PRIVACY POLICY

LoomlyAI fully understands the importance of personal information to you, and your trust is very important to us. We will strictly comply with legal and regulatory requirements to take appropriate security measures to protect your personal information. Based on this, we have formulated this Privacy Policy (hereinafter referred to as 'this Policy') to help you fully understand how we collect, use, share, store, and protect your personal information during your use of our products, as well as how you can manage your personal information, so that you can make better decisions.

Before officially starting this product, please be sure to read and understand this policy carefully, paying particular attention to the clauses marked in bold or underlined, ensuring you fully understand and agree before proceeding with use. In addition to this policy, under specific circumstances, we will also inform you through immediate notifications (including pop-ups, page prompts, internal messages, etc.) and function update explanations about the purposes, scope, and usage methods of information collection. These immediate notifications and function update explanations are part of this policy and have equal authority to it. Furthermore, you acknowledge and understand that the functions of LoomlyAI products may continuously evolve, and we will periodically update this policy. You should regularly check the content of this policy and read it thoroughly along with any updates. If you disagree with this policy or any update, you can contact us through the contact information provided in this policy. You must not use or continue using this product or its corresponding functions until you reach an agreement with us. If you use this product or its corresponding functions in any way, it will be deemed that you have accepted this policy and the aforementioned updates.

We will try our best to explain the professional terms involved in this policy in a concise and common way so that you can understand it. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the contact information at the end of this policy.

This Privacy Policy will help you understand the following:

  • HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
  • HOW WE USE COOKIE AND SIMILAR TECHNOLOGIES
  • HOW WE SHARE, TRANSFER AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION
  • HOW WE KEEP AND PROTECT YOUR PERSONAL INFORMATION YOUR RIGHTS
  • SPECIAL PROVISIONS ON THE INFORMATION OF MINOR USERS
  • SCOPE OF APPLICATION OF PRIVACY POLICY
  • REVISION OF PRIVACY POLICY
  • HOW TO CONTACT US
  • APPENDIX: RELATED DEFINITIONS

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

When you use our products/services, the scenarios in which you need to/choose to authorize us to collect and use personal information include:

In order to provide you with the basic functions of our products/services, you need to authorize us to collect and use the necessary information. If you refuse to provide the above-mentioned necessary information, you will not be able to normally use our products/services;

1. Information collection

1.1 We receive and store your personal information provided in the use of the Website, products and services.

Personal information refers to any information recorded electronically or otherwise that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information. It includes the following information:

