Update Date: February 18, 2025
Effective Date: February 28, 2025
Welcome to Use the PawPic Service!
Shanghai Benqu Network Technology Co., Ltd. (registered address: Room 1003, Building 1, No. 100 Qinzhou Road, Xuhui District, Shanghai, hereinafter referred to as "we") is the provider of the PawPic service. We fully understand the importance of Personal Data to users (hereinafter referred to as "you") and are strongly committed to keeping secure your Personal Data. To this end, we have formulated the PawPic Privacy Policy (hereinafter referred to as "this policy") to help you fully understand how we process and protect your Personal Data during your use of the PawPic service, as well as how you can manage your Personal Data.
[Scope of Application]
This policy applies to the AI services we provide to you through websites, client applications, and new forms that may emerge with technological development. If specific services are governed by a separate privacy policy or contain special provisions within their respective user service agreements, those provisions shall take precedence; however, for matters not covered by the specific service’s privacy policy or user service agreement, the content of this policy shall prevail. If our AI services are used in the services provided by us or our affiliates without an independent privacy policy, this policy will also apply to those services.
Apart from the data processing activities described in this policy, this policy does not apply to services provided to you by third parties. Such services are subject to the personal data collection and usage rules separately specified by those third parties.
Before your usage of our AI services, please carefully read and understand this policy, particularly notice the terms highlighted in bold or underlined.
Your approval of this policy indicates that you acknowledge and agree that we may collect and process the necessary information required for the basic functions of our AI services. However, your agreement to this policy does not imply consent to the collection or processing of unnecessary personal data for optional features, for which we will seek your separate consent before processing your personal data.
This policy will help you understand the following:
In accordance with relevant laws and regulations, we will collect Personal Data within the necessary scope required to provide the basic functionalities of our AI services. If you refuse to provide the data, you may be not able to use our AI services. Additionally, you may choose to use optional features of our AI services and authorize us to collect Personal Data; if you refuse to provide relative data, it may limit your access to the optional features but not affects your use of the basic functionalities.
You understand and agree:
(a) To meet the diverse needs of users, we strive to create a variety of AI services. Since the various types of AI services we may offer, and users may select different services, the functionalities (basic/optional) and the types and scope of Personal Data collected and used may vary. Please refer to the specific features of the AI service you are using.
(b) We are keeping improving our technology like all Internet companies, as a result, we may introduce new or optimized features that may require collecting and using new Personal Data or altering the purposes or methods of using the data. In such cases, we will inform you of the purpose, scope, and usage methods of such data through updates to this policy, pop-up notifications, or on-screen prompts. You are allowed to choose and consent it and we will not collect or use the data before your express consent.
The PawPic services generate content based on the original portraits you voluntarily upload, using artificial intelligence models. Therefore, when you use the services, we will process the original portrait information you voluntarily upload. This information is essential for providing the AI services. We will take strict encryption measures as required by law during the collection, transmission, and storage of such information to ensure its security.
Note:
We only provide image (including face data) processing services and do not extract identifying information. Once the service is completed, the system will automatically delete the uploaded information, without storing or sharing it with any third party.
We will request your authorization to access your camera and photo album when uploading the aforementioned information.
To assist you to share and view content shared by others, we may access your clipboard locally to write or read PawPic sticker commands for proper redirection. We have strict clipboard filtering rules that only locally identify clipboard information meeting the filter criteria (i.e., PawPic sticker commands) , without collecting or storing your clipboard content, nor uploading it to the servers. Such permissions will only be used with your explicit consent. Refusal to provide this information will not affect other features or services but may limit the use and sharing of sticker commands.
When you provide feedback, file a complaint, make an inquiry, or submit an appeal to us, we need to collect the feedback contentyou voluntarily provide, related image information, and your contact details (such as email)to facilitate communication, resolve issues, and provide timely feedback. If you choose not to provide the aforementioned information, it will not affect your use of AI services but may impact your ability to use the feedback feature.
In order to fulfill obligations related to network security, and secure the services, we need to collect your device’s name, model, identifiers (ANDROID_ID/OAID), IP address, access date and time, service logs, PawPic software version, and operational logs.Refusal to provide this information will not affect your use of the AI services.
Please understand and agree that we have the right to apply de-identification or anonymization technologies that comply with national and industry standards to process the portrait informationyou provide, which helps improve PawPic recognition and its speed and quality of response, and optimize its functionality, so that offering you more intelligent AI services. If you have questions about the improvements or object to using portrait information you provide for it, you can contact us through the methods outlined in Section 9, "How to Contact Us."
1.5.1 If the information you provide includes Personal Data of others, you must ensure you have obtained their legal authorization before sharing it with us.
1.5.2 If the information involves children’s Personal Datan, you must obtain the consent of their guardians before providing it. Guardians can contact us through the methods in Section 9 to request corrections or deletions of such information.
