Privacy Policy

Version: 3.2

Last Modified: Nov 04, 2021

Your privacy is important to us.

Pixocial Technology (Singapore) Pte. Ltd. ("Pixocial", "we", "us" or "our") is dedicated to protecting the privacy of our users ("users" or "you"). This Privacy Policy (the "Policy") is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal information) as a controller and/or business under applicable data protection laws during your use of VCUS application including all its features (the "Services").

Please note that the scope of this Policy is limited solely to your user information (including your personal information) collected or received by Pixocial when you are using the Services. In this Policy, "personal information" refers to any information or combination of information that can be used to identify, contact or locate an individual to whom the collected information pertains. Such personal information may include your email address, date of birth, images, geo-location, personal identity number, identifiable biological information, and financial information (such as credit card or bank account number, WeChat Pay or Alipay account information).

BY USING OUR SERVICES, YOU ARE AGREEING TO THIS POLICY AND THE COLLECTION, USE, PROCESSING, RETENTION, DISCLOSURE AND SHARING OF YOUR USER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, IN THE MANNER PROVIDED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY OR ANY SUBSEQUENT CHANGES TO THIS POLICY, PLEASE DO NOT USE OUR SERVICES.

Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with our Services. Also, please note that, unless we define a term in this Policy, all capitalized terms used in this Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

If you have any questions regarding this Policy or any privacy-related matters, please contact our Data Protection Officer via email at [email protected] (please quote “VCUS” in your email title) or via registered mail at 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial).

The Information We Collect

The Information You Provide to Us

When you use the Services, we might recommend you sign up for an Account to take full advantage of the Services and all their features. When you create an Account, we will collect certain information that can be used to identify you or provide the Services to you, such as your user name, gender, date of birth and mobile phone number and location (collectively, “Registration Data”).

Mobile Device Information

When you use our Services on your mobile device, we will collect information about your device, including its International Mobile Equipment Identity ("IMEI"), Unique Device Identifier (“UDID”) or Android ID, Universally Unique Identifier (“GUUID”), Identifier for Advertising ("IDFA") and Identifier for Vendor ("IDFV"), Integrated Circuit Card Identifier ("ICCID"), Media Access Control ("MAC") address, the type of device you use, operating system version, and resolution, which will be used by us for statistical and/or analytical reasons, including without limitation to improve our technical functionality, server load-balancing, analysis of technical data relating to your mobile device so as to optimize the Services and graphics adaptation.

We may send you push notifications on your mobile device from time to time. If you no longer wish to receive these types of communications, you may turn them off from your mobile device.

As stated below in the “Location Information” section, we may collect your location-based information from your mobile device if you choose to share it with us. If you subsequently wish to stop sharing Location Information, you may do so at any time by editing the relevant setting on your mobile device.

Mobile Analytics

We use mobile analytics software to allow us to better understand and improve the functionality of our Services. Such software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.

Network Information

When you use the Services, we will collect information about the network you use, including the name of the operator and the type of network, so as to understand the distribution of operators and networks used by our users. In addition, we will collect information such as the name of the WiFi network to which you connect, the location of the WiFi network, and the duration of your WiFi connection to understand the environment under which you prefer to use our Services. We may use such information to provide customized services, for example to provide you with location-based advertising through push-notification.

Location Information

We will collect your Location Information, including the country code, latitude and longitude, network location, IP address and the system country and system time zone recorded on your device. This information will help us understand user distribution and usage scenarios and allow us to provide users with the correct version of our apps, the reappearance of the geo-location or the publishing of the real-time geo-location where you take any photos or shoot any videos, send relevant advertisements to you, and improve the Services. Unless we obtain your consent, location data WILL NOT BE ACQUIRED or USED to identify you individually. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device. Please note that we may still continue to receive some Location Information, such as your Network Information, IP address and system time zone, as a result of you using the Services.

Log Information

When you use some of the Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in VCUS ("Log Information"). Log Information may include (i) details on when and how often you use the Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve the Services and is NOT USED to identify our users individually.

Image Information

By choosing to use the cloud editing feature of our service, you understand and agree that we must upload your photos to our server for processing before returning processed photos to you for the purposes of providing such service to you and continuous optimization and that we will also receive the EXIF data about your photos (EXIF data may contain GPS coordinates where photos were taken and processed, equipment type, ISO and information about the front and rear cameras and creation time, depending on the equipment manufacturer) for the purpose of further optimizing our Services, such as providing a better match of photo effects to your equipment.

Metadata

Metadata refers to technical data associated with user content. Put simply, metadata is data that describes data. For example, metadata can describe the analysis results of facial features, gender, age, race of the characters in photos and other elements contained in photos, which are generated and tagged by the computer algorithm and artificial intelligence. When you use the Services, we will use photo metadata to provide you with certain features including precise "Facial Recognition", "Key-Points Recognition", "Region Segmentation", "Content Tags" and other custom features based on a combination of these basic features. We may use your photo metadata to provide you with more suitable filters and better photo effect when our apps process your photos; we may also make use of the metadata to serve up a more contextually relevant products or services to you.

We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.

Forum

You should be aware that ANY CONTENT OR INFORMATION THAT YOU PROVIDE IN A FORUM WILL BE MADE PUBLIC and may be read, collected, copied, distributed and used by others who access the forums, and may result in unsolicited messages from third parties and further distribution of such content or information. The activities of the third parties who collect your information from such publicly accessible forums are beyond Pixocial’s control. As such, you should not post sensitive personal information or any other information that you do not want to be made public. You can remove your personal information from these forums by yourself or by contacting us at [email protected] (please quote “VCUS” in your email title). In some cases, we may not be able to remove your personal information from the forums, in which case, we will let you know if we are unable to do so and why. However, please be aware that if a third party has collected or otherwise saved the information you have made public, Pixocial will not be able to assist you in removing or deleting that information from wherever the third party has stored or posted it.

