StarFace Privacy Policy

Last Modified Date: July 18, 2023
We place great emphasis on the protection of users' personal information. HengZhu (hereinafter referred to as "we"), as the operator of StarFace, strictly adheres to legal provisions to protect your personal information and privacy. When you download, install, activate, browse, register, log in, or use (hereinafter collectively referred to as "use") StarFace and related services, we will collect, store, use, share, disclose, and protect your personal information in accordance with this "Privacy Policy". Please note that this policy does not apply to products or services provided to you by other third parties. If you use products or services provided by a third party, please carefully read the user agreement and personal information protection policy of that third-party product or service.
We recommend that you carefully read and understand the entire content of this policy, paying special attention to the important content related to your personal information rights highlighted in bold. If you do not agree to any of the terms in this policy, please do not use our services.
This privacy policy helps you understand the following:

1. Facial Data Policy

2. How We Collect and Use Personal Information

3. Use of Cookies and Similar Technologies

4. How We Store This Information

5. How We Share, Transfer, and Publicly Disclose This Information

6. How We Protect Your Personal Information

7. How You Can Access and Manage Your Personal Information

8. Minor Protection Provisions

9. Revision and Notification of Privacy Policy

10. Scope of Application

11. How to Contact Us

12. Facial Data Policy

13. Special Note: Please be aware that StarFace processes facial data.
    For the photos you upload, we will conduct facial feature point analysis (such as eyes, nose, and mouth, etc.) to perform necessary facial processing. Please rest assured that we will not collect any of your facial data. After the analysis is completed, all related data will be immediately deleted, and no information will be retained. Please note that if you refuse to provide the above information, you may not be able to use some core functions, but it will not affect the normal use of other functions and services.
    

14. Facial Data Processing Procedure
    To provide you with "facial effects" related effects, we need to identify facial feature points (such as eyes, nose, mouth points, etc.).
    The complete process is:
    We provide a photo synthesis service that protects your privacy. The photo you choose will be submitted to our server in an encrypted manner. The server will analyze the facial data in your photo and apply it to the template you have selected to generate the final rendering effect. This process is entirely completed by the server, ensuring your privacy and safety. We attach great importance to customer privacy. After the synthesis is completed, the server will return the final effect to you through the application and temporarily store it in encrypted storage. To further protect your privacy, we will permanently delete your "work" after a certain period of time. At the same time, after the synthesis process is completed, we will immediately delete the facial image you submitted to the server.
    

15. Facial Data Sharing and Storage
    We will not share your facial data with any third party, nor will we store any facial information you submit. After the analysis process is completed, the photo you uploaded will be deleted.
    

16. How We Collect and Use Personal Information
    Except as required by law or government departments with legal authority, or with the consent of the user, [StarFace] will not disclose user personal privacy information to any third party other than cooperative units without the user's consent. However, this does not apply if the user agrees to the disclosure or use of their personal privacy information when registering, or if there is a separate agreement between the user and [StarFace] and its cooperative units regarding the disclosure or use of the user's personal privacy information. The user should bear any risks that may arise from this, and [StarFace] will not be responsible for it.
    (1) Permissions that may be obtained when you use [StarFace] functions:
    

17. Camera Permission
    When using the photo-taking function during the image and video production process, we need to obtain authorization from your device's camera and collect the image information (containing personal information) you provide. This permission requires your authorization. If you refuse to provide this permission, you will not be able to use this function. However, this will not affect the normal use of other features of the product and/or services. When we request authorization, you can choose to refuse or turn off the permission. Please rest assured that we will protect your personal information security.
    

18. Privacy Tracking Permission
    When using [StarFace], in order to better serve you, we need to obtain your privacy tracking permission and device advertising identifier IDFA, which is used to remember your identity, analyze your use of [StarFace], and identify you as our user. These permissions need to be authorized by you to take effect. If you choose to refuse authorization, it will not affect the other functions of the product and services. When we request your authorization, you can choose to refuse or protect your privacy by turning off the permission authorization.
    

