Effective Date: April 29, 2024
Last Updated: April 29, 2024
Welcome to AI fans! At Galaxyeye Technology Co., Ltd. ("we," "us," or "our"), we are deeply committed to protecting the privacy and security of your personal information. This Privacy Policy is designed to provide you with clear and transparent information about how we collect, use, and share information about you when you use our AI fans APP.
We understand that your personal information is valuable, and we are dedicated to safeguarding it. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of your personal data, and it is important that you read it carefully. It explains your rights and our obligations concerning your personal information.
This Privacy Policy is governed by and construed in accordance with the laws of [Target Country/Region], and is applicable to the provision of our services within the [Target Country/Region]. By using our AI fans APP, you agree to the terms of this Privacy Policy.
2.1 Personal Information
"Personal Information" refers to any information relating to an identified or identifiable natural person. This includes, but is not limited to, names, addresses, email addresses, phone numbers, device identifiers, cookies, IP addresses, and any other information that can directly or indirectly identify you. For users in the European Economic Area (EEA), this definition aligns with the General Data Protection Regulation (GDPR) and encompasses "personal data" as defined therein.
2.2 Sensitive Personal Information
"Sensitive Personal Information" refers to Personal Information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (including facial images collected for face swap functionality, classified as biometric data under GDPR/CCPA), health data, data concerning a natural person's sex life or sexual orientation, or criminal convictions and offenses. This category of information is subject to heightened protection under data protection laws, including the GDPR. We will only process such data with your explicit consent or when legally required, and we will implement enhanced security measures to protect it.
3.1 Scope of Collection
We collect various types of information to provide and improve our AI fans APP services, and to personalize your experience. The categories of information we collect include, but are not limited to:
Registration Information: When you create an account with us, we may collect your email address, password, and other information you provide during the registration process.
Device Information: We may collect information about the device you use to access our APP, including device identifiers (such as IDFA, Android ID, and MAC address), device type, operating system version, and mobile network information. This information helps us optimize our services for your device.
Usage Information: We may collect information about how you use our APP, including your interactions with the APP, the features you use, and the content you view. This information helps us understand how you use our services and improve them.
Log Information: We automatically collect certain information when you use our APP, such as your IP address, browser type, access times, and pages viewed. This information helps us analyze trends, administer the APP, and track user movements.
Information from Third-Party Social Accounts: If you choose to log in using a third-party social account (such as Google or Facebook), we may receive your profile information, including your name, email address, and profile picture. This information helps us personalize your experience and pre-fill registration forms.
Facial Features: Extracted solely for face swap functionalities, immediately deleted after processing.
We only collect information that is necessary for the purposes outlined in this Privacy Policy. We do not collect information that is not relevant to the provision of our services.
3.2 Methods of Collection
We collect information through various methods, ensuring transparency and obtaining your consent where required by law:
Direct Input: We collect information that you directly provide to us, such as during account registration, profile updates, or when you submit feedback or requests through our APP.
Cookies and Similar Technologies: We use cookies and similar tracking technologies, such as pixels and local storage, to collect information about your usage patterns and preferences. These technologies help us understand how you interact with our APP, personalize your experience, and improve our services. You can manage your cookie preferences through your browser settings.
Device Permissions: We may request certain permissions from your device to access information necessary for the functioning of our APP, such as storage permissions to save files or camera permissions for photo uploads. You can manage these permissions through your device settings.
Third-Party SDKs: We may integrate third-party software development kits (SDKs) into our APP, which may collect information about your device and usage. These third-party SDKs are subject to their own privacy policies, and we are responsible for the data collection practices of these third-party SDKs to the extent we are aware of them and have control over them. We carefully select our third-party partners and ensure that they comply with applicable privacy laws.
3.3 Facial Data Collection and Use
3.3.1 Scope of Facial Data
When you use face swap features (video or image), we collect only the facial images you voluntarily upload. We do not collect biometric templates, facial geometry scans, or other biometric identifiers.
3.3.2 Purpose of Use
Your facial data is used exclusively to:
Provide real-time face swap functionality within the APP;
Generate user-requested synthetic media (e.g., swapped videos/images);
Never used for identity verification, profiling, or AI model training.
3.3.3 Storage & Retention
Storage Location: Encrypted on cloud servers located in US;
Retention Period: Deleted immediately after processing (typically within 24 hours), unless you manually save outputs to your device.
3.3.4 Third-Party Sharing
We do not share raw facial data with any third parties. Processed outputs (swapped media) are stored only on your device unless you actively share them externally.
We are committed to transparency in our data collection practices and will provide you with clear information about the information we collect and how we use it.
4.1 Purposes of Use
We use the information we collect for the following purposes, which are essential to providing and enhancing our AI fans APP services:
To Provide and Improve Services: We use your information to deliver the core functionalities of the AI fans App, including account registration, user authentication, and providing you with a personalized experience. Facial data is used exclusively for real-time fitting into user-selected creative works (e.g., applying effects to photos/videos). We also continuously improve services, develop features, and optimize user experience based on your feedback and usage patterns.
