Privacy Policy

Last updated: 2022/06/24


Thanks for choosing this mobile application( the “App” or “Software”) and related services( “Service” ) provided by Cloud High Investment Limited ( “we”, “our”, or “us” ). For operating the Software and providing the Service to you, we need to collect some privacy information about you. We understand the importance of protecting your privacy. Therefore, we have established this Privacy Policy to explain how we treat your information and protect your privacy when you use the Software and the rights and options available to you regarding your information. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

Please read this Privacy Policy carefully to understand it. If you use the Software and Service, we consider you to consent the terms and conditions described in this document.

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE AND SERVICES.

Information We Collect and Use

There are two general categories of information we may collect.

1.  Information provided or permission granted to us by you

a) Permission to Access to the Camera, Photo Album. In order to use certain features of the Software, you may voluntarily grant us the permission to access to the camera or photo album to obtain photos in your mobile device or save pictures to your photo album. Only if you confirm the permission, will we gain access to your camera and photo album.

b) Permission to Access to Microphone. In order to use certain features involved recording videos, you may voluntarily grant us the permission to access to the Microphone, Only if you confirm the permission, will we gain access to the Microphone of your device.

c) Facial Features Information.

Collection and processing of your facial features information

When you use certain features of the Software to process your facial photos, we will analyze the facial features data, recognize the position and shape of the five sense organs, and gender in the photos, then process them, and feedback the special effect photos to you.

If you cease to consent or affirmatively revoke consent for our collection and processing of your facial features information, we will promptly cease all such collection and processing.

The purposes we collect your facial features information.

We capture the facial features information only for operating the face recognition functions and providing better special effect photos for you.

Storage and sharing of your facial features information.

For such facial photos, facial features information and special effect photos, we will neither store in our server nor share them with any third parties after processing.

d) Storage of Your Device. For using certain features to process the photos in your device, or saving processed photos or cache other information normally to your device, we may access to the storage of your device.  

e) Permission to Access to the Identifier For Advertising( IDFA).

To provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners, we will collect the IDFA of your device after you grant us the permission to access to such data.

2. Information collected automatically

For analytical, business and operational purposes, we automatically collect the following types of information:

a) Technical Information. We may collect certain technical information, which is regarding your device configuration and identifiers, and your use of the Software and Services, including the type, name and version of operating system, internet service provider (ISP), internet protocol (IP), International Mobile Subscriber Identification Number (IMSI), Status of the WLAN, International Mobile Equipment Identity (IMEI).

b) Usage Information. We may collect certain usage related information regarding your use and interaction with your device, including the Software and Services, such as when and how you use the Software and Services, how frequently you use them.

c) Payment data. We may collect information about your subscription orders, such as purchase items, subscription time, order status, payment time. We do not collect and we are not responsible for the collection or security of payment details. Payment information is processed and stored using third-party companies (such as Apple). These companies can be contacted through their websites. Before entering your personal payment details, we suggest that you read and become familiar with the privacy policy of these third-party companies.

d) Geolocation Information. If you turn on the geolocation features of your device, we will collect the geolocation information to improve our Service and provide you with personalized advertisements from our partners.

How We Use Information

The main reason we use your information is to deliver and improve the Software and Services. Read on for a more detailed explanation of the various reasons we use your information:

1. Deliver Services. Deliver the Software and Services to you and maintain, improve the quality and operation of the Software and Services, ensure their optimal functionality and operation.

2. Maintain Relationship. Identify, establish and manage your account and our relationship with you.

3. Respond Requests. Provide you with customer support and respond to your requests.

4. Customize the Services. (i) To improve and customize the Software and Services; (ii) To provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners.

If any new purposes for processing your information arise we will let you know before we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

While it is not our intention to collect any personally identifiable information (“PII”) (except for those set forth in this Privacy Policy), the data collected may include PII. As part of our privacy measures, we implement certain rules designed to avoid the unintentional collection of PII such as email addresses, social security numbers, credit card numbers etc. Such rules are based on known field types, parameters, values and algorithms but they are not foolproof and hence the Software and Services may sometimes, unintentionally, collect unwanted information. We regularly examine and update these rules to avoid this happened.

If you located in the EEA, as required by law, you hereby grant your consent to us to use or process your personal information only for the purpose described above once you use the Software or the Service. And you may withdraw your consent at any time by contacting us.

Sharing Information with Third Parties.

We will not share any PII that we have collected from you except for the following events:

1. If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the team’s users, its partners, or the general public);

2. In the event the team goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred.

Third Party Service.

The Software and Services may include and/or enable you to use or access some service provided by third parties ("Third Party Service"). The use of such Third Party Service is subject to its privacy policy. You shall be aware that the use of the Third Party Service may give this third party the ability to access, collect, store, and/or share your information, both your PII and non-personally identifiable information. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Service and your access to any Third Party Service is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Service. You expressly relieve us from any and all liabilities arising from your use of such Third Party Service. We recommended that you read the terms, conditions and privacy policy of such Third Party before using or accessing any of them.

Security of Your Information

The security of user’s information is our utmost priority, and we take strict measures in order to protect the data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s information. We also protect user’s privacy by seeking to minimize the amount of sensitive data and PRI. We also seek appropriate contractual protection from our partners regarding their treatment of user data. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Data Retention.

We retain the information we collect as described in this Privacy Policy for as necessary for the provision of the Services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the Services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes). We will only keep your personal information for three (3) years.

Your Data Rights

You have the right to access, modify, correct or delete any personal data which we may have collected, to exercise this right please contact us by email at: lotusvideo@outlook.com. If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. To exercise these rights please contact us by email at: lotusvideo@outlook.com.

Notices

If we are required to provide you with notice of a particular event or incident, we will send you such notice by mail, email or telephone.

Children’s Policy

We ensure that we comply with the Children's Online Privacy Protection Act (COPPA), and does not knowingly collect personal information from children under the age of thirteen (13). If you are in the EEA, our Software and Services is not directed to children under 16, and we do not knowingly collect PII from children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without his/her consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

Transfer of Data Outside Your Territory.

The Software and Services work over the Internet. We may store and process your information in various locations throughout the world. Where you located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where may be outside of EEA once you use the Software and/or Services. You may withdraw your consent at any time.

How to Contact us.

If you have any questions or concerns with respect to any matter covered by this Privacy Policy, you may contact us by email at: lotusvideo@outlook.com. We may modify, update and publish this Privacy Policy in the Software from time to time. Please continue to play close attention to this Policy.