Your privacy is important to us.
When you use our Services, we might recommend you sign up for an account with us to take full
advantage of our Services and all their features. When you create an account, we will collect the following
information that can be used to identify you or provide our Services to you:
• Mandatory: device ID
• Optional: name, username, gender, date of birth, and location
Anyone can access our Services, but there are certain services that require a subscription fee, such as accessing to our premium content and enjoying advertisement privileges (“Subscription Service”). If you choose to make a purchase on our Subscription Service, we will collect certain personally identifiable information, such as your device ID. A third-party app store or payment processor may receive, access or use your financial information and billing address for the purpose of processing transactions and renewals. If you purchase content or sign up for Subscription Services through a third-party app store or a payment processor, you should refer to that third party’s terms for information on how it maintains and uses personal financial information for all purchases. For the avoidance of doubt, we will not collect any financial information from you.
When you use our Services on your mobile device, we will collect information about your device, including its International Mobile Equipment Identity (“IMEI”), Unique Device Identifier (“UDID”) or Android ID, Universally Unique Identifier (“GUUID”), User ID (“UID”), Identifier for Advertising (“IDFA”) and Identifier for Vendor (“IDFV”), Open Anonymous Device Identifier (“OAID”) Integrated Circuit Card Identifier (“ICCID”), Media Access Control (“MAC”) address, the type of device you use, device platform, device manufacturer, device brand, device model, operating system version, a list of mobile applications installed on your device and resolution, which will be used by us for statistical and/or analytical reasons, including without limitation to improve our technical functionality, server load-balancing, analysis of technical data relating to your mobile device so as to optimize our Services and graphics adaptation.
As stated below in the “Location Information” section, we may collect your location-based information from your mobile device if you choose to share it with us. If you subsequently wish to stop sharing Location Information, you may do so at any time by editing the relevant setting on your mobile device.
We use mobile analytics software to allow us to better understand and improve the functionality of our Services. Such software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
When you use our Services, we will collect information about the network you use, including the name of the operator and the type of network, so as to understand the distribution of operators and networks used by our users. In addition, we will collect information such as the name of the WiFi network to which you connect, the location of the WiFi network, and the duration of your WiFi connection to understand the environment under which you prefer to use our Services.
We may collect your location-based information from your mobile device if you choose to share
it with us.
• Mandatory: network information, IP address, and system time zone
• Optional: country code, latitude and longitude, network location, and system country
This information will help us understand user distribution and usage scenarios and allow us to provide users with the correct version of our apps, the reappearance of the geo-location or the publishing of the real-time geo-location where you take any photos or shoot any videos, and improve our Services. Unless we obtain your consent, location data WILL NOT BE ACQUIRED or USED to identify you individually. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device. Please note that we may still continue to receive some Location Information, such as your Network Information, IP address and system time zone, as a result of you using our Services.
When you use some of our Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in SnapPass (“Log Information”). Log Information may include (i) details on when and how often you use our Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve our Services and is NOT USED to identify our users individually.
By choosing to use the cloud editing feature of our Services, you understand and agree that we must upload your photos to our server for processing before returning processed photos to you for the purposes of providing such service to you and continuous optimization and that we will also receive the EXIF data about your photos (EXIF data may contain GPS coordinates where photos were taken and processed, equipment type, ISO and information about the front and rear cameras and creation time, depending on the equipment manufacturer) for the purpose of further optimizing our Services, such as providing a better match of photo effects to your equipment. By allowing access to photos on your device by us, you agree that we may access, collect and/or use your photos for photo editing.
Metadata refers to technical data associated with user content. Put simply, metadata is data that describes data. For example, metadata can describe the analysis results of facial features, gender, age of the characters in photos and other elements contained in photos, which are generated and tagged by the computer algorithm and artificial intelligence. When you use our Services, we will use photo metadata to provide you with certain features including precise “Facial Recognition”, “Key-Points Recognition”, “Region Segmentation”, “Content Tags” and other custom features based on a combination of these basic features. We may use your photo metadata to provide you with more suitable filters and better photo effect when our apps process your photos; we may also make use of the metadata to serve up a more contextually relevant products or services to you.