Cookies

When you are using the Services, Pixocial or a third party designated by Pixocial will use cookies, tags and scripts to collect information for the purposes of analyzing trends, managing the Services, tracking users activity on the VCUS and collecting demographics on the user base. Information collected may include information about your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating system, dates and timestamps, and clickstream data.

Advertising

We and our third-party service providers may include advertisements within our Services, and may collect and use information about you such as your Advertising ID, geographic location and IP address for the purpose of delivering and tracking these advertisements. If your device does not have Advertising ID, we may use other persistent identifiers. We will use this information to help us better count and track advertisements based on language, geographic location and other details. If you wish to opt out of interest-based advertising, you may opt out as your device permits. For more information, please contact us at [email protected] (please quote “VCUS” in your email title). Please note you will continue to receive generic ads after you opt out of interest-based advertising.

Information Collected by Third Party Services

Our Services provided to you may contain our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which may have tracking tools of such service providers. These third parties may use cookies, APIs and SDKs on our Services and collect and analyze user information. In addition, some third-party SDKs may allow advertisers to collect information in order to provide content that is more relevant to you. Third parties may access your information such as your device identifiers, region (defined as the location where a given language is used), location information and IP address under their respective privacy policies. If you want to know more about such third parties, you may send an email to [email protected] (please quote “VCUS” in your email title).

User Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products, services, and advertising that may be of interest to you. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include: Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.

If you provide us any personal information of any third party, you shall obtain the consent of such third party for the collection, use and disclosure thereof by Pixocial in accordance with these purposes. You further represent and warrant that in relation to any such third party personal information that you provide, you have obtained such consent for such collection, use and disclosure by Pixocial.

Other Information

We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you.

HOW WE USE INFORMATION

In addition to the uses listed above, we collect and use your user information and personal information for the following purposes:

INFORMATION SHARING AND DISCLOSURE

We may share your information with third parties who provide services on our behalf to help with our business activities. These services may include:

We will not share with or disclose to third parties (other than our service providers) your personal information in whole or in part except for the purposes of:

THIRD PARTY WEBSITES AND SERVICES

The Services may contain links to other websites and services. In addition, other websites and services may reference or link to our Services. These other domains and websites are not controlled by us, and Pixocial does not endorse or make any representations about third party websites or services. We encourage our users to read the privacy policies of each and every website and service with which they interact. Visiting these other websites or services is at your own risk.

INFORMATION SECURITY

We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal information. However, you understand and accept that (in the Internet industry) even though we take reasonable security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. Further, you understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.

INFORMATION ACCESS AND CONTROL

We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity through the collection of your email address.

DATA RETENTION

Subject to applicable laws and regulations and the fulfillment of our business or legal purposes, we will retain your information (including your personal information) for such period as is required for us to continue to provide you with our Services.

PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

If you wish to exercise your rights, you may send an email to [email protected] (please quote “VCUS” in your email title) or mail your request to 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial). We will process your request in line with applicable laws within a reasonable period of time after receiving your email or mail, and will cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act.

INFORMATION ABOUT CHILDREN

We will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under 16, please do not send your personal information to us, including your name, address, phone number or email address. If you believe we may have any information about children under 16, you may send an email to [email protected] (please quote “VCUS” in your email title) or send a registered mail to 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial). If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information.

CROSS-BORDER DATA TRANSFERS

You understand and agree that all information collected via or by Pixocial may be transferred, processed, and stored anywhere in the world, including but not limited to, Singapore, China, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide the Services.

IF YOU ARE A RESIDENT OF CALIFORNIA

The California Consumer Privacy Act (“CCPA”) provides California residents with the right to know what categories of personal information we have collected about them:

Category of Personal Information Collected by us?
Identifiers Yes
Personal information categories listed in Cal. Civ. Code § 1798.80(e) No
Characteristics of protected classifications under California or federal law No
Commercial information Yes
Biometric information No
Internet activity or electronic network activity information Yes
Geolocation data Yes
Audio, electronic, visual, thermal, olfactory, or similar information Yes
Professional or employment-related information No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) No
Inferences drawn from other personal information to create a profile Yes

The California Consumer Privacy Act also provides California residents with the right to opt out of the “sale” of their personal information. Under the CCPA, a “sale” is broadly defined as making available personal information to a third-party for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information.

For purposes of the CCPA, a “sale” may include using targeted advertising services to deliver targeted advertising on the Services or other sites. Like most mobile applications, we use these services, which enable us to provide the Services and relevant offers to you. As a result, Pixocial may “sell” the following categories of personal information: identifiers (e.g., advertising IDs); internet activity; geolocation data; and inferences drawn to create a profile.

California residents may opt-out of the “sale” of their personal information by turning off the switch next to “Do not sell my personal information”.

If you are a resident of California, every year we will provide you free of charge with an opportunity to obtain a list of third parties to which we have disclosed or with whom we have shared your personal information for their direct marketing purposes during the previous year. If you are a resident of California and wish to obtain this list, you may send an email with the subject "VCUS - The right to privacy of a California resident" to [email protected] or send a registered mail to 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial).

GOVERNING LAW

This Policy is established, comes into force, and will be enforced and interpreted under the laws of Singapore, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.

AMENDMENTS TO THIS POLICY

You agree that we may update this Policy according to relevant laws and regulations or based on Pixocial’s business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on VCUS or notify you by other means as required by law.

