Privacy Policy

Last modified: August 30, 2023

Your Privacy is very important to us.

 CollageMaker Team and it affiliates(collectively as “Company,” “we,” “us” and “our”) are dedicated to protecting the privacy of our users ("users" or "you"). This Privacy Policy (the "Policy") is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal information) as a controller and/or business under applicable data protection laws during your use of CollageMaker application including all its features (our "Services"). 
This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service. Please read the Terms of Service carefully before you use our Services.

BY USING OUR SERVICES, YOU ARE AGREEING TO THIS POLICY AND THE COLLECTION, USE, PROCESSING, RETENTION, DISCLOSURE AND SHARING OF YOUR USER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, IN THE MANNER PROVIDED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY OR ANY SUBSEQUENT CHANGES TO THIS POLICY, PLEASE DO NOT USE OUR SERVICES.

We may periodically make changes to this Policy as we update or expand our Services. We will notify you of any material changes to this Privacy Policy by notifying you via the email we have on file for you, or by means of a notice on our Services in advance of the effective date of the changes. If you do not agree to the changes, you should discontinue your use of the Services prior to the time the modified Policy takes effect. If you continue using the Services after the modified Policy takes effect, you will be bound by the modified Policy.
Furthermore, we may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal information.

1.Information We Collect

In this Policy, the term “personal information” includes any information that identifies or makes an individual identifiable. When you access or use our Services, we may generally collect personal information described below. Please note that we need certain types of information so that we provide the Services to you.

A. Information You Directly and Voluntarily Provide to Us

You consent to provide some or all of the following Personal Information when you create an account on the Apps or use our Services, such as uploading contents on the Apps or contact us for technical support:

l Registration information, such as your email address, phone number or other contact information, password, user identifier and language.

l Profile Information: such as an avatar or profile picture, gender, birthday, nickname or username, or country.

l User-generated contents: such as comments, texts, messages, pictures, images, videos, sounds, code, your device’s camera and microphone or other data or materials that you upload and distribute on the App when you use our Service.

l Payment Information: such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number, or other payment information where required for payment.

l Your Global Positioning System information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device.

l Your opt-in choice and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints.

l Customer Support Information: If you are a visitor to the Site, or a user of the Apps, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.

l Social Media Account Information: the information that you provide from social media when you sign up with a third-party social media,  such as Facebook, Google, Instagram, Twitter, or if you link your account with a third-party social media account.

B. Automatically Collected Information for Legitimate Interests

We may automatically collect some or all of the following Personal Information about you when you use our Services for legitimate interests:

l Network Connection: your type of network information such as your mobile network, Wi-Fi connection and others.

l Information from Other Sources: We may obtain additional information from third parties and sources other than our Service. For example, we may obtain additional information from social media network for which you have approved our access. When you access our Service through social media networks or when you sign up our Service with a third-party social media, you are authorizing us to collect, store, and use such additional information and content in accordance with this Privacy Policy.

l Device Information: such as your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, language setting, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background, mobile device’s advertising ID, Internet Protocol(IP) address, MCC, MNC and media access control address.

l Information regarding your access to and use of other apps.

l Other location information: the general location of your mobile device (not precise geolocation data), such as the information based on your SIM card.

l Mobile advertising identifiers, which are used by mobile operating system and made available to advertising providers to gather metrics on mobile apps(Apple’s IDFA or Google’s AAID) to help us and advertisers provide Ads that may be more relevant to your interests.

l Metadata, associating with the User-generated content you provided us, describes other data and provides information about how, when, and by whom the pieces of User-generated content were collected and how that User-generated content was formatted, such as hashtags used to label the keywords to the photo and captions.

l Cookies & Similar Tracking Information: We use cookies and similar tracking technologies to collect information about your interactions with our Services. The information we collect includes, but is not limited to, account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your Internet Protocol (“IP”) address, your mobile country code, and your user ID.

You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services.

C. Information You Share on Third-Party Websites or through Social Media Services

The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

We do not knowingly collect personal information from children under 18 years old, unless permitted to do so by applicable law. Children are not permitted to use our Services unless they provide us with consent from their parent or guardian. If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately via email at the address provided in the “How to Contact Us”.