To Personalize Content and Recommendations: We may use your information to personalize the content and recommendations you see within the APP, such as suggesting AI fans that align with your interests. You have the right to opt-out of personalized recommendations at any time.
To Communicate with You: We may use your information to send you important notifications, such as updates to our services, security alerts, and administrative messages. We may also use your information to respond to your inquiries, provide customer support, and send you promotional communications (with your consent, where required by law).
For Security and Compliance: We use your information to verify accounts and activity, combat harmful conduct, detect and prevent spam, abuse, and other security threats, maintain the integrity of our services, and promote a safe and secure environment for all users. We also use your information to comply with our legal obligations, enforce our terms of service, and protect our rights and the rights of others.
For Research and Development: We may use anonymized or aggregated information for research and development purposes to improve our understanding of user behavior and trends, and to develop new products and services.
We will not use your information for purposes other than those outlined in this Privacy Policy, except where required by law or with your explicit consent.
4.2 Principles of Use
We adhere to the following principles when using your information, ensuring lawful, ethical, and responsible data processing:
Lawfulness, Fairness, and Transparency: We use your information in a lawful, fair, and transparent manner. We will only use your information for the purposes we have clearly communicated to you, and we will provide you with clear information about how we use your information.
Purpose Limitation: We will only use your information for the specific purposes outlined in this Privacy Policy. We will not use your information for any other purposes without your explicit consent, except where required by law.
Data Minimization: We will only collect and use the minimum amount of information necessary to achieve the purposes outlined in this Privacy Policy. We will avoid collecting excessive or irrelevant information.
Accuracy: We will take reasonable steps to ensure that your information is accurate and up-to-date. You have the right to correct any inaccurate information we hold about you.
Storage Limitation: We will only retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will implement appropriate data retention policies and procedures.
Integrity and Confidentiality: We will implement appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction, or damage. We will maintain the confidentiality of your information and ensure that only authorized personnel have access to it.
Accountability: We are committed to being accountable for our data processing activities. We will implement appropriate mechanisms to ensure compliance with these principles and applicable data protection laws.
5.1 Conditions for Sharing
We do not share your Personal Information with any companies, organizations, or individuals except in the following circumstances:
With Your Consent: We will only share your Personal Information with third parties after obtaining your explicit consent or authorization.
Facial Data Exclusion: We never share, sell, or transfer facial feature data (including biometric templates) with any third party under any circumstances, even with consent. This exclusion applies globally and supersedes other clauses in this Policy.
Legal Requirements: We may share your Personal Information when required by law, such as in response to a subpoena, court order, or other legal process.
With Affiliates: We may share your Personal Information with our affiliates for the purposes outlined in this Privacy Policy. Our affiliates are required to handle and protect your Personal Information in accordance with this Privacy Policy.
With Authorized Partners: We may share your Personal Information with authorized partners who provide services on our behalf. We will only share the minimum amount of Personal Information necessary for these partners to perform their services, and we will require them to protect your information in accordance with this Privacy Policy.
Other Agreements: We may share your Personal Information in accordance with other agreements we have with you.
Exception for Facial Data: Notwithstanding the above, raw facial images collected for face swap functionality (video or image) are never shared with any third party, including affiliates or authorized partners. Processed outputs (e.g., face-swapped media) are stored solely on your device unless you actively share them externally.
5.2 Conditions for Transfer
We do not transfer your Personal Information to any other companies, organizations, or individuals except in the following circumstances:
Business Transactions: In the event of a merger, acquisition, asset sale, or other similar transaction, we may transfer your Personal Information to the acquiring entity. We will require the acquiring entity to continue to be bound by this Privacy Policy, unless you provide your explicit consent to a different arrangement.
With Your Consent: We will only transfer your Personal Information to other parties after obtaining your explicit consent.
5.3 Cross-Border Data Transfers
If we transfer your Personal Information across borders, we will ensure that such transfers comply with applicable data protection laws, including the GDPR for users in the European Economic Area (EEA). We will implement appropriate safeguards, such as standard contractual clauses or binding corporate rules, to protect your Personal Information during cross-border transfers. We will also ensure that the recipient country provides an adequate level of data protection, as determined by the relevant authorities.
6.1 Security Measures
We are committed to protecting the security of your Personal Information. We employ a variety of physical, electronic, and managerial security measures that are designed to protect your Personal Information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:
Encryption Technologies: We use industry-standard encryption technologies, such as SSL/TLS, to protect your data during transmission. We also encrypt sensitive data at rest.
Facial Data Protection: Specifically for facial images used in face swap functionality, we implement:
AES-256 encryption during transmission and storage;
Processing in isolated sandbox environments physically segregated from other systems;Processing in isolated sandbox environments physically segregated from other systems.
Access Controls: We implement strict access controls to limit access to your Personal Information to only those employees, agents, and partners who need to know that information to provide our services.
