PhotoMagic Privacy Policy

Last Updated, Effective and Date of Release: July 23,2025

This Privacy Policy applies to PhotoMagic Software and Services ("the Services"). The Services are provided and controlled by Hong Kong Mishi Technology Co., Ltd. and its affiliates ("we").

We are committed to protecting and respecting your privacy. This Policy explains how we collect, use, share, and otherwise process personal information of users and other individuals using our software. To ensure safer service usage, you should read and comply with the PhotoMagic Privacy Policy (hereinafter referred to as "this Policy"). If you do not agree with this Policy, we may be unable to provide you with the services.

"Personal Information" means any information relating to an identified or identifiable individual. This Policy describes the information we collect from you through our services, how we use and disclose such information, and the steps we take to protect such information.

This policy helps you understand the content:

PhotoMagic Privacy Policy directory

I. Introduction

II.How we collect and use your personal information

III.How we use Cookies and similar technologies

IV. How we share, transfer and publicly disclose your personal Information

V. How we protect your personal Information

VI. Your Rights

VII. How we store your personal Information

VIII.How we handle the personal information of minors

IX. How to update this Policy

X. Other

XI. Contact Us

I. Introduction

1.1 The PhotoMagic Privacy Policy applies to all products and services provided by PhotoMagic to you, including the PhotoMagic mobile client ("APP") and other clients.

1.2 Please read and fully understand the contents of this Privacy Policy carefully before using any PhotoMagic products and/or services. Once you use or continue to use PhotoMagic products/services, you agree that we will use and process your relevant information in accordance with this Privacy Policy.

1.3 We may revise this Privacy Policy from time to time in accordance with laws and regulations or business adjustments. When this Privacy Policy is changed, we will display the changed content to you through prominent prompts after the version update.

1.4 You should understand that we will only collect, use, process and store your personal information in accordance with this Privacy Policy after you confirm and agree to it. You have the right to refuse to agree to this Privacy Policy, but please note that doing so may result in your inability to fully utilize PhotoMagic's services and features, or prevent us from achieving the intended service objectives.

II.How we collect and use your personal information

2.1 We fully recognize the importance of your personal information and will make every effort to protect it. Committed to maintaining your trust, we take comprehensive security measures in compliance with local regulations to safeguard your data. Should we need to use your personal information for purposes not explicitly stated in this Privacy Policy, or repurpose collected data for other purposes beyond its original intent, we will promptly notify you through appropriate channels and obtain your consent.

2.2 Under normal circumstances, we will collect and use your personal information for the following purposes:

2.2.1 [Maintaining the normal operation of basic functions] In order to identify abnormal status of accounts, understand product adaptability, provide you with basic services such as browsing, and ensure the normal operation of services, we may collect and store information about your use of services and usage methods, including:

Log information: When you use our services, we may collect your detailed usage of our services as part of the network log preservation. This includes your login account, access history, membership opening records, collection and sharing history.

Device Information: We may receive and record the device information you use, including device model, operating system and version, client version, and device identifier (IMEI/ Android ID/OAID), according to the specific permissions you grant during software installation and use.

Mobile network information such as public land mobile network (PLMN) provider ID, geographical location (cell ID in the area where the device is located) and Internet Protocol (IP) address.

Location Information. When you access certain location-based services, we collect, use, and process your approximate or precise device location. This information may be obtained through GPS, wireless local area networks (WLAN), or service provider network IDs. We will ask you to enable location services. You can disable the corresponding permissions and refuse to share your location.

2.2.2 [Account Registration and Login] When you register a PhotoMagic account, we collect your voluntarily provided information including nickname, gender, date of birth, city, personal profile, and third-party media platform account details. This information is collected to assist you in completing PhotoMagic registration and establishing your personal account. The aforementioned information will remain authorized for our use throughout your service engagement.