In order to provide certain Services, apart from utilizing metadata as mentioned above, we may collect your facial feature information (including but not limited to facial images) and use face recognition technology to recognize faces in photos and camera experiences. We may detect and use facial marks to provide face recognition contents and facial manipulation features. Our Services may utilize calculation results of certain AR technologies in relation to depth of facial mapping information, which may require to use your facial recognition features in order to ensure the face image processing effect and perform feature analysis using the algorithm. The information we collect will not be used for identifying a specific person, and is used to provide the mentioned features only. When the content recommendation is finished or upon the closing of the application, the facial mapping information is discarded. This information is not shared with any third parties.
We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.
We use “cookies” that store and retrieve information of user’s usage from time to time to
provide customized Services for each user. Cookies are small amounts of information that the server uses to
operate the app/website, sends to the user’s device and are also stored on the hard disk in the user’s device. You
may refuse the installation of cookies. Information collected may include information about your Internet
Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating
system, dates and timestamps, and clickstream data.
• Purpose of use of cookies: Cookies are used to provide information optimized for each user by identifying the
visit to and use type of each service and website that the user has visited, popular search terms, secure access
status, etc.
• Installation, operation and refusal of cookies: A user may refuse the installation of cookies by sending an email
to snappass@starii.com (please quote “SnapPass” in your email title).
• If a user refuses to store cookies, he or she may experience difficulties in using customized Services.
We and our third-party service providers may include advertisements within our Services, and with your consent, we may collect and use information about you such as your Advertising ID, geographic location and IP address for the purpose of delivering and tracking these advertisements. If your device does not have Advertising ID, we may use other persistent identifiers. We may also access your App list and collect the application package names of the applications installed on your device. We use the above information to help us better count, track and provide advertisements based on suitability, language, geographic location and other details. If you wish to opt out of interest-based advertising, you may opt out by sending email to snappass@starii.com . Please note you will continue to receive generic ads after you opt out of interest-based advertising.
Our Services provided to you may contain our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which may have tracking tools of such service providers. These third parties may use cookies, APIs and SDKs on our Services and collect and analyze user information. In addition, some third-party SDKs may allow advertisers to collect information in order to provide content that is more relevant to you. Third parties may access your information such as your device identifiers, region (defined as the location where a given language is used), location information and IP address under their respective privacy policies. If you want to know more about such third parties, you may send an email to snappass@starii.com (please quote “SnapPass” in your email title).
When you contact us (including but not limited to our customer support team and Data Protection Officer), we collect the data you provide to us, for example, your contact details (e.g. email address and/or telephone number).
We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you.
In addition to the uses listed above, we collect and use your user information and personal information for the following purposes:
(i) Services. To provide, process, maintain, improve and develop our Services provided
to
you, including customer support, and other services provided through our products.
(ii) Statistical analysis. To develop and analyze statistics on the use of our products
and
Services for the purpose of improving our products and our Services.
(iii) To create an account. The personal information that we collect when you use our
Services to create an account will be used by us to create your account and profile.
(iv) To provide location-based services. When you use our Services, we or third party
service
providers may take advantage of your location information to provide you with advertising, the correct version of
our Services and help you gain good user experience.
(v) To improve user experience. Certain optional features such as user experience
programs allow
us to analyze data regarding the use of our products and our Services and improve user
experience.
(vi) To provide push services. Device information may be used by us to provide push
services to
assess the performance of adverts and the success of software updates, or provide notifications on new product
releases.
(vii) To verify your identity. Verifying your identity using a text message when you log in to
your account helps prevent unauthorized logins to your account.
(viii) To collect feedback from you. Your feedback is of great value in helping us
improve
our Services. To keep track of your feedback, We may use the personal information provided by you to contact
you and retain the records.
