Legal Documents

Introduction

This Privacy Policy is formulated by Shenzhen Huanle Technology Co., Ltd. (hereinafter referred to as “the Company”, “we” or “us”) to explain how our OTA system update product (the “Service”) collects, uses, stores, shares and protects your personal information when providing device system detection, version updates, firmware upgrades and performance optimisation, and to describe the rights you enjoy.

Please read and fully understand this Policy before using the Service. By enabling or using the Service, you acknowledge that you have read, understood and agreed to all terms of this Policy. If you do not agree with any part of it, please stop using the Service immediately.

1. Information We Collect

To keep the OTA update service running, match upgrade resources accurately, fix system vulnerabilities, troubleshoot device faults and safeguard update security, we strictly follow the principle of minimum necessity and collect and use only the information necessary for the Service. Information is collected either locally on the device or passively on the server side, as detailed below:

1. Unique device identifiers and basic hardware information: device model, unique device identifier (Device ID / IMEI / MAC address), hardware serial number, hardware parameters, device configuration and manufacturer information — used to identify your device accurately and match the dedicated firmware and installation package, thereby avoiding compatibility errors during updates.
2. System version and update configuration information: current system version, firmware version, kernel version, installed module versions, your update preferences (automatic / scheduled / manual update) and update switch settings — used to determine update requirements and push compatible versions.
3. Update service and device diagnostic logs: update detection records, download progress and status, installation logs, failure codes, system diagnostic logs, module update records and service interaction logs — used to troubleshoot update anomalies, fix vulnerabilities and keep the update process secure and stable.
4. Network and access information: connection type, mobile carrier, network access status, network node information and network environment parameters — used solely to ensure stable download of update files and to support resumable transfers, preventing failures caused by network anomalies.
5. Server-side statistical and diagnostic data: to continuously improve service stability and resolve common issues across devices, our servers automatically collect anonymised update statistics, service access requests, feature usage rates and crash diagnostics. Such data is de-identified and anonymised and cannot be linked to any individual user, and is used only for product analysis and service optimisation.
6. Firmware and module verification information: update package checksums, firmware compatibility verification data and module update verification logs — used to verify update file integrity, prevent malicious firmware injection and safeguard device update security.

2. How We Use Your Information

The information we collect is used only for the following lawful, legitimate and necessary purposes, and will not be used for any unauthorised commercial or other purpose:

1. Matching the system update package and firmware resources that fit your device, and pushing compliant and compatible version updates;
2. Detecting device system status, troubleshooting update anomalies and faults, and completing fixes and service optimisation;
3. Compiling service operation statistics to optimise the update process, improve download and installation stability, and continuously enhance product experience;
4. Complying with applicable laws, regulations and regulatory requirements, including compliant data retention and industry filings.

3. Storage and Protection of Information

1. Retention period: We retain your device information and service logs only for the period necessary for the Service. When the update service ends or the information is no longer necessary, the data will be automatically de-identified or deleted. Where laws and regulations require mandatory retention, we will retain it strictly for the statutory period.
2. Storage method: Relevant information is stored in encrypted form on compliant servers, protected by multiple technical and organisational measures including hierarchical access control, data masking and full-process security auditing, so as to fully protect the security of your device information.
3. Security safeguards: We continuously improve our security mechanisms to prevent leakage, tampering, loss and misuse of data. If a personal information security incident occurs or may occur, we will activate our emergency plan in accordance with the law and fulfil our notification and reporting obligations in a timely manner.

4. Sharing, Transfer and Disclosure

We do not sell, rent or share your personal information with any third party. We will not provide your information to any third party without your prior explicit authorisation, except in the following statutory circumstances:

1. Where disclosure is required by laws and regulations, or by judicial or administrative authorities in accordance with statutory procedures;
2. Where disclosure is necessary in an emergency to protect the life or property of you or other users, or to safeguard public interests;
3. Where you have voluntarily and explicitly authorised a legitimate third-party service scenario.

In the above circumstances, we will strictly require the recipient to observe confidentiality obligations and data processing restrictions, and to use the relevant information only within the authorised scope.

5. Your Rights

You enjoy the following rights regarding your device-related information: the right to know, the right to access and copy, the right to rectification, the right to deletion and the right to withdraw authorisation.