2.2.3 [Image Editing & Feedback] When using PhotoMagic for image editing, feedback, or related features, we may need to access your device's camera permissions and photo album storage permissions. These are sensitive permissions that we only use with explicit authorization from you. You can revoke this authorization at any time.

When using PhotoMagic's editing tools—including special effects, filters, and stickers—some may require processing of your personal information. For example, when selecting facial-related tools during content editing, we need to identify your facial features (e.g., eyes, nose, mouth corners) for facial processing to enhance visual quality. Unless explicitly stated and with your separate consent, we will not transmit, store, or share this information with third parties. All processed data remains exclusively stored on your device.

When you use AI features like outfit swapping or photo dancing, PhotoMagic needs to identify key facial features in the image (such as eyes, nose, and mouth). The complete process is: (1) You upload your photo to our servers. (2) The server analyzes your image and returns facial data processing results. (3) The app automatically combines these processed results with existing materials to create final effects. (4) This information is temporarily stored in encrypted storage. After synthesis completion, your uploaded photos will be automatically deleted immediately. We neither store any photo data nor share it with third parties.

We will never open the camera, read the photo album information to steal your privacy, read your picture content, and will not use such illegal means to push information and advertisements.

2.2.4 [Audio-Visual Display, Playback, and Download Services] When you use audio-visual displays or playback services, we collect browsing history, playback records, and favorites during your usage. If you need to use the download function, we will request access to your device's storage permissions. If you refuse to grant these permissions, you will be unable to use PhotoMagic's video download feature, but this will not affect your access to basic audio-visual display and playback services.

2.2.5 [Personal Data Editing Function] When you use PhotoMagic to edit your personal profile, we need to access the storage permission of your device to access the pictures in the device album for you to choose.

You can view the PhotoMagic Application Usage Instructions to learn about the purpose, method, and scope of each permission required for the above functions.

Permissions

Permission Name

Usage scenarios and purposes

Storage permissions

Read and write storage card permissions

READ_EXTERNAL_STORAGE

WRITE_EXTERNAL_STORAGE

When entering the local video creation module, read the videos and pictures in the local album

Album access permissions

READ_EXTERNAL_STORAGE

In local videos, when setting avatars, it is used to obtain local videos and pictures

Installation package download permission, application installation permission

REQUEST_INSTALL_PACKAGES

1. When there is a new version upgrade, it is used to download the latest version installation package and install it

Network permissions

INTERNET, ACCESS_NETWORK_STATE, ACCESS_WIFI_STATE, CHANGE_NETWORK_STATE

1. Read the current network type to determine whether it is wifi or mobile network

2. Connect to the network and request interface data through the network

2.2.6 [Third-Party Services] Our products may include third-party SDKs, advertisers, or similar applications. When using these third-party services on our platform, you agree to allow them to directly collect and process your information (e.g., through embedded code). The collection and processing of information by third-party SDK providers and advertisers shall comply with their own privacy policies and are not covered by this policy. To ensure maximum protection of your information security, we recommend reviewing the privacy terms of any third-party SDK service before use. To safeguard your legal rights, if you identify risks associated with an SDK or similar application, please immediately terminate the operation and contact us promptly.

2.2.7 [Customer Support] When you file a complaint, appeal, or request assistance with PhotoMagic, we may require you to provide account details for identity verification and system security. To facilitate communication and resolve issues, we may also need your name, email, and other contact information (including sensitive data). Additionally, we collect communication records (text, images, audio/video) and relevant details to investigate issues. If you refuse to provide this information, we may delay responding to your request. During interactions, you may need to access your photo albums or camera permissions to communicate with customer service. You can always disable these permissions through your device's settings at any time.

2.2.8 When you upgrade our mobile client ("APP") or click on the third-party advertising information in our products or services, you may need to open the permission to install the application. If you refuse to open it, you may not be able to complete the upgrade of our APP or use the third-party products or services.

2.2.9 The functions and services provided to you are constantly updated and developed. If a certain function or service is not mentioned in the foregoing description and collects your information, we will explain the content, scope and purpose of information collection to you separately through page prompts, interactive processes, announcements, etc., so as to obtain your consent.

