FocoClipping Privacy Policy

 

Update date:2021-05-26

Effective date:2021-05-26

 

 

    Introduction:

Welcome to use FocoClipping! FocoClipping is a multi-functional AI intelligent picture cutout tool. We attach great importance to your privacy and personal information protection. The personal information we collect, use, manage, share and transfer in this privacy policy includes bold and underlined sensitive personal information as well as other personal information. We hope this policy will help you know the following contents:

. 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 protect your personal information

. How you manage your personal information

. How we handle the personal information of minors

. How your personal information is transferred throughout the world

. Privacy policy modification and notice

. How to contact us

We know the importance of personal information to you and will do our best to protect your personal information security. We are committed to maintaining your trust to us and abiding by the following principles: the principle of integration of power and responsibility, the principle of definite purpose, the principle of choice of consent, the principle of the least information for use, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. We promise to take appropriate security protection measures to protect your personal information according to the mature security standards in the industry. We hope that you will read and confirm that you have fully understood the policy content before using our services. If you register as a user, use or continue to use our products and/or services after we update this privacy policy(we will prompt you the update status in time), it means you agree that this privacy policy and its update contents take effective as a supplemental agreement to the FocoClipping User Service Agreement and agree to authorize us to collect, use, store and share your information in accordance with this privacy policy.

 

   Ⅰ. How we collect and use your personal information

We will collect and use your personal information based on the following purposes:

() User registration and login functions

When you use the FocoClipping platform and services, we recommend that you register a FocoClipping account. In this process, you can complete registration through a third party (Facebook, Google, email) and authorize us or allow third-party channels to provide us with third-party network information, including account number, nickname, avatar, registration date, etc. If you only need browsing and other basic services, you have no need to register a FocoClipping account and provide the above information.

If you need to change your avatar, we will ask for your permission to access your photo album or authorize the camera to take a picture as your avatar.

Ⅱ)Use picture cutout service

1. Local files: In order to upload your cutout pictures into FocoClipping, we need to access your local files. At the same time, this permission can be used to save your cutout pictures in your local files.

2. Upload pictures: We will store your uploaded pictures so that you can use them again. We will ensure that your pictures will be safe and we will not share them with third parties or publish them.

3. Picture cutout record: We will store the final cutout pictures so that you can check them from the picture cutout record. We will ensure that your pictures will be safe and we will not share them with third parties or publish them.

() Purchase products and services

If you apply for FocoClipping membership or purchase products and services provided by FocoClipping (if any), we will generate a purchase order for you through our system, which contains product information or service information you have purchased, amount payable and purchasing date, and we collect these necessary information to help you complete the transaction smoothly, guarantee your transaction safety, and facilitate your inquiry of order information.

() Safe operation

In order to improve the security of using services provided by the FocoClipping platform, protect personal and property safety of you or other users or the public from infringement, better prevent phishing websites, frauds, network faults, computer viruses, network attacks, network intrusion and other security risks, and identify circumstances that violate laws and regulations and relevant FocoClipping agreements more accurately, we may use or integrate your equipment information, log information, etc., to comprehensively determine your account and transaction risks, carry out authentication, detect and prevent security incidents, and take necessary record, audit, analysis and disposal measures in accordance with the law.

 1. Equipment information: We will receive and record your equipment information (such as equipment model, equipment settings, unique equipment identifier and other hardware and software characteristic information), and equipment location information (such as IP address) according to the specific permissions you have granted in the installation and use of the platform.

2. Log information: When you use the products or services provided by FocoClipping, we will automatically collect and save the detailed information of service conditions as network logs, such as your picture upload time, download time, final cutout picture, etc.

Please note that individual equipment information and log information can not identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information will be considered as personal information during the period of combined use.

Ⅴ) Functions necessary to improve our platform and/or services

In order to make the provided services better meet your expectation and requirements, and improve our service quality, we will record the relevant information when you contact our customer service, and answers you send to us when you participate in the questionnaire survey, so that we can give you feedback.

() Service regulations

After we collect your personal information, we will use it in strict accordance with the following regulations:

1. We will use your personal information in strict compliance with laws and regulations as well as this privacy policy.

2. We will use technical means to encrypt, de-identify or anonymize your personal information according to law.

3. When you cancel your account, we will delete or anonymize your personal information.

4. When we need to use your personal information for other purposes not stated in this policy, we will ask for your consent again.