1. You may view the information collection and use rules of the Service at any time in your device settings or the APP settings page;
2. You may stop further information collection by turning off automatic OTA updates or disabling the update detection permission;
3. To access, copy, correct or delete device service data retained by us, you may submit a request through the in-product customer service or our official contact channel, and we will handle it promptly after verifying your identity;
4. You may withdraw any authorisation you have granted at any time. After withdrawal, we will stop collecting and using the corresponding information (withdrawal does not affect processing already carried out on the basis of the authorisation before withdrawal).

6. Protection of Minors

The Service is open to users of all ages. If you are a minor (in particular a child under the age of 14), please read this Policy and use the Service under the guidance and supervision of a guardian. We do not proactively collect sensitive personal information of minors; if such information is collected inadvertently, we will delete it completely at the earliest opportunity.

7. Updates to This Policy

We may revise this Privacy Policy from time to time in response to product iteration, business adjustments, and changes in laws and regulatory requirements. After an update, we will proactively notify you through in-APP pop-ups, page announcements or similar means. The updated Policy takes effect on the date of publication. Where the update involves material changes such as the scope of information collected or the purposes of use, we will obtain your explicit consent again. Your continued use of the Service constitutes acceptance of all updated terms.

8. Contact Us

If you have any questions, suggestions or complaints regarding this Privacy Policy, please contact us through our official customer service channel. We will verify, handle and respond to your request in a timely manner.

Introduction

These Terms of Service are formulated by Shenzhen Huanle Technology Co., Ltd. (the “Company”) to govern the use of its OTA system update product (the “Service”) and to define the rights, obligations and liabilities between users and the Company. Any user who enables, accesses or uses the Service is deemed to have fully read, understood, voluntarily accepted and agreed to be bound by all provisions of these Terms. If you do not accept any part of these Terms, please stop using the Service immediately.

1. Description of the Service

The Service is a dedicated OTA system update service providing compliant users with basic technical services including device system version detection, firmware update delivery, system vulnerability patching, feature iteration and optimisation, update security verification and device operation protection.

The Company may continuously update, optimise and adjust firmware resources and service features in accordance with product iteration, technological upgrades, device adaptation optimisation, and applicable laws and regulatory compliance requirements, so as to keep users' device systems secure and stable.

2. Rules of Use

Throughout your use of the Service, you shall strictly comply with national laws and regulations, industry norms and the Company's service agreements, use the Service lawfully and shall not engage in any of the following violations:

1. Using the Service in violation of laws, public order and good morals, or regulatory requirements, or for any activity that is illegal, infringing, endangers public safety, harms public interests or the legitimate rights and interests of third parties;
2. Beyond the scope of normal personal use, cracking, reverse engineering, decompiling, tampering with or copying the Service, device firmware or system programs, or carrying out malicious adaptation or batch flashing;
3. Interfering with or disrupting the normal operation of the Service by technical means, attacking, intruding into or occupying the Company's server resources, stealing, tampering with or forging service data and device information, or bypassing the official update verification mechanism;
4. Using the Service to harvest service resources in bulk, conduct malicious testing, divert traffic in violation of rules, or engage in any other conduct that damages the security and operational order of the Company's services.

If you breach the above rules, the Company has the right to restrict, suspend or terminate the Service to you at any time depending on the circumstances, without any obligation to compensate or indemnify.

3. Service Permissions and Changes

1. Independent permission management: you may enable or disable OTA update detection, automatic updates, scheduled updates and other functional permissions in your device system settings according to your needs. After a permission is disabled, the corresponding update service will be suspended, without affecting the basic functions of the device;
2. Adjustment of service content: the Company reserves the right to adjust, optimise, iterate or partially take offline the functions, push rules, service scope and supported device models of the Service based on technological iteration, business optimisation, compliance rectification and product upgrade needs;
3. Temporary interruption: where the Service is temporarily interrupted, slowed down or suspended due to reasonable and objective causes such as system maintenance, server upgrades, network failure, force majeure, regulatory orders or third-party service anomalies, the Company shall not be liable for any user losses and will restore normal operation within a reasonable period.

4. Disclaimer

1. The Service is provided to you on an “as available” basis. The Company will use existing technology to endeavour to ensure the stability, security and integrity of the Service, but does not warrant that the Service is completely free of faults, interruptions, vulnerabilities or anomalies;
2. Provided that you operate in compliance with the rules, maintain a normal network connection and your device hardware is intact, the Company guarantees the secure adaptation and update compliance of official firmware. Problems such as update failure, device abnormality, system failure or data abnormality caused by your own reasons (including but not limited to unauthorised flashing, tampering with system files, cracking firmware, interrupting an update midway, device hardware failure, network anomalies, third-party software interference or use of non-official tools) shall be borne entirely by you, and the Company shall not be liable;
3. You expressly acknowledge and agree that the Service is intended only for official system optimisation and security updates of your device. All device risks, security risks and legal consequences arising from your unlawful use, illegal modification of the device or unauthorised modification of system parameters shall be borne by you.