(ix) Other purposes. We will collect, store, maintain and use information about you for purposes under the
“The
Information We Collect”, and for purposes of running our operations, pursuing our legitimate interests (e.g.,
research
(including marketing research), network and information security, and fraud prevention), and satisfying our legal
obligations.
We may share your information with third parties who provide services on our behalf to help with our business
activities. These services may include:
(i) Fulfilling orders and delivering packages;
(ii) Providing you with advertising;
(iii) Payment processing;
(iv) Providing customer services;
(v) Fulfilling subscription services;
(vi) Conducting research and analysis; and
(vii) Providing cloud computing infrastructure.
We will not share with or disclose to third parties (other than our service providers) your personal information in
whole or in part except for the purposes of:
(i) protecting the security of others or their property;
(ii) preventing or dealing with fraud;
(iii) safeguarding our legitimate rights and interests;
(iv) taking action in line with our purposes as described in the “The Information We Collect”
or
the “How We Use Information” sections;
(v) complying with laws, rules and regulations or requests by government departments, judicial
authorities, law enforcement, or private parties, which are typically designed to uphold Internet security and the
rights, property and safety of us, our users and third parties; and/or
(vi) evaluating or completing a transaction where we are involved in a merger, acquisition,
financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or other event where
your
information may be sold or transferred.
We will only collect and process personal information where we have lawful bases and we typically rely on one of the
following four legal bases: -
(i) consent (where you have given consent);
(ii) contract (where processing is necessary for the performance of a contract with you, for
example, to operate the site or deliver any services you have requested);
(iii) legitimate interests (for example we need to use your information to provide and improve
our Services, including protecting your account, providing customer support). We rely on our legitimate interests
as our lawful basis only where those interests are not overridden by the impact on you (unless we have your
consent or our processing is otherwise required or permitted by law); and
(iv) legal obligations (to comply with the laws, rules and regulations or requests by
government departments, judicial authorities or law enforcement).
If you have questions about the lawful bases on how we process your personal information, please contact us at
snappass@starii.com (please quote “SnapPass” in your email title).
Our Services may contain links to other websites and services. In addition, other websites and services may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about third party websites or services. We encourage our users to read the privacy policies of each and every website and service with which they interact. Visiting these other websites or services is at your own risk.
We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal information. However, you understand and accept that (in the Internet industry) even though we take reasonable security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. Further, you understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.
We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity in order to protect the security of your account.
[Subject to applicable laws, rules and regulations and the fulfillment of our business or legal purposes, we will delete your information (including your personal information) promptly after a period of 180 days from the date of collection of the relevant information.]
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (right to data portability); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.
If you wish to exercise your rights, you may send an email to snappass@starii.com (please quote “SnapPass” in your email title) or mail your request to Unit 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Starii). We will process your request in line with applicable laws within a reasonable period of time after receiving your email or mail, and will cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.
We will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under 16, please do not send your personal information to us, including but not limited to your name, address, phone number or email address. If you believe we may have any information about children under 16 (or any other age stipulated by law as children applicable to your region), you may send an email to snappass@starii.com (please quote “SnapPass” in your email title) or send a registered mail to Unit 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Starii). If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information and terminate the associated account.
Depending on the jurisdiction in which you are a user of, and subject to the special rules and policy of such jurisdiction as stated in this Policy, you understand and agree that all information collected via or by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the People’s Republic of China, the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), Japan, South Korea, Singapore, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide our Services.
This Policy is established, comes into force, and will be enforced and interpreted under the laws of Hong Kong, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.
You agree that we may update this Policy according to relevant laws and regulations or based on our business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on SnapPass or notify you by other means as required by law.
Right to data disclosure, correction, erasure or suspension of use
If you are in Japan, as a data subject, you have the right to request the disclosure, correction, erasure or suspension of use of your personal information, and we are obliged to meet your request without undue delay. You may send your request by email to snappass@starii.com (please quote “SnapPass” in your email title) or by mail to Unit 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Starii).