2.How We Use Information

We will only use your Personal Information when the applicable laws allow us to . In general ,we use the personal information we gather through the Services for the purposes described below. If we use your personal information in any other ways, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.

l To provide the Services to you. We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services.When you use the AI avatar function and other face-related functions provided by us to apply effects, you understand and agree that we may use facial geometry or other facial data (the "Facial Data") in the pictures, images and videos provided by you directly to generate the image or effects you request. We store the pictures, images, or videos you directly provided and the generated effect image data on servers. We use the Facial Data to provide the applicable services to you and to improve our service, and we are not using this face data to identify any individual person or for authentication purposes. We cannot provide you with Services without such information.

l To provide customer service. We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.

l To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies; enforce our agreements with third parties and partners; and, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.

l To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.

l For security purposes. We process your personal information to: improve and enforce our security measures; combat spam, malware, malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes.Designated Countries: For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

l To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to comply with our legal obligations.

l To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook, Google, Instagram, Twitter, etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.

l To conduct research and development. We process information about the way you use and interact with our Services to: help us improve our Services; build new Services; and build customized features or Services; and to train and improve our technology such as our machine learning modules, algorithms, and labs. Such processing ensures your continued enjoyment of part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.

l To engage in marketing activities. We may process your contact information or information about your interactions on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars, or other materials, including those of our partners; and, keep you up-to-date with our relevant products and Services. Transactional communications about your account or our Services are not considered “marketing” communications. In addition, when you share your friends’ contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can opt-out of our marketing activities at any time. Designated Countries: For users located in the Designated Countries, please see section 6.C. below.

3.How We Share Your Information with Third Parties

We may share your personal information with third parties in the following circumstances:

A. Employees, Third-Party Processors and Third-Party Service Providers

We disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our contract with you.

B. Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies

To the extent permitted by law, we will disclose your personal information if:

l Required to do so by law, or in response to a subpoena or court order or similar request from judicial authority, law enforcement authorities or other competent public authorities;

l We believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or

l We believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.

Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our legal obligations, in the public interest, or your vital interests.

C. Business Transfers or Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal information will be subject to this Privacy Policy. However, any personal information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on legitimate interests described above.

D. Our Affiliates

Based on your consent, we may share some or all of your contact information with our, parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by contacting us as provided in the “How to Contact Us” section.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on your consent.

E. Third-Party Business Partners.

Base on you consent, we may work with and share some of your information with our third-party advertising partners to provide you with advertisements or other tailored content. We may share information related to users of our service with affiliates or unaffiliated third parties on a de-identified, aggregate basis. While this information will not identify you personally, in some instances these parties may be able to compile these aggregate ,de-identified information with other data they have about you, or that they receive from other parties, in a manner that allows them to identify you personally.
Designate Countries: Pursuant to the Data Protection Laws, we process the personal information of user located in the Designated Countries based on your consent.

4.Information Security

We will take reasonable measures to prevent the loss, improper use of , unauthorized access to or disclosure of information. However, you understand and accept that (in the Internet industry) even though we take reasonable security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. Further, you understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.

5.Retention of Personal Information

Subject to applicable laws, rules and regulations and the fulfillment of our business or legal purposes, we will retain your information (including your personal information) for such period as is required for us to continue to provide you with our Services.

6.Information for Residents in the European Economic Area, United Kingdom and Switzerland (the “Designated Countries”)

This section only applies to users of our Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in.
Where we rely on your IP address, we cannot apply the terms of this section to any user that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries.

A. Our Relationship to You

CollageMaker Team and its affiliates are data controllers with regard to any personal information collected from users of its Services. A “user” is an individual providing personal information to us via our Services, such as by creating an account with our Apps, signing up for our newsletter(s), or otherwise accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.

B. Legal bases for processing Personal Information

We describe our legal bases for processing in “How We Use the Information We Collect” and “How We Share Your Information With Third Parties” under headings entitled “Designated Countries.” The legal bases on which we rely on to process your personal information include: your consent to the processing; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; necessity to process in the public interest; or for our legitimate interests as described in those sections.