Additionally, we only use your personal data in accordance with legal requirements. Under applicable local laws, we may utilize your personal data for one of the following purposes: with your consent; to fulfill obligations under contracts between you and us; to protect the legitimate interests of you or others; to comply with legal requirements; or to safeguard the lawful interests of our company.

III.How we use Cookies and similar technologies

3.1 Cookie

To ensure the website operates smoothly and provides a more seamless browsing experience, we store small data files called Cookies on your computer or mobile device. These Cookies typically contain identifiers, the site's name, and some numbers and characters. Through Cookies, websites can store data such as your preferences.

3.2 Website beacons and pixel tags

In addition to Cookies, we utilize other technologies like website beacons and pixel tags on our platform. For example, emails we send may contain links to content within our site. When you click these links, we track the action to understand your preferences regarding products or services, enabling us to proactively enhance your experience. A website beacon typically appears as a transparent image embedded in webpages or emails. Through pixel tags in emails, we can determine whether they have been opened. If you wish to opt out of such tracking, you may unsubscribe from our mailing list at any time.

3.3 Ensure the safe and efficient operation of products and services

If you do not accept our use of Cookies and similar technologies to collect and process your information, you may manage (partial/complete) rejection of Cookies and/or similar technologies through browser settings if available. Alternatively, you can delete Cookies and/or similar technologies already stored on your computer, mobile device, or other devices to prevent us from tracking your personal information in whole or in part. For detailed instructions on modifying browser settings, please refer to the specific settings page of your browser. You acknowledge that certain products/services require Cookies or similar technologies for functionality. Refusing or deleting these may result in impaired usability of our products/services or prevent you from receiving optimal service experiences.

IV. How we share, transfer and publicly disclose your personal Information

4.1 Sharing

We will not share your personal information with third parties unless you expressly authorize and consent to do so, but we may share your personal information under the following circumstances:

4.1.1 Your personal information may be shared among our affiliates. We only share necessary personal information (such as account information required for using other products/services of affiliated companies, identifying abnormal accounts, or protecting the personal and property safety of PhotoMagic affiliates or other users/the public) that aligns with the purposes stated in this Privacy Policy. If we share sensitive personal information or if affiliates modify the use and processing purposes of personal information, we will seek your authorization and consent again.

4.1.2 To provide you with more comprehensive and high-quality products and services, some of our services will be delivered through authorized partners. We may share certain personal information with these partners to enhance customer service and user experience. We only share your personal information for legally valid, necessary, specific, and clearly defined purposes, and exclusively for the essential functions required to deliver our services. Our partners are prohibited from using the shared information for any other purposes. Furthermore, we have signed strict confidentiality agreements with our partners, requiring them to handle your personal information in accordance with our instructions, this Privacy Policy, and all relevant security protocols. Our partners are not permitted to use the shared information for any unauthorized purposes. If you refuse to allow our partners to collect necessary personal information during service provision, you may be unable to access the third-party services on our platform.

At present, our partners are:

(1)Third-party SDK service providers: Our products may contain third-party SDK applications. If you use such third-party service providers on our platform, you agree that they will directly collect and process your information, subject to the privacy terms of the third-party service providers themselves.

(2)Advertisers: We share with advertisers how many users view or click on an AD in the Service.

4.2 Transfer

We will not transfer your personal information to any company, organization or individual except as follows:

4.2.1 Transfer with explicit consent: With your explicit consent, we will transfer your personal information to other parties;

4.2.2 In the event of merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will notify you in advance and require the new company or organization holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require the company or organization to seek authorization from you again.

4.3 Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

1) After obtaining your express consent;

2) Disclosure based on law and reasonable reasons: We may publicly disclose your personal information in the case of legal, legal procedures, litigation or mandatory requirements of government authorities.