In order to provide our Services to you, we may need to collect your personal information, transfer it to, and store and process it elsewhere.
• Personal information transferred: please refer to the section “The Information We Collect” of this Policy above
You agree that we may use facial recognition technology to collect biometric information from the photos or images you provide.
We may use such information to verify your identity, to provide and improve the Service, and for our internal research purposes.
If your biometric information is subject to the Illinois Biometric Information Privacy Act, we will delete your biometric information
within three years of your last interaction with the Service.
In accordance with applicable law, you may have the right to:
(i) confirm whether or not we are processing your personal information;
(ii) obtain access to or a copy of your personal information with accompanying details;
(iii) receive an electronic copy of personal information that you have provided to us, or ask us to
send that information to another company i.e., right of data portability;
(iv) correct your personal information;
(v) request to opt-out of certain processing activities including, as applicable, if we process your
personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we
“sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in profiling in furtherance
of certain decisions that produce legal or similarly significant effects concerning you;
(vi) request erasure of personal information held about you by us; and
(vii) appeal our decision to decline to process your request.
If you would like to exercise any of your rights under the applicable privacy laws, please contact our Data Protection Officer via email at snappass@starii.com (please quote “SnapPass” in your email title) or via registered mail at Unit 8106B, Level 81, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong (attention: Legal Department, Starii). We will process such requests in accordance with applicable laws.
If you are a Virginia resident and would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
The following paragraphs only apply to our processing of your personal information that is subject to the California Consumer Privacy Act (as amended from time to time) (“CCPA”).
The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
| Category of Personal Information Collected | Category of Third Parties to Whom Personal Information is Disclosed to for a Business Purpose |
|---|---|
| Identifiers | • Service Providers • Our Affiliates |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | • Service Providers • Our Affiliates |
| Protected classification characteristics under California or federal law | • Service Providers • Our Affiliates |
| Commercial information | • Service Providers • Our Affiliates |
| Biometric information | • Service Providers • Our Affiliates |
| Internet or other electronic network activity | • Service Providers • Our Affiliates |
| Geolocation data | • Service Providers • Our Affiliates |
| Sensory data | • Service Providers • Our Affiliates |
| Professional or employment-related information | N/A |
| Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)) | N/A |
| Inferences drawn from other personal information to create a profile about a consumer | • Service Providers • Our Affiliates |
| Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number | N/A |
| Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | • Service Providers • Our Affiliates |
| Personal information that reveals a consumer’s precise geolocation | • Service Providers • Our Affiliates |
| Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership | N/A |
| Personal information that reveals the contents of a consumer’s mail, email, and text messages unless Figma is the intended recipient of the communication | • Service Providers • Our Affiliates |
| Personal information that reveals consumer’s genetic data | N/A |
| Biometric information that is processed for the purpose of uniquely identifying a consumer | N/A |
| Personal information collected and analyzed concerning a consumer’s health | N/A |
| Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation | N/A |
The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing Personal Information are set forth in “The Information We Collect”, “How We Use Information”, and “Information Sharing and Disclosure” above, respectively. We will retain personal information in accordance with the time periods set forth in “Data Retention” above.
In the preceding twelve months, we have not “sold” any personal information (as defined by the CCPA), nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
In the preceding twelve months, we have not “shared” any personal information for “cross-context behavioral advertising” (as such terms are defined in the CCPA), nor do we have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising”.
We only use and disclose sensitive personal information for the following purposes:
(i) To provide the Services.California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide the email address or phone number we have associated with you and providing a verification code that is sent to your email address or phone number.
To Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent and contact us using the information in “Privacy Rights” above for additional instructions.
We do not “sell” personal information or “share” personal information for “cross-context behavioral advertising” so we do not respond to opt-out preference signals.
If you are a Nevada resident, we do not “sell” your personal information.