Privacy Policy

The Phomemo Privacy Policy was updated on December 25th, 2019.

Your privacy is important to Phomemo so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information.

In addition to this Privacy Policy, we provide data and privacy information imbedded in our products connected with our Data & Privacy Icon for certain features that ask to use your personal information.

You can review this information before enabling these features, in Settings related to those features and/or online at https://phomemo.com/policies/privacy-policy. Please take a moment to familiarize yourself with our privacy practices and contact us if you have any questions.

What personal information we collect?

Personal information means details which identify you or could be used to identify you, such as your name, contact details, and purchase history.

This website collects and uses personal information for the following reasons:

For management and administrative purposes. We may use and retain your personal information, including your purchase history, for administrative purposes, which may include, for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud screening and systems testing, maintenance and development.
To send status updates and service communications to you.
To carry out marketing and keep you informed of Phomemo products.
To improve our websites, products and services. We may monitor the way that you and other customers use our website so that we can identify ways to improve your user experience.

How do we collect information?

We collect information on our website, through our ads, and through our email and other communications and interactions with you. We obtain information directly from you when you provide it to us and we also obtain information about you from third-party sources, including automatically collected information (discussed below) and information we receive from publicly available sources. We collect and obtain:

User provided information: We collect information you provide to us when you sign up for our newsletter or mailing lists, sign up for contests and special promotions, fill out a survey, send us email, send us postal mail, engage in a business relationship with us, or speak with us on the telephone.

Information from social media: When you interact with us over social media, we may collect information about you. If you post information or otherwise interact with us through social media websites, social media platform plug-ins, or other applications we use, we may collect or receive information that you provide or that is automatically collected by the social media platform. Information that you post on social media platforms may become public, depending on your account settings. Information collected by social media platforms when you interact with their services is governed by the social media platforms’ respective privacy policies. For more information about how you can customize your privacy settings and how third-party social media websites handle your personal information, please refer to their privacy policies. We have a presence on Facebook, Twitter, Instagram, YouTube, Snapchat, and Pinterest.

Information from third parties: We receive personal information from:

(a) Third-party service providers that we use to perform business functions on our behalf (including, without limitation, web hosts, email service providers, analytics companies and advertising networks);

(b) Marketing affiliates that we work with to develop and encourage relationships with consumers interested in Phomemo products;

(c) Brand licensees with whom we have a relationship in which they may, depending on the relationship, develop, manufacture, market, and/or sell Phomemo products;

(d) Other third-party partners we work with to supplement or enhance our information. We also may collect information from publicly available sources.

Information collected using automated collection methods / cookies: When you use our website, read our emails, interact with our ads and other online content, interact with us on social media platforms, or otherwise engage with us through a computer or mobile device, we and our third-party partners collect automatically collected information. This information typically is collected through a variety of technologies, including cookies, web beacons, location-identifying technologies, social media widgets, and similar technologies (collectively, “automated collection methods”).

How do we use your personal information?

The following is a description of how we use the personal information we collect and receive from other sources. Automatically collected information and other personal information may be combined with other information that we collect directly from you or that we receive from other sources and used for the purposes described below.

To provide services to you.
To provide the website and its functionalities to you.
To provide services requested by you.For example, if you sign up for our newsletter, we will use the information you give us to send you our newsletter.
To respond to your requests.If you contact us with a question or a request, we will use your information to respond to your request. For example, if you contact us via email with a question, we will use the information in that email and the email address you used to contact us to respond to you.
To provide you with location-specific services.If you elect to share your location information with us, we may use that information to tailor options, functionality or offers related to your location. We also may use your IP address to determine your general location, which also may be used to tailor offers to you.
To offer and conduct promotions and contests.
To conduct data analytics to support our website and business

Typically, these analyses are done using of aggregated or otherwise de-identified data. We use information, including automatically-collected information collected using automated collection methods, to manage and improve our website and our business. For example, we use such information to:

Manage our business needs, such as monitoring, analyzing, and improving the services and the website’s performance and functionality.For example, we analyze website user behavior and conduct research and analysis about the way you and other users use our website.
Manage risk and protect the website.We use data to better protect our services, our website, and you by helping to detect and prevent fraud and abuse of the website and our services.
Tailor ads to your apparent interests.For more information about interest-based advertising, review the “Which analytics and interest-based advertising partners do we use?” section below.
Develop new products, services and offers.

How do we disclose your personal information?

We do not share your personal information with third parties except in the circumstances described below.

