This policy will help you understand the following contents that might be involved when you use Camera360:

• 1、Our collection and use of your personal information
• 2、Our using of Cookie and similar technologies
• 3、Our sharing, transfer and public disclosure of your personal information
• 4、Our protection of your personal information
• 5、Your rights
• 6、Our handling of personal information of juveniles
• 7、Global transfer of your personal information
• 8、Applicable laws and jurisdictions
• 9、Renewal of the Policy
• 10、Our contact details

With profound understanding of the importance of personal information to you, Camera360 will do its best to protect your personal information. We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of explicit purpose, explicit consent principle, the principle of minimum sufficiency, the principle of security, the principle of subject participation and the principle of publicity and transparency. Furthermore, Camera360 promises to take appropriate security measures to protect your personal information in accordance with the mature security standards in the industry.

Please read and understand this Privacy Policy carefully before using our products (or services).

I. Our Collection and Use of Your Personal Information

Personal information refers to all kinds of information recorded in the electronic form or other forms, which can be used to identify some natural persons or reflect the activities of certain natural persons, either independently or in combination with other information.

Camera360 only collects and uses your personal information out of the following purposes hereby specified in this policy:

A. Business function one: account registration

When you register a Camera360 account, you need to provide your e-mail address and create a new account name and a password . Collection of such information is to help you register a Camera360 account and access all functions of Camera360. If you don’t provide the above-mentioned information, you won’t create the account successfully, but you will still be able to access other fundamental functions except Challenge and Community functions. In registration, you may provide the following information at your own discretion: profile photo, nickname, gender, and country and city where you are located, for us to know you better. If you don’t provide the real information aforesaid, you will still be able to register a account. The system will fill them by default.

B. Business function two: shooting and editing

• 1. When you shoot or edit the photos or videos, to provide you with corresponding services, we may need you to grant the permissions for the following terminals:
• (1) Cameras, for shooting photos and taking videos;
• (2) Microphone, for recording voices in the videos;
• (3) Album (iOS)/storage (Android) permissions, for reading and storing photos and videos;
• (4) Face ID permission, for album encryption;
• (5) GPS permission, for adding location information to details of photos;
• (6) Bluetooth permission, for connecting with the selfie rod to take photos;
• (7) Software installation permissions, for software update and installation;
• (8) Permission to read mobile phone status and user identity, only for in-app purchases made by part of HUAWEI mobile phone users;

If you refuse to grant any of the permissions above, the corresponding functions would not be realized. You can still use Camera360 for other functions.

• 2. When you shoot or edit photos or videos, you will use your face information. Such information is mainly used for identifying the human face and the location of human faces in photos and videos. Based on these locations, users can edit photos and videos by adding filters, stickers and make-up looks. These data of human faces can only be used on your device and we would not collect or store such information.

C. Business function three: community challenge

When you upload videos via Challenge function, we need to collect the videos you uploaded to display them on the Challenge page.

D. In-app purchases

When you made in-app purchases ( e.g. filters, VIP, etc.) in Camera360, we will collect related order information , including IP address, unique device identification code, order number, transaction time, product category, product price and local language.

E. Other business functions

• 1. To constantly improve and optimize our services, rule out the product faults and protect the safety of your account, we might collect the information of your device specification, operation system, unique device identification code, IP address, Device MAC address, network address method, type and status, software use record, click record, operation log, language and time zone, version and browsing history of the browser which uses this product and EXIF data.
• 2. To provide you with customized product contents, recommend product update and functions, and push notifications, we may collect the following information: device specification, operation system, unique device identification code, IP address, network address method, type and status, software use record, click record, operation log, language and time zone, and geographic location information . Such information will be used for establishing user portrait but will not be connected or applied to identify a certain user. In the meantime, we may need you to grant GPS permission and allow notifications. If you refuse to grant any of the permissions above, the corresponding functions would not be realized. You can still use Camera360 for other functions.
• 3. When you provide advice, feedback, enquiry or file complaints to Camera360, to better contact you and help you solve the problem, we might need your name, mobile phone number, e-mail address and other valid contact information . If you refuse to provide above information, the handling of your feedback may not be in time.
• 4. Some third-party functions may be accessed in Camera360, for example, e-commerce, games, livestream, etc. Please read carefully the User Agreement and Privacy Policy of the third parties before use and confirm first. These third-party functions may need to verify your identification information , collect your payment and order information . We will only store and keep your related information only for the purpose of providing or accessing the above-mentioned functions and such information will not be used for any purposes. If you refuse to provide such information, only the third-party functions will be affected, and you can still use Camera360 for other functions.
• 5. Camera360 may be connected to other third-party Apps, but Camera360 only shows advertisements or provides the link to other pages. Be sure to read carefully the User Service Agreement and Privacy Policy before use and confirm before use. Camera360 will not access or store your personal information collected when you use third-party App.
• 6. We may obtain your personal information indirectly from some third party. When you log into Camera360 via a third-party account ( Twitter, WeChat, Apple ID or Huawei ID ), you may allow Camera360, in accordance with relevant laws and regulations, to read and obtain the public information (including your nickname and profile photo) you registered, made public or recorded on such a third party platform.