() Exception for information collection without authorization

According to the relevant laws and regulations, your personal information can be collected without your authorization under the following circumstances:

1. Related to national security and national defense security;

2. Related to public security, public health, and major public interests;

3. Related to criminal investigation, prosecution, trial and execution of judgment, etc.;

4. For the purpose of protecting lives, property and other major legitimate rights and interests of personal information agent or other individuals but difficult to obtain your consent;

5. The personal information collected is disclosed by yourself to the public;

6. The personal information collected is disclosed publicly according to law, such as legitimate news reports, government information publicity and other channels;

7. Necessary for signing a contract according to your requirements;

8. Necessary for maintaining the safe and stable operation of products or services provided, such as finding out and handling failure of products or services;

9. Necessary for legitimate news reports;

10. Necessary for academic research institutions to conduct statistical or academic research based on the public interests, and when providing the results of academic research or descriptions, the personal information contained in the results is de-identified;

11. Other conditions stipulated by laws and regulations.

Please understand that the functions and services we provide for you are  updated and developed continuously. If a function or service is not described in the preceding description while your information is collected, we will separately explain the content, scope and purpose of information collection to you through page prompts, interactive processes, announcements, etc., in order to obtain your consent. If we stop the operation of the FocoClipping platform or services, we will stop the activities that continuously collect your personal information in time, notify you by delivery one by one or by announcement, and delete or anonymize the personal information we hold.

Ⅱ. How we use Cookie and similar technologies

In order to guarantee the normal operation of platform, we will store a small data file on your computer or mobile device called Cookie, which usually contains identifiers, website names as well as some numbers and characters. Cookie allows us to store data such as your preferences to help you avoid repeatedly filling in personal information, inputting history search contents and other complex actions. At the same time, we may also use the above-mentioned technologies to recommend, display and push the contents you are interested in. You can manage or delete Cookie according to your preferences, such as clearing all Cookies stored on your computer through your browser settings, but if you do so, you need to change your user settings in person each time you visit FocoClipping, and any corresponding information you have previously recorded will be deleted and may have an impact on the service security.

Ⅲ. How we share, transfer and publicly disclose your personal information

() Share

We will not share your personal information with companies, organizations and individuals other than the FocoClipping platform service providers with the following exceptions:

1. Share under the condition of obtaining explicit consent: We will share your personal information with other parties after obtaining your explicit consent.

2. Share under legal situations: We may share your personal information with other parties in accordance with the provisions of laws and regulations, the need for litigation dispute resolution, or as required by administrative or judicial authorities in accordance with the law.

3. Share with authorized partners:

We may entrust the following authorized partners to provide you with related services or perform functions on our behalf, and we will only share your information for the lawful, legitimate, necessary, specific, and explicit purposes stated in this privacy policy. Authorized partners will only have access to the information they need to perform their duties and shall not use this information for any other purpose.

At present, the types of our authorized partners and authorization purposes are mainly as follows:

(1) Specific functions. When software service providers, intelligent equipment providers or system service providers jointly provides services for you with us, such as authentication service, short message service, etc. In order to realize this function, we may collect your equipment information (e.g. hardware model, operating system version number, International Mobile Equipment Identity (IMEI), MAC address of network equipment) and provide the information for the above-mentioned providers after de-identification.

(2) Advertisement push. We may share information with partners who entrust us to carry out promotion and advertisement putting, but we will not share information for personal identification, such as your name, cell phone number, etc. We will only provide these partners with your user portrait tag and de-identified or anonymized statistical information that is difficult for personal identification, in order to help them improve the effective contact rate of their advertisements without identifying your personal identification.

(3) Product analysis. In order to analyze our services and improve the user experience, we may share statistical data on product service conditions (crash, flash back) with third parties, which is difficult to combine with other information to identify your personal identification.

    () Transfer

We will not transfer your personal information to any company, organization or individual with the following exceptions:

1. We will transfer your personal information to other parties with your explicit consent;

2. In the event of personal information in merger, acquisition or bankruptcy liquidation, we will ask the new company or organization holding your personal information to continue to be restricted by this privacy policy. Otherwise, we will request this company or organization to seek your consent again.

Ⅲ)Public disclosure

We will only disclose your personal information publicly under the following circumstances:

1. After obtaining your explicit consent;

2. Disclosure based on the law: We may publicly disclose your personal information under the mandatory requirements by laws, legal procedures, litigation or responsible government departments.  