Our Related Companies.We may share your personal information with our related companies, which, for the purposes of this Privacy Policy, include our wholly-owned subsidiaries. We require these companies to use your personal information in a manner that is consistent with this Privacy Policy.

Our Third-Party Partners.We may share your information with the categories of third parties listed below:

(a) Third-Party Service Providers. We may share personal information with third parties who provide business services to us or on our behalf.

(b) Brand Partners. We may share your personal information with our brand partners, typically, our brand licensees. These third parties operate as separate controllers, and are responsible for their own compliance with data protection laws. For more information about brand partners with whom we may share your personal information, and information about their practices.

Mergers or Business Transactions.As we continue to evolve our business, we might enter into mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, users’ personal information may be shared, sold or transferred and used subsequently by third parties. If personal information is shared, sold or transferred in one of these types of transactions, its use will remain subject to the provisions of this Privacy Policy (unless you consent otherwise).

Legal Protection.It may become necessary for us to release personal information to law enforcement, government entities, courts, government regulators, our legal advisors, or other third parties as required or allowed by applicable law if we believe the release is necessary or required for us to:
Satisfy any applicable law, regulation, legal process or enforceable governmental request;
Enforce our Terms and Conditions or other policies, contracts or agreements;
Detect, prevent, or otherwise address fraud, security or technical issues; or protect the rights, property or safety of Phomemo.com, our owners, service providers, licensees, users or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Upon Your Consent.Unless otherwise shared in a manner provided above in this Privacy Policy, you will receive notice before personal information is shared with third parties, and you will have an opportunity to choose to share your personal information for such purpose.

Third-party partners use included

Cookies, which are small text files that many websites automatically download to a user's computer or other device when they browse online. Cookies are often used to collect standard Internet log information and visitor behavior data. We use cookies to increase website functionality, personalize content and ads, to provide social media features, to collect information about how our website is used, and to analyze our website traffic. We also share information about your use of our website with brand licensees. The browser cookies that our website uses may include both session-based cookies and persistent cookies (which remain on your computer or other device after your browsing session has ended).

Web beacons or tags, which are small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our website, or open an email we send to you;
Website log files, which we or our service providers create automatically when you access and use our website;
Flash cookies, also known as locally shared objects, which are able to handle more complex information than a browser cookie and are able to pass information across the different browser types you may have installed on your device.
Scripting languages, such as JavaScript, used by Google Analytics, to transmit information to Google's servers about site visitors, including the specific web pages that are being viewed, some technical information about the visitors computer (such as if they are using a Windows or Mac machine, or on a desktop or mobile device), how they arrived at the website, and the way that they navigated throughout its pages.

Web beacons or tags, which are small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our website, or open an email we send to you;

How long do we retain your personal information?

We will keep your personal information for the period necessary to fulfill the purposes described in this Privacy Policy unless a longer retention period is permitted or required by law. In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

How secure is my information?

Phomemo has implemented reasonable physical, technical, and administrative security standards to protect personal information from loss, misuse, unauthorized access, alteration, or destruction. Although we take reasonable steps to safeguard personal information, no practices are 100% secure, and we do not guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. You must protect against unauthorized access to your computer and important information. We strongly recommend that you log off each time you finish using a shared computer.

Do we collect information from children?

Our website is not directed to or intended to be used by children under 16 years of age. No one under the age of 16 is authorized to provide any personal information to or on the website, and we do not knowingly request or collect personal information from any individual under 16 years of age. If you are under 16 years of age, do not use this website, sign up for our newsletter, or provide any information about yourself to us, including without limitation your name, email address, postal address or location. If you are a parent or guardian and believe that your child under the age of 16 has submitted personal information to us in connection with the website or otherwise, please email us at support@phomemo.com so that we can take steps to delete the personal information as required in accordance with applicable law.

Our blog

Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third-party data processors detailed below. Only your name will be shown on the public-facing website.

Your comment and its associated personal data will remain on this site until we see fit to either

(a) Remove the comment or (b) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us at support@phomemo.com using the email address that you commented on.

If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.

NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.

Payment information

When you buy our products over the Internet, your web browser connects with the website through an SSL ("Secure Sockets Layer"). SSL is an industry-standard protocol for encryption over the Internet.

All of your personal information is encrypted as it travels over the Internet, to and from this website. When information is encrypted, it is scrambled between your computer and our server. The information is only unscrambled when it safely reaches us. It's fast and safe, and it ensures that your personal information cannot be read by anyone else.

Data Breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

The Existence of Automated Decision-Making, Including Profiling.