  • 1、
    You need to provide the information used to create an account (mobile phone number, password, nickname) when you register, and we may require you to provide more contact information, including contact address and email address, when you contact us later and continue to use the product/service.
  • 2、
    Device identification information (such as IMEI, Android ID, hardware serial number, MAC address, CPUID) and device connection information when you log in to use the company's AI products.
  • 3、
    Information about your operation, upload, browse, download and access when you use the functions of the company's AI products/services.
  • 4、
    When you upload text, images, audio, video, and other original materials, we will collect the above information and, in accordance with legal requirements, take strict encryption measures during the collection, transmission, and storage of such information to ensure your information security and compliance with our policies. We only provide material processing services and will not extract or identify any information for identification purposes. After the service is completed, the system will delete the aforementioned information. When you upload, create, edit, or publish audio and video (including image and text content services), we may request permission to use your camera, clipboard, photos, microphone, albums, media library, storage (including SD cards), or vibration (for Lego tapping). We will also request permission for device information (including device model, operating system version, device settings, unique device identifier, and personal internet usage records (including browsing history, software usage history, click history, interaction history); if you do not agree or revoke the authorization, you will be unable to use the corresponding functions, but this will not affect your ability to use other functions normally.
  • 5、
    Transaction information generated by you when using paid products/services, including amount, time, order number, payment method and transaction status.
  • 6、
    Face information: When you use our service to create A1 content featuring portraits, we will analyze the original materials you upload, identifying key points (such as vector points of eyes, nose, and mouth) and contours for portrait processing. Throughout this process, we employ secure encryption measures. Unless explicitly stated and with your consent, we will not use your facial pixel information for any other purposes or share it with third parties. To enable you to trace and manage your historical generated content, and to continue using the historical images and videos as materials for future creations, as well as to facilitate cross-platform transmission and interaction of the aforementioned content across all your logged-in devices, we will store the uploaded and generated content (including facial information). Under the premise that the data has been processed with security encryption technology and strictly de-identified to the point where it cannot re-identify specific individuals, we may optimize the data collection and the corresponding content generated by the model to adjust and improve the effectiveness of the optimization model from time to time. If you do not wish us to continue using all or part of the authorized content, you can notify us to revoke the authorization.
  • 7、
    Content browsing and information release: During your browsing of content or posting, we will record your clicks, views, follows, likes, feedback, shares, downloads, and other usage activities. Based on your posts (interactive needs, the AI model system processes the original portrait information you upload voluntarily; this type of information is essential for providing our service. We will strictly encrypt such information during collection, transmission, and storage to ensure your information security. When you share information or receive shared information, we will read the password, link, and other content from the clipboard to facilitate the redirection and sharing of information. Interaction: When you engage in interactive communication, we will collect and publicly display your interaction records and content, including browsing, liking, commenting, following, collecting, forwarding, sharing, and @ing other users. When you share or receive shared content, event information, etc., we need to access your clipboard to read the included passwords, share codes, links, etc., to achieve redirection, sharing, claiming benefits, and event linkage services, helping users open relevant content and enhancing user experience. We only recognize clipboard content locally and upload it to the server only when it is within our instructions. Additionally, we may need to read your photo albums so that you can share or receive shared videos or images.

1.2 Sources and collection of third-party information.

We may collect information about you from public sources (within the limits of the law) and combine it with other information we receive or are associated with from you. If we combine this information with personal information received from you, such information will be considered personal information during the period of combined use.

2. Information use

We may use information that you provide or we collect in connection with your use of the Product/Service in the following product/service related aspects, including:

  • 1、
    Verify identity to meet the requirements of network real-name system in applicable laws and regulations;
  • 2、
    Conduct risk verification to remind users of safety;
  • 3、
    Process and respond to your questions and comments;
  • 4、
    Send you updates and real-time information;
  • 5、
    Improve products and services, and use them to optimize or develop new products and services;
  • 6、
    Provide you with information about selected products and services that may interest you;
  • 7、
    Solicit your information and feedback, including through research and questionnaire;
  • 8、
    Perform business analysis, or other purposes such as improving the quality of our business, website, SDK/API, and services provided;
  • 9、
    Help us effectively manage website content to prevent our products/services from being abused and trace the basis of end-user personal information leakage, and provide software certification or manage software upgrades;
  • 10、
    Use your information to prevent, detect and investigate fraud, security hazards, illegal or violation of our or our affiliates 'agreements, policies or rules, so as to protect you, other users or our and our affiliates' legitimate rights and interests;
  • 11、
    We will keep statistics on the use of products and services. At the same time, we may share this statistical information with the public to show the overall usage trend of our services. This statistical information will not include any identification information about you;
  • 12、
    Others In order to provide you with a better experience, improve our services or for purposes you agree to, we may use the information collected through one service to aggregate information or personalize it for our other services, subject to relevant legal requirements.

3. Information security

3.1 We will only retain your personal information during the period of your use of our products/services and within the time limit required by applicable laws and regulations.

When using our service to release information, you may need to disclose your personal information to others, such as contact details or postal addresses. Please protect your personal information carefully and only provide it to others when necessary. If you discover that your personal information has been leaked, especially if your account and password have been compromised, please contact us immediately so we can take appropriate measures.

If the information you provide contains other users' personal information, you must ensure that you have obtained legal authorization before providing such personal information to us.

We have taken customary security measures to protect the personal information you provide to us. However, no method of transmitting or storing electronic data is completely secure and we cannot guarantee that such information will never be accessed, used or published in a manner inconsistent with this Privacy Policy.

