Privacy Policy

Introduction

Welcome to use our products and services!

We value the protection of your personal information and commit to taking appropriate security measures in accordance with legal requirements to protect your personal information. This policy applies throughout the entire process of downloading, installing, opening, browsing, using, and canceling (hereinafter collectively referred to as "using") the SwapX App. Before using our products and services, please carefully read and fully understand this policy, and pay special attention to the bold text.

Your consent to the basic functionality personal information protection policy only indicates your agreement to the necessary permissions and processing of personal information required by AI portrait, AI clothing change, or other basic functions, as well as login or other core functionalities.

I. How We Collect, Store, and Use Your Personal Information

(1) Account and Security

1. Registration, Login, and Use of SwapX App Account

You can create a SwapX App account through third-party login and complete your account information; you can also choose to skip account registration and select anonymous login, which will not affect your use of the basic functions of SwapX App.

When creating your SwapX App account, the nickname and avatar from the third-party social platform will be automatically synchronized, and this information will be publicly displayed in some interactive scenarios. This type of information is considered non-essential personal information, and not providing such information will not affect your use of SwapX App services.

2. Providing Network and Operational Security

To ensure the security of your account, network, operations, and system, and to prevent phishing fraud and malware, we may collect your device information (android_id, oaid, gaid for Android; idfa, idfv for iOS) during your use of our product. Please understand that when you switch SwapX App from your device screen to run in the background, due to certain device models and system reasons, the information collection behavior that occurred while you were using SwapX App related functions may not stop immediately, resulting in brief background information collection. When SwapX App is in a static background state, no information will be collected.

3. Maintaining Product Security and Troubleshooting

To maintain the normal operation of our services, ensure the security of your account, troubleshoot product issues, and improve and optimize our services, we collect your IDFA, OAID, network carrier and type, device model information, login IP address, operation log information, device brand, system version, and CPU information. This information is necessary for providing services and is de-identified after collection, not being used to identify any specific user.

4. Saving Network Traffic

We may also collect your network type to help you save network traffic during content delivery.

5. Auto-Start

To ensure that the application can normally modify the in-app language and shortcut icon language when closed or running in the background, the application must use (auto-start) capability when you actively change the system language.

6. Providing Suitable Regional Versions

We collect your SIM card status to determine your approximate region and provide you with the SwapX App version that best matches your language and lifestyle habits.

(2) Photo Enhancement

When you use features such as image enhancement, AI portrait, AI clothing change, etc., the relevant calculations are performed on the server, and when the results are returned to your phone, the image content you uploaded to the server will be cleared simultaneously.

(3) Message Notifications and Content Pushing

1. Message Notifications

We will send one or more types of notifications to the contact information (e.g., email) you provided during your use of SwapX App products or services, such as product activities and benefits notifications, identity verification, security verification, marketing information, renewal notifications, or related surveys. However, if you do not wish to receive such information from us, you can unsubscribe through the following path:

[Me] Settings - Privacy and Notifications - Turn off the "Allow device to receive SMS notifications" button.

2. Content Pushing

To help you better manage your preferences, obtain a more relaxed access experience, help you obtain community content that interests you more in the product community, or present content that better meets your needs in tool materials and advertisement recommendations to reduce your filtering time for massive internet content, we need to collect information including your device identification information (android_id, oaid, gaid for Android; idfa, idfv for iOS), IP address, and language for personalized advertisement pushing.

(4) System Permissions and Personal Information List

1. Personal Information List

You can also easily and conveniently understand the personal information required for basic functions and additional functions through the list below. We will separately obtain your consent when you use additional functions.

