Privacy Policy
Last Modified: 10 01 2023
Your privacy is important to us.
AirGlow (“AirGlow”, “we”, “us” or “our”) is dedicated to protecting the privacy of our users (“users” or “you”). This Privacy Policy (this “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 AirGlow application including all its features (our “Services”).
Please note that the scope of this Policy is limited solely to your user information (including your personal information) collected or received by AirGlow when you are using our Services. In this Policy, “personal information” refers to any information or combination of information that can be used to identify, contact or locate an individual to whom the collected information pertains.
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.
Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with our Services. Also, please note that, unless we define a term in this Policy, all capitalized terms used in this Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.
If you have any questions regarding this Policy or any privacy-related matters, please contact our Data Protection Officer via email at ludpixpt@gmail.com (please quote “AirGlow” in your email title). Please note that for all other enquiries, feedback, suggestions and/or complaints not related to privacy or intellectual property infringement (including but not limited to any cancellation of subscription, payment disputes, refund requests and technical support of AirGlow), you should contact us via email at ludpixpt@gmail.com. If your email is sent to an incorrect email address, relating to an incorrect subject matter, it may lead to a potential delay or failure in processing your requests properly.
THE INFORMATION WE COLLECT
In order to provide and improve our Services, we, by ourselves or through our third-party service providers, will collect and process your personal information and user information in accordance with this Policy. If you do not provide this information, we may be unable to provide you with our products or Services. You should ensure that all personal information and user information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with all or some of our Services.
Account Information
When you use our Services, we might recommend you sign up for an account with us to take full advantage of our Services and all their features. When you create an account, we will collect the following information that can be used to identify you or provide our Services to you:
Anyone can access our Services, but there are certain services that require a subscription fee, such as accessing to our premium content and enjoying advertisement privileges (“Subscription Service”). If you choose to make a purchase on our Subscription Service, we will collect certain personally identifiable information, such as your device ID. A third-party app store or payment processor may receive, access or use your financial information and billing address for the purpose of processing transactions and renewals. If you purchase content or sign up for Subscription Services through a third-party app store or a payment processor, you should refer to that third party’s terms for information on how it maintains and uses personal financial information for all purchases. For the avoidance of doubt, except for AirGlow Studio, we will not collect any financial information from you.
Mobile Device Information (applicable to App only)
When you use our Services on your mobile device, we will collect information about your device, including its International Mobile Equipment Identity (IMEI), Unique Device Identifier (UDID) or Android ID, Universally Unique Identifier (GUUID), Identifier for Advertising (IDFA) and Identifier for Vendor (IDFV), Integrated Circuit Card Identifier (ICCID), Media Access Control (MAC) address, Customer User ID field (CUID), Click ID, attribution fields, the type of device you use, operating system version, a list of mobile applications installed on your device and resolution, which will be used by us for statistical and/or analytical reasons, including without limitation to improve our technical functionality, server load-balancing, analysis of technical data relating to your mobile device so as to optimize our Services and graphics adaptation.
As stated below in the “Location Information” section, we may collect your location-based information from your mobile device if you choose to share it with us. If you subsequently wish to stop sharing Location Information, you may do so at any time by editing the relevant setting on your mobile device.
Mobile Analytics (applicable to App only)
We use mobile analytics software to allow us to better understand and improve the functionality of our Services. Such software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
Network Information
When you use our Services, we will collect information about the network you use, including the name of the operator and the type of network, so as to understand the distribution of operators and networks used by our users. In addition, we will collect information such as the name of the WiFi network to which you connect, the location of the WiFi network, and the duration of your WiFi connection to understand the environment under which you prefer to use our Services.
Location Information
We may collect your location-based information from your mobile device if you choose to share it with us.