II. Our Using of Cookie and Similar Technologies

A. Cookie

We will store small data files called cookies on your computer or mobile device to ensure the website works properly. Cookies usually contain identifiers, site name and some numbers and characters. Cookies enable the website to store your preference data.

We do not use cookies for any purpose other than the purposes described in this policy. You can manage or delete cookies according to your preferences. Please see AboutCookies.org for more information. You can empty all cookies stored on your computer. Since most web browsers support blocking cookies, you can empty all cookies stored on your computer by browser setting.

B. Website Beacons and Pixel Tags

In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our websites. For example, an email we send to you may contain a click URL that links to the content of our website. If you click on the link, we will track the click to understand your product or service preferences and improve customer service. A web beacon is usually a transparent image embedded in a website or email. With the pixel tags in the email, we can know if the email has been opened. If you do not want your activity to be tracked this way, you can unsubscribe from our mailing list at any time.

III. Our Sharing, Transfer and Public Disclosure of Your Personal Information

A. Share

We may share your personal information under the following circumstances:

• 1. Sharing with explicit consent: we will share your personal information with other parties upon your explicit consent.
• 2. We may share your personal information externally in accordance with laws and regulations, need for litigation and dispute resolution, or compulsory requirements put forward by government authorities or judicial authorities.
• 3. We may provide your personal information for third parties when it is necessary for protecting Camera360 and its users or the public interest, property or safety from damage to the extent required or permitted by law.
• 4. Sharing with our affiliates: Your personal information may be shared with affiliates of Camera360. Only necessary personal information will be shared for the purposes stated in this Privacy Policy. Your authorization will be asked for again if the affiliate wants to change the purpose of processing personal information.
• 5. Sharing with authorized partners: some of our services will be provided by authorized partners only for the purposes stated in this Policy. We may share some of your personal information with our partners to ensure the delivery of services to you and to provide you with better customer service and user experience. We will only share your personal information for legitimate, proper, necessary, specific and explicit purposes and only share the personal information necessary for service providing. Our partners are not authorized to use the shared personal information for any other purpose.

At present, our authorized partners are classified into the following three types:

• 1) Advertising partners. They assist us in statistics and evaluation of the performance of advertising display and product data analysis, so that we can optimize the service to render you with a better experience. The personal information we provide to these partners may include IP address, device information (device model, operating system, unique device identification number, network access method, type and status, language and time zone).
• 2) E-commerce suppliers. When you use E-commerce platforms connected with Camera360, we may share your order content, user name and contact information and shipping address with third-party merchants to meet your needs for purchasing goods or services from them and facilitate their fulfillment of subsequent after-sales service.
• 3) Technical support partners. In order to utilize corresponding functions, we will access the third-party SDK for technical support, such as helping us to understand the distribution of product users statistically and conduct data analysis. We may provide the following personal information to such partners. Camera360 may choose to use some of these partners or change partners from time to time, so the partners on the list are subject to adjustment.

