Last updated:May 21, 2019
Joali Holdings Limited (hereinafter as “we”, “our” or “us”) understands the importance of protecting your privacy. Therefore, we have established the Privacy Policy to explain how we treats your information and protects your privacy when you use this software (the “Software”) and services this Software provided (the “Service”) and the rights and options available to you regarding your information. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Any information that we collect is subject to the Privacy Policy in effect at the time that information is collected. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE AND SERVICES.
We may, moreover, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Software. Please check and pay close attention to this Policy from time to time.
Information We Collects and Purposes of Collection
For the purposes of European data protection laws, we are the data controller of your personal information. There are two general categories of information we will process:
1.Information you give to us
(1) Support Related Information. If you communicate with us via our support section or via email, we may collect your email address, name and any information voluntarily submitted by you in connection with such support (for example, your name, company name, and particular support query or request). Such information will only be used to provide you with support services and will not be connected with any other information collected from you on or through the Software and Service including but not limited to any individual user ID which will be automatically generated by the Software and assigned to you when you use the Software.
(2) Camera and Photos. In order to use some of the features of the Software, you may voluntarily grant us the permission to access to the camera or photo album to obtain photos in your mobile device. We may use Photokit framework API to collect your photos, and send them to the third party service provider to process the photos and analyze the data. The conclusion or feedback will be provided to us after such analyzing. For such photo, we will not save the data, the conclusion or feedback after the processing and analysis.
The purposes of collection of such information are: (1) to operate and update the Software and the Services; (2) to improve and customize the Software and the Services; (3) to maintain, test and monitor the quality and operation of the Software; (4) to comply and satisfy any applicable law regulation, legal process or enforceable governmental request.
2.Information we collect automatically
When you use the Software and Service, for analytical, business and operational purposes, we automatically collect and store the following types of information:
(1)Technical Information. We may use iOS API to collect the following information: -- universally unique identifier(UUID), type of your mobile device, and applications and operational system version which are installed on your mobile device ; -- country, language, network data.
(2) Subscription Data. We use In-app purchase API provided by the third party to collect information about your subscription orders, such as purchase items, subscription time, order status, payment time. We do not collect and we are not responsible for the collection or security of payment details. Payment information is processed and stored using third-party companies (such as Apple). These companies can be contacted through their websites e.g. https://www.apple.com. Before entering your personal details, we suggest that you read and become familiar with the privacy policy of these third-party companies. Our purpose is to manage your account and provide you with customer support. We may use your subscription data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. Please note that irrespective of your email settings, we may send you messages about the availability of our Service, security, payment transactions, status of your orders, legal notices regarding revision of our Terms of Use or this Privacy Policy, or other Service-related information.
The purposes of the information that is processed automatically are:(1) to operate and update the Software and the Services, and provide you with existing and new functionality and features; (2) to improve and customize the Software and the Services; (3) to maintain, test, monitor and improve the quality and operation of the Software; (4) to notify you of the Software and the Services updates.
While it is not our intention to collect any personally identifiable information (“PII”) (except for the purposes as set forth in this Privacy Policy), the data collected may include PII. As part of our privacy measures, we implement certain rules designed to avoid the unintentional collection of PII such as email addresses, social security numbers, credit card numbers etc. Such rules are based on known field types, parameters, values and algorithms but they are not foolproof and hence the Software and the Services may sometimes, unintentionally, collect unwanted information. We regularly examine and update these rules. If you located in EEA, as required by law, you hereby grant your consent to us to use or process your PII only for the purpose described above once you use the Software or the Service. And you may withdraw your consent at any time.
Sharing Information with Third Parties
We will not share any PII that we have collected from you except for the following events:
If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of our users, its partners, or the general public);
In the event we go through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred;
We may share your information with certain third parties (including, without limitation, search engines, content providers, and advertising networks and platforms) that provide various services (such as advertising, marketing, analysis, content, and search) in connection with the Software and the Service. We take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with the Service; and (iii) to use the data solely in compliance with the applicable date protection laws and this Privacy Policy.
If you want to delete any PII which we have shared with the third parties, please contact us by email at SnapicsPhotoEditor@mail.com . We would try our best to notify the third party of deleting the relative personal data, but no warranty as to the deletion is made by us.
Information may be Collected by Third-Party
Certain Services may contain contents linking to advertisements, websites, products and other services provided by third parties in our Software (collectively, "Third Party Services"). The use of such Third Party Services is subject to their privacy policies. You shall be aware that the use of the Third Party Services may give these third parties the ability to access, collect, store, and/or share your information, both your PII and non-personally identifiable information. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Services and your access to any Third Party Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Services. You expressly relieve us from any and all liability arising from your use of such Third Party Services. We recommended that you read the terms, conditions and privacy policies of such third party before using or accessing any of them.
Moreover, for providing customized advertisement, the third-party advertising companies may collect or use your PII (not including your name, address, email address or telephone number) when you use the Software or the Service. If you would like more information about this practice and to know your choices about not using this function or sharing this information with these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp.
Transfer of Data outside Your Territory
The Software and the Services work over the Internet. We may store and process your information in various locations throughout the world. Where you located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where may be outside of EEA once you use the Software and/or the Services. You may withdraw your consent at any time by notify us.
Security of Your Information
The security of your information is our utmost priority, and we take strict measures in order to protect the data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s information. We also protect user’s privacy by seeking to minimize the amount of sensitive data and PII. We also seek appropriate contractual protection from our partners regarding their treatment of user data. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
Data Retention
We retain the information we collect as described in this Privacy Policy for as necessary for the provision of the Services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the Services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
Your Data Rights
You have the right to access, modify, correct or delete any personal data which we may have collected. If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA. To exercise this right please contact our Data Protection Officer by email at: SnapicsPhotoEditor@mail.com .
Children’s Privacy
The Software is not intended for children under the age of 16 or other statutory minimum age according to the applicable laws and regulations in your country (the “Minimum Age”) . Therefore, we do not knowingly collect or solicit any personal information from children under the Minimum Age. No one under the Minimum Age may provide any personal information to the Software. If you are under the Minimum Age, do not use or provide any information on this Software or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under the Minimum Age without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under the Minimum Age, please contact us through the email displayed below.
Contact us
If you have any questions or concerns with respect to any matter covered by this Privacy Policy, you may contact our Data Protection Officer by email at: SnapicsPhotoEditor@mail.com .