FOR USERS IN THE EUROPEAN ECONOMIC AREA

If you are in the European Economic Area (“EEA”), we will not collect any of your information set forth above. However, we will process certain information related to your SIM card which enables us to verify whether you are in the EEA. We use this information to verify whether you are in the EEA and to prevent the processing operations outlined above. Where we are unable to collect such information we will ask you whether you are in the EEA. The legal basis for the processing of this SIM card data or your answer to the question about your whereabouts is the performance of a contract with you (Art. 6 para. 1 lit. b) of the Regulation (EU 2016/679 of the European Parliament and of the Council (“GDPR”)). Without the provision of such data we may not be able to provide you with any Services.

As we are located in the People’s Republic of China we are required to transfer this information to the People’s Republic of China. Please be aware that the European Commission has not issued an adequacy decision in relation to the People’s Republic of China.

We will retain this information for as long as needed to provide you with our Services.

Controller

The Controller for the purposes of Art. 4 no. 7 GDPR with respect to the processing outlined in this Policy is Pixocial Technology (Singapore) Pte. Ltd., 80 Robinson Road #02-00 Singapore 068898. You may contact us via registered mail at the above address (attention: Legal Department, Pixocial) or via e-mail at [email protected]. (please quote “VCUS” in your email title.)

Representative

Our representative in the European Union is Rivacy GmbH, you may contact our representative via e-mail at [email protected] or via registered mail at Rivacy GmbH, Mexikoring 33, 22297 Hamburg.

Your rights as a Data Subject

As a data subject in the European Economic Area you have the following rights with regard to the processing of your personal data:

Right of access

As a data subject you have the right to obtain confirmation from us as to whether we are processing your personal data (Art. 15 para. 1 GDPR). If so, you also have the right to obtain access to the personal data and the information listed in Art. 15 para. 1 GDPR. This includes information regarding the purposes of the processing, the categories of personal data that are being processed and the recipients or categories of recipients to whom the personal data have been or will be disclosed.

Right to rectification

As a data subject, you have the right to rectification set out in Art. 16 GDPR, i.e. to have your inaccurate data processed by us rectification and incomplete personal data completed.

Right to erasure (“right to be forgotten”)

As a data subject, you have a right to obtain from us the erasure of your personal data and we are obliged to erase your personal data without undue delay when one of the reasons listed in Art. 17 para. 1 GDPR applies. This can be the case, for example, if personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (Art. 17 para. 1lit. a) GDPR).

If we have made the personal data public and are obliged to erase it, we are also obliged, taking account of available technology and the cost of implementation, to take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of those personal data (Art. 17 para. 2 GDPR).

The right to erasure (“right to be forgotten”) does not apply if the processing is necessary for one of the reasons listed in Art. 17 para. 3 GDPR. This can be the case, for example, if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims (Art. 17 para. 3 lit. a) and e) GDPR).

Right to restriction of processing

As a data subject, you have a right to obtain from us the restriction of processing if one of the conditions provided in Art. 18 para. 1 GDPR applies. This can be the case, for example, if you contest the accuracy of the personal data. In such a case, the restriction of processing lasts for a period that enables us to verify the accuracy of the personal data (Art. 18 para. 1 lit. a) GDPR).

Restriction means that stored personal data are marked with the goal of restricting their future processing (Art. 4 para. 3 GDPR).

Right to data portability

As a data subject, you have a right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from us if the processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and the processing is carried out by automated means (Art. 20 para. 1 GDPR).

In exercising your right to data portability, you also generally have the right to have your personal data transmitted directly from us to another controller if technically feasible (Art. 20 para. 2 GDPR).

Right to object

As a data subject, you have a right to object under the conditions provided in Art. 21 GDPR.

Right to object on grounds relating to the particular situation of the data subject

As a data subject, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Art. 6 para. 1, lit. e) or f) GDPR including profiling based on those provisions.

To verify whether our processing is based on Art. 6 para. 1, lit. e) or f) GDPR, please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to object to direct marketing

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, we no longer process your personal data for these purposes.

Right to withdraw consent

Where our processing of your personal data is based on your consent, you have the right, pursuant to Art. 7 para. 3 GDPR, to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal.

To verify whether our processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

Right to lodge a complaint with a supervisory authority

As a data subject, you have a right to lodge a complaint with a supervisory authority under the conditions provided in Art. 57 para. 1 lit. f) GDPR.

Exercise of your rights under GDPR

As a data subject, you may exercise any of the rights listed above in accordance with the instructions and limitations set forth in “Data Retention and Correction, Update and Deletion” above.

Additional Information on Your Rights as a Data Subject

For further information on your rights as a data subject please refer to Art. 12 to 21 GDPR, which can be accessed here: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

FOR USERS IN JAPAN

Right to data disclosure, correction, erasure or suspension of use

If you are in Japan, as a data subject, you have the right to request the disclosure, correction, erasure or suspension of use of your personal data, and we are obliged to meet your request without undue delay. You may send your request by email to [email protected] (please quote “VCUS” in your email title) or by mail to 80 Robinson Road #02-00 Singapore 068898 (Attention: Legal Department, Pixocial).

VCUS隐私政策

最新修改日期:2019年【4】月【29】日

本隐私政策(“本政策”)旨在向您说明,在使用VCUS APP(以下称“产品”或 “服务”)时,您应了解的内容:

一、我们如何收集和使用您的个人信息

二、我们如何使用Cookie

三、我们如何共享、转让、公开披露您的个人信息

四、我们如何保护您的个人信息

五、您的权利

六、我们如何处理未成年人的个人信息

七、您的个人信息如何在全球范围转移

八、适用法律及管辖

九、本政策如何更新

十、我们的联系方式

我们非常重视对您的个人信息的保护,我们也致力于维持您对我们的信任,我们承诺将按业界普遍适用的安全标准,采取相应的安全保护措施来保护您的个人信息。但需要特别说明的是,本政策不适用于其他第三方向您提供的产品或服务。如果您使用第三方提供的产品或服务,请关注第三方产品或服务的用户协议及隐私政策。