Android permission list as follows:

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iOS permission list as follows:

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2. System Permissions

When using certain functions, mobile system permission authorization is required. We will separately seek your consent. Refusing or withdrawing such permission applications will only affect your use of specific product functions. If you do not agree to enable permissions, please click "Do not allow." If you wish to withdraw authorization, you can do so according to the following paths:

• Camera permission: Me - Settings (top right) - System Permission Management - Camera Permission
• Storage permission: Me - Settings (top right) - System Permission Management - Storage Permission
• Notification permission: Me - Settings (top right) - System Permission Management - Notification Permission
• Geographic location permission: Me - Settings (top right) - System Permission Management - Geographic Location Permission
• Advertising identifier permission: Me - Settings (top right) - System Permission Management - Advertising Identifier Permission

(5) Indirectly Obtaining Your Personal Information from Third Parties

1. Third-Party Accounts

When you independently use a third-party account (Facebook, Twitter, Apple, Google), we will obtain the following personal information from third-party partners: public information registered, published, and recorded on that platform (including nickname and avatar).

2. Authorization for Third-Party Information

SwapX App needs your authorization to obtain the above information from third parties to remember your login identity as a SwapX App user and to provide you with better products and/or services. We will only collect and use your personal information within the scope of your authorized consent.

After you register or log in using a third-party account, your third-party account will be bound to your SwapX App account, but you can choose to "unbind" in [Me - Settings] to cancel the account binding.

II. How We Use Cookies

To ensure the normal operation of the website, to help you obtain a more relaxed access experience, and to recommend information that may interest you, we will store small data files called Cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. With Cookies, websites can store your preference data, helping you avoid repeatedly filling in personal information and inputting historical search content; we may also use the above technology to recommend, display, and push content that interests you. You can manage or delete Cookies according to your preferences, and you can also clear all Cookies saved on your computer. For details, please refer to AboutCookies.org. We will not use Cookies for any purpose beyond those stated in this policy. Most web browsers have functions to block Cookies. You can clear all Cookies saved on your computer through browser setting options, but if you do so, it may cause you to have to personally change user settings each time you visit our website.

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

(1) Sharing

We will not share your personal information with any company, organization, or individual, except in the following situations:

1. Sharing with Explicit Consent

After obtaining your explicit consent, we will share your personal information with other parties.

2. Sharing Under Legal Conditions

We may share your personal information externally in accordance with legal and regulatory requirements, litigation dispute resolution needs, or according to mandatory requirements legally put forward by government authorities or judicial organs.

3. Sharing Personal Information with Partners

Only when you actively choose to use corresponding functions/services, we may share certain personal information with partners to ensure the smooth completion of services shared with you and help us share better customer service and user experience. We will only share your personal information based on principles of legality, legitimacy, necessity, and good faith, and will only share personal information necessary for the service, such as "obtaining information about installed apps." At the same time, for companies, organizations, and individuals receiving personal information, we will sign strict confidentiality agreements with them or require them to process personal information according to our requirements and any other relevant confidentiality and security measures. Our partners have no right to use the received personal information for any other purpose.

(2) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following situations:

1. With Your Explicit Consent

With your explicit consent, we will transfer your personal information to other parties.

2. In Case of Mergers, Acquisitions, or Bankruptcy Liquidation

If personal information transfer is involved in mergers, acquisitions, or bankruptcy liquidation, we will inform you of the name and contact information of the personal information recipient through SMS, phone call, or other means, and seek your consent. We will require the new company, organization, or other entity holding your personal information to continue to be bound by this SwapX App personal information protection policy. If the collection, processing method, or purpose of use of personal information as stipulated in this policy changes, we will require that company, organization, or other entity to re-seek your authorization consent.

(3) Public Disclosure

We will only collect or publicly disclose your personal information in the following situations:

1. With Your Individual Consent

After obtaining your individual consent;

2. Based on Legal Requirements

Based on the mandatory requirements of laws, regulations, judicial organs, or administrative authorities, we may disclose your personal information.