Phomemo does not take any decisions involving the use of algorithms or profiling that significantly affects you.

Integrity and Retention of Personal Information

Phomemo makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Phomemo to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to Phomemo employees and strictly enforce privacy safeguards within the company.

Changes to our Privacy Policy

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the changelog below.

Contact forms and email links

Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third-party data processors defined in this Privacy Policy.

Additional Information and How to Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us ：

Email At: support@phomemo.com

Facebook：PhomemoPlus

write to us at: Phomemo

Phomemo APP Privacy Policy

Updated: November 9, 2023

Effective Date: November 9, 2023

Zhuhai Quin Technology Co., Ltd. (hereinafter referred to as "we" or "us") respects and protects the privacy of our users. When you use the services provided by the Phomemo's APP platform (hereinafter referred to as "Phomemo"), we will follow the principles of lawfulness, legitimacy, and necessity to openly and explicitly collect and use your personal information in accordance with the "Phomemo Privacy Policy" (hereinafter referred to as "this Privacy Policy").

Please read this entire Privacy Policy carefully so that you understand the purpose, scope, and manner in which Phomemo collects and uses your personal information.

We realize how important your personal information is to you and we do our best to keep it safe and secure. We are committed to maintaining your trust in us by adhering to the following principles to protect your personal information: the principle of consistency of authority and responsibility, the principle of clarity of purpose, the principle of opt-in consent, the principle of minimum necessity, the principle of ensuring security, the principle of subjective participation, the principle of openness and transparency, and so on. At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with the industry's mature security standards.

This privacy policy will help you understand the following:

Ⅰ. Scope of application

Ⅱ. How we collect and use your personal information

Ⅲ. How we use cookies and similar technologies

Ⅵ. How we commission, share, transfer and publicly disclose your personal information.

Ⅴ. How you manage your information and account cancellation

Ⅵ. How we store your personal information

Ⅶ. How we protect your personal information

Ⅷ. Revisions of this policy

Ⅸ. Dispute Jurisdiction

Ⅹ. Contact Us

Ⅰ. Scope of Application

This Privacy Policy applies to all services offered by Phomemo except for certain specific products and services. These specific products and services will be subject to specific privacy policies.
It should be noted that this Privacy Policy does not apply to services provided to you by third parties except for the sharing of information with third parties as agreed in Article 4 of this Privacy Policy and confirmed by you. Please know that if you provide personal information to a third party when you browse its website or use its products or services, your information shall be subject to the privacy policy of the third party, and we shall not be responsible for any legal liability, so please be sure to read the third party's privacy policy carefully and confirm your acceptance of it.

Ⅱ..How we collect and use your personal information

Personal information refers to all kinds of information recorded by electronic or other means that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

Sensitive personal information refers to personal information that, if leaked, illegally provided or misused, may jeopardize the safety of persons and property, and is highly likely to lead to damage to a person's reputation, physical or mental health, or discriminatory treatment.

The products and services we provide need to rely on some of your information to operate, so when you use Phomemo, you need to provide us with or allow us to collect the necessary information for us to use this information to provide you with basic services and better and better services, based on the different business functions, we will collect and use the type of your personal information is divided into two kinds: first, to realize the products and services of the basic business functions necessary information and may need to collect information, second, if you refuse to provide the information necessary to realize the basic business functions of the products and services and the corresponding services, we will not be able to provide you with the basic business functions and the corresponding services. The information that is necessary to realize the basic business functions of the products and services and the information that may need to be collected, the information that is necessary to realize the basic business functions of the products and services is the necessary personal information, if you refuse to provide it, we will not be able to provide you with the basic business functions and the corresponding services; the second is the information that may need to be collected for the expansion of the business functions, you can independently choose whether to provide it or to authorize us to collect it, and we will collect the necessary personal information on the basis of your authorization to agree or to authorize us to collect the necessary information. We will process such personal information based on your authorized consent or for the purposes necessary for the realization of the extended business functions you have chosen. If you refuse to provide such information, we will not be able to provide you with the extended business functions, but it will not affect your use of our basic business functions.

1.We collect and use your personal information for the purposes stated in the following scenarios:

1.1Maintaining the normal operation of basic functions, network and operational security

When you use Phomemo APP, in order to ensure your normal use of our services, to maintain the normal operation of our services, to improve and optimize the experience of our services and to protect the security of your account, we will collect your operation logs, service logs (network request information, operation paths, exception information, Bluetooth connection of the device and print interaction logs, interaction parameters, SDK initialization results) information, so that we can analyze and troubleshoot the causes of user failures. We will collect your operation logs, service logs (network request information, operation path, exception information, device Bluetooth connection and print interaction logs, interaction parameters, SDK initialization results) so that we can analyze and troubleshoot the causes of user failures.