C. Marketing Activities

If you are located in the Designated Countries and are a current user, we will only contact you by electronic means (such as email or SMS) per your communication preferences and/or with information about our Services that are similar to the Services you previously purchased from us or negotiated to purchase from us.
For new users located in the Designated Countries, we will contact you by electronic means for marketing purposes only based on your consent or based on your friends’ consent. You can always withdraw your consent or change your marketing communication preferences at any time and free of charge. To opt out of the emails, please click the “unsubscribe” link in the footer of marketing emails or contact us via email at the address provided in the “How to Contact Us”. Marketing communications are promotional in nature and do not include transactional or Service-related communications.

D. Individual Rights

In accordance with applicable law, you may have the right to:

(i)   request confirmation of whether we are processing your personal information;

(ii)   obtain access to or a copy of your personal information;

(iii)   receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (“right to data portability”);

(iv)   object to or restrict our uses of your personal information;

(v)   seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information;

(vi)   withdraw your consent;

(vii)   request erasure of personal information held about you by us, subject to certain exceptions prescribed by law; and

(viii)   notification to third-parties any requests for rectification, erasure or restriction of your personal information when we share your personal information with third parties.

Please contact us if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

l Where denial of access is required or authorized by law;

l When granting access would have a negative impact on other’s privacy;

l To protect our rights and properties; and

l Where the request is frivolous or burdensome.

You may reach our Data Protection Officer via email at the address provided in the “How to Contact Us”.

E. Transfer of Personal Information

You understand and agree that all information collected via or by us may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Designated Countries: We transfer your personal information subject to appropriate safeguards as permitted under the Data Protection Laws. Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for transferring personal information in place with the third-parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

7.California Residents

This section only applies to residents of California or individuals whose information has been collected in California. We have adopted and included this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). If you are a resident of California, the following additional terms apply:

A. Selling Information. We do not sell Your Personal Information, as defined under CCPA. If in the future we do sell your personal information, we will notify you and you may have the right to opt-out of such sale.

B. Your rights and Choice. The CCPA provides individuals residing in California or whose Personal Information was collected in California with specific rights regarding their Personal information. The below describes your rights and how you may exercise them:

a. Access to Specific Information and Data Portability Rights. You have the right to request us to disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receives and confirms your verifiable information access request, we must disclose to you: (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting or, if applicable, selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; (v) the specific data points or pieces of Personal Information we collected about you. If we disclosed for a business purpose or sold your Personal Information, we must also provide separate lists that: (x) identify the personal information categories that were sold to each category of recipient in connection with sales of your Personal Information; and (y) identify the personal information categories that were provided to each category of recipient in connection with business purposes disclosures of your Personal Information.

b. Deletion Request Rights. You have the right to request us to delete any of your Personal Information that we collected from you and/or retained. Unless subject to a certain limited exception, once we receives and confirms your verifiable data deletion request, we will delete (and direct our service providers to delete) your personal information from our records. We will notify you promptly if it determines it must deny your deletion request.

c. Do Not Sell Opt-Out Rights. You have the right to opt-out of any sales, as defined by the CCPA, of Personal Information by us. However, we do not sell your information.

C. Exercising Your Rights. To exercise your access, data portability, and deletion or do not sell opt-out rights described above, you may submit a verifiable consumer request by any of the following means: By email to us via via email at the address provided in the “How to Contact Us”. You may only make a verifiable consumer request for access or data portability up to two times within a 12-month period. You may make a verifiable do not sell opt-out request at any time. Any such request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative thereof; and (ii) describe your request with sufficient detail such that we may understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with the Service. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

D. Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you in writing of the extension period and the reason for it. We will deliver any required or requested responses or other communications in writing to you by email. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, the response we provide will also explain any reasons we cannot comply with a request. For data portability requests, we will provide your personal information in a format that is readily usable and transferable. We do not charge a fee to process or respond to your verifiable consumer request unless such requests become excessive, repetitive, or manifestly unfounded or as otherwise permitted by the CCPA. If we determine that a request warrants charging a fee, we will notify you and provide you with a cost estimate before completing your request.

 

8. How to Contact Us.

If you have any questions about this Privacy Policy, please feel free to contact us at collageword.help@gmail.com.