulated by laws and regulations.

IV. Your Rights

You can contact us through the methods provided at the end of this policy. After verifying your identity, we will provide you with information access and management. We will respond to your requests in accordance with legal requirements:

(1) Access, Correction, and Supplement

(2) Copy

(3) Deletion

In the following circumstances, you can request the deletion of personal information by contacting us:

(1) If our processing of personal information violates laws and regulations;

(2) If we collect and use your personal information without obtaining your explicit consent;

(3) If our processing of personal information seriously violates our agreement with you;

(4) If our processing purpose has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;

(5) If we cease to provide products or services, or the retention period has expired.

If we decide to respond to your deletion request, we will also notify, to the extent possible, the entities that have obtained your personal information from us and request them to promptly delete (unless otherwise provided by laws and regulations, or these entities have independently obtained your authorization).

After you or we assist you in deleting relevant information, due to applicable legal and security technical limitations, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and restrict any further processing until the backup can be cleared or anonymized.

(4) Change of Authorization Scope

Please note that for certain types of personal information, such as information required to enable the basic functions of Ai4u Software or information necessary for us to fulfill legal obligations, we may not be able to respond to your requests to change the scope of authorization. After you revoke your authorization, we will no longer process the corresponding personal information. However, your decision to revoke authorization will not affect the personal information processing conducted based on your prior authorization.

(5) Account Closure

After you voluntarily close your account, we will cease to provide you with products and/or services and, in accordance with applicable legal requirements, delete or anonymize your personal information. If it is technically difficult to delete personal information, we will anonymize it or cease processing it beyond storage and necessary security protection measures, except as otherwise provided by laws and regulations.

(6) Constraint on Automated Decision-Making in Information Systems

In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms, including algorithms. If these decisions affect your legitimate rights and interests, you can contact us through customer service.

(7) Response to Your Requests

For your requests or the requests of your guardians, close relatives, and other authorized subjects under the laws of the People's Republic of China, and other applicable laws and regulations regarding your relevant personal information rights, you can contact us through customer service, and we will respond within 15 days.

To ensure the security of your account and your personal information, when you make the above-mentioned requests to us, we may first verify your identity (such as increasing account verification, requiring you to provide written requests, or other reasonable methods), and then process your requests.

For your reasonable requests, we generally do not charge a fee, but for repeated requests beyond reasonable limits, we may charge a fee at our discretion. Requests for information that is not directly related to your identity, repeated requests without reasonable cause, or requests that involve significant technical effort (such as the need to develop a new system or fundamentally change current practices), pose risks to the legitimate rights of others, or are impractical may be refused.

V. Information Storage

(1) Storage Period

We will only retain your personal information for the period required to achieve the purposes stated in this policy, unless there are mandatory retention requirements under the law,

Our determination of the storage period for personal information is primarily based on the following criteria:

1. Completion of transaction purposes related to you, maintaining relevant transaction and business records to respond to your potential inquiries or complaints;

2. Ensuring the security and quality of the services we provide to you;

3. Your consent for a longer retention period;

4. Other special agreements or legal regulations on retention periods.

After the retention period expires, we will delete or anonymize your personal information in accordance with applicable legal requirements.

(2) Storage Location

Our servers are located in Singapore. Unless you provide separate consent, or to fulfill contracts made with you, or to comply with legal obligations as required by laws and regulations, we will not provide any of your personal information to third parties.

(3) Storage Security

1. Data Protection Technical Measures

We have adopted security protection measures in line with industry standards and reasonable practices to protect your information from unauthorized access, public disclosure, use, modification, damage, or loss. For example, we use encryption technology to enhance the security of personal information, which is protected by SSL protocol during data exchange between your browser and server, and we provide a secure browsing method via the HTTPS protocol; we use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to ensure that only authorized personnel can access personal information.

2. Data Protection Management Organizational Measures

We have established an advanced data security management system with data at its core, which enhances the security of personal information from the dimensions of organization building, system design, personnel management, and product technology. We have set up a dedicated department for personal information protection and designated individuals responsible for the protection of children's personal information. We continuously strengthen employees' awareness of the importance of personal information protection through training courses and examinations.