(4) Circumstances for Processing Personal Information Without Authorization in Accordance with the Law

According to relevant laws and regulations, we may process your personal information without your consent in the following situations:

1. Necessary for concluding or performing a contract to which you are a party;
2. Necessary for fulfilling statutory duties or obligations;
3. Necessary for responding to public health emergencies or protecting your life, health, and property safety in emergency situations;
4. Processing personal information within a reasonable scope for implementing news reporting, public opinion supervision, or other acts for public interest;
5. Processing personal information that you have voluntarily made public or other legally published personal information within a reasonable scope in accordance with relevant legal provisions;
6. Other circumstances stipulated by laws and administrative regulations.

IV. How We Protect Your Personal Information

1. We have used industry-standard security protection measures to protect the personal information you provide, preventing data from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and feasible measures to protect your personal information. For example, data exchanged between your browser and the "service" is protected by SSL encryption; we provide HTTPS secure access methods for the web services that come with the product; we use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent data from malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
2. We will follow up in real-time on updates and compliance with relevant laws, regulations, and standards. We will make our best efforts to resist and handle various types of information security threats to provide comprehensive protection for your information security. Subject to having fulfilled the security guarantee obligations stipulated by laws and regulations such as the National Cybersecurity Law and GDPR, if data leakage occurs due to the following circumstances not attributable to our company, our company shall not bear compensation responsibility:
   • Unforeseeable and irresistible network attacks such as hacker attacks and exploitation of new unknown vulnerabilities;
   • Chain security incidents caused by users' improper password management;
   • Compliance errors of third-party service providers (such as cloud infrastructure providers). However, the platform promises to initiate emergency response within 24 hours after discovering anomalies and report to regulatory authorities in accordance with the requirements of the "Data Security Law".
3. Retention period: We will only retain your personal information for the period necessary to achieve the purposes stated in this policy. Product and service, transaction information will be kept for no less than three years from the date of transaction completion. For personal information exceeding the period, we will delete it immediately.
4. For images uploaded by users to the server, they will be protected by encryption protocols during transmission and storage. They are only used for the generation of AI images.
5. For image content generated by users, we will store it in the corresponding data center in accordance with relevant regulations (allowing you to retrieve historical generation records after switching hardware devices). After user deletion, the system will automatically clear it within 24 hours.
6. The Internet is not an absolutely secure environment, and email, instant messaging, and other ways of communicating with other users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use complex passwords to help us ensure the security of your account.
7. The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send to us.
8. In the unfortunate event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposition measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant circumstances of the incident by email, letter, telephone, push notification, or other means. When it is difficult to inform the personal information subjects one by one, we will adopt reasonable and effective ways to publish announcements. At the same time, we will also actively report the handling of personal information security incidents according to the requirements of regulatory authorities.

V. Your Rights

(1) Access, Delete, and Correct Your Personal Information

1. Personal information access and correction: You can access and correct personal information and nickname in your account through [Me] - [Personal Homepage] - [Edit Profile].
2. Search information: You can delete your search history records in [Search Bar] - [Search Records] - [Clear Search Records].
3. Publishing content sharing and deletion: You can enter [Personal Homepage] through [Me], and through the management function, share or delete the information content you published at any time.
4. Account information access and correction: You can access or change your bound email, login records, and third-party account binding in [Me] - [Settings] - [Account Management].
5. Personal information browsing and export: When logged into your account, if you need to browse your personal information or wish to export a copy of your personal information, you can apply for the extraction of a personal information copy in [Settings] - [Account Management] - [Security Center] - [Personal Information Browsing and Export]. After you submit the application, we will send it to the email you specified within 24 hours.
6. In the following situations, we will delete the relevant personal information we have collected, and you can also request us to delete your personal information:
   1. The processing purpose has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;
   2. We have stopped providing products or services, or the retention period has expired;
   3. You have withdrawn consent;
   4. We have processed personal information in violation of laws, administrative regulations, or agreements;
   5. Other circumstances stipulated by laws and administrative regulations.
   If the retention period stipulated by laws and administrative regulations has not yet expired, we will cease processing except for storage and taking necessary security protection measures.