19. Photo Permission
    When using the video or image production function of [StarFace], if you want to add photos from your mobile phone's photo album, we need to obtain your device's photo permission and collect the image information stored in your mobile phone's storage space (which is personal information). Of course, we will request your authorization before doing so. If you refuse to provide the permission, it will only affect the use of this function and will not affect the normal use of other products and services. If you do not want to authorize, please refuse or turn off the permission authorization when we request your authorization.
    (2) Personal Information We Collect and Use Directly
    We will collect information that you actively provide when using the service, as well as information generated during the use of functions or acceptance of services through automated means:
    

20. Ensuring the Normal Operation of [StarFace] and Services
    To ensure the security of your account, network, operation, and system, and to prevent phishing website fraud and malware viruses, we may collect your device information, including device identifier information (referring to a series of characters embedded by the device manufacturer into the device for identification, such as IMEI, AndroidID, OAID, IMSI, ICCID, GAID, MEID, VAID, AAID for Android, and IDFV, IDFA for iOS, the "device identifier information" referred to in this policy is the same as this definition), hardware serial number, MAC address,
    IP address, browser type. Please understand that when you switch the StarFace APP on the device screen to run in the background, due to some device models and system reasons, the information collection behavior generated by using the relevant functions of StarFace may not be able to stop immediately, resulting in a brief background information collection behavior.

21. Registration, Authentication, Login, and Related Services
    (1) When you register or log in to [StarFace], when you use this product and service, we will automatically create a unique account for your device, which is generated by a timestamp through certain rules and does not contain any of your personal or device information.
    (2) When you use some core functions or services, according to relevant laws and regulations, you may need to provide your mobile phone number to complete real-name verification. If you do not provide this information, you will not be able to save the generated content, but you can continue to use other services. However, we may also verify the security of your account through real-name authentication (ID card number) when we have a reasonable reason to believe that your account is at risk. During the real-name authentication process, it may be necessary for the third-party authentication agency providing the authentication service to verify your real identity information. This information is only for the purpose of completing real-name authentication, or other purposes stipulated by laws and regulations, and will not be used for other purposes without your explicit authorization. You can refuse to provide it, but you may not be able to use the functions or related services that require real-name authentication. The inability to use such functions or services does not affect your use of other features and services. The aforementioned information contains sensitive person
    

StarFace product may be revised or iterated in the future, which does not mean that our company is committed to providing the related functions or services. However, this does not affect your rights to the intellectual property ownership of the user images and any legal use of the user content. We will maintain respect for user privacy and intellectual property rights and strive to provide the best quality service experience for users.

III. Use of Cookies and Similar Technologies
Cookies and similar technologies are common and widely used technologies on the Internet. When you use the [StarFace] software and related services, we may use these technologies to send one or more cookies or anonymous identifiers to your device to collect and store information about your access and use of this product. We use cookies and similar technologies mainly to achieve the following functions or services:
(1) Ensuring the security and efficient operation of the product and services
We may set authentication and security protection cookies or anonymous identifiers to confirm whether you have safely logged into the service, or whether you have encountered unauthorized use, fraud, and illegal activities. These technologies will also help us improve service efficiency and enhance login and response speeds.
(2) Helping you have a more convenient access experience
Using such technologies can help you avoid the steps and processes of repeatedly entering your personal information and frequently logging in (implementing one-click login processes, recording video production history).

We promise that we will not use cookies for any other purposes beyond those described in this privacy policy.

IV. How We Store Personal Information
(1) Location of Information Storage
In accordance with the provisions of laws and regulations, we will store the personal information collected and generated during the operation within the territory of the People's Republic of China. At present, we will not transfer the above information overseas. If we transfer the information overseas, we will follow the provisions of laws and regulations and seek your explicit consent.

(2) Storage Period
We will only retain your personal information for the period necessary to provide [StarFace] and related services. After the necessary period, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations.

V. How We Share, Transfer, and Publicly Disclose Personal Information
(1) Sharing and Transfer of Personal Information
We will not share or transfer your personal information to a third party without your prior consent, unless you have authorized the sharing or transfer of your personal information when registering, or there is a separate agreement between you and [StarFace] and its cooperative units regarding the disclosure or use of your personal privacy information. The user should bear any risks that may arise from this, and [StarFace] will not be responsible for it.