5. Termination of the Service

The Company has the right to unilaterally suspend or terminate the Service to you, without prior notice, in any of the following circumstances:

1. You breach these Terms of Service or applicable national laws, regulations or regulatory requirements;
2. You maliciously use, attack, damage or interfere with the normal operation of the Service or server systems;
3. The product or service must cease operation due to business adjustment, compliance requirements or regulatory orders;
4. Other reasonable circumstances determined by the Company that require suspension or termination of the Service.

6. Updates to These Terms

The Company may revise these Terms from time to time in response to business development, updates to laws and regulations, regulatory policy adjustments and industry norms. After revision, users will be notified through device announcements, service pop-ups, page publication or similar means, and the revised Terms take effect on the date of publication. Your continued use of the Service constitutes voluntary acceptance of and agreement to be bound by all revised terms.

7. Governing Law and Dispute Resolution

The formation, entry into force, performance, interpretation and dispute resolution of these Terms are governed by the laws of the mainland region of the People's Republic of China. Any dispute arising between you and the Company in connection with the Service shall first be resolved through friendly negotiation; if negotiation fails, either party has the right to bring an action before the people's court with jurisdiction at the place where the Company is located.

8. Contact Us

If you have any questions, suggestions or complaints regarding these Terms of Service or the rules of use, please contact us through the Company's official customer service channel. We will verify, handle and respond to your enquiry in a timely manner.

Introduction

This Privacy Policy is formulated by Shenzhen Huanle Technology Co., Ltd. (the “Company”, “we” or “us”). To protect your legitimate rights and interests and to regulate our collection and use of information in the Beauty Camera product (the “App”), we have formulated this Policy in accordance with the Personal Information Protection Law of the People's Republic of China, the Cybersecurity Law, the Data Security Law and other applicable laws and regulations.

This Policy explains how we collect, use, store, transmit and protect your personal information when providing photo capture, video recording, beauty retouching, filter effects, image editing and material saving services, as well as all the legal rights you enjoy. By downloading, installing or using the App, you acknowledge that you have voluntarily read, understood and agreed to all terms of this Privacy Policy.

1. Information We Collect

We strictly follow the principle of minimum necessity and collect only information necessary for the Beauty Camera service. We do not force or request any unnecessary information. The scope of collection is as follows:

1. Camera and media permission information: after you actively authorise it, we obtain the device camera permission (for photo capture, video recording and real-time beauty preview) and the gallery read/write permission (for saving your works and reading local images for editing and retouching);
2. Basic device information: device model, system version, device identifier, application operation logs and service interaction records — used only for adapting beauty effects, fixing operational faults and optimising user experience;
3. User-created content: original photos and videos you shoot or edit through the App are stored locally on your device by default. Unless you actively choose to upload or share them, we will not proactively obtain, back up or retain your creative content;
4. Optional authorised information: after your separate and active authorisation, we may obtain the device network permission to load online filters and effect materials and to complete app version updates. Without network permission, we provide only basic local beauty editing services.

2. How We Use Your Information

All information collected is used solely for service performance, function implementation and compliant product optimisation, and will not be used in unrelated scenarios. Specific purposes are as follows:

1. Core functions: stably delivering basic services such as photo capture, video recording, real-time beautification, filter application, image and video editing, and saving of works;
2. Function adaptation: adapting beauty algorithms and effect materials according to different device parameters to ensure normal operation and compatibility across device models;
3. Experience optimisation: compiling lawful app operation data, troubleshooting lag, crashes and functional anomalies, and continuously refining beauty effects and product features;
4. Loading online resources: after you authorise the network permission, updating effect materials, iterating new version features and pushing compliant service content;
5. Compliant operation: strictly complying with national laws, regulations and regulatory requirements to keep the service lawful, compliant and secure.

