Privacy
Policy
Date of Issue: 2/16/2022
Effective Date: 2/16/2022
Welcome
to use the application that is developed by Xiao Dou Studio. (“us” or the “Company”) and can be downloaded from the app
store or pre-installed on third-party mobile devices (the “Product”), as
well as related services (Collectively, the “Product and Services”). The Privacy Policy (the “Policy”) represents
our commitment to protecting your privacy, and we will strictly comply with and
implement the Policy. We hope our efforts can reassure you and let you feel
safe when using our Product and Services.
The
Policy will help you understand:
I.
How will we collect and use your personal information
II. How will we store your personal information
III. How will we share, transfer and disclose your
personal information
IV. How will we protect your personal information
V. Your right to manage your personal information
VI. Protection of minors’ personal information
VII. Application scope of the Policy
VIII.
Change and modification of the Policy
IX. How to contact us
Please
carefully read and comprehend the Policy before using our Product and Services,
and do not use our Product or Services until you fully understand and agree to
the Policy. Your use of our Product and Services means you fully understand and
agree to the Policy, and allow us to collect, use, store and share your
personal information according to the Policy. If you have any problem, advice
or suggestion about the Policy, please get in touch with us at the contact
information provided in the Policy.
I.
How
will we collect and use your personal information
You
may need to provide your personal information when you use our Product or
Services. You don’t have to provide your personal information to us. However,
in some cases, your refusal to provide personal information will make us unable
to provide Product or Services to you, or unable to respond to or solve your
problem.
We
will only collect and use your personal information for purposes described
herein, which are as follows:
(1)The
information that we will collect in your process of using our Product or
Services:
1 Information
arising from your use of application: In order to provide you with application
updates and related services and bring you a better interactive experience, we
will collect information such as application version information, application
distribution channel information, system version and device model.
2 Information
in your feedbacks: your feedback is very important to the improvement of our
Services. To process your feedbacks, we may use your personal information to
contact you, and keep related records to solve your problems and improve our
Services.
(2)Non-personal
information
Subject
to applicable laws and regulations, we may anonymize, summarize, desensitize
and encrypt your personal information so as to generate statistics or user
profile (such user profile cannot be used to identify any individual,
hereinafter referred to as “Non-Personally Identifiable Information”), in a bid
to improve our Services provided to you.
(3)Personal
information that can be collected without your approval:
Without
your prior approval, we will not use the information collected hereunder for
any purpose undescribed herein or purpose different from what such information
is originally intended for. However, subject to applicable laws and
regulations, we may collect your personal information without your
authorization or approval in any of the following cases:
1 Collecting
information related to national defense or national security;
2 Collecting
information related to public security, public health or material public
interests;
3 Collecting
information related to criminal investigation, prosecution, trial and
enforcement of judgements;
4 We
need to collect information for the purpose of protecting lives, properties and
other major legitimate interests of personal information subjects or other
individuals, and it’s difficult to obtain your approval;
5 Collecting
information that is already disclosed to public by you;
6 Collecting
information from legal and open sources, such as legal media report, government
information and other channels;
7 Collecting
information required to sign contracts upon your request;
8 Collecting
information required to ensure the safe and stable operation of the Product or
Services, such as detecting and removing any failures in our Product or
Services;
9 Collecting
information required by legal media report;
10 Personal
information is collected by academic institutions to conduct statistical or
academic research projects that can enhance public interests, and the personal
information contained in results of such research projects is de-identified
when being disclosed for academic research or for describing such results; or
11 We
are required to do so by applicable laws and regulations in other cases.
(4)Access
Related Authority of your Device
Our
app may access the mobile network permission on your device for material and
file download, server query interaction; mobile phone storage permission is
used to store your pictures and videos or edit your pictures in the app
Pictures and videos; the recording function is turned on so that you can
synchronously record the corresponding audio during the video recording
process; the camera permission is the basic function of this application, used
to take photos or videos; the bright screen permission is used when the AI
video processing It takes a long time to process to avoid errors caused by
the screen off; the installation package permission is used to send a request
to jump to the system installer to upgrade the application when the application
is updated.
You
understand and know that this app is an app that provides camera services.
Except for camera permissions and storage permissions, if you refuse to enable
other permissions, it will not affect your use of the basic functions of this
application. If you want us to stop obtaining your aforementioned permissions,
you can close the relevant permissions through the system settings (system
settings-application management-permission management). In addition, the screen
off and installation package permissions cannot be closed due to system
problems. Please also be aware.
II.
How
will we store your personal information
The
information collected and generated in People’s Republic of China (PRC) is
stored within PRC.
We
may transmit domestically-collected personal information to overseas
institutions in the process of providing cross-border services, and such
transmission shall comply with all applicable laws, administrative rules and
related regulatory requirements. We ensure your personal information is well protected
via measures such as anonymization, encryption, among others.
We
only store your personal information within the period required by law and
necessary for fulfilling purposes described herein.
If
we cease operating our Product or Services, we will immediately stop all
activities of collecting your personal information, inform you of such stop on
a case by case basis or via a public notice, and delete or anonymize all the
stored personal information.
III.
How
will we share, transfer and disclose your personal information
(1)Sharing
We
do not share your personal information with any company, organization or
individual except:
1 We
may share your personal information with others after obtaining your explicit
approval;
2 We
may share your personal information to comply with applicable laws and
regulations, to settle a lawsuit or dispute, or to fulfill requirements set
forth by administrative or judiciary authorities;
3 Subject
to applicable laws and regulations, we may share your personal information to
protect the interests or properties, or ensure the safety of you, us, our
affiliates or partners, other users, or the public.