Name of Third-party SDK	Description of usage scenarios	Types of personal information shared	Privacy Policy
Fabric	For crash log collection	Unique device identifier, geographic location information	Crashlytics Terms of Service
GrowingIO	For data statistics and analysis	Device MAC address, software usage and click history, unique device identifier, geographic location information	GrowingIO Privacy Policy
Bugly(not in iOS)	For crash log collection	Crash log, unique device identifier	Bugly User Agreement
Mi Push(not in iOS)	Personalized push for Mi mobile phone	Login account, unique device identifier	Mi Push Privacy Policy
Umeng Push(not in iOS)	For personalized push	Device MAC address, unique device identifier, IP address	Umeng Privacy Policy
MobTech SDK(not in iOS)	For automatic sharing the shooting results to Facebook, Twitter, Weibo, QQ or WeChat by users	Device MAC address, unique device identifier	MobTech Privacy Policy
AppsFlyer (only for iOS)	For data statistics and analysis	Software usage and click history, unique device identifier, geographic location information , IP address	AppsFlyer Privacy Policy

B. Transfer

We will never transfer your personal information to any company, organization, or individual, except as follows:

• 1. Transfer with explicit consent: we will transfer your personal information upon your explicit consent.
• 2. If transfer of personal information is involved in merger, acquisition or bankruptcy liquidation, we will request the new company or organization which holds your personal information to continue to follow this Privacy Policy; otherwise, we will request the company or organization to ask for your authorization again.

C. Public Disclosure

We only disclose your personal information publicly in the following cases:

• 1. Your explicit consent is obtained;
• 2. Law-based disclosure: We may disclose your personal information publicly as required by laws, legal procedures, litigation or government authorities.

D. Exception

In accordance with the relevant laws and regulations, we may collect, share, transfer or publicly disclose your personal information without obtaining your consent in the following cases.

• 1. Cases directly related to national interests such as national security and national defense security;
• 2. Cases directly related to vital public interests such as public safety, public health and public acquisition;
• 3. Cases directly related to crime investigation, prosecution, trial and judgment enforcement;
• 4. Cases where it is difficult to obtain your consent but the purpose is to protect your or other individuals' vital legitimate interests such as life, property and reputation, etc.;
• 5. Cases where it is necessary for signing and performing contracts according to your requirements;
• 6. Cases where it is necessary for maintaining safe and stable operation of the products or services provided, such as identification or disposal of failures of products or services;
• 7. Cases where it is necessary for statistics or academic research in the public interest and personal information contained in the results of academic research or description provided externally is de-identified;
• 8. Cases where personal information is collected from legally and publicly disclosed information, such as legal news reports, government information publicity, etc.;
• 9. Other circumstances stipulated by laws and regulations.

IV. Our Protection of Your Personal Information

• A. We’ve applied industry-standard safety protection measures to your personal information provided to prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We’ll take all reasonable and feasible measures to protect your personal information. For example, exchange of data between your browser and the “Service” (such as credit card information) is protected by SSL encryption; we provide supporting Web service for products with HTTPS secure access; we’ll apply trusted protection mechanisms to preventing data from malicious attack; we’ll deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will organize security and privacy protection training courses to strengthen employees' awareness of the importance of personal information protection.
• B. We’ll take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We promise that the storage time of your personal information is always within rationally necessary term as required by laws or needed for realization of product features and services. We’ll delete or anonymize personal information immediately upon expiration.
• C. We highly recommend avoiding sending personal information by means of Email, instant messaging and unencrypted ways to communicate with other Camera360 users, as the Internet environment is not absolutely safe. Please use complex passwords to help us keep your account secure.
• D. We’ll do our best to ensure or guarantee the security of any information you send us, as the Internet environment is not 100% safe.
• E. In case of incidents of personal information security, we will promptly inform you as required by laws and regulations of: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risk autonomously and remedies for you, etc.. We will promptly inform you of everything about the incident by email, phone and push notification, etc., and make an announcement in a reasonable and effective manner when it is difficult to notify the subjects of individual information one by one. Furthermore, we will take the initiative to report the handling of personal information security incidents as required by regulatory authorities.

V. Your Rights

In accordance with relevant laws, regulations and standards of China, and the established practices of other countries and regions, we guarantee your following rights for your personal information:

A. To visit your personal information

If you wish to visit or modify you personal information in your account, you can realize it by visiting [Camera360]-[Home Page]-[My]-[Account Information].