(2) Withdraw Your Authorization

If you wish to revoke consent for us to collect, use, and disclose your other personal information, or wish us to correct, update, or delete your personal information, you can withdraw through the withdrawal paths provided in different versions or operating systems, or contact us through the contact information in this policy. We will process your request and stop collecting, using, and disclosing your personal information within a reasonable time after receiving your email or registered letter.

When you withdraw certain authorizations, it will result in related product functions becoming unavailable. We will not be able to continue providing you with the specific functions and/or services corresponding to the withdrawn consent or authorization, and your decision to withdraw authorization will not affect the processing of personal information based on your prior authorization.

(3) Account Cancellation

1. Canceling the current application account: You can do this through [Settings] - [Account Management] - [Security Center] - [Cancel Account] - [Cancel Current Application Account]. When you choose to cancel your current SwapX App account, we will immediately clear all your personal information and data stored within SwapX App after cancellation.
2. Canceling the SwapX App account: You can do this through [Settings] - [Account Management] - [Security Center] - [Cancel Account] - [Cancel SwapX App Account]. Choosing to cancel your current SwapX App account is an irreversible action. After cancellation, the SwapX App account cannot be logged in and cannot be recovered. All information about that SwapX App account within SwapX App will be cleared. Please operate with caution.

After successful cancellation, we will stop providing you with products or services and delete your corresponding personal information in accordance with the requirements of applicable laws.

(4) Our Commitment to Your Requests

We commit to completing the verification and processing of your requests for correction, withdrawal, deletion of personal information, and account cancellation within 15 working days.

VI. How We Handle Minors' Personal Information

1. Our products are primarily aimed at adults. Due to the characteristics of this product, our company has not developed other product functions to identify your true age.
2. Minors under fourteen years of age (referred to as "minors" in this policy, specifically meaning minors under fourteen years of age) should not create their own personal information subject accounts without the consent of their parents or guardians. If you are under 14 years of age, before using our products and/or services, please be sure to read this policy accompanied by your guardian and ensure that you have obtained the explicit consent of your guardian before using our services.
3. For situations where we collect personal information of minors with guardian consent for using our products or services, we will only process this information when permitted by laws and regulations, with explicit consent from the guardian, or when necessary to protect the minor.
4. If your guardian does not agree with your use of our services according to this policy or providing us with personal information, please immediately terminate your use of our services and promptly notify us.
5. If you are a parent or guardian and have any questions about the use of our products/services by the minor under your guardianship or the user information they provide to us, please contact us promptly.
6. If we discover that we have collected personal information of a minor without obtaining guardian consent, we will endeavor to delete the relevant minor's information as soon as possible.

VII. How Your Personal Information Is Transferred Globally

We will store user personal information collected in respective countries within those countries in accordance with the provisions of laws and regulations. We will not transfer the above information abroad. When it is necessary to transfer information abroad, we will follow relevant national laws and regulations to conduct assessments, certifications, and obtain your individual consent.

VIII. How This Policy Is Updated

Our SwapX App personal information protection policy may change from time to time according to business adjustments, changes in laws, regulations, or policies. Without your explicit consent, we will not reduce the rights you should enjoy according to this SwapX App personal information protection policy. After this policy is updated, we will issue an updated version and remind you of the updated content through private messages, notifications, announcements, or other appropriate means before the updated terms take effect, so that you can timely understand the latest version of this policy.

If the type of policy change involves changes in the purpose, method of processing, and types of personal information processed, our company will re-obtain your consent. If you do not agree with the modified SwapX App personal information protection policy, you have the right and should immediately stop using our products and/or services. If you have any doubts about the updates to this policy, please contact us promptly through the contact information publicized in this policy.

IX. Our Contact Information

The developer of SwapX App is SprayJoy Company (only the developer, not the operating entity and the collector of personal information).

If you have any questions, comments, suggestions, or complaints about the content of this policy, you can contact us through the following means: Please send an email to the personal information protection specialist mailbox: support@sprayjoy.com