在使用我们的产品和服务前,请您务必仔细阅读并充分了解本政策。

一、我们如何收集和使用您的个人信息

1) 客户服务。当您向美图提起投诉、进行咨询、意见反馈或申诉时,为了方便与您联系或帮助您解决问题,我们可能需要您提供QQ或微信或电子邮件及其他有效的联系方式。 如您拒绝提供上述信息,我们可能无法向您及时反馈相关处理结果。

2) 优化产品和服务。为维护我们服务的正常运行,以及保障您的帐号安全、排查产品故障、改进及优化我们的服务,我们会收集您的 网络运营商及种类、网络类型、设备型号、 操作日志信息。这类信息是为提供服务必须收集的信息,收集后即作去标识化处理,不会用于识别任何特定的用户。

3) 提供多语言支持。我们可能会收集您使用设备的语言及时区,以区别用户来源,提供多语言支持。

4) 美图基于其它特别情况对您的个人信息的使用

请您理解,我们向您提供的功能和服务是不断更新和发展的,如果我们要将您的个人信息用于本政策未载明的其它用途,或基于特定目的将收集的信息用于其它目的,我们将以合理的方式(例如页面提示、交互流程、网站公告等)向您告知,并在使用前再次征得您的同意。

二、我们如何使用Cookie

为保证网站正常运行,为帮助您获得更轻松的访问体验,并向您推荐您可能感兴趣的信息,我们会在您的计算机或移动设备上存储名为Cookie的小数据文件。Cookie通常包含标识符、站点名称以及一些号码及字符。借助于Cookie,网站能够存储您的偏好等数据,以此帮助您免去重复填写个人信息、输入历史搜索内容等繁琐;同时我们还可能利用上述技术为您推荐、展示、推送您感兴趣的内容。您可根据自己的偏好管理或删除Cookie,您也可以清除计算机上保存的所有 Cookie。有关详情,请参见AboutCookies.org。我们不会将 Cookie 用于本政策所述目的之外的任何用途。大部分网络浏览器都设有阻止Cookie的功能,您可以通过浏览器设置选项清除计算机上保存的所有Cookie,但如果您这么做,可能会导致您在每一次访问我们的网站时都需要亲自更改用户设置。

三、我们如何共享、转让、公开披露您的个人信息

1、共享

我们不会与任何公司、组织、个人分享您的个人信息,但以下情况除外:

1) 在获取明确同意的情况下共享:获得您的明确同意后,我们会与其他方共享您的个人信息。

2) 在法定条件下共享:我们可能会根据法律法规规定、诉讼争议解决需要、按照政府主管部门或司法机关依法提出的强制要求,对外共享您的个人信息。

3) 在法律要求或允许的范围内,为了保护美图及其用户或社会公众的利益、财产或安全免遭损害而有必要提供您的个人信息给第三方。

4) 与我们的关联公司共享:您的个人信息可能会与我司(厦门美图网科技有限公司)的关联公司进行共享,我们只会在为实现向您提供本产品相关功能和服务的目的下共享必要的个人信息且受本隐私政策所声明目的的约束。关联公司若要改变个人信息的处理目的,将再次征求您的授权同意。我们的关联公司包括:厦门鸿天创视科技有限公司;厦门美图之家科技有限公司及其分、子公司;厦门美图移动科技有限公司及其分、子公司等。我司及我司关联公司合称“美图”。

5) 与授权合作伙伴共享:仅为实现本政策中声明的目的,我们的某些服务将由授权合作伙伴提供。如推广服务、产品分析服务、技术支持服务。我们可能会与合作伙伴共享您的某些个人信息,以提供更好的客户服务和用户体验。我们仅会出于合法、正当、必要、特定、明确的目的共享您的个人信息,并且只会共享提供服务所必要的个人信息;同时,对我们与之共享个人信息的公司、组织和个人,我们会与其签署严格的保密协议,要求其按照我们的隐私政策以及其他任何相关的保密和安全措施来处理个人信息。我们的合作伙伴无权将共享的个人信息用于任何其他用途。如果您拒绝我们的合作伙伴在提供服务时收集或使用为提供服务所必须的个人信息,将可能导致您无法使用该第三方服务。

2、转让

我们将不会将您的个人信息转让给任何公司、组织和个人,但以下情况除外:

1) 在明确获得您的同意的前提下,我们会向其他方转让您的个人信息;

2) 在涉及合并、收购或破产清算时,如涉及到个人信息转让,我们会在要求新的持有您个人信息的公司、组织等主体继续接受此隐私政策的约束,如果本政策约定的个人信息的收集、处理方式、使用目的等发生改变,我们将要求该公司、组织等主体重新向您征求授权同意。

3、公开披露

我们仅会在以下情况下,收集或公开披露您的个人信息:

1) 获得您明确的同意后;

2) 基于法律法规、司法机关或行政主管部门的强制性要求,我们可能会披露您的个人信息。

4、不经授权收集、共享、转让或公开披露个人信息的例外

根据相关法律法规的规定,在以下情形中,我们可以在不征得您的授权同意的情况下收集、共享、转让或公开披露您的个人信息。

A. 与国家安全、国防安全等国家利益直接相关的;

B. 与公共安全、公共卫生、公众知情等重大公共利益直接相关的;

C. 与犯罪侦查、起诉、审判和判决执行等直接相关的;

D. 出于维护您或其他个人的生命、财产、声誉等重大合法权益但又很难得到本人同意的;

E. 根据您要求签订和履行合同所必需的;

F. 用于维护所提供的产品或服务的安全稳定运行所必需的,例如发现、处置产品或服务的故障;

G. 出于公共利益开展统计或学术研究所必要,且其对外提供学术研究或描述的结果时,对结果中所包含的个人信息进行去标识化处理的;

H. 从合法公开披露的信息中收集到的个人信息的,如合法的新闻报道、政府信息公开等渠道;

I. 法律法规规定的其他情形。

四、我们如何保护您的个人信息

1、我们已使用符合业界标准的安全防护措施保护您提供的个人信息, 防止数据遭到未经授权访问、公开披露、使用、修改、损坏或丢失。我们会采取一切合理可行的措施,保护您的个人信息。例如,在您的浏览器与 “服务”之间交换数据时受 SSL 加密保护;我们对产品提供的配套Web服务提供HTTPS 安全访问方式;我们会使用加密技术确保数据的保密性;我们会使用受信赖的保护机制防止数据遭到恶意攻击;我们会部署访问控制机制,确保只有授权人员才可访问个人信息;以及我们会举办安全和隐私保护培训课程,加强员工对于保护个人信息重要性的认识。

