CO2 Ai Headshot

INTRODUCTION. REGIONAL PATTERNS

AI Apps (“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or use of AI Apps software application for mobile devices (the "App", "our App").

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy policy applies to all users, and others who access the App (“Users”).

FOR CO2 Ai Headshot APP

A small note on how CO2 Ai Headshotfeature works.

1. What kind of information do we collect?

We may access or collect the following information in order to provide you with a better user experience and better services and to improve our products:

Categories of information may be collected from the following categories of sources:

Directly from you or your agent, such as through your submissions to the Services.

Directly or indirectly from activities through the Services, such as through your interactions with the Services.

From third parties with whom we partner to provide services.

We may access your personal information when you voluntarily choose to use our services, applications or provide us with your personal information.

• Content Information, i.e. photos, pictures and other data that you transfer using the App.

• Product interaction information and any user-generated content.

Facial Data Policy

• The facial data we collect

We analyze your photo and find out the feature points of the face in the photo (such as eyes, nose, mouth, etc.) for face processing. We do not collect facial data. After the analysis process is completed, all data will be deleted and no data will be saved.

For the core functions of photo processing (beautifying, coloring, repairing blurry old photos, and turning blurry photos into high-definition photos), our application will collect the avatar photos you upload or take. You can voluntarily allow our application to access the camera or album to obtain photos from your mobile device. Our application can only access your camera and album after you confirm your permission.

• Face recognition:

When you use certain facial recognition features, we will automatically capture the positions and shapes of your five senses, analyze facial feature information, store this information on our server for photo processing, and return the rendering to you. We will not store or share such processed photos, facial features, or renderings with any third party. After the analysis process is completed, all data will be deleted and no data will be saved.

• The purpose and process of collecting facial data

To give you a "face changing" effect, we need to find feature points (such as eyes, nose, mouth points).

Based on the core functions of photo processing (beautifying, coloring, and repairing blurry old photos to turn them into high-definition photos), we need to find feature points (such as eyes, nose, and mouth points).

The complete process is: (1) Submit the photos you have selected to our server in encrypted format; (2) The server analyzes the facial data in your photos and processes the photos you choose; (3) After processing, the server returns the final rendering effect to you through the application; (4) The final synthesized effect will be temporarily stored in encrypted storage and will be permanently deleted after a certain period of time. After the synthesis process is completed, we will immediately delete the facial image you submitted to the server.

• Face data sharing and storage

We will not share your facial data with any third party, nor will we store any facial information you submit. The photos you upload will be deleted after the analysis process is completed.

How long are my photos stored on your servers?

Images uploaded to the app to generate AI Avatars are automatically deleted from our servers after your avatars are created.

Analytics information

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information.

We use third-party automatic data processing technologies (such as Google and Facebook) to analyze certain information sent by your device or our App. Automatic data processing technologies (advertising or analytics tools) provide us with the data described below. We do not control, supervise or respond for how the third parties process your personal data, that might be processed by their own means (not through our App). Any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Facebook Privacy Policy: https://www.facebook.com/about/privacy/

Google Privacy Policy: https://www.google.com/policies/privacy/

Information other users provide about you

We also receive and analyze content, communications and information that other people provide when they use our Services. This can include information about you, such as when others invite you to use our application, and for doing so they provide us your phone number, name and other information. We require that these users have the legal rights to collect, use and share your data before they provide us with any information.

Regarding the Website: your browser transfers certain data so that it can access the Website, namely:

• the date and time of the request

• the browser type

• the operating system

• the language and version of the browser software.

To ensure your normal use of product features and services, CO2 Ai Headshot will use the following permissions for other data that we may access

We will also access the following information to provide you with an enhanced user experience and better services, as well as to improve our products. Relevant permission content is dynamically obtained when you use product services and features. You can control whether permissions are turned on or off in system settings, but your selections and settings may affect the normal use of certain features of the product. "The information that may be accessed, collected, or shared may be used for application analysis or advertising analysis or other third-party SDKs. The specific content can be viewed in the privacy policy of" "APPENDIX - ADVERTISING NETWORKS AND PARTNERS" "below.".

• Camera permissions: for shooting functions;

• Read/write external memory card: uRead the external storage space of the device and save the picture;

• Receive notification messages: used to receive messages;

• Obtain the current network status: remind the user whether the current mobile network is in use or determine whether the user's network is available;

• Advertising ID: Collect the device advertising identifier GAID for personalized advertising content;

We may disclose your personal information in accordance with your wishes or as required by law in the following circumstances:

1) Your prior permission;

2) In accordance with applicable laws, legal procedures, and litigation claims within and outside your country of residence;

3) At the request of public and government agencies;

4) To protect our legitimate rights and interests.

Users with whom you share information

We have no control over the behavior of other users with whom you share information. We cannot and do not control the information you share with other users using the application, service or website (including through forums) or how such information is used or shared by other users. We are not responsible for third parties circumventing our security measures.

2. How do we use this information?

To provide you with a better user experience, we may use your information for the following purposes:

General Use of Information.

The information we collect is used to:

1) To meet the purpose of your information provision.

