Last updated: Nov 17, 2020
Your privacy is important to Seashell Mobile Limited (the “team”, “we” or “us”) and we are committed to protecting your privacy. So we’ve developed a Privacy Policy.
This Privacy Policy explains how we treat your information and protects your privacy when you use our mobile applications and related services (“the Software and Services”) and the rights and options available to you regarding your information. We believe that you have a right to know our practices regarding the information we may collect and use when you use the Software and Services. The Software and Services may include various features and content that are offered and delivered to you by us. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE AND SERVICES.
For the purposes of European data protection laws, the team is the data controller of your personal information. When you use the Software and Services, we consider you consent to provide your personal information voluntarily. There are two general categories of information we may collect.
1.Information provided or permission granted to us by you
a) Permission to Access to the Camera and Photo Album. In order to use certain 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 or save pictures to your photo album. Only if you confirm the permission, will we gain access to your camera and photo album.
b) Facial Features Information.
Collection and processing of your facial features information
When you first use the face recognition function, the App will pop up a popup window to ask for your confirming. You may choose to grant us the permission to access to your camera or 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 then use facial recognition technology developed by us to process the facial features data in the photos, analyze the information on the photos, automatically capture the position and shape of the five sense organs in the photos, and feedback the effect drawing to you.
If you cease to consent or affirmatively revoke consent for our collection and processing of your facial features information, we will promptly cease all such collection and processing.
Storage and sharing of your facial features information
The purpose of processing facial features information is only to operate the face recognition functions of the App. For such facial features information, photo and effect drawing, we will neither store nor share them with any third parties.
c) Permission to Access to the Storage. To ensure that you may save photos or cache information normally to your device, you may voluntarily grant us the permission to access to the storage of your device.
d) Support Related Information. If you communicate with us via our support section or via email, we may also collect your email address 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.
2.Information collected automatically
For analytical, business and operational purposes, we automatically collect the following types of information:
a) Technical Information. We may use the API provided by IOS to collect certain technical information, which is regarding your device configuration and identifiers, and your use of the Software and Services, including the type, name and version of operating system, internet service provider (ISP), internet protocol (IP), media access control (MAC) address, anonymous user identifiers, Identifier for advertising (IDFA), Apple ID.
b) Payment data.
We may use the API of Apple 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: 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 main reason we use your information is to deliver and improve the Software and Services. Read on for a more detailed explanation of the various reasons we use your information:
1 Deliver Services. Deliver the Software and Services to you and maintain, improve the quality and operation of the Software and Services, ensure their optimal functionality and operation.
2 Maintain Relationship. Identify, establish and manage your account and our relationship with you.
3 Respond Requests. Provide you with customer support and respond to your requests.
4 Customize the Services. (i) To improve and customize the Software and Services; (ii) To provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners.
If any new purposes for processing your information arise we will let you know before we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.
While it is not our intention to collect any personally identifiable information (“PII”) (except for those 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 Services may sometimes, unintentionally, collect unwanted information. We regularly examine and update these rules to avoid this happened.
If you located in the EEA, as required by law, you hereby grant your consent to us to use or process your personal information only for the purpose described above once you use the Software or the Service. And you may withdraw your consent at any time by contacting us.
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 the team’s users, its partners, or the general public);
In the event the team goes 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.
The Software and Services may include and/or enable you to use or access some service provided by third parties (“Third Party Service”). The use of such Third Party Service is subject to its privacy policy. You shall be aware that the use of the Third Party Service may give this third party 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 Service and your access to any Third Party Service 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 Service. You expressly relieve us from any and all liabilities arising from your use of such Third Party Service. We recommended that you read the terms, conditions and privacy policy of such Third Party before using or accessing any of them.
The security of user’s 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 PRI. 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.
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). We will only keep your personal information for three (3) years.
You have the right to access, modify, correct or delete any personal data which we may have collected, to exercise this right please contact us by email at: . 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. To exercise these rights please contact us by email at: .
If we are required to provide you with notice of a particular event or incident, we will send you such notice by mail, email or telephone.
We ensure that we comply with the Children’s Online Privacy Protection Act (COPPA), and does not knowingly collect personal information from children under the age of thirteen (13). If you are in the EEA, our Software and Services is not directed to children under 16, and we do not knowingly collect PII from children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without his/her consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.
The Software and 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 Services. You may withdraw your consent at any time.
If you have any questions or concerns with respect to any matter covered by this Privacy Policy, you may contact us by email at: LoopYaTeam@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.