2、我们会采取一切合理可行的措施,确保未收集无关的个人信息。我们承诺将使您的个人信息存储时间始终处于法律要求或实现产品功能和服务所需的合理必要的期限内。对于超出期限的个人信息,我们会立即删除或做匿名化处理。

3、互联网并非绝对安全的环境,而且电子邮件、即时通讯、及与其他用户的交流方式并未加密,我们强烈建议您不要通过此类方式发送个人信息。请使用复杂密码,协助我们保证您的账号安全。

4、互联网环境并非百分之百安全,我们将尽力确保或担保您发送给我们的任何信息的安全性。

5、在不幸发生个人信息安全事件后,我们将按照法律法规的要求,及时向您告知:安全事件的基本情况和可能的影响、我们已采取或将要采取 的处置措施、您可自主防范和降低风险的建议、对您的补救措施等。我们将及时将事件相关情况以邮件、信函、电话、推送通知等方式告知您,难以逐一告知个人信息主体时,我们会采取合理、有效的方式发布公告。 同时,我们还将按照监管部门要求,主动上报个人信息安全事件的处置情况。

五、您的权利

1、撤销授权

如果您希望撤销同意我们收集、使用和披露您的其他个人信息或者希望我们更正、更新或删除您的个人信息,可通过本政策中的联系方式与我们联系。我们将会在收到您的电子邮件或者挂号信后的合理时间内处理您的请求并停止收集、使用和披露您的个人信息。

但请您理解并同意,当您撤回某些授权时,将导致与之相关的产品功能不可用,我们无法继续为您提供撤回同意或授权所对应的特定功能和/或服务,并且您撤回授权的决定不会影响此前基于您的授权而开展的个人信息处理

2、对于您的权利要求的响应

为保障安全,在您提出上述权利主张时,您可能需要提供书面请求,或以其他方式证明您的身份。我们将在验证您的身份后再处理您的请求。一般情况下,我们将在【15】天内做出答复。对于您合理的请求,我们原则上不收取费用,但对多次重复、超出合理限度的请求,我们将酌情收取一定费用。对于与您的身份不直接关联的信息、无端重复信息,或者需要过多技术手段(例如,需要开发新系统或从根本上改变现行惯例)、给他人合法权益带来风险或者不切实际的请求,我们可能会予以拒绝。

在以下情形中,按照法律法规要求,我们将无法响应您的请求:

1、与国家安全、国防安全有关的;

2、与公共安全、公共卫生、重大公共利益有关的;

3、与犯罪侦查、起诉、审判和执行判决等有关的;

4、有充分证据表明个人信息主体存在主观恶意或滥用权利的;

5、响应您的请求将导致您或其他个人、组织的合法权益受到严重损害的;

6、涉及商业秘密的。

六、我们如何处理未成年人的个人信息

1. 我们特别重视未成年人的个人信息的保护。如果您为14周岁以下的未成年人,在使用我们的产品和/或服务前,请您务必在监护人的陪同下阅读本政策,并确保已征得您的监护人明确同意后,再使用我们的服务并向我们提供您的个人信息。

2. 对于经监护人同意使用我们的产品或服务而收集未成年人个人信息的情况,我们只会在法律法规允许、监护人明确同意或者保护未成年人所必要的情况下使用、共享、转让或披露此信息。

3. 如果您的监护人不同意您按照本政策使用我们的服务或向我们提供个人信息,请您立即终止使用我们的服务并及时通知我们。

4. 如果您对您所监护的未成年人使用我们的产品/服务或其向我们提供的用户信息有任何疑问时,请您及时与我们联系。

七、您的个人信息如何在全球范围内转移

我们会按照法律法规的规定,将中华人民共和国境内(以下简称“中国”)收集的用户个人信息存储于中国境内。

由于我们通过遍布全球的资源和服务器向用户提供产品或服务,这意味着,在获得您的授权同意后,您的个人信息可能会被转移到您使用产品或服务所在国家/地区的境外管辖区,或者受到来自这些管辖区的访问。

此类管辖区可能设有不同的数据保护法,甚至未设立相关法律。在此类情况下,我们会确保您的个人信息得到在中华人民共和国境内足够同等的保护。例如,我们会请求您对跨境转移个人信息的同意,或者在跨境数据转移之前实施数据去标识化等安全举措。

八、适用法律及管辖

本隐私政策适用中华人民共和国大陆地区法律。本隐私政策项下争议,由被告住所地法院管辖。

九、本政策如何更新

我们的隐私政策可能会根据业务的调整、法律法规或政策的变化而适时变更。未经您明确同意,我们不会削减您按照本隐私政策所应享有的权利。我们会在专门页面上发布对本政策所作的任何变更。对于重大变更,我们会在产品或服务内通过弹窗、推送等方式向您提示。

若您不同意修改后的隐私政策,您有权并应立即停止使用我们的产品和/或服务。如果您继续使用我们的产品和/或服务,则视为您接受我们对本政策相关条款所做的修改。

本政策所指的重大变更包括但不限于:

1) 我们处理个人信息的目的、处理个人信息的类型、个人信息的使用方式等发生变化;

2) 您参与个人信息处理方面的权利及其行使方式发生变化;

3) 个人信息安全影响评估报告表明存在风险时。

十、我们的联系方式

我公司为在中华人民共和国境内成立的【厦门美图网科技有限公司】,注册地址:厦门市软件园二期望海路6号楼302单元。

如果您对本政策内容有任何疑问、意见、建议或进行申诉,您可通过以下方式联系我们:请发送电子邮件至个人信息保护专员邮箱:[email protected],也可以挂号信方式寄送至:中华人民共和国厦门市思明区软件园二期望海路6号楼2单元1-3层(收件人:美图公司-法务部)。

Privacy Policy

Version: 3.1

Last Modified: Nov 06, 2020

Your privacy is important to us.

