Privacy Policy

Last Updated: January 29, 2025

This Privacy Policy is designed to help you understand how we collect, use, store, and protect your personal information when you use the "Passport Photo AI" application (hereinafter referred to as "this App"). Please read and fully understand this policy before using our services.

1. How We Collect and Use Your Personal Information
2. How We Use Cookies and Similar Technologies
3. How We Share, Transfer, and Publicly Disclose Your Personal Information
4. How We Protect Your Personal Information
5. Your Rights
6. How We Handle Children's Personal Information
7. How Your Personal Information Moves Globally
8. Governing Law and Jurisdiction
9. How This Policy is Updated
10. How to Contact Us

We understand the importance of personal information to you and are committed to protecting your privacy and security. We will adhere to the principles of consistency of rights and responsibilities, clear purpose, consent, minimization, security, participation, and transparency to provide you with safe and reliable services. At the same time, we promise to adopt appropriate security measures to protect your personal information in accordance with mature industry security standards.

Please read and understand this "Privacy Policy" carefully before using our products (or services).

I. How We Collect and Use Your Personal Information

Personal information refers to various information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

This App will only collect and use your personal information for the purposes described below:

1. Core Business Functions

When you use this App, in order to provide you with passport photo creation services, we need you to grant the following system permissions:

1. Camera Permission: Used to take photos for creating passport photos;
2. Photo Library Permission: Used to access photos for processing or to save the created passport photos;

If you refuse to grant the above permissions, you will not be able to use the corresponding functions.

2. Use and Protection of Facial Data

This App uses the Vision API provided by Apple on your local device to identify and cut out facial data to generate passport photos that meet specific size requirements. All processing is completed locally, data is deleted immediately after use, and is never uploaded to any server or third party.

3. Data Collection Method

• We will only access relevant data when you explicitly authorize and use specific functions (such as taking photos, accessing the photo library). We will not collect data in the background or without authorization.

4. Purpose of Data Use

• Your facial data is only used for local cutout and passport photo generation. After creation is complete, you can save the photo to your system album, and temporary data will be immediately cleared from memory.

We promise: We will not sell your personal information to any third party, will not share it with third parties, and will not upload it to servers.

5. Third-Party Service Commitment

This App only processes your facial data locally. We will not share your original facial data with any third parties (such as advertising networks, analytics tools) or affiliates. All biometric information is destroyed locally on your device and is never uploaded.

6. Data Retention and Destruction

Your facial data is only processed temporarily on your local device. After the passport photo is created and saved, the relevant facial data will be permanently deleted from memory immediately, will not be retained, and will not be uploaded or shared.

7. Other Functions and Data Collection

1. With your authorization, we collect the device Advertising Identifier (IDFA) for ad attribution, ad delivery optimization, and conversion tracking. This data is used only for advertising statistics and not for any other purposes.
2. To continuously improve service experience and troubleshoot application faults, we may collect non-personally identifiable information (such as device model, system version, crash logs). This data is used for internal analysis only.
3. This App may contain links to third-party services (such as advertisements). Please note that these third-party services are governed by their respective privacy policies, and we recommend that you read them carefully before use.
4. When you contact us through the feedback function, we may need you to provide your name or contact information to facilitate communication. This information is used for customer service purposes only.

II. How We Use Cookies and Similar Technologies

1. This App itself does not use Cookies or similar technologies to track your personal information. If you browse this policy page, no Cookies are involved.
2. If you click on third-party advertisements or links within the App to jump to external webpages, these webpages may use Cookies, and their use is subject to the relevant third-party privacy policies.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

(I) Sharing

We promise to keep your personal information strictly confidential and will not share it with any company, organization, or individual, except in the following cases:

1. Explicit Consent: We may share information with other parties after obtaining your explicit authorization.
2. Legal Circumstances: According to laws and regulations, litigation dispute resolution needs, or mandatory requirements by administrative or judicial authorities.
3. Protecting Interests: To the extent required or permitted by law, to protect the interests, property, or safety of users or the public from harm.
4. Affiliates: We may share de-identified statistical data with affiliates, but we will never share your personally identifiable information.
5. Partners: Only for the purposes stated in this policy (such as technical support, data statistics), we may share de-identified device information with authorized partners. We will not share your personally identifiable information.