Security Audits: We regularly conduct security audits and assessments to identify and address potential vulnerabilities in our systems and processes.
Employee Training: We provide regular training to our employees on data security and privacy best practices to ensure they understand their responsibilities in protecting your Personal Information.
6.2 Security Incident Handling
Despite our best efforts, no security measure is perfect or impenetrable. In the event of a Personal Information security incident, we will take the following steps:
Prompt Investigation: We will promptly investigate the incident to determine the nature and scope of the breach, and to identify the affected individuals.
Notification: We will notify you of the security incident without undue delay, in accordance with applicable laws and regulations. Our notification will include a description of the incident, the types of Personal Information involved, the steps we are taking to address the incident, and recommendations on how you can protect yourself.
Mitigation and Remediation: We will take reasonable steps to mitigate the risks posed by the security incident and to prevent future incidents. This may include implementing additional security measures, providing credit monitoring services, or offering other forms of remediation.
Regulatory Reporting: We will comply with our legal obligations to report security incidents to relevant regulatory authorities.
7.1 Access and Correction
You have the right to access and correct your Personal Information that we hold. If you wish to access or correct your Personal Information, you may do so by contacting us using the information provided in the "Contact Us" section of this Privacy Policy. We will respond to your request within a reasonable timeframe and in accordance with applicable laws and regulations.
7.2 Deletion and Account Deactivation
Deletion:
You have the right to request the deletion of your Personal Information. If you wish to delete your Personal Information, you may do so by contacting us using the information provided in the "Contact Us" section of this Privacy Policy. We will delete your Personal Information in accordance with applicable laws and regulations, unless we are required or permitted by law to retain it.
Specifically for facial images used in face swap functionality:
Raw facial images are automatically purged from our servers within 24 hours after processing completes;
Processed outputs (e.g., face-swapped media) remain only on your device unless you manually delete or share them.
Account Deactivation:
You have the right to deactivate your account at any time. You may deactivate your account by contacting us using the information provided in the "Contact Us" section of this Privacy Policy. Upon deactivation:
We will delete or anonymize your Personal Information in accordance with applicable laws and regulations;
Raw facial images (if any) are immediately and permanently deleted from all systems.
7.3 Other Rights
In addition to the rights outlined above, you may have other rights under the laws of your country or region, such as:
Data Portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
Right to Object: The right to object to the processing of your Personal Information for certain purposes, such as direct marketing.
Right to Restrict Processing: The right to request that we restrict the processing of your Personal Information in certain circumstances.
Right to Withdraw Consent: The right to withdraw your consent to the processing of your Personal Information at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
8.1 Age Limit
Our AI fans APP services are exclusively intended for adults aged 18 and over. We do not knowingly collect, use, or disclose Personal Information from children under the age of 18. If we become aware that we have inadvertently collected Personal Information from a child under the age of 18, we will take immediate steps to delete the information from our systems.
8.2 Prohibition of Service to Minors
We strictly prohibit the use of our services by individuals under the age of 18. Our APP is not designed or intended for use by minors, and we do not knowingly permit minors to create accounts or access our services.
8.3 Guardian Responsibilities
Parents and legal guardians are responsible for monitoring and supervising the online activities of minors. We encourage parents and guardians to educate minors about the importance of not providing Personal Information online without parental consent.
8.4 Reporting of Unauthorized Use
If you are a parent or legal guardian and you become aware that your child has attempted to use our services or has provided us with Personal Information without your consent, please contact us immediately using the information provided in the "Contact Us" section of this Privacy Policy. We will investigate the matter and take appropriate action, which may include deleting the minor's Personal Information from our records and terminating their access to our services.
9.1 Dispute Resolution Methods
We are committed to resolving any disputes or concerns you may have regarding this Privacy Policy or our information practices in a fair and timely manner. If you have any questions or concerns, please contact us using the information provided in the "Contact Us" section of this Privacy Policy. We will make every effort to address your concerns and resolve any disputes through good faith negotiations.
9.2 Governing Law and Jurisdiction
This Privacy Policy and any dispute arising out of or in connection with this Privacy Policy shall be governed by and construed in accordance with the laws of [Target Country/Region], without regard to its conflict of law principles. Any legal action or proceeding arising out of or relating to this Privacy Policy shall be brought exclusively in the courts of [Target Country/Region], and you hereby consent to the jurisdiction of such courts.
10.1 Contact Information
If you have any questions, concerns, or complaints about this Privacy Policy or our information practices, please contact us using the following information:
Email: business@galaxyeye-tech.com
Address: Room 2302, 23rd Floor, Building 1, No. 650 Bin'an Road, Changhe Street, Binjiang District, Hangzhou City, Zhejiang Province
10.2 Response Time
We strive to respond to all user inquiries and complaints in a timely manner. We will acknowledge receipt of your inquiry or complaint within 2 business days, and we will endeavor to provide a substantive response within 15 business days of receipt. In complex cases, we may require additional time to investigate and respond to your inquiry or complaint, and we will notify you of any such delay.