Privacy Policy -Pose AI

To fulfill our commitment to respecting and protecting your privacy, we will adhere to our basic principles as explained in detail below, and crafted this Privacy Policy in accordance with these basic principles:

• We inform you of the personal information that will be collected, and seek your consent to collect, use, or disclose your personal information.

• We identify the purposes of use for collecting your personal information.

• We collect only information that is necessary to carry out the identified purposes of use.

• We use or disclose your personal information only for the purposes for which it is collected, except with your consent or as required or permitted by law, and we will keep your information only as long as necessary to fulfill those purposes.

• We endeavor to make sure that your personal information is accurate, complete, and up-to-date.

• We protect your personal information via appropriate security safeguards.

• We make our policies and practices for the handling of your personal information as transparent as possible.

• You will have access to your personal information and will be able to correct your personal information as appropriate.

• We will be accountable to you. We are always interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy, and applicable law. Introduction

Welcome to Pose AI (the “App”). Pose AI is an online face swap application that uses artificial intelligence algorithms to generate a unique content (“Services”). We are committed to protecting and respecting your privacy. We take your privacy seriously and we will collect, process and use your personal information to provide the services only after obtaining your consent. By downloading, using, accessing this App, you agree to this privacy policy which explains when, where, how and why we collect personal information about you, how we use the information, the conditions under which we may disclose it to others, your rights in respect of your personal information, as well as how we keep it secure.

Face Data Policy

What face data is our app collecting?

We analyze users' photos and find out the feature points (like eyes, nose, mouth points) of the face in photo for face processing purpose. We do not collect face data. After the analyzing process ends all data will be deleted, no data will be saved.

For what purposes are we collecting this information?

In order to provide users their "Change face" effects, the app needs to find out the feature points (like eyes, nose, mouth points). The complete process is:

(1) You transfer pictures to our server.

(2) The server analyzes your photo and returns the result of facial data processing.

(3) The application automatically synthesizes the facial data processing results and materials into the final effect.

(4) This information is temporarily stored in Google Cloud's encrypted storage. After the synthesis process is completed, your pictures will be automatically deleted immediately.

Will the data be shared with any third parties? Where will this information be stored?

The data will not be shared with any third parties. The photos you uploaded will be deleted after the analyzing process ends.

Welcome to Pose AI Privacy Policy. (Pose AI, “we”, “us” or “our”). Thank you for taking the time to read it.

• (1) We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

• (2) This Privacy Policy applies beginning May 25, 2018. The previous version of this Privacy Policy, will apply until then.

• (3) EFFECTIVE DATE: May 25, 2018

1. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by Pose AI. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services. Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.

2. INFORMATION WE COLLECT

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

1) Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

• Other Users

Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

• Other Partners

We may receive info about you from our partners, for instance where Pose AI ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

2) Information collected when you use our services

When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

• Usage Information

We collect information about your activity on our services, for instance how you use them (e.g. date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

• Camera and Photos.

Many of our services require us to collect images and other information from your device’s camera and photos. We’ll access your camera and photos only after you give us your consent.

• Device Information.

We collect information about your device, including the hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), browser type and language, mobile device phone number, and mobile network information. We also collect certain device information that will help us diagnose problems in the (hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we detect a crash or other problematic event, we may collect the list of apps on your device and other information about your device’s performance at the time of the event for troubleshooting purposes.

• Read the Contents of SD Card

Read, Modify or delete the contents of your SD card as your instructions. We use this permission so that you can save new pictures to your SD card.

3. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

Like most online services, we use cookies, web beacons, and other technologies. Cookies are small data files stored on your hard drive or in device memory that store information about your use of the Services, which authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features. Web beacons are small pieces of software on a webpage or email that help us see how you interact with that webpage or email. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services.

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual User.

And we use third-party advertising agencies to place advertisements on the Internet or in other media. To measure the effectiveness of the advertisements and determine how much to pay to the advertising agencies, we install third-party modules within the App. We may also install third-party modules within the App in order to help us understand how the Service is used. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Pose AI, do not currently respond to DNT signals.

4. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

1) To administer your account and provide our services to you

• Create and manage your account

• Provide you with customer support and respond to your requests

• Complete your transactions

• Communicate with you about our services, including order management and billing

2) To ensure a consistent experience across your devices

• Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

3) To help you connect with other users

• Analyze your profile and that of other users to recommend meaningful connections

• Show users’ profiles to one another

4) To provide new Pose AI services to you

• Register you and display your profile on new Pose AI features and apps

• Administer your account on these new features and apps

5) To serve you relevant offers and ads

• Administer sweepstakes, contests, discounts or other offers

• Develop, display and track content and advertising tailored to your interests on our services and other sites

• Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

6) To improve our services and develop new ones

• Administer focus groups and surveys

• Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)

• Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

7) To ensure legal compliance

• Comply with legal requirements

• Assist law enforcement

• Enforce or exercise our rights, for example our Terms

8) To prevent, detect and fight fraud or other illegal or unauthorized activities

• Address ongoing or alleged misbehavior on and off-platform

• Perform data analysis to better understand and design countermeasures against these activities

• Retain data related to fraudulent activities to prevent against recurrences

9) To process your information as described above, we rely on the following legal base

• Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us.

