Updated: 2023-10-19

We attach great importance to protecting the personal information and privacy of users (hereinafter referred to as "you"). When you register, log in and use MELLOW, we will collect, use, save and share your relevant personal information. In order to present the situation of how we handle your personal information, we have specially formulated the "MELLOW Privacy Policy" (hereinafter referred to as the "Privacy Policy"), and we promise to handle your personal information strictly in accordance with this Privacy Policy.

Before you register and log in to MELLOW, please be sure to read this Privacy Policy carefully and fully understand the terms and conditions. You know and confirm that when you check or click "Agree" to this Privacy Policy, you agree that we will handle your personal information in accordance with this Privacy Policy.

This privacy policy will help you understand the following:
I. Face Data Policy
II. Personal Information
III. Rights Related to Personal Information
IV. Third-party Terms and Conditions
V. Permissions
VI. Third-party SDK Service Description
VII. Account Deletion/Cancellation
VIII. Contact Us
IX. Minor Terms
X. Amendment of Privacy Policy
XI. Others

I. Face Data Policy

1. Collected Face Data
We analyze your photos to find the feature points of the face (such as eyes, nose, mouth points) or body features in the photos for face clipping (body segmentation). We do not collect face data. After the analysis process is completed, all data on the server will be deleted and no data will be saved. Refusing to provide the above information may prevent you from using core functions (such as flying special effects), but will not affect the normal use of other functions and services.

2. Purpose and process of collecting facial data
In order to provide you with the "portrait cutout" related effects, we need to find facial feature points (such as eyes, nose, mouth points) or body features.
The complete process is:
(1) You submit the selected photo to our server in an encrypted manner;
(2) The server analyzes the facial data or body data in your photo and automatically cuts out the image;
(3) After the cutout is completed, the server returns the final cutout effect to you through the application;
(4) The final synthesized effect (i.e. your "work") will be temporarily stored in the encrypted storage of your device (history), and you can delete it manually.
After the synthesis process is completed, we will immediately delete the facial image you submitted to the server.

3. Sharing and storage of facial data
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 photos you uploaded will be permanently deleted.

II. Personal Information

1. Document Reading and Management
When you store automatic tasks, record crash logs and other information, we need to call your device storage, all document access and clipboard permissions. We call the above permissions to help you complete document reading, management, document search, document naming and content editing. Except for the document materials you select, we will not process other document materials in your storage space. If you do not agree to our calling the above permissions, you may not be able to complete document reading and management and cannot use our services normally.

2. Ensure the basic security of network access and services
In order to ensure the basic security of your account, network access and services, we need to call your device's phone permissions. We need to collect your unique device identifier (IDFA, Face ID, unique identifier derived by algorithm), mobile phone system language, country, city, IP address, MAC address, device information, your network behavior track (including number of clicks, participation time), access date and time, service log information. We will combine the above information with the information provided or generated when you use the service, process and analyze the data, and form a user profile and relevant risk control records for the account. We collect the above information to ensure the security of your account, network access and application operation.

3. Ensure the reliability and stability of the service
In order to ensure the reliability and stability of the service, we need to collect your device model, operating system version, browser type, language used, network access method, network quality data, and the software registration account ID. We will also collect the operation data and software crash data of this software through Umeng SDK and Tencent bugly. We collect the above information to ensure the reliability and stability of the application operation.

4. Customer Service
When you make a complaint, suggestion or feedback to us, in order to facilitate contact with you, help you solve the problem as soon as possible or record the solution and results of the relevant problem, we may collect your communication or call records with us, the account information you provide, the contact information you provide, the information you provide to prove the relevant facts, program operation logs, device information, system version, device language country. We collect the above information to provide customer service. If you do not provide such information, your complaints, suggestions and feedback may not be handled in a timely and effective manner, but it will not affect your normal use of our other services.

III. Rights related to personal information

1. Correct your personal information
When you find that there is an error in the personal information we process about you, you have the right to ask us to make corrections. You can contact us in time to correct the information through the customer service contact information in the software, and we will respond to your correction request within three working days.

2. In the following circumstances, you can ask us to delete personal information:
If our processing of personal information violates laws and regulations;
If we collect and use your personal information without your consent;
If our processing of personal information violates the agreement with you;
If you no longer use our products or services;
If we no longer provide you with products or services.
If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us and request them to delete it in a timely manner, unless otherwise provided by laws and regulations, or these entities obtain your independent authorization. When you delete information from our services, we may not immediately delete the corresponding information from the backup system, but we will delete the information when the backup is updated.

3. Your right to know about the management of personal information going abroad
The above information you provide will continue to be authorized for our use during your use of this service. When you cancel your account, we will stop using and delete the above information. The above information will be stored in the territory of the People's Republic of China. If cross-border transmission is required, we will strictly comply with laws and regulations and obtain your authorization and consent separately.

IV. Third-party terms and conditions

1. Please note that when you use and access our services, you may also be subject to the terms and conditions and privacy policies of certain third parties such as app stores, map providers, mobile software platforms, online game platforms, social networking sites, etc. You acknowledge and agree that we do not need to be responsible for the terms and conditions of these third parties and how they use your personal information.
2. We may choose to allow you to link to third-party products or services through advertising or other forms. Please note that the third-party products and services you use are not developed and managed by people and companies affiliated or controlled by us. We are not responsible for the actions, products and services of these people or companies, or how they use the information you provide. Our provision of links to them does not allow us to be associated or controlled by them.
3. We may provide services from our partners at any time, such as competitions, surveys, etc. Their services may require you to provide personal information to register or access. These services will indicate the identity of the partner when you need to disclose personal information. If you choose to disclose personal information, then this data may be provided to third parties directly or indirectly through us. You will be subject to the privacy policies and practices of these third parties. We are not responsible for the privacy policies and practices of these third parties. Therefore, you should review their privacy policies and practices before disclosing personal information.