3. Response to Personal Information Security Incidents

If our physical, technical, or managerial protective facilities are compromised, leading to unauthorized access, public disclosure, tampering, or damage to your legal rights, we will promptly initiate emergency plans and take reasonable necessary measures to minimize the impact on your personal information. In the event of a personal information security incident, we will also notify you of the basic situation of the security incident and its potential impacts, the measures we have taken or will take, advice on how to prevent and reduce risks, and remedial measures you can take, in accordance with legal requirements. We will inform you through SMS, phone calls, push notifications, and other reasonable channels. If it is difficult to notify each individual, we will announce the information in a reasonable and effective manner. In addition, we will report the handling of personal information security incidents to regulatory authorities as required.

4. Prevention of Account Security Risks

When using Ai4u Software products and services, please protect your personal information properly, provide it to others only when necessary, and avoid relying on other transaction tools to avoid theft of information or even telecommunications network fraud.

If you are concerned about the leakage of your personal information, especially your account, please contact our customer service immediately so that we can take appropriate measures based on your request.

VI. Policy Updates

To provide you with a better product and/or service experience, we continue to improve our products, services, and technology. When new services and changes to business processes occur, we may update our privacy policy, but we will not restrict your rights under this policy without your explicit consent. We will post changes to this policy on a dedicated page. For significant changes, we will provide more prominent notice (including through platform announcements or system messages) to inform you.

Significant changes referred to in this policy include but are not limited to:

1. Significant changes in the business model of the product. Such as the purpose of processing personal information, the types of personal information processed, and the methods of using personal information;

2. Changes in the subjects of privacy policies due to business adjustments, mergers, and acquisitions, where the new subject receiving the information changes the original processing purpose and method;

3. Major changes in the main recipients of personal information sharing or public disclosure;

4. Major changes in user personal information rights and how they are exercised;

5. Changes in contact information for the personal information protection responsible person and complaint channels;

6. The personal information impact assessment report indicates a significant impact on personal rights when the product is used.

We will also archive old versions of this policy on a dedicated page for your reference.

VII. Protection of Minors

We attach great importance to the protection of personal information of minors. If you are a minor, we require you to have your parents or other guardians carefully read this policy and use our services or provide information to us only with the consent of your parents or other guardians.

If you are a parent or guardian of a child, please pay attention to whether the child is using our services after obtaining your authorized consent. If you have any questions about the personal information of children, please contact our dedicated department for personal information protection.

VIII. Contact Us

You can contact us through the following methods, and we will respond to your requests within 15 days:

If you have any questions, opinions, or suggestions about the content of this policy, you can contact us via email (ai4u88888@gmail.com);

Appendix: Relevant Definitions

Ai4u Software: Refers to the Ai4u Software operated by ZUIEI Co., Ltd., including but not limited to webpages, app applications, and more.

Personal Information: All kinds of information recorded electronically or by other means, relating to identified or identifiable natural persons, excluding information processed anonymously.

Sensitive Personal Information: Sensitive personal information refers to personal information that, once disclosed or used illegally, could easily lead to infringement of the personal dignity of a natural person or endanger personal safety and property, including biometric data, religious beliefs, specific identities, medical and health information, financial accounts, location data, and personal information of individuals under the age of 14.

Children: Refers to individuals under the age of 14.

Device Information: Includes device identifiers (IMEI, IDFA, Android ID, MAC, OAID, IMSI, ICCID, AAID, device serial number, and other device-related information), application information (application crash information, notification switch status, application installation lists, and other application-related information), device parameters and system information (device type, device model, operating system, and hardware-related information), device network environment information (IP address, WiFi information, base station information, and other network-related information), and clipboard data. The actual data collection may vary.

Service Log Information: Includes search and browsing history, following, access volume, IP address, WLAN networks (SSID, BSSID), telecommunications carrier networks, language used, access date and time.

De-identification: The process by which personal information is processed so that it cannot be identified as a specific natural person without additional information.

Anonymization: The process by which personal information is processed in a way that it cannot be identified as a specific natural person and cannot be restored.