2) Carry out the activities described to you at the time your information was collected or as set forth in the California Consumer Privacy Act (“CCPA”).

3) To provide you with the requested information, products or services.

4) Execute internal and external marketing, including providing targeted advertisements and information.

5) Fulfillment of obligations and enforcement of contractual rights.

6) To improve the Services, for example through testing, research, analysis and development.

7) Respond to requests from law enforcement agencies and government organizations as required by law, court orders, or government regulations.

8) Evaluate or effect a merger, divestiture, reorganization, reorganization, dissolution, sale or other transfer of some or all of our assets, whether on an ongoing basis or as part of a discrete transaction in which the information collected is the transfer of assets.

9) Use information for security purposes; we may use information for account and network security purposes, including protecting our services for the benefit of all users, and pre-screening or scanning uploaded content for potentially illegal content. We may use your information for identity verification, monitoring account and transaction risks, detection and security prevention, fraud monitoring, file backup, customer security services, etc.

10) We store and maintain your information to fulfill our legal obligations; for example, in an emergency, we may record, review, analyze and dispose of your information in accordance with applicable laws.

11) Without prior notice to you, other categories of information will not be used for substantially different purposes.

Use the information as appropriate.

Information voluntarily provided to us or lawfully obtained by us is our property and we may use it for any lawful purpose, including selling, renting or transferring the information to publishers, advertisers and data aggregators for marketing purposes.

Targeted Advertising and Information.

We may use personal information to more effectively target advertisements and other information. While individuals are online, we may use technical information to associate individuals with their personal information and to attempt to display information and advertisements for products and services that you may respond to. We may use data collected from responses to one type of advertisement or information to target advertisements or other information across different venues.

Legal Proceedings.

We may disclose personal information in response to subpoenas, court orders and other legal process required by law.

Disclosure and Sale of Information.

We may sell or disclose personal information for business purposes. For example, we may provide your information to service providers or third-party advertisers who perform services on our behalf. For example: identities, inferences drawn from any other information.

Cookies and similar technologies

When you use our Services, certain information may be stored locally on your mobile device using "cookies" or similar technologies (such as Google Analytics and web beacons). We use cookies and similar technologies mainly to achieve the following functions or services:

• Ensure safe and efficient operation of products and services

We may set cookies or anonymous identifiers for authentication and security so that we can confirm that you are safe to log into the Services, or that you are not experiencing theft, fraud or illegal activity. These technologies also help us to make our services more efficient and improve login and responsiveness.

• Help you have an easier access experience

Using such technologies can help you avoid repeated steps and processes of filling in personal information and frequent logins.

To improve, test and monitor the effectiveness of our App/Website.

We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App/Website.

To generate avatars.

Users can upload their own pictures and Generate unique avatars. In order to protect your rights and security, the generated pictures will be automatically deleted after being stored for a certain period of time.

To make our service available.

We use functional information and information that is processed automatically to provide you with all requested services.

To communicate with you.

We use the contact information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

To prevent fraud and spam, to enforce the law.

We really want our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes for processing your personal data arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

3. How do we share your information?

We will not rent or sell your personal data to third parties, but we may share information you obtain through tools such as cookies, log files and device identifiers with third-party organizations that provide automatic data processing technology for this website. We do not control or influence these third parties' tracking technologies or how they are used.

Please note that while we only work with third parties to ensure that we take the necessary technical and organizational measures to protect your data, we cannot guarantee the security of any information directly transmitted from the website to such third parties. We will not be liable for any accidental loss or unauthorized access to your data due to the fault of third parties.

CO2 Ai Headshot only shares personally identifiable information with third parties when you allow it to be shared, or as necessary to complete operations within the software or services, or as required by law. Here are some situations where this might happen:

To help improve or promote our services:

We may share information and aggregate data we collect on usage and user behavior with third parties, to help improve or promote CO2 Ai Headshot, but we do it in such a way that no individual user can be identified or linked to any specific action or information.

CO2 Ai Headshot allows third-party companies to collect certain information information from users of CO2 Ai Headshot. These companies may utilize cookies, pixels or other technologies to collect and use non-personally identifiable information (e.g., hashed data, click streaming information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other website in order to provide advertisements about goods and services likely to be of greater interest to you. Even so, you always have the option to uninstall the software if you no longer want to be a CO2 Ai Headshot user.

To provide you with services:

We may provide information to service providers who help us operate CO2 Ai Headshot. For example, we may use third parties to help host our site, send e-mail or SMS related to the operation of CO2 Ai Headshot, removing repetitive information from our user lists, to any process payments or to provide search results. These service providers can technically access your personal information for use for a limited time but when this occurs, it is reasonable to apply the contractual and technical protections of limiting the use of this information to help us provide the CO2 Ai Headshot service.

To offer services in association with other companies:

We may provide services in conjunction with other companies. If you opt in for these services, we may share your information to facilitate this service. However, we will identify the partners and display the privacy policy before you use such services.

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

We may contain links to third party sites/services. You also may visit the Website following a link from a third party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

· as required by law;

· when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

· if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;

· in some cases, we may share your information with our affiliates, subsidiaries, contractors, business partners or other third parties who perform services on our behalf.