Pixocial Technology (Singapore) Pte. Ltd. ("Pixocial", "we", "us" or "our") is dedicated to protecting the privacy of our users ("users" or "you"). This Privacy Policy (the "Policy") is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal information) as a controller and/or business under applicable data protection laws during your use of VCUS application including all its features (the "Services").

Please note that the scope of this Policy is limited solely to your user information (including your personal information) collected or received by Pixocial when you are using the Services. In this Policy, "personal information" refers to any information or combination of information that can be used to identify, contact or locate an individual to whom the collected information pertains. Such personal information may include your email address, date of birth, images, geo-location, personal identity number, identifiable biological information, and financial information (such as credit card or bank account number, WeChat Pay or Alipay account information).

BY USING OUR SERVICES, YOU ARE AGREEING TO THIS POLICY AND THE COLLECTION, USE, PROCESSING, RETENTION, DISCLOSURE AND SHARING OF YOUR USER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, IN THE MANNER PROVIDED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY OR ANY SUBSEQUENT CHANGES TO THIS POLICY, PLEASE DO NOT USE OUR SERVICES.

Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with our Services. Also, please note that, unless we define a term in this Policy, all capitalized terms used in this Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

If you have any questions regarding this Policy or any privacy-related matters, please contact our Data Protection Officer via email at [email protected] (please quote “VCUS” in your email title) or via registered mail at 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial).

The Information We Collect

The Information You Provide to Us

When you use the Services, we might recommend you sign up for an Account to take full advantage of the Services and all their features. When you create an Account, we will collect certain information that can be used to identify you or provide the Services to you, such as your user name, gender, date of birth and mobile phone number and location (collectively, “Registration Data”).

Mobile Device Information

When you use our Services on your mobile device, we will collect information about your device, including its International Mobile Equipment Identity ("IMEI"), Unique Device Identifier (“UDID”) or Android ID, Universally Unique Identifier (“GUUID”), Identifier for Advertising ("IDFA") and Identifier for Vendor ("IDFV"), Integrated Circuit Card Identifier ("ICCID"), Media Access Control ("MAC") address, the type of device you use, operating system version, and resolution, which will be used by us for statistical and/or analytical reasons, including without limitation to improve our technical functionality, server load-balancing, analysis of technical data relating to your mobile device so as to optimize the Services and graphics adaptation.

We may send you push notifications on your mobile device from time to time. If you no longer wish to receive these types of communications, you may turn them off from your mobile device.

As stated below in the “Location Information” section, we may collect your location-based information from your mobile device if you choose to share it with us. If you subsequently wish to stop sharing Location Information, you may do so at any time by editing the relevant setting on your mobile device.

Mobile Analytics

We use mobile analytics software to allow us to better understand and improve the functionality of our Services. Such software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.

Network Information

When you use the Services, we will collect information about the network you use, including the name of the operator and the type of network, so as to understand the distribution of operators and networks used by our users. In addition, we will collect information such as the name of the WiFi network to which you connect, the location of the WiFi network, and the duration of your WiFi connection to understand the environment under which you prefer to use our Services. We may use such information to provide customized services, for example to provide you with location-based advertising through push-notification.

Location Information

We will collect your Location Information, including the country code, latitude and longitude, network location, IP address and the system country and system time zone recorded on your device. This information will help us understand user distribution and usage scenarios and allow us to provide users with the correct version of our apps, the reappearance of the geo-location or the publishing of the real-time geo-location where you take any photos or shoot any videos, send relevant advertisements to you, and improve the Services. Unless we obtain your consent, location data WILL NOT BE ACQUIRED or USED to identify you individually. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device. Please note that we may still continue to receive some Location Information, such as your Network Information, IP address and system time zone, as a result of you using the Services.

Log Information

When you use some of the Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in VCUS ("Log Information"). Log Information may include (i) details on when and how often you use the Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve the Services and is NOT USED to identify our users individually.

Image Information

By choosing to use the cloud editing feature of our service, you understand and agree that we must upload your photos to our server for processing before returning processed photos to you for the purposes of providing such service to you and continuous optimization and that we will also receive the EXIF data about your photos (EXIF data may contain GPS coordinates where photos were taken and processed, equipment type, ISO and information about the front and rear cameras and creation time, depending on the equipment manufacturer) for the purpose of further optimizing our Services, such as providing a better match of photo effects to your equipment.

Metadata

Metadata refers to technical data associated with user content. Put simply, metadata is data that describes data. For example, metadata can describe the analysis results of facial features, gender, age, race of the characters in photos and other elements contained in photos, which are generated and tagged by the computer algorithm and artificial intelligence. When you use the Services, we will use photo metadata to provide you with certain features including precise "Facial Recognition", "Key-Points Recognition", "Region Segmentation", "Content Tags" and other custom features based on a combination of these basic features. We may use your photo metadata to provide you with more suitable filters and better photo effect when our apps process your photos; we may also make use of the metadata to serve up a more contextually relevant products or services to you.