• Legitimate interests: We may use your information where we have legitimate interests to do so.

• Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the email provided at the end of this Privacy Policy.

5. HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, in some cases, legal authorities. Read on for more details about how your information is shared with others.

1) With other users

• You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

• If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

2) With our service providers and partners

• We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

• We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

• We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

3) With other Pose AI businesses

• Pose AI is part of the Pose AI family of businesses which, as of the date of this Privacy Policy, includes websites and apps.

• We share your information with other Pose AI businesses for them to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other Pose AI businesses may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.

• We may also share information with other Pose AI businesses for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user information with other Pose AI businesses to remove users who violate our terms of service, or have been reported for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms.

4) When required by law

• We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

5) For corporate transactions

• We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

6) To enforce legal rights

• We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

7) With your consent or at your request

• We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

• We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.

• We may also share this information with other Pose AI businesses and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.

6. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 4 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA.

7. YOUR RIGHTS

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us - or our data protection officer - using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

8. HOW LONG WE RETAIN YOUR INFORMATION Where we process registration data, we do this for as long as you are an active user of our sites and for 12 months after this. Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future. Where we process personal data in connection with performing a contract, we keep the transactional data for six years from your last interaction with us (or such longer period as may be required by law). Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

9. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

10. CHILDREN’S PRIVACY

If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian (collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also recommend minors to obtain guardians’ prior consent and guidance before submitting personal information in your use of our services. Pose AI respects the privacy of children under the terms of COPPA. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us via [email protected] .

11. Refund Policy

Before contacting Pose AI to request a refund at [email protected] you may need to check whether your order is eligible for a refund. The following products are not eligible for return.

- The purchase has exceeded 7 days from the initial payment date.

- The product suggestion can’t be met.

- An unauthorized payment was made due to credit card fraud or other reasons. Pose AI recommends you contact the card issuer if there is any suspicion of fraud or unauthorized payment. As Pose AI cooperates with an independent payment platform, it's impossible to monitor authorization during payment.

- Purchase of a wrong product, which has already been followed by the purchase of the correct product from another company.

- Pose AI price differences between different regions.

- A 'change of mind' after purchase.

- A refund request for the renewal order with personal reasons like "I don't know it was renewed" or "I don't need it anymore". A notification email would be sent to you 14 and 7 days ahead of the deduction date. The auto subscription can be canceled at anytime before the deduction time.

- A refund request due to technical issue, with the customer refusing to cooperate with the Pose AI Support Team in attempts at troubleshooting by declining to provide detailed descriptions and information regarding the problem, or refusing to try to apply the solutions provided by the Pose AI Support Team.

- Products purchased from individuals, resellers, or online auction sites (such as eBay, Amazon Marketplace)

12. PRIVACY POLICY CHANGES

Pose AI may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Pose AI or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification. By using our services, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

13. Cancel Subscription

Tap your subscription in the app's settings. You will be redirected to your Google Play subscriptions. Find Reface subscription and cancel it. You can find more info on subscription cancellation onGoogle's support page: https://support.google.com

If it’s less than 48 hours since you bought an app or made an in-app purchase, you can request a refund. This does not apply to annual subscriptions with 3-day trial period.

1. On your device, go to https://play.google.com/store/account

2. Click Order History.

3. Find the order you want to return.

4. Select Request a refund or Report a problem and choose the option that describes your situation.

5. Complete the form and note that you'd like a refund.

6. You'll get a message that says "Thank you for sharing your concerns." You'll then get an email with your refund decision.You’ll usually get this within 15 minutes but it can take up to 4 business days.

Visit this link for additional information: https://support.google.com If Google refuses to make a refund within 48 hours, contact usand send us your Order number, we will consider it.

14. HOW TO CONTACT US

If you have questions about this Privacy Policy, here’s how you can reach us: Email: [email protected] . Third Part Policy check list：

Advertisement platform

• Admob https://www.google.co.uk/about/company/consenthelpstaging.html

• Facebook https://www.facebook.com/about/privacy/update

Analytics platform

• Google Analytics https://www.google.com/analytics/terms/us.html/

• Firebase https://firebase.google.com/terms/