B. To delete your personal information

1. You can request us to delete your personal information if:

• (1) Our behavior of handling personal information violates laws and regulations;
• (2) We collect and use your personal information without your consent;
• (3) Our behavior of handling personal information violates the agreement with you;
• (4) If you leave off your products or services, or cancel your account;
• (5) We no longer provide you with products or services.

2. If we decide to respond to your request for information deletion, we will also notify the entities that have obtained your personal information from us at the same time and require them to delete the information in a timely manner, unless otherwise provided by laws and regulations, or these entities have obtained your separate authorization. We may not delete the corresponding information from the standby system immediately upon your deletion of information from our services, but we’ll delete it when the backup is updated.

C. Revocation of Your Authorization

You can contact us via the contact details stated in this policy to revoke your authorization. We will process your request within a reasonable time after receiving your email or registered mail.

However, please understand and agree that the product functions related to authorizations revoked by you will be unavailable, we cannot continue to provide you with specific functions and/or services corresponding to the consents or authorizations revoked by you and the decision for your revocation will not affect the previous processing of your personal information based on your authorization.

D. Cancellation of account by the subject of personal information

You may cancel the account you registered at any time by following the steps below:

Canceling the account in [Camera360]-[Home Page]-[My]-[Account Information].

After cancellation, unless otherwise prescribed by laws and regulations, we will stop providing you with any product or service and delete your personal information upon your requirements.

E. To respond to your above requests

• 1. You may need to provide a written request, or otherwise prove your identity for security. We may ask you to authenticate yourself before processing your request. We’ll respond within fifteen days.
• 2. Your reasonable request is free of charge in principle, but we may charge the cost for repeated, unreasonable requests appropriately. We may reject requests that repeat for no reason, need excessive technical means (for example, need to develop a new system or alter existing practices radically), risky for the legitimate rights and interests of others or totally unrealistic (for example, involving information stored on backup tapes).
• 3. In accordance with laws and regulations, we are unable to respond to your request in the following cases:
• (1) It is directly related to national security and national defense security;
• (2) It is directly related to public safety, public health and vital public interests;
• (3) It is directly related to crime investigation, prosecution, trial and judgment enforcement;
• (4) It is replete with evidence that you are malicious subjectively or abusing your rights;
• (5) Response to your request will impose serious damage to the legitimate rights and interests of you or other individuals and organizations.
• (6) Any commercial secret is involved.

VI. Our Handling of Personal Information of Juveniles

A. Our products, websites and services are primarily for adults. Juveniles are not allowed to create their own user accounts without the consent of their parents or guardians. If you are a minor under the age of 14, please read this policy together with your guardian and make sure of acquisition of explicit consent of your guardian before using our products/services and providing us with your personal information.

B. In the case of collecting personal information of Juveniles upon consent of their parents, we’ll only use or publicly disclose the information when it is permitted by laws, agreed by parents or guardians explicitly or it is necessary for protecting the Juveniles.

C.If your guardian refuses your use of our services or providing us with personal information in accordance with this policy, please terminate your use of our services immediately and notify us in a timely manner.

VII. Global Transfer of Your Personal Information

We will store the personal information collected inside the Republic of Korea within the People’s Republic of China.

In the meantime, because we provide products or services through the resources and servers all over the globe, which means, your personal information may be transferred to the overseas jurisdiction of the country/region where you use the product or services or may be accessed by these jurisdictions.

VIII. Applicable Laws and Jurisdictions

The laws of the mainland of the People’s Republic of China shall apply to this Privacy Policy. Any disputes under this Private Policy shall be settled in the local court (Hi-tech Industrial Development Zone, Chengdu City, Sichuan Province, China) where Camera360 is located.

IX. Renewal of the Policy

• A. Our Privacy Policy may be modified or changed. Without your explicit consent, we will not deprive you of any rights deserved according to this Privacy Policy. We will release on this page any modifications made on this Policy. For major changes, we will notify you through e-mails, phone calls or notifications, etc.
• B. The major changes of this Policy include but not limited to:
• 1. The purpose of how we handle personal information, the type and use method of such personal information, etc.;
• 2. The major changes in the rights and how you realize the rights of your personal information;
• 3. When the report on personal information safety impact indicates potential risk.

X. Our Contact Details

If you have any questions, advice, suggestions of complaints about this policy or service contents, you can contact us by sending e-mails to: support@pinguo.us.