UPhoto Privacy Policy
UPHOTO PTE. LTD. (hereinafter referred to as "we" or "UPhoto") attaches great importance to users' privacy and personal information protection, and thanks you for your trust in us. We will take corresponding security protection measures in accordance with legal and regulatory requirements to protect the security and controllability of your personal information, and provide you with reasonable and efficient privacy protection. In view of this, we formulate this "Privacy Policy" (hereinafter referred to as "this Policy" or "this Privacy Policy") to explain to you how we will collect, use, store, protect and externally display your information, and explain the rights you enjoy.
This policy applies to the UPhoto photo live broadcast platform developed and operated by UPhoto, and also applies to other internet products developed and operated by UPhoto (UPhoto Photo Live App, I Am a Photographer WeChat Mini Program, UPhoto Cloud Album WeChat Mini Program, UPhoto Appointment WeChat Mini Program, etc.). This privacy policy is the general privacy terms applicable to UPhoto. The user rights and information security guarantee measures stipulated therein apply to the UPhoto Photo Live App and other UPhoto products or services. This privacy policy does not apply to services provided to you by other independent third parties. When third parties on our platform provide services to you relying on our platform, the personal information you provide to third parties does not apply to this privacy policy.
This policy will help you understand the following:
1. How we collect and use your personal information
2. How we entrust the processing, share, transfer, and publicly disclose your personal information
3. How we protect your personal information
4. Your rights
5. How we handle personal information of minors
6. How we store your personal information
7. How this policy is updated
8. How to contact us
9. Dispute resolution
I. How we collect and use your information
We collect and use your personal information based on the principles of lawfulness, justification, and necessity to realize the basic functions described below in this policy.
(I) Guarantee the normal operation of products
1. How we collect and use your personal information
In order to provide you with services, guarantee the normal operation of services, and improve and optimize our services, UPhoto will collect your personal information based on the principles of consistency of rights and responsibilities, explicit purpose, choice and consent, minimum necessity, ensuring security, subject participation, and openness and transparency. The types of personal information we collect and use include two types:
The first type is the necessary information for the core business functions of our products/services. This type of information is essential for the normal operation of the products/services, and you must authorize us to collect and use it. If you refuse, you will not be able to use our products/services normally.
The second type is the information that may need to be collected for non-core business functions, and you can choose whether to authorize us to collect it. If you refuse to provide it, it will cause certain functions to not be realized or fail to achieve the effect we intend to achieve, but it will not affect your normal use of core business functions.
2. Our products integrate third-party SDKs. In order to provide you with more complete and professional services, our client will embed the software tool development kits ("SDK") of authorized partners. For details, please refer to the attached Appendix I "Third-party SDK Usage Instructions Document".
3. Other circumstances stipulated by laws and regulations
| Service Type | Service Description | Collect/Use Personal Information |
|---|---|---|
| User registration, login | Registered users can obtain photo live broadcast and other related services |
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| Purchase services | Users can purchase related services and data cables provided by the platform, and the platform provides delivery functions |
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| Real-name authentication | According to the "Regulations on the Administration of Internet Live-streaming Services", real identity information authentication based on mobile phone numbers and other methods is carried out for Internet live-streaming users |
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| Order Hall | Photographer users on the platform post shooting needs or take orders |
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| Photo live broadcast function | Provide real-time photo transmission, online live broadcast, album browsing and other functions |
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| Product operation analysis | Collect user usage data through burying points in various functions, and the background conducts operation analysis on the data (analysis of opening rate, number of visitors, visit duration, etc. of each function) and account security analysis |
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4. Use and description of related permissions of UPhoto Photo Live APP
| Permission Name | Permission Code | Permission Purpose |
|---|---|---|
| View network status | ACCESS_NETWORK_STATE | Need to know the current network status of the mobile phone to provide better photo upload services |
| View WLAN status | ACCESS_WIFI_STATE | A smooth network connection is required to transmit photos normally to the cloud server |
| Access the network | INTERNET | A smooth network connection is required to transmit photos normally to the cloud server |
| Dial phone numbers | CALL_PHONE | If users encounter problems while using the APP, they can directly dial the customer service phone for consultation |
| Take pictures | CAMERA | Users directly use the mobile phone to take pictures and upload the photos to the cloud server for photo live broadcast |
| Change network connectivity | CHANGE_NETWORK_STATE | A smooth network connection is required to transmit photos normally to the cloud server |