1. Under the following circumstances, we may share personal information:
   (1) To implement programmatic advertising display, we may share de-identified or anonymized information with advertising partners. We will not share information that can be used to identify your personal identity (your name, mobile phone number), but will only provide partners with user portrait tags and de-identified or anonymized statistical information that are difficult to identify your personal identity, to help them improve the effective reach rate of advertising without identifying your personal identity.
   (2) Sharing with business partners to implement specific functions
   To ensure the implementation and safe and stable operation of related functions, we may integrate third-party software development kits (SDKs) provided by third parties. We will conduct strict security monitoring of the software development kits (SDKs) obtained by the partners to protect data security. The third-party SDKs we integrate are listed in this privacy policy. Please note that the data processing types related to the integrated third-party SDKs may change due to reasons such as version upgrades and policy adjustments, and the official statements of the third parties shall prevail.
   

2. Prudent Evaluation and Responsibility Binding of the Third Party to Which Personal Information is Shared
   (1) With your consent, we will only share the necessary information with the third party to achieve the purpose. If the third party needs to use the personal information beyond the scope of the aforementioned authorization due to business needs, the third party will need to seek your consent again.
   (2) For the third parties with which we share your personal information, these third parties will sign confidentiality agreements with us. At the same time, we will evaluate their data security capabilities and environment and require the third party to handle the information with confidentiality and security measures that are not lower than the requirements of this privacy policy.
   

3. Transfer of Personal Information in the Event of Acquisition, Merger, or Reorganization
   As our business continues to develop, we may undergo mergers, acquisitions, and asset transfers, and your personal information may be transferred as a result. When such changes occur, we will continue to protect or require the successor to continue to protect your personal information according to the legal provisions and safety standards that are not lower than the requirements of this privacy policy, otherwise, we will require the successor to re-obtain your authorization consent.
   

(2) Public Disclosure of Personal Information
We will not publicly disclose your information unless it is necessary to disclose the necessary information when penalizing accounts for violations or fraudulent behavior, or in accordance with national laws and regulations or with your consent. We will adopt industry-standard security protection measures when publicly disclosing your personal information.

(3) Personal Information Shared, Transferred, or Publicly Disclosed by Law Without Consent
Please understand that in the following situations, according to laws and regulations and national standards, we may share, transfer, or publicly disclose your personal information without your consent:
(1) Directly related to national security and national defense security;
(2) Directly related to public safety, public health, and major public interests;
(3) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(4) To protect the life, property, and other major legitimate rights and interests of you or others, but it is difficult to obtain your consent;
(5) Personal information that you have publicly disclosed to the public;
(6) Collecting personal information from legally disclosed information, including legal news reports, government information disclosure channels.

VI. How We Protect Your Personal Information
(1) We take the security of your personal information very seriously and will strive to take reasonable security measures (including technical and management aspects) to protect your personal information, prevent the improper use of the personal information you provide, and prevent unauthorized access, disclosure, use, modification, damage, loss, or leakage.

(2) We will use encryption technology that is not lower than the industry standard and anonymization processing to protect your personal information through reasonable and feasible means, and use security protection mechanisms to prevent malicious attacks on your personal information.

(3) We will establish a dedicated management system, processes, and organization to ensure information security.

(4) Due to technical limitations and various malicious means that may exist, the Internet environment is not 100% safe. We will strive to ensure the security of the personal information you provide to us. You are aware and understand that the system and communication network you use to access our services may have issues due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information.

(5) We will develop emergency response plans and immediately activate emergency plans when a user information security incident occurs, striving to prevent the expansion of the impact and consequences of such security incidents. Once a user information security incident (leakage, loss) occurs, we will inform you of the possible risks, risks, and remedial measures in a tim

Settings - Account Security to cancel your account. Please be aware and understand that canceling your account is an irreversible action. Once you cancel your account, we will delete the relevant information about you or process it anonymously, except as otherwise provided by laws and regulations.