This information will help us understand user distribution and usage scenarios and allow us to provide users with the correct version of our apps, the reappearance of the geo-location or the publishing of the real-time geo-location where you take any photos or shoot any videos, and improve our Services. Unless we obtain your consent, location data WILL NOT BE ACQUIRED or USED to identify you individually. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device. Please note that we may still continue to receive some Location Information, such as your Network Information, IP address and system time zone, as a result of you using our Services.
Log Information
When you use some of our Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in AirGlow (“Log Information”). Log Information may include (i) details on when and how often you use our Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve our Services and is NOT USED to identify our users individually.
Image Information
By choosing to use the cloud editing feature of our Services, you understand and agree that we must upload your photos to our server for processing before returning processed photos to you for the purposes of providing such service to you and continuous optimization and that we will also receive the EXIF data about your photos (EXIF data may contain GPS coordinates where photos were taken and processed, equipment type, ISO and information about the front and rear cameras and creation time, depending on the equipment manufacturer) for the purpose of further optimizing our Services, such as providing a better match of photo effects to your equipment.
Voice Information
By enabling the microphone on AirGlow, you agree that we may collect your voice data (i.e., audio clips or recordings of your voice) for video editing. We will not use your voice information for advertising purposes. You can turn off AirGlow’s access to your microphone on your device at any time using the operating system settings on the device or by muting the microphone on your devices.
Metadata
Metadata refers to technical data associated with user content. Put simply, metadata is data that describes data. For example, metadata can describe the analysis results of facial features, gender, age, race of the characters in photos and other elements contained in photos, which are generated and tagged by the computer algorithm and artificial intelligence. When you use our Services, we will use photo metadata to provide you with certain features including precise “Facial Recognition”, “Key-Points Recognition”, “Region Segmentation”, “Content Tags” and other custom features based on a combination of these basic features. We may use your photo metadata to provide you with more suitable filters and better photo effect when our apps process your photos; we may also make use of the metadata to serve up a more contextually relevant products or services to you.
Facial Feature Information
We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.
Cookies
We use “cookies” that store and retrieve information of user’s usage from time to time provide customized Services for each user. Cookies are small amounts of information that the server uses to operate the app/website, sends to the user’s device and are also stored on the hard disk in the user’s device. You may refuse the installation of cookies. Information collected may include information about your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating system, dates and timestamps, and clickstream data.
Advertising-Related Information
We and our third-party service providers may include advertisements within our Services, and with your consent, we may collect and use information about you such as your Advertising ID, geographic location and IP address for the purpose of delivering and tracking these advertisements. If your device does not have Advertising ID, we may use other persistent identifiers. We may also access your App list and collect the application package names of the applications installed on your device. We use the above information to help us better count, track and provide advertisements based on suitability, language, geographic location and other details. If you wish to opt out of interest-based advertising, you may opt out by sending email to ludpixpt@gmail.com(please quote “AirGlow” in your email title). Please note you will continue to receive generic ads after you opt out of interest-based advertising.
Information Collected by Third Party Services
Our Services provided to you may contain our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which may have tracking tools of such service providers. These third parties may use cookies, APIs and SDKs on our Services and collect and analyze user information. In addition, some third-party SDKs may allow advertisers to collect information in order to provide content that is more relevant to you. Third parties may access your information such as your device identifiers, region (defined as the location where a given language is used), location information and IP address under their respective privacy policies. If you want to know more about such third parties, you may send an email to ludpixpt@gmail.com(please quote “AirGlow” in your email title).
Payment Information (applicable to AirGlow Studio only)
When you make a purchase or subscribe to our Services through AirGlow Studio, we may collect payment information to process your transactions. This may include your credit card information.
Other Information
We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you. In addition, our Services may utilize calculation results of ARKit from Apple in relation to depth of facial mapping information, in order to achieve better facial image processing effect.