Special Note: For your personal information disclosed publicly, we will immediately review the legitimacy, rationality and legality of the disclosure application upon receipt, and take the strictest personal information security protection measures and means to protect it during and after the disclosure.

V. How we protect your personal Information

5.1 We implement security measures compliant with local standards to protect your personal information, preventing unauthorized access, public disclosure, use, modification, or loss of data. We maintain reasonable security protocols including encryption technologies (e.g., SSL) and anonymization processes to safeguard your data. An access control system ensures only authorized personnel can access personal information, while we regularly conduct security and privacy training sessions to enhance staff awareness of data protection importance.

5.2 We continuously enhance the security capabilities of software installed on your device through advanced technical measures to prevent personal information leaks. For instance, we perform partial encryption of data locally on your device for secure transmission. Additionally, we implement protective measures against viruses, malware, and other malicious programs, while also preventing websites from accessing installed applications or running process details on your device.

5.3 We have established a special personal information protection department, management system, process and organization to ensure the security of information. For example, we strictly limit the scope of personnel who have access to information, require them to comply with confidentiality obligations and conduct audits.

5.4 In case of security incidents such as personal information leakage, we will start the emergency plan to prevent the expansion of security incidents and inform you by announcement.

5.5 We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will retain your personal information only for the period necessary to achieve the purposes stated in this Policy, unless the retention period needs to be extended or permitted by law.

5.6 The Internet is not an absolutely secure environment. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to not disclosing your account passwords or other sensitive details to others. If you discover any leakage of your personal information, please immediately contact PhotoMagic customer service so we can take appropriate actions based on your request.

5.7 The internet environment is not 100% secure. We will make every effort to ensure or guarantee the security of any information you provide to us. In the event of a personal information security incident, we will promptly inform you in accordance with local legal requirements: the basic circumstances and potential impacts of the incident, the measures we have taken or will take to address it, suggestions for you to independently mitigate risks, and remedial actions available to you. We will notify you of the incident details via email or other means. When individual notifications are difficult to deliver, we will issue public announcements through reasonable and effective channels. Additionally, we will proactively report the handling progress of personal information security incidents to local regulatory authorities as required.

VI. Your Rights

We appreciate your concerns regarding personal information. To facilitate easier access, correction, supplementation, and deletion of your data, while ensuring you can revoke consent for information usage and cancel accounts, we have incorporated user-friendly settings in our product design. Please refer to the following instructions for implementation. Additionally, we have established a complaint reporting channel where your feedback will be addressed promptly.

6.1 Access, correct and supplement your personal information

Access, correct and supplement basic information such as birthday, gender, profile picture, personal profile, etc.:

After you log in to your account, click "My"; click the profile column to access, correct and supplement information.

6.2 Access to Google/FaceBook/Apple ID account information

After you log in, click "My"; click the Settings button in the upper right corner, click "Account Management", and access the information.

If you cannot access such personal information through the above paths, you may contact us at any time through "Contact Us" in Article 10 of this Privacy Policy. PhotoMagic will respond to your request within 15 days.

If you encounter difficulties in exercising the aforementioned rights or if we currently cannot provide online self-correction/modification services, you have the right to correct or modify erroneous or incomplete information after identity verification, provided such corrections do not affect the objectivity and accuracy of the data. In specific cases, particularly when dealing with data errors, you may submit your correction requests through our published feedback channels and error reporting mechanisms. We will make corrections or modifications to your data, except where otherwise required by law. However, for security and identity verification purposes, you may not be able to modify certain initial registration details submitted during account setup.

6.3 Delete your personal information

With respect to some of your personal Information, you may also delete some of your personal Information by yourself through the methods specified in this Article "Access, Correction and Supplement of Your Personal Information".

In the following circumstances, you may request us to delete your personal information:

1) If our handling of personal information violates laws and regulations;

2) If we collect and use your personal information without your express consent;

3) If our handling of personal information seriously violates the agreement with you;

4) If you no longer use our products or services, or you voluntarily cancel your account;

5) If we permanently cease to provide you with products or services.