3.2 Authorization and consent of end-user personal information

You understand and agree that, for the purpose of providing identity authentication services to you and/or your end users, we need to collect, store, and use the personal information obtained from your integrated product end users anonymously and in an unidentifiable manner. Therefore, by accepting our Privacy Policy and integrating our SDK into your product, you confirm and warrant:

  • 1、
    You have disclosed and explained to the end user, and have obtained the necessary authorization, consent, and permission from the end user, allowing us to collect, store, process, use, and share the essential personal information of the end user for the full purpose of the product/service. If your product is designed and developed for children under fourteen years old, you should have taken the necessary technical measures to ensure that the authorization, consent, and permission of their guardians have been obtained.
  • 2、
    You have complied with and will continue to comply with applicable laws, regulations, national standards, industry standards, and regulatory requirements, including but not limited to formulating, publishing, and updating policies related to personal information protection and privacy protection. You also commit that during the use of our products/services, the applicable Privacy Policy between you and end users shall not be less stringent than the personal information protection and privacy protection standards agreed upon in the content provided to us.
  • 3、
    You promise that the above authorization, consent and license are legal and valid, and will not conflict with any agreement or document signed by you and a third party or infringe the rights of a third party.
  • 4、
    You have provided the end user with an easy-to-use mechanism for the realization of the rights of the information subject, and you should inform your end user that the exit/cancellation right can be exercised through the terminal device of the integrated product. Once the end user exercises this right, his/her information will not be collected or processed in any form, nor will he/she be frequently asked for consent.

HOW WE USE COOKIE AND SIMILAR TECHNOLOGIES

To ensure smooth operation and provide you with a more enjoyable browsing experience, we may store a small data file named Cookie on your mobile device. Cookie typically includes identifiers, site names, and some numbers and characters. We can only read the Cookie provided by us.

You can manage Cookies according to your preferences, and you can also clear all Cookie saved on your computer. Most web browsers have a feature to block Cookies. However, if you do this, you will need to change your user settings every time you visit our website. For more detailed information on how to change browser settings, please refer to the relevant settings page of the browser you are using.

More information about our use of Cookies can be found in the LoomlyAI Cookie Policy.

HOW WE SHARE, TRANSFER AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

1. Information sharing

Some modules and functions in our products or services will be provided by service providers. For this purpose, we may share certain personal information with partners to offer better customer service and user experience. When collaborating with such partners, we will adhere to the following principles: (1) Legality and Minimization Principle: Data processing should have a legal basis, serve a legitimate purpose, and be limited to the minimum necessary for achieving that purpose; (2) Maximization of User Rights Principle: During data processing, we fully respect users' rights to be informed and to make decisions regarding their personal information; (3) Maximum Security Principle: We will take necessary measures to ensure the security of the personal information we process, carefully evaluate the purposes for which partners use the data, comprehensively assess their security capabilities, and require them to comply with the relevant terms of the cooperation agreement.

2. Information transfer

We will not transfer your personal information to any company, organization or individual other than us, except in the following circumstances:

  • 1、
    Obtain your explicit authorization or consent in advance;
  • 2、
    To meet the requirements of applicable laws and regulations, legal procedures or mandatory government requirements or judicial rulings;
  • 3、
    If we or our affiliates are involved in mergers, spin-offs, liquidations, acquisitions or sales of assets or businesses, your personal information may be transferred as part of such transactions. We will ensure the confidentiality of this information during transfer, inform you of the name or title and contact details of the receiving party, and require that the new entity holding your personal information continue to be bound by our privacy policy. Otherwise, we will require the company or organization to obtain your authorization and consent again.