1.2 Customer Service
When you contact us, you can describe the problem by uploading a picture or video, which requires access to your camera or photo album; you can upload a picture for feedback, which requires access to your camera or photo album, in order to provide you with customer service. Our customer service will use your account information to verify your identity with you. It is possible that you may provide information other than that given above when communicating with our customer service staff. Failure to do so will not affect your ability to use other features and services of this product.

1.3 Permissions Required for Business Functions

1.3.1. Based on the implementation of business functions, each business function may collect your system privileges as follows:
1.3.1.1. Phomemo APP belongs to the category of utilities, and no personal information is required to use the basic functions. The basic business functions include:

Add Device: When you use the device search, connect, print function, we will request your camera (camera) permission, Bluetooth permission for searching and connecting Phomemo printer. Due to the operation mechanism of the cell phone operating system, the system Bluetooth function will force to ask for the location permission, so after applying for the Bluetooth permission, we will apply for your location information, including the approximate location and the exact location, in order to finally realize the connection to the printer via Bluetooth.

Graphic editing: When inserting pictures, you need to get your store/read (and album) permission to generate a print document for printing.

Picture Printing: Using Picture Printing requires obtaining your Store/Read (and Album) permissions for inserting pictures from an album for printing.

Document Printing: Using Document Printing requires you to obtain store/read permissions to read and find documents from storage for printing.

Scanning: To use the scanning function, you need to get the camera (camera) permission and album permission, which are used to use the camera to take pictures for scanning and printing, and to insert pictures from albums for scanning and printing.

Query Print History and Save Print History: You need to get Store/Read permission to find the content saved in the storage space and save the content in the storage space.

1.3.1.2. Expand business functions:

Photo Translation: When you use the photo translation function, obtain camera (camera) permissions and album permissions, which are used to use the camera to take photos for scanning and printing, and to insert pictures in albums for OCR recognition and translation; obtain your storage/reading (and album) permissions, which are used to use to find contents saved in the storage space and to save contents in the storage space.

Featured templates/common materials: Get your store/read (and album) permission to use to save content in the storage space.

2. Exceptions to Prior Consent

According to the laws and regulations, in the following cases, the partner does not need to obtain your authorized consent when using or we transfer or disclose your personal information:

2.1. Necessary for the conclusion and fulfillment of the contract signed between us and you;

2.2. Necessary for the fulfillment of legal duties or obligations;

2.3. necessary to respond to a public health emergency or to protect the life, health and property of natural persons in an emergency;

2.4. to handle personal information within a reasonable range for the purpose of news reporting and public opinion monitoring in the public interest;

2.5. to handle personal information that has been disclosed by an individual on his or her own initiative or that has been otherwise lawfully disclosed within a reasonable scope in accordance with the provisions of this Law;

2.6. in other cases prescribed by laws and administrative regulations.

3.Anonymization

The information we collect about you will be anonymised in a timely manner by technical means. On the premise of not disclosing your personal information, we have the right to analyse, mine and utilise the anonymised user data, and to carry out statistical analyses of the use of Phomemo's products for the purpose of possible third-party information sharing.

III. How we use cookies and similar technologies

We, or our third party partners, may collect and use your information through cookies and web beacons and store such information as log information. We use our own cookies and web beacons for the purpose of providing you with a better user experience and service and for the following purposes:

1. remember your identity. For example, cookies and web beacons help us to recognize you as our user or to store information you provide to us about your preferences or other information.

2. to analyze your use of our Services. For example, we may use cookies and web beacons to understand what activities you use our Services for or which Services are most popular with you.

While we use cookies and web beacons for these purposes, we may provide non-personally identifiable information collected through cookies and web beacons to other partners for statistical processing to analyze how users use our Services.
Our products and services may have cookies and web beacons placed by other partners, which may collect non-personally identifiable information about you for the purpose of analyzing how you use such products or services. The collection and use of such information by these third-party cookies and web beacons is not governed by this Privacy Policy, but rather by the privacy policies of the relevant third parties, and we are not responsible for such cookies and web beacons.

You can refuse or manage cookies through your browser settings, but please note that if cookies or web beacons are deactivated, you may not be able to enjoy the best possible experience with the Services, and certain products or services may not function properly.