If we decide to respond to your deletion request, we will also notify as many subjects who have obtained your personal information from us as possible to request them to delete it in a timely manner, unless otherwise provided by laws and regulations, or such subjects have obtained your independent authorization.

When you or we assist you to delete information from our services, we may not immediately delete the corresponding information from the backup system in accordance with relevant laws and regulations. We will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.

6.4 Cancel your account

After you log in to your account, click "My", click the Settings button in the upper right corner, click "Account Management", and click "Log out".

6.5 Feedback and Suggestions

You can click "Me" and then click "Feedback".

6.6 Access Privacy Policy

You can go to the login page, or directly click "My", click the Settings button in the upper right corner, click "About Us", and click "Privacy Policy".

6.7 Withdrawal of your consent to personal Information

Some features of our products and services require access to your device permissions. You may revoke these permissions at any time after authorization. To revoke permissions, you can go to the permission management section in your mobile system settings. However, your decision to revoke permissions will not affect any personal information processing activities that were already conducted based on your previous authorization.

6.8 Respond to your above request

To ensure security, you may be required to provide a written request or otherwise identify yourself. We may ask you to verify your identity before processing your request.

We will respond within 15 days. We may refuse requests that are unwarranted, repetitive, require excessive technical means (e.g., the development of new systems or fundamental changes to existing practices), risk the legitimate rights and interests of others, or are otherwise impractical.

We will not be able to respond to your request under the following circumstances:

1)Local laws do not grant data subjects relevant rights;

2)The applicant's identity cannot be verified;

3)The application cannot be verified or beyond the scope, especially when the application is sent repeatedly;

4)The information requested relates to compensation that we will make or receive as a result of the ongoing dispute and disclosing such information would be detrimental to our interests;

5)The retained information is only for statistical and research purposes, and the publication of statistical and research results will not disclose personal identity;

6)Other circumstances provided by law.

If we refuse the request of the data subject, we will provide a formal explanation to the requester.

special explanation :

1)Only legal guardians or persons authorized by law have access to other people's personal data.

2)Most laws/legislation provide for situations in which organizations may not provide data to the data subject, including where providing the data would undermine ongoing counter-terrorism efforts; where the data subject has made multiple requests; or where obtaining and providing such information would be too resource-intensive.

3)Normally, we do not provide the following information:

4)Information about others: The request may involve other individuals. We will not provide such information unless authorized by the person concerned.

5)Repeating requests: If a data subject makes the same or similar request to the same data subject more than once and the data has not changed since we last provided it, in most cases we will not provide a copy of the data. In addition, we have no obligation to provide information that has already been made public.

6)Confidentiality: If the information is confidential, we have no obligation to provide the requested information.

7)Special Information: We will not disclose any special information in response to requests for access to personal data. In general, special information includes any confidential documents (e.g., attorney-client communications) and information obtained or expressed in connection with the provision of legal advice (whether or not it relates to the litigation itself or court proceedings).

6.5 To California users

Under the applicable California Consumer Privacy Act ("CCPA"), you have certain rights regarding your personal information collected for commercial purposes. Please note that this section applies only to individuals residing in California. Your rights include:

1)Understand your rights to the personal information collected by the enterprise and how it is used and shared;

2)The right to delete the information collected from you;

3)The right to opt out of personalized advertising;

4)The right to be free from discrimination in the exercise of the right to CCPA.

6.6 To EU users

Under the applicable General Data Protection Regulation ("GDPR"), you have certain rights to your personal information collected by us for commercial purposes. Please note that this section applies only to persons residing in the EU. Your rights include:

1)The right to obtain certain information about how we process your personal data, including: the purpose for which your personal data is processed; the categories of personal data processed; the recipient of your personal data; and how long we will keep your personal data;

2)The right to receive copies of any personal data we process about you in a commonly used and machine-readable format;

3)The right to delete;

4)Restricting your right to process your personal data;

5)The right to object to the processing of your personal data;

6)Withdraw your right to grant consent to us;

7)If you believe that we have infringed any of your rights, you have the right to file a complaint with the relevant data protection authority;

8)The right not to be bound by automated decisions relating to your personal data. We can confirm that we do not use automated decisions;

9)The right to be notified in the event of a personal data breach that may put your rights at high risk.