3. Exceptions to obtaining prior authorization and consent when sharing, transferring or publicly disclosing personal information

In the following cases, we will not obtain your prior authorization and consent to share, transfer or publicly disclose your personal information:

  • 1、
    Necessary for the performance of lawful duties or obligations (for example, statutory obligations directly related to national security, defense security, criminal investigation, prosecution, trial and execution of judgment);
  • 2、
    To establish or exercise our legal rights or defend a legal claim, at the request of an administrative agency, by judicial order or other legal process;
  • 3、
    Information is required to protect or defend the legitimate rights and interests of our company, as well as to respond to public health emergencies or protect the life, health and property safety of natural persons in emergency situations;
  • 4、
    Process your personal information that you have disclosed by yourself or that has been legally disclosed (such as legal news reports, government information disclosure and other channels) within a reasonable scope;
  • 5、
    Necessary for the signing and performance of a contract at the request of the owner or authorized person of personal information;
  • 6、
    Implement news reports and public opinion supervision for the public interest, and process personal information within a reasonable scope;
  • 7、
    As required by law and regulation and/or national standards.

HOW WE KEEP AND PROTECT YOUR PERSONAL INFORMATION

1. Storage period

We will keep your personal information for the period required to provide the product/service, but if there are other provisions in applicable laws and regulations on the retention period, to ensure the quality and safety of the service/product, to achieve the purpose of dispute resolution, or if it is technically difficult to achieve, we will extend the retention period after the expiration of the aforementioned retention period in accordance with the law or contract or within a reasonable scope.

2. Preservation area

Your personal information is stored in our data systems. If we need to provide your personal information to an entity in another country for any reason, we will make every reasonable effort to comply with the provisions of such applicable laws and regulations and ensure the security of your personal information.

3. Safety measures

We will take industry-standard, reasonable and feasible security measures and technical means to store and protect your personal information to prevent unauthorized access, public disclosure, use or tampering with your information. We will use trusted protection mechanisms to ensure the confidentiality of data.

Despite taking reasonable and effective security measures in accordance with applicable laws and regulations, we cannot guarantee one hundred percent information security due to technical limitations and/or potential malicious actors or actions. Please understand that the systems and communication networks we provide may encounter issues due to factors beyond our control. Therefore, we strongly recommend that you take proactive steps to protect your personal information, such as using complex passwords, changing them regularly, and not disclosing your account credentials or related personal information to others.

YOUR RIGHTS

In accordance with applicable laws and regulations, you have the following rights with respect to your personal information:

1. Information query and processing

1.1 You can access, update and modify your personal information by logging in to your account.

1.2 You can request us to delete your personal information through online contact information by customer service in the following circumstances:

  • 1、
    We collect and use your personal information without obtaining your explicit consent;
  • 2、
    The purpose of processing has been achieved, cannot be achieved or is no longer necessary to achieve the purpose of processing;
  • 3、
    Our handling of personal information violates applicable laws and regulations or agreements with you;
  • 4、
    We stop providing the product or service, or the retention period has expired;
  • 5、
    Other circumstances prescribed by applicable laws and administrative regulations.

In such event, we reserve the right to limit or terminate access where such personal information is required to continue your use of our products and/or services.

2. Revocation of authorization

For the personal information we process based on your consent, you can revoke it through the cancellation path provided in your operating system or by sending an email to us via the contact information in this policy to withdraw your authorization. Please note that for certain types of personal information, such as information necessary for the basic functionality of our products or information required to fulfill our legal obligations, we may not be able to respond to your request to change the scope of authorization. Once you withdraw your consent or authorization, we will no longer be able to provide you with the corresponding product/service functions or process your personal information. However, your decision to withdraw consent or authorization will not affect any previous processing of personal information based on your prior consent or authorization.

3. Cancel your account

You can log out at any time through the path provided in the operating system or submit an account cancellation request to us. To protect your and our legitimate rights and interests, we will assess whether to support your cancellation request based on your usage of products and services. If there are outstanding payments for which you have not made, we will not immediately support your request. Cancellation is an irreversible action; once you cancel your account, you will no longer be able to use our services (except for some functions that do not require registration or login). Your account will no longer be accessible, and all information within the product (including but not limited to your personal information, transaction details, etc.) will be deleted. Therefore, please proceed with caution.

