SnapFit Privacy Policy

1. Introduction

Welcome to SnapFit (hereinafter referred to as "the App")! The App is a mobile application dedicated to providing convenient clothing replacement experiences. To protect your personal information security and legitimate rights and interests, and to clarify the rules regarding the collection, use, storage, and protection of personal information by the App, we have formulated this Privacy Policy (hereinafter referred to as "the Policy") in compliance with applicable data protection laws and regulations globally, including but not limited to the General Data Protection Regulation (GDPR) of the European Union, the California Consumer Privacy Act (CCPA), and other relevant regional regulations.

Before downloading, installing, registering, logging in to, or using the services of the App, you should carefully read and fully understand all contents of this Policy, especially the clauses related to the collection and use of personal information, as well as limitation or liability exemption clauses. By clicking "Agree", "Register", "Log In", or actually using the services of the App, you indicate that you have fully understood and agreed to all provisions of this Policy, and consent to our processing of your personal information in accordance with this Policy. If you disagree with any content of this Policy, please immediately stop downloading, installing, or using the services of the App.

2. Personal Information We Collect and Its Purpose of Use

To provide you with the core clothing replacement service, we only collect personal information that is necessary to fulfill the service and do not collect information unrelated to the service. The details are as follows:

(1) Album-Related Information

• Scope of Collection: After you actively grant authorization, we will access your mobile device's album and obtain the images you choose to upload (including but not limited to your personal portrait photos, clothing photos, etc.).
• Collection Method: When you trigger functions such as "Upload Image" or "Select from Album" within the App, a system authorization request will pop up. We will only obtain access permission after your explicit consent, and will only read the specific images you actively select. We will not batch read or collect all images in your album in the background.
• Purpose of Use: To realize the core clothing replacement function, including performing image synthesis processing on the personal portrait photos and clothing photos you upload to generate a preview of the clothing replacement effect; and to save the replacement effect images to your album (subject to your reconfirmation and authorization).
• Important Note: If you refuse to grant album access permission, we will be unable to provide you with core services such as clothing upload, effect synthesis, and saving. However, you may still browse non-core functions such as clothing displays within the App (if applicable).

(2) Clothing Information

• Scope of Collection: Clothing-related information actively uploaded by you, including clothing images and clothing attributes you fill in or select yourself (such as clothing type, style, color, size, brand, etc.).
• Collection Method: Collected through your active operations within the App, such as manual upload, form filling, and option selection.
• Purpose of Use: To build your personal clothing library for convenient quick selection of clothing for replacement and matching; to optimize the clothing synthesis algorithm and improve the accuracy and naturalness of the replacement effect; to provide more tailored matching suggestions based on your clothing preferences (if you agree to enable this function).

(3) Other Non-Personal Information

We may collect relevant operational data about your use of the App, such as function usage frequency, device model, operating system version, and App version number. However, such information is all anonymized and aggregated data that cannot identify your personal identity. It is only used for purposes such as App performance optimization, troubleshooting, and service experience improvement.

3. Collection, Storage, and Protection of Personal Information

(1) Collection Principles

We strictly adhere to the principles of "legality, legitimacy, necessity, and good faith", and only collect personal information that is necessary to provide the service. We will not collect additional personal information beyond the scope required to achieve the service purpose. All collection of personal information is based on your explicit authorization, and we will not actively collect your personal information without your consent.

(2) Storage Method and Period

• Storage Method: Your personal information (including album images and clothing information) will be stored on our designated secure servers. We use encryption technology to ensure the security of data transmission and storage, preventing information leakage, tampering, or loss.
• Storage Period: We will only store your personal information for the period necessary to achieve the service purposes agreed upon in this Policy. When the service purpose is fulfilled, you cancel your account, or you request the deletion of personal information, we will delete your relevant personal information within a reasonable period or anonymize it (anonymized data is no longer considered personal information). If otherwise specified by applicable laws and regulations, such provisions shall prevail.

(3) Protection Measures

We have established and improved a sound personal information security management system, and adopted a combination of technical and management security protection measures to ensure the security of your personal information:

• Technical Level: Adopt technical means such as data encryption, access control, and security auditing to prevent unauthorized access, theft, or tampering of personal information;
• Management Level: Implement strict permission management and security training for staff who have access to personal information, clarify data processing responsibilities, and conduct regular security assessments;
• Emergency Response: Formulate an emergency plan for personal information security incidents. In the event of a personal information leakage, tampering, or other security incident, we will immediately take remedial measures and notify you and report to the relevant authorities in accordance with the requirements of applicable laws and regulations.