Currently, our partner types include:

• Advertising and Analytics Providers: Help us track ad performance and analyze product usage. We only provide de-identified device information (such as device model, system version) and do not include personally identifiable information.
• Technical Support Providers: Provide infrastructure technical support.

(II) Transfer

We will not transfer your personal information to any third party unless:

1. We obtain your explicit consent;
2. In the event of a merger, acquisition, or bankruptcy liquidation, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require it to seek your authorization again.

(III) Public Disclosure

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

1. After obtaining your explicit consent;
2. Disclosure based on law: In the case of laws, legal procedures, litigation, or mandatory requirements by government authorities.

(IV) Exceptions

According to relevant laws and regulations, the collection or use of your personal information does not require your authorization or consent in the following circumstances:

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 investigation, prosecution, trial, and execution of judgments;
4. To protect the major legitimate rights and interests of you or other individuals, such as life and property, but it is difficult to obtain consent;
5. The personal information collected is disclosed to the public by you yourself;
6. Collecting personal information from legally publicly disclosed information;
7. Necessary for signing and performing contracts at your request;
8. Necessary for maintaining the safe and stable operation of the products or services provided;
9. Other circumstances stipulated by laws and regulations.

IV. How We Protect Your Personal Information

(I) We adopt industry-standard security measures to protect your personal information from unauthorized access, use, or disclosure. The core functions of this App are completed locally, reducing data risks from the source.

(II) We will take reasonable and feasible measures to ensure that unrelated personal information is not collected. We will retain your personal information only for the period necessary to achieve the purposes stated in this policy, unless there is a mandatory retention requirement by law.

(III) Please understand that the Internet environment is not 100% secure. Although we have taken security measures, we cannot absolutely guarantee the security of information.

(IV) The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us.

(V) In the event of a security incident, we will inform you in a timely manner through announcements, push notifications, etc., and proactively report to regulatory authorities.

V. Your Rights

According to relevant laws and regulations, we guarantee your rights to your personal information:

(I) Withdraw Authorization

You can withdraw your authorization at any time by turning off the corresponding permissions (such as camera, photo library) in your device settings.

After withdrawing authorization, we will no longer be able to provide you with the corresponding functions, but this will not affect the personal information processing previously carried out based on authorization.

(II) Respond to Your Requests

1. To ensure security, we may ask you to verify your identity before processing your request. We will reply within 15 business days.
2. In principle, we do not charge for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the situation.
3. In special circumstances stipulated by laws and regulations (such as involving national security, trade secrets, etc.), we may be unable to respond to your request.

• Directly related to national security or defense security;
• Directly related to public safety, public health, or major public interests;
• Directly related to criminal investigation, prosecution, trial, and execution of judgments;
• There is sufficient evidence that you have subjective malice or abuse of rights;
• Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
• Involving trade secrets.

VI. How We Handle Children's Personal Information

(I) Our products are mainly intended for adult users. If you are a minor, please read this policy accompanied by a guardian and use our services after obtaining the guardian's consent.

(II) For cases where children's personal information is collected with guardian consent, we will only use it when permitted by law or necessary to protect the child.

(III) If we discover that we have collected personal information of a minor without guardian consent, we will try to delete the relevant data as soon as possible.

VII. How Your Personal Information Moves Globally

In principle, personal information we collect within the People's Republic of China will be stored within the People's Republic of China. Since this App mainly processes data locally, it does not involve cross-border transmission of sensitive personal information. If cross-border data transmission is involved in the future, we will strictly abide by relevant laws and regulations and obtain your authorization and consent.

VIII. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the People's Republic of China. In case of any dispute, it shall be under the jurisdiction of the People's Court in the defendant's domicile.

IX. How This Policy is Updated

(I) We may revise this Privacy Policy from time to time. When major changes occur, we will show you the changed content through app version updates or other appropriate means.

(II) Major changes referred to in this policy include but are not limited to: major changes in service models, changes in personal information sharing or transfer objects, changes in your rights regarding personal information processing and how to exercise them, etc.

1. Changes in the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.
2. Major changes in your rights regarding personal information processing and how to exercise them.
3. When the personal information security impact assessment report indicates a high risk.

X. How to Contact Us

If you have any questions, comments, or suggestions about this Privacy Policy or data processing, please contact us through the following means. We will review and reply within 15 business days:

Email: huanggang2025@icloud.com