() Exceptions for sharing, transferring, and publicly disclosing personal information with prior consent

Under the following circumstances, we may share, transfer and publicly disclose your personal information without obtaining your prior consent:

1. Related to national security and national defense security;

2. Related to public security, public health, and major public interests;

3. Related to criminal investigation, prosecution, trial, execution of judgement and other judicial or administrative law enforcement;

4. For the purpose of protecting lives, property and other major legitimate rights and interests of personal information agent or other individuals but difficult to obtain your consent;

5. The personal information collected is disclosed by yourself to the public;

6. The personal information collected is disclosed publicly according to law, such as legitimate news reports, government information publicity and other channels;

Ⅳ. How we protect your personal information

1. We have used security protection measures that meet the industry standard to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, we provide HTTPS protocol for safe browsing of the FocoClipping platform. We will use encryption techniques to ensure the confidentiality of data, and use trusted protection mechanism to prevent malicious attacks on data. We will deploy access control mechanism to ensure that only authorized personnel have access to personal information, and organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

2. We will take reasonable and feasible measures to avoid collecting irrelevant personal information, and will retain your personal information only during the period necessary to achieve the purposes described in this policy or during the statutory period, unless the extension of retention period is required or permitted by law.

3. We only allow employees and partners who are necessary for knowing such information to access personal information, and have set up strict access control, permission approval process and monitoring mechanism for this purpose. We also require all personnel who may have access to your personal information to fulfill the corresponding confidentiality obligations. If a third party fails to perform its confidentiality obligations, we may investigate and affix legal liability and terminate our cooperation.

4. The Internet is not an absolutely secure environment, and e-mail, instant messaging, and communication modes with other users are not encrypted. We strongly recommend that you do not send personal information through such modes. Please use complex password to help us ensure your account security.

5. After the occurrence of personal information security incident, we will inform you in accordance with the provisions of laws and regulations: the basic situation of security incident and the possible influence, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will inform you by email, letter, telephone, push notification, etc. When it is difficult to inform the personal information agent one by one, we will take a reasonable and effective way to make an announcement. At the same time, we will also report the handling condition of personal information security incident in accordance with the requirements of supervision department.

Ⅴ. How you manage your personal information

We attach great importance to the management of your personal information and protect your rights to access, correct, withdraw and delete your personal information. Your rights include:

() Access, modify and correct your personal information

You may access, modify and correct your registration information and other personal information provided in the process of using the FocoClipping platform and its services. If you find that the data collected by us is incomplete or incorrect, you may inform us to correct it. If you can not to do so or have any questions, you may contact us to find a solution.

() Delete your personal information

You can request us to delete personal information in the following conditions:

1. We handle personal information in violation of laws and regulations; 

2. We collect and use your personal information without your consent; 

3. Our processing of personal information violates the agreement with you;

4. You cancel your FocoClipping account;

5. We terminate our services and stop the operation.

If we decide to respond to your request for deletion, we will also notify the third parties from whom we have obtained your personal information at the same time, and require them to delete it in time, unless otherwise provided for by laws and regulations or unless these third parties have been authorized by you. When you delete information from our services, we may not immediately delete the corresponding information in our backup system, but will delete it during backup update.

() The scope of withdrawing your consent

Each business function requires some basic personal information to be completed. In addition, if you hope to withdraw your consent to our additional collection, use and disclosure of personal information, you may withdraw your consent by contacting us.

When you withdraw your consent, we will no longer deal with the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information that is carried out on the basis of your previous authorization.

If you do not want to receive commercial advertisements from us, you can unsubscribe commercial advertisements by SMS prompt or other means provided by us.

() Transfer and carry your personal information

Under the circumstance of automatic processing and technical operability, you may request us to provide structured, general and machine-readable personal data information and transfer the information obtained to other data controllers. You shall keep the data transferred and carried by you properly and prudently.

() Object to processing your personal data

You have the right to object to processing your personal data for direct marketing purposes and other special circumstances, such as religion, race, etc. We will not process the corresponding personal data after receiving your notification.

    () Cancel an account

You can cancel your FocoClipping account at any time as per your choice. You can request to cancel your account directly from our products or contact us to assist you in canceling your account. After you cancel your account, we will stop providing you with products or services and, we will delete your personal information at your request, except as otherwise provided by laws and regulations.