4. Data storage

Storage of Personal Information. We store personal information on servers with security measures designed to prevent loss, misuse and alteration of the information under our control. We also maintain physical and procedural safeguards designed to protect personal information. Notwithstanding these measures, we cannot guarantee that its security measures will prevent unlawful access, theft or alteration of personal information.

The length of time we retain personal information is for the purpose of providing our services or achieving the original or directly related purpose of collecting such information, or for other commercial purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements The law requires us to retain certain types of information (such as time limits) for a period of time. "If your personal information is no longer needed for legal or commercial purposes for processing it, we typically destroy or anonymize it.".

If there is a retention of personal data information, the following principles will be followed.

Personal data shall be processed and stored as required for the purpose for which it was collected.

so:

1) Personal data collected for the purpose of fulfilling our contract with you will be retained until such contact has been fully fulfilled.

2) Personal data collected for the realization of the legitimate interests of the company shall be retained for the period necessary to achieve the purpose. Users can find specific information on the legitimate interests pursued by the Company in the relevant sections of this document or by contacting the Company.

As long as the user consents to such processing, the company may be permitted to retain personal data for a longer period of time as long as such consent is not withdrawn. In addition, companies may be obliged to retain personal data for longer periods of time when required to comply with legal obligations or as ordered by authorities.
Once the retention period has expired, the personal data will be deleted. Therefore, the rights of access, deletion, rectification and data portability cannot be enforced after the expiration of the retention period.
Log data

Our servers automatically record information generated when you connect to the Services ("Log Data"). Our log data is anonymous, so it does not include information such as your IP address, user ID, phone number, cookie information, browser type, operating system or device model, location, carrier or internet service provider information.

5. AGE LIMINTATION USE OF THE SERVICE

In order to access and/or use the Website, you must be eighteen (18) years of age or older.

All users who are minors in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by their parent or guardian to access and/or use the Website, so if you are between the ages of thirteen (13) and seventeen (17) years and you wish to access and/or use the Website, before doing so you must: (a) assure and confirm (if needed) that your parent or guardian have read and agreed (get your parent or guardian’s consent) to this Agreement prior to your access and/or use the Website; (b) have the power to enter a binding contract with us and not be barred from doing so under any applicable laws.

Parents and guardians must directly supervise any access and/or use of the Website by minors.

6. Security

The security of your personal information is highly important. We will try our best to make sure the data is protected from any fraud. For this reason, we have a secure environment to collect, store and track the information using latest technologies.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

7. SHARING OF YOUR INFORMATION

We will share your information with third parties only in the ways that are described in this Privacy policy. Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your personal data, we cannot guarantee the security of any information transmitted from the App directly to such third party. We are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our services:

Entity name

Services performed

Entity location

Link to Privacy Policy

Analytics service provider

Germany

https://www.adjust.com/terms/privacy-policy/

AdMob (Google LLC)

Analytics / ad management service provider

U.S.A.

https://policies.google.com/privacy

Fabric (Google LLC)

Analytics service provider

U.S.A.

https://policies.google.com/privacy

Facebook Inc.

Analytics and marketing service provider

U.S.A.

https://www.facebook.com/privacy/explanation

Firebase Crashlytics (Google LLC)

Analytics service provider

U.S.A.

https://policies.google.com/privacy

MoPub

Analytics / ad management service provider

U.S.A.

https://www.mopub.com/legal/privacy/

Yandex.Metrika (Yandex LLC)

Analytics service provider

Russia

https://yandex.com/legal/privacy/

In case you want to learn more about these services and their privacy options (including opt-out) please consult the correspondent websites and privacy policies. We are not responsible for any usage of your personal data by the abovementioned third parties in violation of our instructions.

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

as required by law;
when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

8.INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

9. HOW LONG WE USE YOUR PERSONAL DATA

10. EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:

Data Access and Portability. You can request copies of your personal information.
Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct change, update or rectify your data.
Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us through [contact form]. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

11. EU privacy rights

You, as subjects of personal data, have the following rights:

Right to access: You can request an explanation of the processing of your personal data.

Right to rectification: You can change the information if it is inaccurate or incomplete.

Right to erasure: You can send us a request to delete your personal data from our systems.

Right to data portability: You can request all the data that you provided to us, as well as request to transfer data to another controller.

Right to object: You can object to the processing of your data.

Right to restriction: You may partially or wholly prohibit us from processing your personal data.

Right to withdraw consent: You can withdraw your consent at any time.

Right to lodge a complaint: If your request was not satisfied, you can file a complaint to the regulatory body.

To exercise your rights, write us an email contact@pinsotech.com

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

Exercising Your Rights

To make a request for access, portability or deletion according to your rights under CCPA, mail your request for the attention of the Privacy / Legal Department to contact@pinsotech.com

The Verifiable Consumer Request must:

1)Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

2)Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer's personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

12. SECURITY

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

If you have any questions about security of our App, you can contact us at through the email or contact form displayed below.

13. CHILDREN’S PRIVACY

Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

14. CHANGES TO THE PRIVACY POLICY

This Privacy policy is updated regularly.

Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

15. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us.

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