Privacy Policy

Last modified: April,20,2020

Starpool Data Limited (“we”, “our” or “us”)takes your privacy information very seriously. To provide you with our personalized software (the“Software”) and services(the “Service”), we need to collect some privacy information about you, and this privacy policy explains the information we collect, how we treats your information and protects your privacy. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Thanks for choosing our Software and Service. Please read this Privacy Policy carefully to understand it.

If you use the Software and Service, we consider you to consent the terms and conditions described in this document. If you do not agree with any term of this Privacy Policy, you may not use the Software.

This Privacy Policy contains the following sections:

1. 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: (1) how long the personal data is needed to provide the Services and operate the business; (2) the type of personal data collected; and (3) 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). We will only keep your personal information for three (3) years.

2. Information We Collects and Purposes of Collection

Information You submit

(1) Camera and Photos. We access your camera to provide you camera function normally. We access your photos to provide you a lot of photo editor features, gallery function and photo preview function normally. Photos by choosing to upload photos in our community may upload to and stored in our server. You may delete these photos kept in our server whenever you like.

(2) Facial Features Data. When you use the functions related to face recognition, such as cartoon effect, you may choose to grant us the permission to access to your camera and album to obtain your facial photo in your mobile device. Only if you confirm the permission, will we gain access to your camera and album. We will not collect the facial features data, and only use our own algorithm to capture the position and shape of the five sense organs in the photos, and then feedback the effect drawing to you. We capture such information only for operating the functions related to face recognition. For such photos, information and effect drawing, we will neither store nor share them with any third parties.

(3) Support Related Information. If you communicate with us via our support section or via email, we may collect your email address, and any information voluntarily submitted by you in connection with such support.

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 provide you with support and handle your complaints and/or feedback.

Information We Collect Automatically

(1) Technical Information. We may use API provided by IOS to collect certain technical information regarding your device, and your use of the Software and Services , including the type, name and version of operating system : (i) Your configuration and settings of the Software and Services, version of the Software and Services; (ii)ISP (Internet Service Provider) , Internet protocol (IP) address, Media Access Control (MAC) address,anonymous user identifiers, device configuration and identifiers; (iii)Advertising ID; (iv) location; (v) Apple ID.

(2) Usage Information. We may use API provided by IOS to collect certain usage related information regarding your use and interaction with your device, including the Software and Services, such as when and how you use the Software and Services, how you use your internet browser and internet search related applications, the web pages you visit and the content you see, access and utilize on such web pages; for example, offerings and advertisements that you view, use and access, how you use them and your response to them, how frequently you use them, your search queries and the time and date of your searches.

(3) Social Networks. We may use API provided by IOS to collect your interactions on social networks through the Software and Services.

(4) Payment data. We may use API provided by Apple Store 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 by third-party companies (such as Apple). These companies can be contacted through their websites: https://www.apple.com. Before entering your personal payment details, we suggest that you read and become familiar with the privacy policy of these third-party companies.

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.

If any new purposes for processing your information arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

3. How Your Information May be Shared?

(1) We will share your information with third parties only in the ways that are described in this Privacy Policy.

(2) We will not rent or sell your personal information to the third- party, but for your better use of the services provided by third-party organizations, we may share your information with third-party organizations that provide automatic data processing technologies for the Software or providing service to the Software. We do not have power to control or influence these third- parties’ tracking technologies or how they may be used. Therefore, if you do not want to share your personal information with any third-party organizations, please do not use such service provided by that third-party organizations. The Software may contain links to third-party websites/services or you may access the Software from a third-party site. We are not responsible for the privacy practices or the content of these third-party sites or services linked to or from our Software, including the information or content contained within them.

(3) We may disclose your personal information if it needed for objective reasons, due to public interest or in other unforeseen circumstances: (i) as required by law; (ii)when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

4. Security of Your Information

We take precautions — including administrative, technical, and physical measures — to safeguard your information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. 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 your data. We also protect your privacy by seeking to minimize the amount of sensitive data. We also seek appropriate contractual protection from our partners regarding their treatment of your information. 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.

5. Right of Access, Modification and Deletion of Your Information

In compliance with legal provisions, you have a general right to access, edit and delete your personal information which have been collected pursuant to your access to and/or use of the Service. In order to exercise this right, please contact us through the email displayed below.

6. Privacy Policy Concerning Children

The Service offered by us are not intended for children under 13 or other statutory minimum age according to the applicable laws and regulations in your country (the “Minimum Age”). Anyone under the Minimum Age should not use the Service. With this in mind, we do not willingly collect personal data from children under the Minimum Age. All the same, if the collection of such data is brought to the attention of us, we will take all useful measures possible to delete the corresponding data. 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.

7. Transfer of Data Outside Your Territory.

The Software and Service 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 Service. You may withdraw your consent at any time.

8. How to Contact us.

If you have any questions or concerns with respect to any matter covered by this Privacy Policy, you may contact us by email at: RecShot@outlook.com. We may modify, update and publish this Privacy Policy in the Software from time to time. Please continue to play close attention to this Policy.