1. Complaints and Reports
   If you believe that your personal information rights may be infringed, or if you discover clues of personal information rights infringement, you can contact us through the contact information disclosed in Article 12 of this privacy policy. We will verify and provide feedback on your complaint and report within 15 working days.
   

2. Access to Privacy Policy
   You can view the entire content of this privacy policy when the software is first installed, or by going to Settings - Privacy Policy.
   

3. Notification of Cessation of Operations
   If we cease operations, we will promptly stop collecting your personal information, notify you of the cessation of operations through individual delivery or announcement, and delete or anonymize the personal information we hold.
   

VI) Response to Your Rights Requests
To ensure security, when you make the above rights claims, you may need to provide a written request or prove your identity in other ways. We will process your request after verifying your identity. Generally, we will respond within [15] days. For your reasonable requests, we will not charge a fee in principle. However, for repeated, excessive requests, we will charge a certain fee as appropriate. For information not directly related to your identity, frivolous repetitive information, or requests that require excessive technical means (e.g., developing a new system or fundamentally changing existing practices), pose a risk to the legitimate rights and interests of others, or are impractical, we may refuse.

(1) Related to national security and national defense;
(2) Related to public safety, public health, and major public interests;
(3) Related to criminal investigation, prosecution, trial, and execution of judgments;
(4) There is sufficient evidence that the personal information subject has malicious intent or abuses rights;
(5) Responding to your request will cause serious damage to the legitimate rights and interests of you or others;
(6) Involving trade secrets.

VIII. Minors Clause
If you are a minor under the age of 18, you should read and agree to this privacy policy together with your guardian before using the [StarFace] software and related services.

We protect the personal information of minors according to the provisions of relevant national laws and regulations, and will only collect, use, share, or disclose the personal information of minors when legally permitted, with the explicit consent of parents or other guardians, or when necessary to protect the minor. If we find that we have collected the personal information of minors without prior verifiable parental consent, we will try to delete the relevant information as soon as possible.

If you are a guardian of a minor and have any questions about the personal information of the minor under your guardianship, please contact us through the contact information disclosed in this privacy policy.

IX. Revision and Notification of Privacy Policy
(1) To provide you with better services, the [StarFace] software and related services will be updated and changed from time to time, and we will timely revise this privacy policy. Such revisions will be part of this privacy policy and have the same effect as this privacy policy. However, without your explicit consent, we will not reduce the rights you are entitled to under the current effective privacy policy.

1. In the following circumstances, as required by laws and regulations, we will be unable to respond to your request:

(2) After the privacy policy is updated, we will issue the updated version in [StarFace] and remind you of the updated content through an in-app pop-up or other appropriate means before the updated terms take effect, so that you can be informed of the latest version of this privacy policy in a timely manner. If you continue to use our services, you agree to accept the content of the revised policy. However, if the updated content requires the collection of new personal sensitive information, we will still seek your consent in a prominent manner.

(3) For major changes, we will also provide more prominent notifications (we will notify you of the specific changes in the privacy policy through methods including but not limited to SMS, push notifications, or special prompts in specific locations).

1. A major change in our service model, including the purpose of processing personal information, the types of personal information processed, and the method of use;

2. A major change in our ownership structure and organizational structure, including changes caused by business adjustments, bankruptcy, and acquisitions;

3. A change in the main entity with which personal information is shared, transferred, or publicly disclosed;

4. A change in the department responsible for processing personal information security, contact methods, and complaint channels.

X. Scope of Application
This privacy policy applies to all services provided by [StarFace].

The [StarFace] and related services referred to in this privacy policy may vary depending on factors such as the mobile phone model, system version, and software application version you use. The final products and services are subject to the [StarFace] software and related services you use.

XI. How to Contact Us

1. The copyright of this privacy policy belongs to us, and we have the right to interpret and modify it within the scope allowed by law.

If you have any questions, opinions, suggestions, or complaints about the content of this policy, you can contact us by sending an email to the Personal Information Protection Officer: newface_007@163.com