We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.

Forum

You should be aware that ANY CONTENT OR INFORMATION THAT YOU PROVIDE IN A FORUM WILL BE MADE PUBLIC and may be read, collected, copied, distributed and used by others who access the forums, and may result in unsolicited messages from third parties and further distribution of such content or information. The activities of the third parties who collect your information from such publicly accessible forums are beyond Pixocial’s control. As such, you should not post sensitive personal information or any other information that you do not want to be made public. You can remove your personal information from these forums by yourself or by contacting us at [email protected] (please quote “VCUS” in your email title). In some cases, we may not be able to remove your personal information from the forums, in which case, we will let you know if we are unable to do so and why. However, please be aware that if a third party has collected or otherwise saved the information you have made public, Pixocial will not be able to assist you in removing or deleting that information from wherever the third party has stored or posted it.

Cookies

When you are using the Services, Pixocial or a third party designated by Pixocial will use cookies, tags and scripts to collect information for the purposes of analyzing trends, managing the Services, tracking users activity on the VCUS and collecting demographics on the user base. Information collected may include information about your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating system, dates and timestamps, and clickstream data.

Advertising

We and our third-party service providers may include advertisements within our Services, and may collect and use information about you such as your Advertising ID, geographic location and IP address for the purpose of delivering and tracking these advertisements. If your device does not have Advertising ID, we may use other persistent identifiers. We will use this information to help us better count and track advertisements based on language, geographic location and other details. If you wish to opt out of interest-based advertising, you may opt out as your device permits. For more information, please contact us at [email protected] (please quote “VCUS” in your email title). Please note you will continue to receive generic ads after you opt out of interest-based advertising.

Information Collected by Third Party Services

Our Services provided to you may contain our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which may have tracking tools of such service providers. These third parties may use cookies, APIs and SDKs on our Services and collect and analyze user information. In addition, some third-party SDKs may allow advertisers to collect information in order to provide content that is more relevant to you. Third parties may access your information such as your device identifiers, region (defined as the location where a given language is used), location information and IP address under their respective privacy policies. If you want to know more about such third parties, you may send an email to [email protected] (please quote “VCUS” in your email title).

User Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products, services, and advertising that may be of interest to you. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include: Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.

If you provide us any personal information of any third party, you shall obtain the consent of such third party for the collection, use and disclosure thereof by Pixocial in accordance with these purposes. You further represent and warrant that in relation to any such third party personal information that you provide, you have obtained such consent for such collection, use and disclosure by Pixocial.

Other Information

We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you.

HOW WE USE INFORMATION

In addition to the uses listed above, we collect and use your user information and personal information for the following purposes:

INFORMATION SHARING AND DISCLOSURE

We may share your information with third parties who provide services on our behalf to help with our business activities. These services may include:

We will not share with or disclose to third parties (other than our service providers) your personal information in whole or in part except for the purposes of:

THIRD PARTY WEBSITES AND SERVICES

The Services may contain links to other websites and services. In addition, other websites and services may reference or link to our Services. These other domains and websites are not controlled by us, and Pixocial does not endorse or make any representations about third party websites or services. We encourage our users to read the privacy policies of each and every website and service with which they interact. Visiting these other websites or services is at your own risk.

INFORMATION SECURITY

We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal information. However, you understand and accept that (in the Internet industry) even though we take reasonable security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. Further, you understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.

INFORMATION ACCESS AND CONTROL

We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity through the collection of your email address.

DATA RETENTION

Subject to applicable laws and regulations and the fulfillment of our business or legal purposes, we will retain your information (including your personal information) for such period as is required for us to continue to provide you with our Services.

PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

If you wish to exercise your rights, you may send an email to [email protected] (please quote “VCUS” in your email title) or mail your request to 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial). We will process your request in line with applicable laws within a reasonable period of time after receiving your email or mail, and will cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act.

INFORMATION ABOUT CHILDREN

We will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under 16, please do not send your personal information to us, including your name, address, phone number or email address. If you believe we may have any information about children under 16, you may send an email to [email protected] (please quote “VCUS” in your email title) or send a registered mail to 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial). If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information.

CROSS-BORDER DATA TRANSFERS

You understand and agree that all information collected via or by Pixocial may be transferred, processed, and stored anywhere in the world, including but not limited to, Singapore, China, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide the Services.

IF YOU ARE A RESIDENT OF CALIFORNIA

The California Consumer Privacy Act (“CCPA”) provides California residents with the right to know what categories of personal information we have collected about them:

Category of Personal Information Collected by us?
Identifiers Yes
Personal information categories listed in Cal. Civ. Code § 1798.80(e) No
Characteristics of protected classifications under California or federal law No
Commercial information Yes
Biometric information No
Internet activity or electronic network activity information Yes
Geolocation data Yes
Audio, electronic, visual, thermal, olfactory, or similar information Yes
Professional or employment-related information No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) No
Inferences drawn from other personal information to create a profile Yes

The California Consumer Privacy Act also provides California residents with the right to opt out of the “sale” of their personal information. Under the CCPA, a “sale” is broadly defined as making available personal information to a third-party for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information.

For purposes of the CCPA, a “sale” may include using targeted advertising services to deliver targeted advertising on the Services or other sites. Like most mobile applications, we use these services, which enable us to provide the Services and relevant offers to you. As a result, Pixocial may “sell” the following categories of personal information: identifiers (e.g., advertising IDs); internet activity; geolocation data; and inferences drawn to create a profile.

California residents may opt-out of the “sale” of their personal information by turning off the switch next to “Do not sell my personal information”.

If you are a resident of California, every year we will provide you free of charge with an opportunity to obtain a list of third parties to which we have disclosed or with whom we have shared your personal information for their direct marketing purposes during the previous year. If you are a resident of California and wish to obtain this list, you may send an email with the subject "VCUS - The right to privacy of a California resident" to [email protected] or send a registered mail to 80 Robinson Road #02-00 Singapore 068898 (attention: Legal Department, Pixocial).