IV. How we entrust the handling, sharing, transfer and public disclosure of your personal information

1.We will treat your information with a high degree of diligence, and we will not share your personal information with any company, organization or individual outside of our company unless we have obtained your express consent, except for those cases where we are unable to identify a specific individual after processing and cannot be recovered. Currently, we may ask you for your authorized consent to share personal information in the following situations:

1.2. Based on technical needs, Phomemo APP is required to integrate a third-party software development kit (SDK). The information to be collected or shared with the integrated third-party SDK is as follows:

SDK name：Umeng+SDK

Third party name：Umeng Tongxin (Beijing) Technology Co.

Usage Scenario：Provides statistical analysis services and calibrates report data accuracy by geolocation, providing basic anti-cheat capabilities.

Information collected by SDK: Device information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI/ICCID), location information, network information

SDK name：Baidu Text Recognition SDK

Third party name：Beijing Baidu Netcom Technology Co.

Usage Scenario：For end users to perform text recognition when finally selecting album images, with support for model loading, memory optimisation and log message storage; for users to take pictures for text recognition

Information collected by SDK: IP address, device information, read/write access to external memory card, open camera access

SDK name：Bugly SDK

Third party name：Shenzhen Tencent Computer System Co.

Usage Scenario：If the app runs abnormally in the background, the SDK may collect the above personal information of the end user in the background for troubleshooting and dealing with the crash issue

Information collected by SDK: Receive and record information about the device you are using (e.g., device model, operating system version, device settings, MAC address and WiFi status, CPU architecture or attributes, disk space, memory space, and other hardware and software characteristics) based on specific permissions granted by you during software installation and use.

We will only share your personal information for lawful, legitimate, necessary, specific and defined purposes. For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to handle the information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures, and the recipients of the information will only have limited access to your information, and they will also be required to take on contractual obligations, including, but not limited to, using lawful and compliant means to obtain your information, taking reasonable They also need to undertake contractual obligations, including the use of lawful and compliant methods to obtain your information, take reasonable security measures to protect your information, and bear the corresponding legal responsibilities in accordance with the provisions of the law and the agreement with us. For some open source, free partners appear if there is leakage of your information and other violations of your personal rights and interests, we bear the corresponding responsibility.

2.we will not unlawfully sell, unlawfully provide your information to others; we will not provide such information about you to any third party or use it for any other purpose or use, except for the following:disclosed to a third party with your prior consent;

a.to a third party or an administrative or judicial body in accordance with the relevant provisions of the law or at the request of the administrative or judicial body;

b.may use your information for authentication, customer service, security prevention, fraud monitoring, archiving and backup purposes in the provision of our services to prevent, detect, and investigate fraud, compromise of security, illegality, or violation of agreements, policies, or rules with us to protect you, other users, our affiliates, partners, and other trusted third-party vendors, service providers, agents and the public to ensure the safety of the products and services we provide to you;

2.4. we cooperate with third parties to provide you with services related to the Phomemo Platform or other network services, and such third parties agree to take the same responsibility as we do to protect the privacy of our users;

2.4. other disclosures that are required by law, regulation or policy.

3.We will publicly disclose your personal information only under the following circumstances:with your individual consent;

a.Disclosure based on law: We may publicly disclose your personal information when required by law, legal process, litigation, or mandatory requirements of governmental authorities.

4.Exceptions to prior authorized consent for sharing, transferring, or publicly disclosing personal information:Related to the fulfillment of obligations by the controller of personal information under laws and regulations;

a.directly related to national security, national defense security;

b.directly related to public safety, public health, or significant public interest;

c.directly related to criminal investigation, prosecution, trial and execution of judgment;

4.5. for the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals, but it is difficult to obtain the authorization of the consent of the person himself/herself.

4.6. Personal information that the subject of personal information discloses to the public on his or her own;

4.7. personal information collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.

5.According to the law, sharing, transferring or disclosing personal information that has been de-identified and ensuring that the recipient of the data is unable to recover and re-identify the subject of the information does not constitute an act of sharing, transferring or publicly disclosing personal information externally, and there is no need to obtain your consent for the preservation and processing of such data.

V. How do you manage your own information and account cancellation

In accordance with the relevant Chinese laws, regulations and standards, as well as the common practice in other countries and regions, we guarantee that you can exercise the right of inquiry, correction, deletion, revocation, cancellation, transfer of personal information, and other rights with respect to your personal information. As there is no login and registration function in Phomemo APP, no relevant personal information is collected, and there is no function to view and cancel relevant personal information.