| Change WLAN status | CHANGE_WIFI_STATE | A smooth network connection is required to transmit photos normally to the cloud server |
| Phone auto-start/associated startup | RECEIVE_BOOT_COMPLETED | Keep the connection between the phone and the camera. The APP needs to stay activated to ensure photos are normally transmitted from the camera to the phone |
| Control vibration | VIBRATE | When the phone and camera are disconnected, etc., clear warning pop-ups and vibration prompts are needed for disconnection |
| Prevent phone from sleeping | WAKE_LOCK | Keep the connection between the phone and the camera. The APP needs to stay activated to ensure photos are normally transmitted from the camera to the phone |
| Modify/delete contents of SD card | WRITE_EXTERNAL_STORAGE | Photos taken by the camera are transmitted to the cloud server via the phone, so photos need to be temporarily stored in the phone's memory or SD card |
| Read contents of SD card | READ_EXTERNAL_STORAGE | Read photos in the phone's SD card and upload the photos to the cloud server for photo live broadcast |
| Install unknown apps | REQUEST_INSTALL_PACKAGES | After the APP version is updated and iterated, it is used for users to download and update to the latest APP version |
5. Use of Cookies
To ensure the normal operation of the website and to give you an easier access experience, we will store Cookies, Flash Cookies, or other local storage commonly containing identifiers, site names, and some numbers and characters provided by browsers or associated applications (collectively referred to as "Cookies") on your computer or mobile device. Through Cookies, we will collect your information to provide you with better user experience and services.
You can manage Cookies through browser settings, but if you modify the degree of acceptance of Cookies or reject our Cookies, it may affect your secure access to our website, and some services may not function normally.
In addition to Cookies, we will also use other similar technologies such as web beacons and pixel tags on our website. For example, emails we send to you may contain address links pointing to content on our website. If you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve the customer service experience. Web beacons are usually transparent images embedded in websites or emails. With the help of pixel tags in emails, we can know whether an email has been opened.
(II) Register Account
1. When you create a UPhoto account, you must provide your mobile phone number in mainland China, set and confirm your login password.
Your submitted mobile number is used to receive verification codes when you register, log in, bind your account, or recover your password, and serves as one of the designated contact methods between you and UPhoto to receive relevant business notifications (such as new product launches, service changes, etc.). UPhoto can send you business notifications (including bills) or conduct business communication with you through this contact method ("Secure Mobile Number" or "Account Contact Mobile Number"). Collecting mobile numbers is to meet the network real-name requirements of relevant laws and regulations. If you do not provide this kind of information, you may not be able to use our services normally.
2. Authorized Login
We may obtain your account information (including WeChat nickname and avatar) from WeChat based on your authorization, and bind it to your UPhoto account so that you can log in directly via WeChat account to use our services or products or services provided by third parties relying on UPhoto. We will use your relevant information within the scope of your authorized consent.
(III) We will also collect and use your personal information to realize the following additional functions
1. Video, picture, audio management
When you use the UPhoto video, picture, and audio upload functions, the text, video, picture, and audio information you upload will be stored in our servers, because storage is necessary to realize this function. You can delete this information at any time. Unless you choose voluntarily or comply with relevant laws and regulations, we will not provide the above information externally, or use it for other purposes outside this function. Please note that the information you publicly release may involve personal information or even sensitive personal information of you or others. If you choose to upload pictures containing personal information, please consider more carefully whether to share or even publicly share relevant information when using our services.
II. How we entrust processing, share, transfer, and publicly disclose your information
(I) Entrusted processing
Certain specific modules or functions among the business functions provided on the UPhoto platform are provided by external suppliers. For companies, organizations, and individuals entrusted by us to process personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our requirements, this privacy policy, and any other relevant confidentiality and security measures.
(II) Sharing
1. Sharing among affiliated companies: To facilitate us providing products and services to you based on your UPhoto account, identifying member account abnormalities, and protecting the personal and property safety of UPhoto affiliated companies or other users or the public from infringement, your personal information may be shared with our affiliated companies and their designated service providers. We will only share necessary personal information, and are bound by the purposes stated in this privacy policy. If we share your sensitive personal information or affiliated companies change the purpose of using and processing personal information, we will seek your authorized consent again;
2. Sharing with authorized partners: We may entrust authorized partners to provide you with certain services
or fulfill functions on our behalf. We will only share your information for legal, legitimate, necessary,
specific, and explicit purposes stated in this privacy policy. Authorized partners can only access the
information necessary to perform their duties, and must not use this information for any other purposes.