4. Restrictions on Use and Rules for Sharing, Transfer, and Public Disclosure

(1) Restrictions on Use

We will only use your personal information within the scope of the purposes agreed upon in this Policy. Without your further consent, we will not use or exploit your personal information beyond this scope.

(2) Sharing

We will not share your personal information with any third party except in the following circumstances:

• Obtaining your explicit written or verbal consent;
• Fulfilling obligations prescribed by applicable laws and regulations, or responding to legitimate law enforcement requests from competent authorities;
• Sharing is reasonably necessary to protect your legitimate rights and interests, the legitimate rights and interests of others, or public interests;
• Sharing with our service providers (such as server operators, technical support service providers), provided that such service providers can only use your personal information within the scope of providing services to us, and must comply with strict confidentiality obligations and shall not use it for any other purposes;
• In the event of corporate changes such as merger, acquisition, restructuring, or bankruptcy liquidation of the company, your personal information will be transferred to the successor entity in accordance with the law, and the successor entity will continue to fulfill the information protection obligations agreed upon in this Policy.

(3) Transfer and Public Disclosure

We will not arbitrarily transfer your personal information, nor will we publicly disclose your personal information, except with your explicit consent or when transfer or public disclosure is required by applicable laws and regulations or competent authorities.

5. Your Rights

Pursuant to relevant data protection laws and regulations, you have the following rights with respect to your personal information, and we will provide convenient channels for you to exercise these rights:

• Right of Access: You have the right to log in to your App account and view your personal information such as uploaded clothing information and personal portrait photos;
• Right to Rectification: If you find that your personal information (such as incorrectly filled clothing attributes) is inaccurate or incomplete, you have the right to request us to correct or supplement it;
• Right to Erasure (Right to be Forgotten): You have the right to request us to delete your personal information (including album images and clothing information) at any time, or directly delete it through operations within the App; if you cancel your account, we will delete all your personal information (except as otherwise specified by applicable laws and regulations);
• Right to Withdraw Consent: You have the right to withdraw your authorization for album access permission (which can be operated through your mobile device's system settings). However, after withdrawing the authorization, we will no longer be able to provide core services that rely on this permission;
• Right to Information: You have the right to understand the specific rules for the collection, use, storage, and protection of personal information by the App. We will fully inform you through this Policy, in-App instructions, and other methods;
• Right to Lodge Complaints and Reports: If you believe that our processing of your personal information violates applicable laws and regulations or the provisions of this Policy, you have the right to lodge a complaint or report with our customer service. We will respond to you within 15 working days of receiving the complaint or report.

To exercise the above rights, you can contact us through "Settings - Customer Service Center" within the App, or via the contact information provided below. To protect your legitimate rights and interests, we may require you to provide necessary identity verification information, and will promptly handle your request after verification.

6. Protection of Minors

The App is not intended for use by minors under the age of 16. We will not actively collect personal information from minors under the age of 16. If you are the guardian of a minor and discover that the minor has used the App and submitted personal information without your consent, please contact us immediately, and we will delete the relevant information promptly.

7. Changes to This Privacy Policy

• We may revise this Privacy Policy in response to updates to applicable laws and regulations, adjustments to service functions, and other circumstances. The revised Privacy Policy will be notified to you through pop-ups, announcements, or other methods within the App. If you continue to use the services of the App after the revision of the Policy, it indicates that you agree to the content of the revised Policy;
• If the revised Policy involves significant changes to your rights and interests (such as expanding the scope of personal information collection, changing the purpose of use, etc.), we will inform you in a prominent manner (such as a separate pop-up prompt) and obtain your explicit consent before it takes effect.

8. Disclaimer

• Despite the strict security protection measures we have adopted, due to the openness of network transmission, computer viruses, hacking attacks, and other force majeure or external factors not attributable to us, your personal information may be leaked, lost, or otherwise compromised. We will take remedial measures promptly within our capabilities, but we shall not be liable for any direct or indirect losses arising therefrom;
• You shall bear the risks arising from your voluntary disclosure of personal information to third parties or submission of personal information through channels other than the App, and we shall not be liable for any such risks;
• When using the services of the App, you shall comply with applicable laws and regulations and the User Agreement of the App. If your illegal operations cause damage to your own or others' rights and interests, we shall not be liable.

9. Dispute Resolution and Governing Law

• This Policy shall be governed by and construed in accordance with the laws of [Jurisdiction, e.g., England and Wales], excluding its conflict of law rules;
• Any dispute arising between you and us in connection with this Policy shall first be resolved through friendly negotiation. If the negotiation fails, either party shall have the right to file a lawsuit with the competent court in the jurisdiction where the App's operating entity is located.

10. Contact Information

This Privacy Policy shall take effect upon your consent.

SnapFit Operation Team