AirGlow – Privacy Policy

Privacy Policy

Version: 1.0

Last Modified: [2019/09/25]

Your privacy is important to us.

Meitu (China) Limited (“Meitu“, “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 during your use of AirGlow 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 Meitu 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 name, gender, phone number, 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 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 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 compliance@meitu.com, or via registered mail at Room 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Meitu). 

THE INFORMATION WE COLLECT

In order to provide and improve the Services, Meitu will collect and process your personal information and user information in accordance with this Policy. If you do not provide this information, we may be unable to provide you with our products or Services. You should ensure that all personal information and user information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with all or some of the Services.

Mobile Device Information

When you use our Services on your mobile device, we will collect information about your device, including its Identifier for Advertising (“IDFA“) and Identifier for Vendor (“IDFV“), 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.

Mobile Analytics

We use mobile analytics software (e.g. Firebase, AppsFlyer and Flurry) 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.

Location Information

We will collect your Location Information, including the country code, when you provide any feedback to us. This information will help us understand user distribution and usage scenarios, identify your problems (if any),,  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.

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 AirGlow (“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. 

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. 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 compliance@meitu.com.

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 Meitu 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 Meitu.

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. In addition, our Services may utilize calculation results of ARKit from Apple in relation to depth of facial mapping information, in order to achieve better facial image processing effect.

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:

  1. Services. To provide, process, maintain, improve and develop our Services provided to you, including confirmation of subscription orders, customer support, and other services provided through our products.
  2. Statistical analysis. To develop and analyze statistics on the use of our products and Services for the purpose of improving our products and our Services.
  3. To improve user experience. Certain optional features such as user experience programs allow Meitu to analyze data regarding the use of our products and our Services and improve user experience.
  4. To provide push services. Device information may be used by us to provide push services to provide notifications on new product releases and in-app promotions. 
  5. To collect feedback from you. Your feedback is of great value in helping Meitu improve our Services. To keep track of your feedback, Meitu may use the personal information provided by you to contact you and retain the records.
  6. Other purposes. We will collect, store, maintain and use information about you for purposes under the “The Information We Collect”, and for purposes of running our operations, pursuing our legitimate interests (e.g., research (including marketing research), network and information security, and fraud prevention), and satisfying our legal obligations.

INFORMATION SHARING AND DISCLOSURE

We will not sell any personal information to third parties. We may share your information with third parties who provide services on our behalf to help with our business activities. These services may include:

  1. Fulfilling orders and delivering packages;
  2. Providing you with advertising;
  3. Payment processing;
  4. Providing customer services;
  5. Sending marketing communications;
  6. Fulfilling subscription services;
  7. Conducting research and analysis; and
  8. Providing cloud computing infrastructure.

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:

  1. protecting the security of others or their property;
  2. preventing or dealing with fraud;
  3. safeguarding the legitimate rights and interests of Meitu;
  4. taking action in line with our purposes as described in the “The Information We Collect” or the “How We Use Information” sections; 
  5. complying with laws and regulations or requests by government departments, judicial authorities, law enforcement, or private parties, which are typically designed to uphold Internet security and the rights, property and safety of us, our users and third parties; and/or
  6. evaluating or completing a transaction where we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or other event where your information may be sold or transferred.

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 Meitu 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 in order to protect the security of your account.

DATA RETENTION AND CORRECTION, UPDATE AND DELETION

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. If you wish to withdraw your authorization to our collection, use and disclosure of your personal information, exercise your rights under any applicable laws, or wish us to correct, update or delete your personal information, you may send an email to compliance@meitu.com or mail your request to Room 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Meitu). 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. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.

INFORMATION ABOUT CHILDREN

We will not knowingly collect or request personal information from children under 13 (or any other age stipulated by law applicable to your region). If you are under 13, 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 13, you may send an email to compliance@meitu.com or send a registered mail to Room 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Meitu). If we learn that we have collected personal information from children under 13 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information and terminate the associated account.

CROSS-BORDER DATA TRANSFERS

You understand and agree that all information collected via or by Meitu may be transferred, processed, and stored anywhere in the world, including but not limited to the United States, 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.

GOVERNING LAW

This Policy is established, comes into force, and will be enforced and interpreted under the laws of Hong Kong Special Administrative Region of the People’s Republic of China, 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 Meitu’s business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on AirGlow or notify you by other means as required by law.

IF YOU ARE A RESIDENT OF CALIFORNIA

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 “The right to privacy of a California resident” to compliance@meitu.com or send a registered mail to Room 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Meitu).