Currently, our authorized partners include the following types:
(1) Authorized partners of analysis services. Unless permitted by you, we will not share your personal identity information with partners providing analysis services. We will provide these partners with information about the coverage and effectiveness of their services, but will not provide your personal identity information, or we will aggregate this information so that it does not identify you personally. These partners may combine the above information with other data they legally obtain to make decision recommendations;
(2) Suppliers, service providers, and other partners. We send information to suppliers, service providers,
and other partners that support our business. Such support includes providing technical infrastructure
services, analyzing how our services are used and the effectiveness of our services, providing customer
service, facilitating payments, or conducting academic research and surveys.
We will agree on strict data protection measures with them, requiring them to process personal
information in accordance with our instructions, this privacy policy, and any other relevant confidentiality
and security measures.
3. In order to provide you with better services or to prevent internet crimes, our affiliated companies and partners will share your personal information with us in accordance with legal provisions or under the premise of obtaining your consent. We may obtain account information (avatar, nickname) authorized by you from a third party, and bind your third-party account to your account after you agree to this privacy policy, so that you can directly log in and use our products or services through the third-party account. We will use your personal information under the premise of complying with relevant laws and regulations after confirming the legality of the source of personal information according to the agreement with the third party.
4. We may share your personal information externally in accordance with the provisions of laws and
regulations, or the mandatory requirements of government authorities or the needs of judicial procedures.
For companies, organizations, and individuals with whom we share personal information, we will sign
strict confidentiality agreements with them, requiring them to process personal information in accordance
with our instructions, this privacy policy, and any other relevant confidentiality and security measures.
Except for situations stipulated by law, under no circumstances will we share any of your personal identity
information with a third party.
(III) Transfer
We will not transfer your personal information to any company, organization, and individual, except in the following cases:
1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
2. In the event of mergers, acquisitions, or bankruptcy liquidation, or other situations involving mergers, acquisitions, or bankruptcy liquidation, if it involves the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy, otherwise we will require the company, organization, and individual to re-seek authorization and consent from you.
(IV) Public disclosure
We will only publicly disclose your personal information in the following cases:
1. After obtaining your explicit consent or based on your active choice, we may publicly disclose your personal information;
2. Disclosure based on law: In the case of laws, legal procedures, litigation, or mandatory requirements of government authorities, we may publicly disclose your personal information.
3. If we determine that you have violated laws and regulations or seriously violated UPhoto's relevant agreements and rules, or to protect the personal and property safety of other users or the public from infringement, we may disclose your personal information in accordance with laws and regulations or with your consent, including relevant violations and the measures UPhoto has taken against you.
III. How we protect your personal information
Your account has security protection functions. Please properly keep your account and password information. We will ensure that your information is not lost, abused, or altered through security measures such as backing up to other servers and encrypting user passwords. Despite the aforementioned security measures, please understand that there are no "perfect security measures" on the information network. If you find that your personal information is leaked, especially your account and password, please immediately contact our customer service according to the public contact information listed at the end of this policy so that we can take corresponding measures.
To protect your information security, we strive to adopt various reasonable physical, electronic, and managerial security measures to protect your information, so that your information will not be leaked, damaged, or lost, including but not limited to SSL, encrypted storage of information, and access control of data centers. We also strictly manage employees or outsourced personnel who may have access to your information, including but not limited to adopting different permission controls according to different positions, signing confidentiality agreements with them, monitoring their operations, etc. We will provide corresponding security measures based on existing technologies to protect your information and provide reasonable security guarantees. We will try our best to prevent your information from being leaked, damaged, or lost.
IV. Your rights
(I) Access, modify, and delete information
During your use of our services, you can access, modify, and delete the registration information and other personal information you provided. The scope and manner in which you access, modify, and delete personal information will depend on the specific services you use.
We will only collect and use your information for the purpose of realizing the functions of our products or services in accordance with this policy. If you find that we collect or use your personal information in violation of laws, administrative regulations, or the agreement between both parties, you can request us to delete it. If you find errors in the personal information we collect and store, you can also request us to correct it.
You can access, modify, or delete your information in the following ways:
1. Log in to the UPhoto platform, and in the Personal Center module, access, modify, or delete information such as your avatar and nickname;
2. Contact us using the public contact information listed at the end of this policy.
(II) Account cancellation
You can cancel your account in the following ways:
1. Log in to the UPhoto Photo Live APP, under "Settings" in the "Personal Center" module, follow the prompts to cancel your account;
2. Contact us according to the public contact information listed at the end of this policy to assist you in canceling your account.
After you actively cancel your account, we will stop providing all products and services associated with the account to you, delete your personal information according to the requirements of applicable laws, or anonymize it.