() Other rights

Your country may grant you specific rights to process personal information other than those mentioned above, and you may contact us if you intend to make a legal request regarding your personal information.

() Respond to your above requests

In order to ensure security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

In principle, we do not charge fees for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits as appropriate. We may refuse requests that are repetitive for no reason, require excessive technical means (for example, a new system needs to be developed or current conventions need to be changed fundamentally), bring a risk to the legitimate interests of others, or are extremely impractical.

In the following conditions, we can not respond to your request in accordance with the requirements of laws and regulations:

1. Related to the performance of the obligations of personal information controller as required by laws and regulations;

2. Directly related to national security and national defense security;

3. Directly related to public security, public health and major public interests;

4. Directly related to criminal investigation, prosecution, trial and execution of judgment;

5. The personal information controller has sufficient evidence to show that the personal information agent has subjective malice or abuses his rights;

6. For the purpose of protecting lives, property and other major legitimate rights and interests of personal information agent or other individuals but difficult to obtain your consent;

7. Response to the request of personal information agent will lead to serious damage to the legitimate rights and interests of personal information agent or other individuals or organizations;

8. Involving commercial secrets.

Ⅵ. How we handle the personal information of minors

FocoClipping will not deliberately collect or request for personal information of minors under 18 years old, and the service and its content are not aimed at children under 18 years old. Minors are not permitted to create their own user accounts without the consent of their parents or guardians. If you are a minor, we recommend that you ask your parents or guardians to read this privacy policy carefully and use our services or provide us with information with the consent of your parents or guardians.

If we learn that we have collected information of minors without the consent of their parents or guardians, we will delete such information as soon as possible. In case of collecting personal information of minors to use our products or services with the consent of their parents or guardians, we will only use, share, transfer or disclose such information as permitted by laws or regulations, with the explicit consent of their parents or guardians, or as necessary to protect minors.

. How your personal information is transferred throughout the world

Because we provide our products or services through resources and servers around the world, this means that your personal information may be transferred to the overseas jurisdictions of the country where you use the product or service or accessed from these jurisdictions with your consent.

Such jurisdictions may have different data protection laws, or even have no such laws. In such cases, we will ensure that your personal information will be protected to the same extent as it is in your country. For example, we may ask for your consent to transfer personal information across borders or implement security measures such as data de-identification prior to cross-border data transfer.

For users in the European Economic Area, we will transfer your information to third party providers outside the European Economic Area. We will require these third parties to sign standard contracts and provide appropriate protective measures for your information. We may seek your consent to transfer your information to a third country outside the European Economic Area from time to time.

Ⅷ. Privacy policy modification and notice

() In order to provide better services for you, FocoClipping and related services may be updated and changed from time to time, and we may modify this privacy policy in time. Such modifications will constitute a part of this privacy policy and have the same effect as this privacy policy. However, we will not reduce your rights under this privacy policy without your explicit consent. 

() When this privacy policy is updated, we will issue an updated version in the FocoClipping mobile client and remind you of the updated contents by notice, announcement, and other appropriate means before the updated terms take effect so that you will know the latest version of this privacy policy in time. If you continue to use our services, it means that you agree to accept the modified policy contents. However, if the updated content requires to collect new sensitive personal information, we will still ask for your permission again by explicit means.

() For major changes, we will also provide more prominent notices (for some services, we will send a notice by email to explain specific changes to our privacy policy)

1. Major changes to our service model. For example, the purpose of processing personal information, the type of personal information handled, the way personal information is used, etc.;

2. Major changes to our ownership structure, organizational structure, etc., such as change of owners caused by business adjustment, bankruptcy merger, etc.;

3. Changes to the main object of sharing, transfer or public disclosure of personal information;

4. Major changes to your rights to participate in the processing of personal information and the mode of exertion;

5. There is a change in the department responsible for handling personal information security, contact information and complaint channel;

6. When the personal information security impact assessment report indicates that there is a high risk, we will also keep an older version of this policy on file for your reference.  

Ⅸ. How to contact us

() If you have any questions, comments or suggestions about this policy or your use of our services, you can send an email to support@Fococlipping.com to contact us;

() We will review the issues involved as soon as possible and deal with them in time after verifying your identity. These issues will be replied within no more than 14 days or within the specified period set by laws or regulations.