3. Storage, Transmission and Protection

1. Storage method: your photos and edited works are stored locally on your device by default, and our servers do not proactively back up or retain user-created content. Only app operation logs and device adaptation data are stored in encrypted form on compliant servers for product optimisation;
2. Retention period: service operation data is retained only for the necessary operational cycle and is automatically cleared and destroyed upon expiry; your locally created content is managed by you and may be deleted at any time;
3. Transmission: all data transmitted during online resource loading and version updates is encrypted, effectively preventing data theft, tampering and leakage;
4. Security safeguards: we have established a comprehensive information security system, applying technical encryption, hierarchical permission control, data security auditing and risk monitoring to fully protect user information security and to prevent leakage, misuse, tampering and loss.

4. Sharing and Disclosure

We never sell, rent or trade your personal information or creative content to any third party. We will not share or disclose your personal information to any third party without your explicit written consent, except in the following statutory circumstances:

1. Where disclosure is required by laws and regulations, judicial authorities or administrative authorities in accordance with the law;
2. Where disclosure is necessary in an emergency to protect users' life and property safety or to safeguard public interests;
3. Where you have actively and explicitly authorised a legitimate third-party service scenario.

In the event of a merger, division, restructuring or asset transfer that changes the personal information controller, we will inform you of the name and contact details of the recipient and require the recipient to remain bound by this Policy. Where the original purpose or method of processing changes, we will obtain your authorisation again.

5. Permissions and Your Rights

1. Permission management: you may enable or disable camera, gallery, network and other permissions at any time in your phone's system settings. After a permission is disabled, the corresponding function will be unavailable, but other basic functions of the App will continue to work normally;
2. Right to know: you may view the complete Privacy Policy and information use rules within the App at any time;
3. Right to deletion and rectification: you may delete locally created content at your own discretion. To access, correct or clear device operation data retained by us, you may contact official customer service and we will process your request promptly after verifying your identity;
4. Right to withdraw authorisation: you may withdraw any permission granted at any time. After withdrawal, we will immediately stop collecting, using and storing the corresponding information.

6. Privacy Protection for Minors

The App is open to general users, and minors should use it under the accompaniment, guidance and supervision of a guardian. We attach great importance to minors' privacy: we do not proactively collect sensitive personal information of minors, and we do not use user information for non-compliant marketing or pop-up promotion, so as to fully protect minors' online privacy and information security.

7. Updates and Notification

We may revise this Privacy Policy in response to product upgrades, business adjustments, and updates to laws and regulatory requirements. After a change, we will proactively notify users through in-app announcements, pop-up reminders or similar means. The updated Policy takes effect on the date of publication. Where the update involves material changes such as the scope of information collected or the purposes of use, we will obtain your explicit consent again. Your continued use of the App constitutes acceptance of all updated terms.

8. Enquiries and Feedback

If you have any questions or objections regarding the content of this Privacy Policy or the way we collect and use information, please contact us through our official customer service channel and we will respond and handle the matter promptly.

Introduction

These Terms of Service are formulated by Shenzhen Huanle Technology Co., Ltd. (the “Company”) to govern the use of its Beauty Camera application (the “App”), to define the rights, obligations and liabilities between users and the Company, and to protect the legitimate rights and interests of both parties. Any user who downloads, installs, accesses or uses all or part of the App's functions and services is deemed to have fully read, understood, voluntarily accepted and agreed to be bound by all provisions of these Terms. If you do not accept any part of these Terms, please uninstall the App and stop using all of its services immediately.

1. Overview of the Service

The App is a lightweight image editing tool for general users, providing personal entertainment services such as photo capture, video recording, real-time beautification, filter effects, image and video editing, material enhancement and local storage of works.

The Company may, at its own discretion and in accordance with product iteration, feature optimisation, system adaptation, compliance rectification and operational needs, add, optimise, adjust or take offline features of the App, so as to keep the product secure, stable and compliant.

2. Rules of Use and User Obligations

When using the App, you must strictly comply with national laws and regulations, cybersecurity norms, public order and good morals and these Terms, consciously fulfil your obligations as a user, and strictly refrain from the following violations:

1. Use the App lawfully. You shall not use the App to create, shoot, edit, store, transmit or publish content that is illegal, pornographic, violent, terrorist, false, rumour-based or infringing, nor create or distribute content that infringes others' rights of portrait, privacy, reputation or other legitimate rights and interests;
2. You shall not perform reverse engineering, cracking, code tampering, plug-in injection, malicious modification, plagiarism or replication of the App, its components, backend systems or servers, nor steal or redistribute the App's proprietary material resources in bulk;
3. You shall not use cheats, scripts, malicious programs or third-party tools to interfere with the normal operation of the App, nor attack, intrude into, occupy or damage the Company's servers and backend system resources;
4. You shall not use the App to conduct fraud, traffic diversion, unlawful promotion, bulk generation of harmful content or malicious marketing that damages the operational order of the platform or the legitimate rights and interests of third parties;
5. You shall properly safeguard your device and app usage permissions. All risks and consequences arising from your own reasons, such as personal operational errors, loss of the device, lending the device to others or unauthorised authorisation, shall be borne by you.