1.Automated decision-making in constrained information systems

In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including algorithms. If these decisions affect your legal rights, you can contact us through customer service.

VI. How we store your personal information

1. The personal information we collect and generate in our operations in the People's Republic of China is, in principle, stored in the People's Republic of China, and your personal information is stored in accordance with the storage period stipulated in the laws and regulations of the People's Republic of China, departmental rules and regulations, and so on.

2. The storage period is for the duration of your use of Phomemo or until you send Phomemo a request to delete your personal information, and we will delete your personal information in a timely manner when you request the deletion of the stored information or decide to stop using Phomemo and cancel your account. We will also retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless there is a mandatory retention requirement by law. For example, the Law of the People's Republic of China on Electronic Commerce requires that information on goods and services and transaction information be retained for a period of not less than three years from the date of completion of the transaction, and that logs of user behavior in connection with the Services be anonymized. The criteria for determining the foregoing period include:to fulfill the purpose of transactions related to you, to maintain corresponding transaction and business records, and to respond to your possible inquiries or complaints;

a.to ensure the security and quality of the services provided to you by the Platform;

b.whether you agree to a longer retention period;

c.whether there is any other special agreement on the retention period.

3.After your personal information exceeds the retention period, the Company will delete or anonymize your personal information in accordance with the requirements of applicable laws (if you are a minor, we will handle your personal information in accordance with the requirements of relevant laws and regulations after your personal information exceeds the retention period). If we are unable to delete your personal information in accordance with the relevant requirements due to special circumstances, we will explain this part of the matter to you.

VII. How we protect your personal information

1. We take the security of your personal information very seriously. We strive to protect your personal information by taking all reasonable physical, electronic, and managerial security measures and use our best reasonable efforts to protect your personal information from disclosure, destruction, or loss, including but not limited to SSL, encrypted storage of information, and access control in data centers. We also take strict management of employees or outsourced personnel who may have access to your personal information, including but not limited to adopting measures such as controlling access rights to information, signing confidentiality agreements with personnel who have access to personal information, and monitoring the operation of such personnel.

2. Despite the agreement in paragraph 1 above, please understand that due to the existence of a variety of unpredictable or existing technology can not be defended against malicious means, even if we have tried to take the necessary protection measures, your information may still be leaked, destroyed or lost. If you find that your account number or password has been or will be leaked for any reason, you should contact us immediately so that we can take timely measures to prevent or minimize your losses. 3.

3. In the unfortunate event of personal information security incident, we will activate the contingency plan to prevent the security incident from expanding, and will promptly inform you in accordance with the requirements of laws and regulations of the following: the basic situation of the security incident and its possible impact, the measures we have taken or will take to deal with the incident, the suggestions you can independently prevent and reduce the risk, and remedial measures for you. We will promptly inform you of the situation related to the incident by email, letter, phone call or push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective ways to publish announcements. At the same time, we will also take the initiative to report the disposition of personal information security incidents in accordance with the requirements of the regulatory authorities.

4. If we undergo a merger or separation of enterprises, your information will continue to be protected by the surviving enterprise subject at that time, and we will notify you by way of announcement, SMS or other written methods; if our products or services cease operation, we will stop collecting your information in time and notify you by way of announcement, SMS, etc., and we will delete or conceal your information at that time. We will delete or conceal your information at that time.

VIII. Revision of this policy

Our User Privacy Policy is subject to change. We may update this policy in due course if there is a material change in any of the following circumstances that may materially diminish or materially affect your rights under this policy:

1. a significant change in our service model. For example, the purposes for which personal information is processed, the types of personal information processed, and how personal information is used;

2. a significant change in our ownership structure, organizational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions;

3. Changes in the main targets of sharing, transferring, or publicly disclosing personal information;

4. Significant changes in your rights to participate in the handling of personal information and how you exercise them;

5. Changes in the department responsible for handling the security of personal information, contact information and complaint channels;

6. When the security impact assessment report of personal information indicates that there is a high risk.

The revised Privacy Policy will be announced through the Phomemo Platform or notified to you by other appropriate means before the revision takes effect. In such cases, if you continue to use our services, you agree to be bound by the revised Privacy Policy.

Ⅸ. Dispute Jurisdiction

1. The laws of the People's Republic of China shall apply to the signing, entry into force, fulfilment and dispute resolution of this Privacy Policy.

2. Disputes relating to this agreement shall be resolved through friendly negotiation; if the negotiation fails, the dispute will be submitted to the court of competent jurisdiction in the place where the company is located to resolve the dispute.