HOW WE USE INFORMATION
In addition to the uses listed above, we collect and use your user information and/or personal information for the following purposes:
INFORMATION SHARING AND DISCLOSURE
We may share your information with third parties who provide services on our behalf to help with our business activities. These services may include:
We will not share with or disclose to third parties (other than our service providers) your personal information in whole or in part except for the purposes of:
BASES FOR USING YOUR INFORMATION
We will only collect and process personal information where we have lawful bases and we typically rely on one of the following four legal bases: -
If you have questions about the lawful bases on how we process your personal information, please contact us at ludpixpt@gmail.com (please quote “AirGlow” in your email title).
THIRD PARTY WEBSITES AND SERVICES
Our Services may contain links to other websites and services. In addition, other websites and services may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about third party websites or services. We encourage our users to read the privacy policies of each and every website and service with which they interact. Visiting these other websites or services is at your own risk.
INFORMATION SECURITY
We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal 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.
INFORMATION ACCESS AND CONTROL
We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity in order to protect the security of your account.
Subject to applicable laws, rules and regulations and the fulfillment of our business or legal purposes, we will delete your information (including your personal information promptly upon your termination of your account with us.
PRIVACY 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; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.
If you wish to exercise your rights, you may send an email to ludpixpt@gmail.com (please quote “AirGlow” in your email title). We will process your request in line with applicable laws within a reasonable period of time after receiving your email or mail, and will cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act.
INFORMATION ABOUT CHILDREN
We will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under 16, please do not send your personal information to us, including but not limited to your name, address, phone number or email address. If you believe we may have any information about children under 16, you may send an email to ludpixpt@gmail.com (please quote “AirGlow” in your email title). If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information and terminate the associated account.
CROSS-BORDER DATA TRANSFERS
You understand and agree that all information collected via or by AirGlow may be transferred, processed, and stored anywhere in the world, including but not limited to, Singapore, Japan, South Korea, the People’s Republic of China, the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide our Services.
GOVERNING LAW
This Policy is established, comes into force, and will be enforced and interpreted under the laws of Singapore, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.
AMENDMENTS TO THIS POLICY
You agree that we may update this Policy according to relevant laws and regulations or based on AirGlow’s business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on AirGlow or notify you by other means as required by law.
FOR USERS IN JAPAN
Right to data disclosure, correction, erasure or suspension of use
If you are in Japan, as a data subject, you have the right to request the disclosure, correction, erasure or suspension of use of your personal information, and we are obliged to meet your request without undue delay. You may send your request by email to ludpixpt@gmail.com (please quote “AirGlow” in your email title) .
FOR USERS IN SOUTH KOREA
International Data Transfers
We process the personal information of users only within the scope specified under HOW WE USE INFORMATION, and in principle, will not provide personal information of users to a third party. However, with your consent, for purposes of providing our Services described under INFORMATION SHARING AND DISCLOSURE to you, we may collect your personal information from, transfer it to, and store and process it elsewhere.
Also, we may transfer your personal information to the following third parties located outside of South Korea:
|
Name of the person providing personal information |
Purpose of the use of personal information |
Particulars of personal information to be collected |
Period for retaining and using personal information |
|
Google LLC https://policies.google.com/privacy?hl=en-US |
To improve website experience and subscription service |
Region user uid |
For such period as stated in the privacy policy of the relevant third party recipient.
|
|
Apple Inc. https://www.apple.com/legal/privacy/en-ww/ |
To improve product experience and subscription service |
Region user uid |
|
|
Appsflyer |
To provide you with advertisement |
IDFV, CUID, Click ID and attribution fields |
Whenever we share information outside of where you live, we ensure that the transfer complies with your local law so that your personal information is adequately protected.
If you do not wish to have your personal information transferred outside of South Korea, we will be unable to provide you with our products or Services.
