Privacy Policy

Your privacy is important to us.

Alpha Gateway Limited ("AlphaGateway", "us", "our" or "we") is dedicated to protecting the privacy rights of our users ("users" or "you") regarding any information we may collect while operating our website and while you are operating our mobile applications available on mobile app stores (including Apple App Store and Google Play) and mobile platforms (including iOS and Android) (collectively, the "Services"). Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of personal information you provide or we collect.

BY USING OUR SERVICES, YOU ARE EXPRESSING YOUR CONSENT TO THIS POLICY AND THE COLLECTION AND PROCESSING OF YOUR DATA, INCLUDING YOUR PERSONAL INFORMATION, IN THE MANNER PROVIDED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY OR REVISED VERSION, PLEASE DO NOT USE OUR APPS OR SERVICES.

Device Information

When you use our Services on your mobile device, we may collect and record certain information about your device, such as its International Mobile Equipment Identity ("IMEI"), Identifier for Advertising ("IDFA") and Identifier for Vendor ("IDFV"), Integrated Circuit Card Identifier ("ICCID"), Media Access Control ("MAC") address, model and resolution, which will be used by us to calculate the number of devices that use our products and Services and analyze data on device models and graphics adaptation. Additionally, we may collect and record the Language & Region information from your device's settings, which will be used to provide better customer support when you reach out to us via Email or the in-app feedback system.

Personal Data

We do NOT collect any personal data. Our definition of personal data is information that relates to an individual and could be used to identify them. This includes but is not limited to: first and last name, home address, telephone number, date of birth, email addresses, bank account details, financial history, among others. In particular, we do not collect, record or store any face data. As no face data is collected, none will be shared with any third parties.

Service Data

To use our Services, you should provide a photo prior to the event of photo editing. Since the processing requires Internet connection and is performed on our servers the photos are sent there through the encrypted connection. We use Secure Socket Layer technology to protect the privacy and integrity of the transmission process.

For non-registered users and users who do not share their results within the Services, the original photos and results are automatically removed from our servers by two weeks after the last interaction.

In addition, most of the Services involve facial recognition mechanism, which is used in two ways:

Locally on your device. Provided that the access to Gallery is granted we use facial recognition mechanism to scan your Gallery for facial photos and group them. This makes part of the recommendation system and can also be used in other ways with the only aim to improve your experience within the Service. The detected facial key points are stored on your device until you delete the Service or clear the Service data.

On the server. Whenever you apply an effect that involves a face manipulation we use other special face recognition technologies on the server side in order to:
- detect a face in a photo;
- find required facial key points (the set of points varies with the effect);
- and apply the effect to your photo based on the detected key points.

In this case the key points are temporarily cached in server RAM between processings and get removed shortly after the last effect has been applied to the corresponding photo.

Advertising

We may collect and use information about you, such as your device identifier, MAC address, and IMEI for the purpose of the tracking of the advertising. This information is used together to create a unique user number to help us to better count and track advertising. This information is NOT SOLD to outside parties.

Information Collected by Third Parties

Third Parties' Services

Our Services provided to you may contain third party tracking tools from our service providers. These third parties may use Cookies, Application Programming Interfaces (APIs) and Software Development Kits (SDKs) on our Services and collect and analyze user information on our behalf. Third parties may access your information such as your device identifier, MAC address, IMEI, region (defined as the location where a given language is used), location information and IP address for the purposes of implementing our Services provided under their respective privacy policies. This Policy does not govern the use of third-party tracking tools. We have no access to or control over such third parties.

How We Use Your Information

We collect user information and personal details so that we can provide our products and Services to you and ensure our compliance with relevant laws. We will use your user information and personal details as provided under "The Information We Collect" for the following purposes:

  1. Services. To provide, process, maintain, improve and develop our Sites and/or our Services provided to you, including customer support, and other services provided through our devices or our Sites.
  2. Statistical analysis. To develop and analyze statistics on the use of our products and Services for the purpose of improving our products and our Services.
  3. To improve user experience. Certain optional features such as user experience programs allow Alpha Gateway Limited to analyze data regarding the use of our products and our Services and improve user experience.
  4. To provide push services. Your device information may be used by us to provide push services to assess the performance of adverts and the success of software updates, or provide notifications on new product releases. You may turn off this feature at any time by changing your preferences under "Settings".
  5. To collect feedback from you. Your feedback is of great value in helping Alpha Gateway Limited improve our Services. To keep track of your feedback, Alpha Gateway Limited may use the personal details provided by you to contact you and retain the records.

Limited Disclosure of Information

We will not sell any personal details to third parties. We have no right to share with or disclosure to third parties your personal details in whole or in part except for the purposes of:

  1. Protecting the safety of any other individuals or property;
  2. Preventing or dealing with any cyber fraud;
  3. Safeguarding the lawful rights and interest of us and our users;
  4. Complying with laws and regulations, the order from the government authority or juridical decision, usually for the purpose of the protection of network security and the rights, property, and safety of us, our users, or others.

Security of Information

We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of the Information. Please note that no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.

Your Consent to International Transfer

You understand and agree that (i) we may collect and store your information, as outlined in this Policy, within servers located in the People's Republic of China ("PRC"), as well as other countries, and that this process would include international transfer of your information; and (ii) we may transfer information that we collect about you to our affiliated companies or to other third parties (please refer to "Third Party Services" in this Policy) across borders according to this Policy. Please note that these countries and jurisdictions may not have the same data protection capacity as your own jurisdiction, and you, therefore, consent to the transfer of information to PRC and the use and disclosure of information about you, including personal information, as described in the Policy.

Governing Law and Dispute Resolution

The Policy, including, but not limited to, its conclusion, validity, construction, performance and settlement of the disputes, shall be governed by the laws of the People's Republic of China ("PRC"), without giving effect to the principles of conflict of law. Any disputes arising from, or in connection with the Policy shall be first settled through friendly negotiation between you and us. In the case where no settlement to the disputes can be reached through amicable negotiation, the disputes shall then be submitted to China International Economic And Trade Arbitration Commission for arbitration in accordance with its arbitration rules in force at the time of application for arbitration. The arbitration shall proceed in Beijing, People's Republic of China. The arbitral award is final and binding upon both parties. The arbitration fees shall be borne by the losing party except otherwise awarded by the arbitration commission.

Amendment to the Policy

You agree that we may update or revise this Policy in order to comply with the laws and regulations or our new commercial arrangement and you consent to be bound by the revised version of this Policy.

EACH OF THE PARTIES HERETO IRREVOCABLY WAIVES ANY AND ALL RIGHT TO PARTICIPATE IN A CLASS ACTION IN ANY LEGAL PROCEEDING ARISING OUT OF OR RELATING TO THE POLICY CONTEMPLATED HEREBY. ANY DISPUTES BETWEEN YOU AND US SHALL BE RESOLVED BY A BINDING AND INDIVIDUAL ARBITRATION AS SET OUT UNDER THE POLICY.