(III) Change the scope of your authorized consent
Each business function requires some basic personal information to be completed. You can grant or withdraw your authorization consent by changing the settings of smart mobile devices such as mobile phones and tablets, or through the methods listed above. After you withdraw the relevant authorized consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the personal information processing previously carried out based on your authorization.
(IV) How we respond to your above requests
When you access, modify, or delete relevant information or accounts, we may require you to authenticate your identity to ensure account security.
Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to satisfy all your requests. We will reply to your request within a reasonable period. Meanwhile, according to relevant laws, regulations, and national standards, we may not be able to respond to your requests in the following circumstances:
1. Directly related to national security or defense security;
2. Directly related to public security, public health, or major public interests;
3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
4. There is sufficient evidence showing that you have subjective malice or abuse of rights;
5. Responding to your request will cause serious damage to the legitimate rights and interests of other individuals or organizations;
6. Involving commercial secrets.
V. How we handle personal information of minors
2. If you have obtained your parents' consent to use our products or services, we will only use or publicly disclose your personal information when permitted by law, with the explicit consent of parents or guardians, or when necessary to protect minors.
3. 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 data as soon as possible. If you believe that we may improperly hold information about minors, please contact us using the public contact information listed at the end of this policy.
VI. How we store your personal information
In principle, the personal information we collect and generate during our operations in the mainland of the People's Republic of China is stored in China, except in the following circumstances:
1. Applicable laws have clear provisions;
2. Obtained your explicit authorization and consent, and conducted security assessments in accordance with the methods formulated by the national cyberspace administration and relevant departments of the State Council.
We promise that the storage time of your personal information will always be within a reasonable and necessary period. For personal information that exceeds the period, we will delete or anonymize it. When our products or services cease operations, we will notify you in the form of SMS notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period.
In the following situations, we may change the storage time of personal information to meet legal requirements:
1. To comply with applicable laws and regulations and other relevant provisions;
2. To comply with court judgments, rulings, or other legal procedures;
3. To comply with the requirements of relevant government agencies or legally authorized organizations;
4. We have reason to believe that we need to comply with laws and regulations and other relevant provisions.
5. Purposes reasonably necessary to enforce relevant service agreements or this policy, maintain public social interests, and protect the personal and property safety or other legitimate rights and interests of customers, us or our affiliated companies, other users, or employees.
VII. How this policy is updated
We will update the terms of this privacy policy in a timely manner when the following situations occur:
1. Changes in business functions;
2. Changes in our basic situation, such as changes in ownership caused by mergers, acquisitions, and reorganizations;
3. Changes in the scope, purpose, and rules of collecting, storing, and using personal information;
4. Changes in the objects, scope, and purposes of externally providing personal information;
5. Changes in the way you access and manage personal information;
6. Changes in data security capabilities and information security risks;
7. Changes in user inquiry and complaint channels and mechanisms, as well as external dispute resolution agencies and contact methods;
8. Other changes that may have a significant impact on your personal information rights.
Due to the large number of users, if this policy is updated, we will notify you through pop-up prompts, sending emails/short messages, or publishing announcements on the UPhoto official website (www.pailixiang.com). So that you can receive notifications in a timely manner, it is recommended that you notify us in a timely manner when your contact information changes. If you continue to use the services we provide after the update of this policy takes effect, it means that you have fully read, understood, and accepted the updated policy and are willing to be bound by the updated policy.
VIII. How to contact us
If you have any questions, comments, or suggestions about our privacy policy, you can contact us at any time through the following methods:
Company Name: UPHOTO PTE. LTD.
Company Address: 601 Macpherson Road, #08-22, Singapore 368242
Customer Service Phone: 00+65+80995060
Generally, we will reply within fifteen working days.
IX. Dispute resolution
1. The interpretation and dispute resolution of this privacy policy shall be governed by the laws of mainland China. Any disputes arising from this privacy policy and our processing of your personal information, you agree to submit it to the Suzhou Arbitration Commission for arbitration; the arbitration award is final and binding on both parties.
2. If you believe that our processing of personal information has harmed your legitimate rights and interests, you can also choose to report to relevant government departments.
3. The headings of this privacy policy are for convenience and reading purposes only and do not affect the meaning or interpretation of any provision in the text.
Appendix I: Third-party SDK Usage Instructions Document
1. WeChat Open SDK
Operating entity: Shenzhen Tencent Computer Systems Company Limited
Official website link: https://open.weixin.qq.com
Purpose of use: Used for users to share albums with WeChat friends, Moments, etc., to improve user experience efficiency