Also, we may receive your personal information from the following third parties:
|
Name of the person providing personal information |
Purpose of the use of personal information |
Particulars of personal information to be collected |
Period for retaining and using personal information |
|
Google LLC https://policies.google.com/privacy?hl=en-US |
Provision of account services |
Email address
|
As stated in the “Data Retention” section above |
|
Meta Platform, Inc. https://www.facebook.com/policy.php/ |
Email address, idfa, idfv, g_uuid |
||
|
Apple Inc. https://www.apple.com/legal/privacy/en-ww/ |
Email address |
||
|
Chargebee Inc. |
Provision of subscription service |
Payment information |
|
|
Improvement of our Services by analyzing problems encountered by users |
user_id, origin_order_id, subscription token, idfa, idfv, g_uuid, IP address, mac_addr, imei, advertising_id |
||
|
Zendesk, Inc. |
user_email |
||
|
Appsflyer |
idfa, idfv, g_uuid, IP address, mac_addr, imei, advertising_id |
Data Retention
Subject to applicable laws, rules and regulations and the fulfillment of our business or legal purposes, we will delete your information (including your personal information) promptly upon your termination of your account with us. We will destroy your personal information according to the following procedures and methods.
Department in Charge of Protecting Personal Information and Handling Complaints
AirGlow
Email: ludpixpt@gmail.com (please quote “AirGlow” in your email title)
History of the Revision of the Privacy Policy
FOR USERS IN THE UNITED STATES OF AMERICA
You agree that AirGlow and the Companies may use facial recognition technology to collect biometric information from the photos or images you provide. AirGlow and the Companies may use such information to verify your identity, to provide and improve the Service, and for our internal research purposes. If your biometric information is subject to the Illinois Biometric Information Privacy Act, we will delete your biometric information within three years of your last interaction with the Service.
In accordance with applicable law, you may have the right to:
If you would like to exercise any of your rights under the applicable privacy laws, please contact our Data Protection Officer via email at ludpixpt@gmail.com (please quote “AirGlow” in your email title) . We will process such requests in accordance with applicable laws.
If you are a Virginia resident and would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
The following paragraphs only apply to our processing of your personal information that is subject to the California Consumer Privacy Act (as amended from time to time) (“CCPA”).
The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
|
Category of Personal Information Collected |
Category of Third Parties to Whom Personal Information is Disclosed to for a Business Purpose |
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Identifiers |
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Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
|
|
Protected classification characteristics under California or federal law |
N/A |
|
Commercial information |
|
|
Biometric information |
AirGlow Affiliates |
|
Internet or other electronic network activity |
|
|
Geolocation data |
|
|
Sensory data |
|
|
Professional or employment-related information |
N/A |
|
Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)) |
N/A |
|
Inferences drawn from other personal information to create a profile about a consumer |
N/A |
|
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number |
N/A |
|
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
|
|
Personal information that reveals a consumer’s precise geolocation |
N/A |
|
Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
N/A |
|
Personal information that reveals the contents of a consumer’s mail, email, and text messages unless Figma is the intended recipient of the communication |
N/A |
|
Personal information that reveals consumer’s genetic data |
N/A |
|
Biometric information that is processed for the purpose of uniquely identifying a consumer |
N/A |
|
Personal information collected and analyzed concerning a consumer’s health |
N/A |
|
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation |
N/A |
The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing Personal Information are set forth in “The Information We Collect”, “How We Use Information”, and “Information Sharing and Disclosure” above, respectively. We will retain personal information in accordance with the time periods set forth in “Data Retention” above.
In the preceding twelve months, we have not “sold” any personal information (as defined by the CCPA), nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
In the preceding twelve months, we have not “shared” any personal information for “cross-context behavioral advertising” (as such terms are defined in the CCPA), nor do we have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising”
We only use and disclose sensitive personal information for the following purposes:
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide the email address or phone number we have associated with you and providing a verification code that is sent to your email address or phone number.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent and contact us using the information in “Privacy Rights” above for additional instructions.
We do not “sell” personal information or “share” personal information for “cross-context behavioral advertising” so we do not respond to opt-out preference signals.
If you are a Nevada resident, we do not “sell” your personal information.