4 We
may disclose your personal information to our affiliates who provide services
to you or us, but such disclosure shall be on need-to-know basis, and our
affiliates receiving your personal information agree to be bound by the Policy.
Our affiliates will never change the purposes of your personal information
without your authorization and approval.
5 Unless
explicitly authorized or permitted by you, we will never share your personal
information with any third-party advertisers, program developers, open platform
or other partners. However, we may provide them with summarized and anonymized
information or other information that is not personally identifiable. For
instance, we may tell program developers how many people have installed their
programs.
6 We
may share your personal information with our suppliers, service vendors,
advisors or agents only for the purpose of the Policy, so as to improve our
customer services and user experiences. Such suppliers, service vendors,
advisors or agents may be providing technological infrastructure to us,
analyzing the ways our services are used, measuring the efficiency in
advertising and services, providing customer services or payment services,
conducting academic researches and investigations, or acting as legal,
financial and technological advisors.
7 We
will enter into stringent data protection agreement with companies,
organizations and individuals that we share your personal information with.
Such agreement will oblige the recipient of your personal information to
process your information pursuant to our requirements, the Policy and other
applicable confidentiality and security rules.
(2)Transfer
We
do not transfer your personal information to any other company, organization or
individual except:
(a) In the course of our business
development, we and our affiliates may undergo merger, acquisition, asset
transfer or other similar transactions that involve transfer of your personal
information, where we will require the company, organization and individuals
receiving your personal information to be bound by the Policy or regain your
authorization and approval for use of your personal information, or
(b) Information transfer is made with your
explicit approval, which means we will transfer your personal information to
another party with your explicit approval.
(3)Disclosure
We
only disclose your personal information to public when:
1
We have obtained your
explicit approval;
2
We are required to do
so by applicable laws, legal proceedings, litigation process or competent
government authorities; or
3 We
are required to do so by applicable laws and regulations in other cases.
IV.
How
will we protect your personal information
We
have adopted safety measures that are commonly used in the industry to protect
your personal information and prevent related data from any unauthorized
access, disclosure, use, change, damage or loss. We will take all reasonable
and feasible measures to protect your personal information.
1 We
encrypt personally identifiable information in the process of transmitting and
storing so as to ensure its confidentiality.
2 If
our applications use WebView technology, we may verify URL for all file
protocols that are used in WebView, and restrict access to sensitive data and
SDCard data of such applications, so as to avoid any unpermitted use or steal
of private files or sensitive information of our product, and thereby prevent
leakage of any of your personal information.
3 We
put in place an access control mechanism in the service side, and apply
principle of least privilege to employees who may have access to your personal
information. In addition, the list of such employees and their access record
are examined regularly.
4 We
store users’ personal information in server operating system with reinforced
security. We also audit and monitor accounts in server operation. If any
external announcement reveals any security issue in any server operating
system, we will upgrade the system security at our earliest opportunity so as
to ensure security of all our server systems and applications.
5 We
regularly train our employees to know more about laws and regulations
applicable to personal information protection, and thereby increase their
awareness of protecting users’ privacy.
6 If
any of our physical, technological or administrative security measures is
disrupted, we may use contingency plans to keep the security incident under
control, and report such incident to competent government authorities according
to applicable laws and regulations. In addition, we may timely inform you of
such security incident, its impact and the measures we have taken and will take
via push notification, public notice or any other reasonable and effective
manners.
V.
Your
right to manage your personal information
You
may revoke your consent to the collection or use of your personal information
by disabling related services in system setting. You can enable or disable
certain features or accesses through authority management in system setting.
Some
basic personal information is necessary in order to provide the services
requested by you. Therefore, please bear in mind that revoking your consent or
authorization can make us unable to provide services that require such consent
or authorization, and we do not process related personal information without
such consent or authorization. Nevertheless, your revoking of such consent or
authorization shall not impact the prior processing of personal information
that is already authorized by you.
VI.
Protection
of minors’ personal information
Minors must be accompanied by their guardians during
the use of our Product and Services, and the guardians shall read the Policy in
such minors’ best interest. Minor users shall seek guidance and approval of
their guardians before submitting personal information. If you are a guardian
of a minor user, and you have any question about personal information of such
minor user, you may get in touch with us at the contacts specified in Article 9
of the Policy.
VII. Application scope of
the Policy
(1)The
Policy is not applicable to third-party products or services contained in our
Product. Providers of such third-party products or services (the “Third-Party
Providers”) may collect your information when you use such products or
services. Therefore, we remind you to read the privacy policies of the
Third-Party Providers.
(2)The
Policy is not applicable to the data collection of external websites after you
click certain hyperlinks.
VIII.
Change
and modification of the Policy
Our
privacy policy may change. We do not restrict your rights under the Policy
without your explicit approval.
We
will notify you of any major changes in the Policy in a highly noticeable way
(for instance, when you re-login or when a software is revised or upgraded, we
may show a popup).
The
aforementioned major changes described in the Policy include, without
limitation:
u Any
major change in our service mode, including the purpose of processing personal
information, the types of processed personal information and the ways of using
personal information, among others.
u Any
major change in our control, such as owner change caused by merger &
acquisition or restructuring;
u Any
change in the persons or entities that we share personal information with, or
transfer or disclose personal information to;
u Any
major change in your rights regarding personal information processing and ways
to exercise such rights;
u Any
change in our department responsible for safeguarding personal information, our
contact information or complaint channels; or
u High
risks specified in personal information risk assessment reports.
IX.
How
to contact us
If
you have any question, advice, suggestion or complaint regarding the Policy or
the processing of your personal information, please use the email name posted
in the app (search path is "application-settings-bottom text"),
please send an email to [ Doulv888@gamil.com ] .
Normally,
we will reply to you within 15 workdays.