Privacy Policy

1. INFORMATION WE COLLECT

1.1 Information You Provide to Us

• Account Information: Name, username, and email address when you create an account
• Customer Support Content: Information you provide when contacting our customer support team
• Photos: Images you upload for AI-powered photography analysis and commentary generation

1.2 Information We Collect Automatically

• Device Information: Device type, operating system, unique device identifiers, and mobile network information
• Usage Statistics: Information about how you use the App, including features accessed and time spent
• Crash Logs: Technical information about App performance and errors
• Location Information: With your permission, we may collect precise or approximate location data

1.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies to maintain your login session and store your preferences. These may include web beacons. You can control cookie settings through your device settings.

2. HOW WE USE YOUR INFORMATION

We use the collected information for the following purposes:

• To provide, maintain, and improve the App's functionality
• To generate AI-powered photography composition analysis, lighting commentary, and shooting suggestions
• To personalize your experience within the App
• To communicate with you, including responding to your inquiries and providing customer support
• To ensure the security and integrity of the App
• To analyze usage patterns and improve our services
• To comply with legal obligations and protect our rights
• To detect, prevent, and address technical issues

3. PHOTO AND IMAGE PROCESSING

3.1 No Facial Recognition or Biometric Data

We do not perform facial recognition or collect biometric identifiers from your photos.

3.2 Processing and Storage

• Photos are processed one-time to generate AI commentary and analysis
• After processing is complete, uploaded photos are automatically deleted from our servers
• By default, photos are stored locally on your device
• Photos are NOT used for AI model training or marketing purposes

4. HOW WE SHARE YOUR INFORMATION

We may share your information only in the following circumstances:

• With Your Consent: When you explicitly authorize us to share specific information
• Service Providers: With trusted third-party service providers who assist us in operating the App, under strict confidentiality obligations
• Legal Requirements: When required by law, regulation, legal process, or governmental request
• Protection of Rights: To protect and defend our rights, property, or safety, or that of our users or the public
• Business Transfers: In connection with a merger, acquisition, or sale of assets

All sharing follows the principle of minimum necessity. Your information may be transferred across borders, and we implement Standard Contractual Clauses (SCCs) or equivalent safeguards for international data transfers.

5. DATA SECURITY

We implement industry-standard security measures to protect your information:

• Encryption: Data is encrypted during transmission (SSL/TLS) and at rest
• Access Controls: Strict access controls limit who can access your personal information
• Regular Audits: We conduct regular security audits and assessments
• Backup Systems: Regular backups to prevent data loss
• Security Monitoring: Continuous monitoring for potential security threats

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. DATA RETENTION

We retain your information for the following periods:

• Account Data: For the duration of your active account
• Account Deletion: Within 30 days of account deletion, your personal information will be deleted or anonymized
• Usage Statistics: Retained for up to 12 months for analysis and improvement purposes
• Customer Support Records: Retained for 6 months after resolution

7. YOUR RIGHTS AND CHOICES

You have the following rights regarding your personal information:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information
• Restriction: Request restriction of processing of your information
• Withdrawal: Withdraw consent for data processing at any time
• Data Portability: Request a copy of your data in a portable format

To exercise these rights, please contact us at shunk64562@outlook.com. We will respond to your request within 5 business days.

8. CHILDREN'S PRIVACY

The App is intended for users aged 17 and above. We do not knowingly collect personal information from children under 17. If you believe we have collected information from a child under 17, please contact us immediately.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes.

10. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. We ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs), to protect your information during international transfers.

11. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of the jurisdiction where Ula Team primarily operates, without regard to its conflict of law provisions.

12. DISPUTE RESOLUTION

Any disputes arising out of or relating to this Privacy Policy shall be resolved through binding arbitration in accordance with the arbitration rules of the jurisdiction where Ula Team primarily operates. You agree to waive your right to a jury trial or to participate in a class action.