GOVERNING LAW

This Policy is established, comes into force, and will be enforced and interpreted under the laws of Singapore, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.

AMENDMENTS TO THIS POLICY

You agree that we may update this Policy according to relevant laws and regulations or based on Pixocial’s business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on VCUS or notify you by other means as required by law.

FOR USERS IN THE EUROPEAN ECONOMIC AREA

If you are in the European Economic Area (“EEA”), we will not collect any of your information set forth above. However, we will process certain information related to your SIM card which enables us to verify whether you are in the EEA. We use this information to verify whether you are in the EEA and to prevent the processing operations outlined above. Where we are unable to collect such information we will ask you whether you are in the EEA. The legal basis for the processing of this SIM card data or your answer to the question about your whereabouts is the performance of a contract with you (Art. 6 para. 1 lit. b) of the Regulation (EU 2016/679 of the European Parliament and of the Council (“GDPR”)). Without the provision of such data we may not be able to provide you with any Services.

As we are located in the People’s Republic of China we are required to transfer this information to the People’s Republic of China. Please be aware that the European Commission has not issued an adequacy decision in relation to the People’s Republic of China.

We will retain this information for as long as needed to provide you with our Services.

Controller

The Controller for the purposes of Art. 4 no. 7 GDPR with respect to the processing outlined in this Policy is Pixocial Technology (Singapore) Pte. Ltd., 80 Robinson Road #02-00 Singapore 068898. You may contact us via registered mail at the above address (attention: Legal Department, Pixocial) or via e-mail at [email protected]. (please quote “VCUS” in your email title.)

Representative

Our representative in the European Union is Rivacy GmbH, you may contact our representative via e-mail at [email protected] or via registered mail at Rivacy GmbH, Hammerbrookstraße 90,20097 Hamburg.

Your rights as a Data Subject

As a data subject in the European Economic Area you have the following rights with regard to the processing of your personal data:

Right of access

As a data subject you have the right to obtain confirmation from us as to whether we are processing your personal data (Art. 15 para. 1 GDPR). If so, you also have the right to obtain access to the personal data and the information listed in Art. 15 para. 1 GDPR. This includes information regarding the purposes of the processing, the categories of personal data that are being processed and the recipients or categories of recipients to whom the personal data have been or will be disclosed.

Right to rectification

As a data subject, you have the right to rectification set out in Art. 16 GDPR, i.e. to have your inaccurate data processed by us rectification and incomplete personal data completed.

Right to erasure (“right to be forgotten”)

As a data subject, you have a right to obtain from us the erasure of your personal data and we are obliged to erase your personal data without undue delay when one of the reasons listed in Art. 17 para. 1 GDPR applies. This can be the case, for example, if personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (Art. 17 para. 1lit. a) GDPR).

If we have made the personal data public and are obliged to erase it, we are also obliged, taking account of available technology and the cost of implementation, to take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of those personal data (Art. 17 para. 2 GDPR).

The right to erasure (“right to be forgotten”) does not apply if the processing is necessary for one of the reasons listed in Art. 17 para. 3 GDPR. This can be the case, for example, if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims (Art. 17 para. 3 lit. a) and e) GDPR).

Right to restriction of processing

As a data subject, you have a right to obtain from us the restriction of processing if one of the conditions provided in Art. 18 para. 1 GDPR applies. This can be the case, for example, if you contest the accuracy of the personal data. In such a case, the restriction of processing lasts for a period that enables us to verify the accuracy of the personal data (Art. 18 para. 1 lit. a) GDPR).

Restriction means that stored personal data are marked with the goal of restricting their future processing (Art. 4 para. 3 GDPR).

Right to data portability

As a data subject, you have a right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from us if the processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and the processing is carried out by automated means (Art. 20 para. 1 GDPR).

In exercising your right to data portability, you also generally have the right to have your personal data transmitted directly from us to another controller if technically feasible (Art. 20 para. 2 GDPR).

Right to object

As a data subject, you have a right to object under the conditions provided in Art. 21 GDPR.

Right to object on grounds relating to the particular situation of the data subject

As a data subject, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Art. 6 para. 1, lit. e) or f) GDPR including profiling based on those provisions.

To verify whether our processing is based on Art. 6 para. 1, lit. e) or f) GDPR, please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to object to direct marketing

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, we no longer process your personal data for these purposes.

Right to withdraw consent

Where our processing of your personal data is based on your consent, you have the right, pursuant to Art. 7 para. 3 GDPR, to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal.

To verify whether our processing is based on consent pursuant to point Art. 6 para. 1 lit. a) GDPR or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR please refer to the section “Legal Basis of the Processing” of this Privacy Notice above.

Right to lodge a complaint with a supervisory authority

As a data subject, you have a right to lodge a complaint with a supervisory authority under the conditions provided in Art. 57 para. 1 lit. f) GDPR.

Exercise of your rights under GDPR

As a data subject, you may exercise any of the rights listed above in accordance with the instructions and limitations set forth in “Data Retention and Correction, Update and Deletion” above.

Additional Information on Your Rights as a Data Subject

For further information on your rights as a data subject please refer to Art. 12 to 21 GDPR, which can be accessed here: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

FOR USERS IN JAPAN

Right to data disclosure, correction, erasure or suspension of use

If you are in Japan, as a data subject, you have the right to request the disclosure, correction, erasure or suspension of use of your personal data, and we are obliged to meet your request without undue delay. You may send your request by email to [email protected] (please quote “VCUS” in your email title) or by mail to 80 Robinson Road #02-00 Singapore 068898 (Attention: Legal Department, Pixocial).