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

4. Respond to your request above

In order to ensure security, we may verify your identity (such as adding account verification, requiring you to provide a written request or other reasonable means) before processing your request.

For your reasonable requests, we generally do not charge fees. However, for repeated requests that exceed reasonable limits, we have the right to charge a certain fee at our discretion. For information not directly related to your identity, requests made without reasonable justification, or those requiring excessive technical means (such as developing new systems or fundamentally changing current practices), posing risks to others' legitimate rights and interests, or being impractical, we may refuse them.

Subject to the relevant legal requirements, your close relatives may exercise the above rights of viewing, correcting, deleting and copying your personal information after our identity verification, except if otherwise arranged by you.

PERSONAL INFORMATION OF UNAUTHORIZED MINOR USERS

We only offer this product and related products to adults.

Constrained by current technology and business models, however, it is difficult for us to proactively identify minors' personal information during account registration. If you are the parent or guardian of a minor and discover that we have obtained their personal information without their authorization, you can contact us through the contact methods listed in this policy. Upon receiving your notification, we will promptly verify the situation and, if confirmed, promptly delete or anonymize the relevant information. If we discover such situations through our own proactive review, we will also delete or anonymize the related personal information.

SCOPE OF APPLICATION OF PRIVACY POLICY

Except for certain specific services, this Privacy Policy applies to all of our products/services. Certain specific services will have their own privacy policies. The specific privacy policies for certain services will more specifically detail how we use your information in those services. These specific service privacy policies form part of this Privacy Policy. In the event of any inconsistency between the privacy policy of a particular service and this Privacy Policy, the privacy policy of that specific service shall prevail.

REVISION OF PRIVACY POLICY

To meet the requirements of applicable laws and regulations and to provide you with a better product and service experience, we will adjust this policy at any time based on changes in products and services, applicable laws, and policies. Without your explicit consent, we will not reduce the rights you are entitled to under this privacy policy. After updating this policy, we will issue an updated version and notify you through announcements or other appropriate means so that you can stay informed about the latest version of the policy. Please check and understand the privacy policy you should comply with from time to time. If you do not agree to accept the updated privacy policy, please stop accessing and using our products/services immediately

HOW TO CONTACT US

Our company address is: 3 Fraser Street, #04-23A, DOU Tower, Singapore 189352.

If you have any questions, complaints or suggestions about our Privacy Policy, please contact us at the following Customer Service and Support Center Email: customer@loomlyai.com.

APPENDIX: DEFINITIONS

We: TRENDORA PTE. LTD. (aka 'LoomlyAI').

Personal information: all kinds of information related to identified or identifiable natural persons recorded electronically or otherwise, excluding the information after anonymization.

Sensitive personal information: Sensitive personal information refers to the personal information that is likely to be infringed upon the dignity of a natural person or the safety of his person or property if it is disclosed or illegally used, including biometric identification, religious belief, specific identity, medical health, financial account, whereabouts track, etc., as well as the personal information of minors under the age of 14.

Child or minor: refers to anyone under the age of 18.

Device Information: including hardware model, hardware serial number, software list, application installation list, software installation list, unique device identification code IMEI, device MAC address, SIM card IMSI information, Android ID, MEID, OpenUDID, GUID, IDFA, IDFV, BSSID, GAID, Bluetooth information, broadcast component communication information, ICCID, BSSID, SSID, operator information, sensors (gyroscope, gravity sensor, accelerometer, environmental sensor, optical heart rate sensor), clipboard. Actual collection status is subject to actual conditions.

Log information: includes time, user ID, conversation ID, conversation content, and IP address, browser type, telecom operator, language used, access date and time.

De-identification: The process by which personal information is processed so that it cannot identify a particular natural person without the help of additional information.

Anonymization: refers to the process in which personal information has been processed so that it cannot identify a specific natural person and cannot be restored.

Cookie: Cookie and similar device identification technologies are widely used on the internet. When you use this product, we may use these technologies to send one or more Cookie or anonymous identifiers to your device to collect, identify, and store information about your visits and use of this product.