VII. How we store your personal Information

7.1 International data transfer

Your information may be stored on servers outside your country of residence, such as Singapore and the United States. In these places, privacy laws may not be as well protected as those in your state, province or country.

7.2 Term of information storage

Generally speaking, we will store your personal information when we obtain it during your use of the Service, and delete or anonymize it within a reasonable period after you cancel your PhotoMagic account.

When our products or services are discontinued, we will notify you in the form of announcements and delete your personal information or anonymize it within a reasonable period of time.

VIII.How we handle the personal information of minors

PhotoMagic provides its products and services exclusively to individuals aged 18 or older (or the age limit specified by your country). If you are a guardian of a child under 18 (or the age limit specified by your country), we urge you to fulfill your guardianship responsibilities to protect the child's personal information security. Additionally, please provide guidance and assistance to children under your supervision when they use our products and services. For children under 13 (or the age limit specified by your country), please carefully read this policy with parental or guardian assistance before using our services, and only provide information or access our services after obtaining their consent. Should we discover that our products have inadvertently collected children's personal information, we will promptly delete such data.

IX. How to update this policy

9.1 To provide you with enhanced services, we will update the terms of the PhotoMagic Privacy Policy in accordance with product updates and legal requirements. These updates shall form an integral part of the Privacy Policy. We will not reduce your rights under this policy without your explicit consent. If such updates substantially diminish or materially alter your rights under this Privacy Policy, we will notify you through prominent notices or other means before the policy takes effect. By continuing to use our services, you expressly acknowledge that you have read, understood, and agreed to be bound by the revised Privacy Policy.

2.2 Material changes include but are not limited to:

1) Major changes have been made to our service model, such as the purpose of processing personal information, the types of personal information processed, and the way personal information is used;

2) Major changes in ownership structure and organizational structure, such as business adjustment, bankruptcy and merger and acquisition that cause the change of owners;

3) Changes in the main objects of personal information sharing, transfer or public disclosure;

4) Major changes occur in your rights and exercise methods in the processing of personal information;

5) Changes in the responsible department, contact information and complaint channels for us to handle personal information security;

6) When the personal information security impact assessment report indicates that there is a high risk.

X. Other

10.1 All notices under this Agreement may be made by means of page reminders, emails, etc., and such notice shall be deemed to have been served on the recipient on the date of service.

10.2 The formation, effectiveness, performance, interpretation and dispute settlement of this Agreement shall be governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China (excluding conflict of laws).

10.3 This Agreement is executed in the Hong Kong Special Administrative Region of the People's Republic of China.

10.4 Any dispute or dispute between you and PhotoMagic shall first be settled through friendly negotiation. If no agreement can be reached through negotiation, you agree to submit the dispute or dispute to the people's court with jurisdiction at the place where this Agreement is signed.

10.5 The headings of all terms and conditions hereof are for convenience of reading only and have no practical meaning and shall not be used as the basis for interpreting the meaning of this Agreement.

10.6 If any provision of this Agreement is invalid or unenforceable for any reason, the remaining provisions shall remain valid and binding on both parties.

(End of text)

XI. Contact Us

11.1 If you have any questions or inquiries or complaints about the contents of PhotoMagic Privacy Policy or privacy protection related matters when using our services, you may contact us through any of the following ways:

1) You may submit feedback to us in accordance with Article 6.5 of this Privacy Policy;

2) You can contact us by email (email: fanshu.help@gmail.com). We will reply to you as soon as possible within 15 days after receiving your comments and suggestions and verifying your user identity.