V. Permission Description

The calls of system privacy permissions by various business functions are as follows:

Serial number Permission name Obtaining method Purpose of obtaining this permission
1 Access the network Silent acquisition Used to obtain network status and make network requests to use network browsing and speed measurement functions
2 Advertising identifier Dynamic acquisition, user active authorization Used for statistical analysis and anti-cheating

VI. Third-party SDK service description

For statistical analysis and other purposes, our products may integrate third-party SDKs or other similar applications. For the security of your information, we have signed a strict data security confidentiality agreement with third-party SDK service providers, and these companies will strictly comply with our data privacy and security requirements. We will not share your personally identifiable information with them unless you agree.

Third-party name (provider name) Scenario description Collection method Personal information/scope of authority Purpose or purpose Privacy policy
UMeng+(com.umeng) Statistical analysis Call system-related interfaces for automatic collection Device Mac address, unique device identification code (IMSI, IMEI, Android_ID, ICCID, device serial number, etc.), obtain running process information Provide statistical analysis services, and provide basic anti-cheating services by calibrating the accuracy of report data through geographic location. Click to view third-party privacy policy

VII. Account cancellation/deletion

If you do not want to continue using this software, please contact the customer service in the software when you need to cancel. We will complete the cancellation within 1 working day. After the account is cancelled, you cannot continue to log in, and the relevant data will be cleared.
You can also cancel yourself. After logging in with your mobile phone number or WeChat, cancel according to the following methods: Go to "My" -> Click "Avatar" -> Click the "Account Cancellation" button at the bottom of the "Personal Information" page -> Click "Agree to Cancellation Agreement" - Complete the cancellation.

VIII. Contact Us

Contact: Qiu Junying, Address: Fuel Garden, No. 27 Dongpu Road Unit 301, Unit 1, Building 1 Xiamen City, Fujian 361000, Contact: 17040493489.

IX. Minor Terms

If you are a minor under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using the "MELLOW" software and related services.
We protect the personal information of minors in accordance with the relevant laws and regulations of the country, and will only collect, use, share or disclose the personal information of minors when permitted by law, with the explicit consent of parents or other guardians, or when necessary to protect minors; if we find that we have collected the personal information of minors without obtaining verifiable parental consent in advance, we will try to delete the relevant information as soon as possible.
If you are the guardian of a minor, please contact us through the contact information disclosed in this Privacy Policy when you have questions about the personal information of the minor you are protecting.

X. Amendment of Privacy Policy

Our privacy policy may change.
Without your explicit consent, we will not reduce your rights under this Privacy Policy. We will post any changes to this Privacy Policy on this page, please pay attention and check at all times.
For major changes, we will notify you on the main exposure page of the product or service or other appropriate means to reach you. If you do not agree to such changes, please immediately stop using this software and its services.

Major changes referred to in this policy include but are not limited to:

1. Major changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;
2. Major changes in our ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy and mergers and acquisitions, etc.;
3. Changes in the main objects of personal information sharing, transfer or public disclosure;
4. Major changes in your rights to participate in the processing of personal information and the way they are exercised;
5. When the responsible department, contact information and complaint channels for handling personal information security change;
6. When the personal information security impact assessment report indicates a high risk.

XI. Others

1. Please understand that social networks and our services may be open. You choose to disclose information about you to our services in the process of creating content. Any data you disclose in forums, blogs, chats and other environments may become public information and cannot be expected to be private or confidential. We are not responsible for any personal information you choose to disclose in the above occasions.
2. If you are considered a minor in your place of residence, please obtain the consent of your guardian before using or accessing our services. We encourage parents and/or guardians to actively guide their children's online activities. If users are considered minors in their place of residence, we will not knowingly collect their information. If we learn that their personal information has been inadvertently collected, we will take reasonable steps to immediately delete their personal information from our records.
3. We may retain and/or disclose your personal information to overseas affiliates and partners in accordance with the law and this Policy. We may disclose your personal information to third parties in connection with major changes such as corporate mergers, reorganizations, and sales of all or part of our stock and/or assets, including but not limited to due diligence, but this Policy will continue to apply to such personal information.
4. Your data is controlled by the Company, and this Policy and our use of your personal information are governed by the laws of our place of residence. Our place of residence is not necessarily where you are. If you do not want to receive communications such as press releases and promotional information from us, please contact customer service.
5. We will strive to enable you to review, update or correct your personal information stored with us. If you need to review, update or correct, please contact customer service. In order to identify you, verify your request and help process your request, we will need sufficient information about you. Please note that even if your personal information is changed or deleted in accordance with your request, we may still retain some of your data for the purpose of resolving disputes, enforcing the user agreement, and complying with technical and legal requirements related to security, integrity, and service operation.
6. We will regularly evaluate compliance with this Agreement. If we receive a formal written complaint from you, we will try to contact you directly to resolve it. We will cooperate with relevant national authorities, including data protection authorities, to resolve any complaints about the collection, use, transfer, and disclosure of personal information that you and we cannot resolve amicably. Any dispute, controversy, or claim arising from this policy or related to the violation, termination, or effectiveness of this policy shall be resolved by a court with jurisdiction over our place of residence.