If you breach the above provisions, the Company has the right, depending on the severity of the case, to restrict functions, freeze permissions, terminate use or delete the violating content, without any obligation to compensate or indemnify. If your violation causes reputational or property damage to the Company, you shall bear full liability for compensation in accordance with the law.

3. Intellectual Property

1. User-created content: original photos, videos and other works you shoot, edit or create through the App are owned by you in terms of intellectual property. You warrant that your created content is lawful and infringes no rights of others; all infringement disputes and legal liabilities arising from your created content shall be borne solely by you;
2. Platform materials: all built-in filters, effects, stickers, templates, copy, interface designs and other materials and functional content of the App are the exclusive intellectual property of the Company. You may use them only within the App for personal non-commercial purposes; private extraction, downloading, redistribution, secondary modification, dissemination, commercial use and bulk misappropriation are prohibited;
3. Infringement liability: without the Company's written authorisation, no entity or individual may misappropriate, replicate, distribute or commercially use the intellectual property content of the App. The Company will safeguard all of its legitimate rights and interests in accordance with the law.

4. Change, Interruption and Termination of the Service

1. Change of service: the Company reserves the right to add, optimise, adjust or take offline features of the App in accordance with product operation, technological upgrades and compliance rectification needs. After such adjustments, users will be notified through in-app announcements, pop-up reminders or similar means;
2. Service interruption: where the service is temporarily slowed down, interrupted or unavailable due to reasonable causes such as server maintenance, system upgrades, network failure, force majeure, regulatory rectification or third-party service anomalies, the Company shall not be liable for user losses and will restore operation as soon as possible;
3. Termination of service: where a user engages in violations such as unlawful use, malicious attacks, image infringement, bulk cheating or dissemination of harmful or illegal content, the Company has the right to unilaterally and permanently terminate the user's right to use the App and ban the device, without prior notice or any compensation.

5. Disclaimer

1. The App is provided on the basis of existing technological conditions. The Company will endeavour to keep the App running stably, but does not guarantee that the service is absolutely free of faults, lag, interruption or vulnerabilities, and makes no absolute commitment to the perfection or absolute stability of the service;
2. All your original works are stored locally on your device by default, and the Company does not proactively back up or retain user-created content. The Company shall not be liable for any loss of content caused by your own reasons, such as device damage, system failure, accidental manual deletion, device replacement or loss of local data;
3. All risks and consequences arising from app malfunction, content loss or device failure caused by non-platform reasons, such as your unlawful operation, private modification of the application, use of third-party tools, network anomalies, device system conflicts or third-party software interference, shall be borne by you;
4. All content you generate, edit, publish or distribute through the App is your sole responsibility. All corresponding legal and infringement liabilities shall be borne by you and are not attributable to the Company.

6. Rules for Use by Minors

The App is open to users of all ages. Minors must use the App lawfully under the accompaniment, guidance and supervision of their legal guardians. Legal guardians bear full supervisory responsibility for minors' use and shall be responsible for all consequences arising from a minor's unlawful use or publication of harmful content. The Company strictly protects minors' privacy and information security, resolutely resists the spread of harmful information and safeguards a healthy online environment for minors.

7. Revision and Notification

The Company has the right to revise these Terms from time to time in response to updates to laws and regulations, regulatory policy adjustments and product and business iteration. After an update, users will be notified through in-app announcements, pop-up publication or similar means, and the revised Terms take effect immediately upon publication. Your continued use of the App constitutes voluntary acceptance of and agreement to be bound by all provisions of the latest version of these Terms.

8. Governing Law and Dispute Resolution

The validity, performance, interpretation and dispute resolution of these Terms are governed by the laws of the mainland region of the People's Republic of China. Any dispute arising between you and the Company in connection with the App shall first be resolved through friendly negotiation; if no agreement can be reached, either party may bring an action before the people's court with jurisdiction at the place where the Company is located.

9. Enquiries and Feedback

If you have any questions, suggestions or complaints regarding these Terms, the App's functions or your service experience, please contact us through the Company's official customer service channel. We will verify, handle and respond to your enquiry in a timely manner.