1.5.3 If we intend to use your Personal Data for purposes not outlined in this policy or use information collected for a specific purpose but for another purpose, we will request your consent in advance.
1.5.4 For functionalities and scenarios not outlined in this policy, we will present the relevant Personal Data collection and usage rules, and request your explicit consent when you use such functionalities or scenarios.
To ensure the normal operation of our website and provide you with an smoother access experience, we store small data files called Cookies on your computer or mobile device. Cookies are small files containing strings of characters that are sent and stored on your computer, mobile devices and other devices (usually encrypted) when you log in and use the website or other online content. Similar technologies refer to tools that serve purposes similar to Cookies, such as Web Beacons, Proxy, and Embedded Scripts.
We use Cookies and similar technologies to enable essential functionalities and services, simplify repetitive actions (e.g., registration and login), facilitate viewing of usage history, protect your information, and improve our products and services. You can manage Cookies via your Browser Settings, including enabling or disabling them. However, disabling Cookies may prevent you from certain services. For detailed instructions on changing your Browser Settings, please refer to the Settings page of the browser you use.
Some web browsers have a Do Not Track feature that sends DNT requests to websites. If your browser's DNT feature is enabled, we will respect your preference.
We will not share your Personal Data with any company, organization, or individual outside our organization, except in the following circumstances:
a. With your explicit consent or authorization;
b. As required by laws, regulations, or mandatory requests from administrative or judicial authorities;
c. To protect our interests, property, and safety, or that of our affiliates, partners, you, other users or the public, within the scope permitted by law;
d. To resolve disputes or conflicts at your request;
e. In accordance with agreements you have entered into with us (including electronic agreements signed online and relevant platform rules) or other legal documents.
We will not transfer your Personal Data except in the following cases:
a. At your explicit request and in compliance with laws, regulations, and regulatory requirements;
b. In cases of company mergers, divisions, dissolution, or bankruptcy declarations requiring Personal Data transfers, we will notify you of the recipient's name and contact details in advance. The new entity will be bound by this policy and must obtain your consent if they change the purposes or methods of processing your information.
c. We may transfer or permit the transfer of your personal data outside of your jurisdiction for any of the purposes set out in this policy. However, we will not transfer or permit any of your personal data to be transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws, including, for example, to inform and obtain your consent on the countries to which your personal data may be transferred to and the applicable standards on data protection under the laws of such countries.
We will not publicly disclose your Personal Data unless otherwise stated in this policy or required by law.
3.4 Exceptions
In accordance with relevant laws and national standards, we may share, transfer, or publicly disclose Personal Data without your prior consent in the following cases:
a. To comply with legal obligations;
b. For national security or defense purposes;
c. For public safety, public health, or major public interest purposes;
d. For criminal investigations, prosecutions, trials, and judgments;
e. To protect your or others' significant legitimate rights and interests, such as life and property, when obtaining your consent is difficult;
f. Personal information you have voluntarily disclosed to the public;
g. To fulfill contracts or agreements you requested;
h. Personal information collected from lawful public sources, such as legitimate news reports or government disclosures;
i. Other circumstances stipulated by laws and regulations.
4.1.1 With your approval, for global business management and service maintenance, we may transfer Personal Data outside your geographic region when necessary and/or allow overseas entities to access it, as permitted by laws. We will comply with the relevant procedures and fulfill the obligations for cross-border transfer of personal information as required by law. In addition, we ensure that recipients process the data per this policy and adopt equivalent or higher protection standards.
4.1.2 In the following circumstances, we will provide your Personal Data to overseas entities after fulfilling legal obligations:
a. As explicitly required by applicable laws;
b. With your explicit authorization.
4.1.3 In these cases, we will ensure that your Personal Data is adequately protected in accordance with this policy and relevant legal requirements.
4.2.1 We retain your Personal Data for the shortest duration required by law or for the purposes outlined in this policy. Once the retention period ends, we will delete or anonymize your information.
4.2.2 If we terminate services or operations, we will notify you at least 30 days in advance and delete or anonymize your Personal Data after termination.
We have employed industry-standard security measures to protect your Personal Data from unauthorized access, disclosure, use, modification, damage, or loss. We will take all reasonable and feasible measures to protect your Personal Data. For instance, data exchanges between your browser and our servers are encrypted by using SSL (Secure Socket Layer); we will use encryption to enhance information security; employ trusted protection mechanisms against malicious attacks; Implement access control mechanisms to ensure only authorized personnel can access Personal Data; conduct privacy protection and security training for employees to enhance their awareness of personal data protection. Our critical information systems have obtained cybersecurity level protection registration and evaluation and hold certifications such as ISO9000.
We will promptly inform you of any relevant events through emails, letters, phone calls, push notifications, and other means. When it is difficult to inform you individually, we will take reasonable and effective measures to publish announcements. At the same time, we will also proactively report the handling of personal information security incidents as required by the regulatory authorities.
If you have any questions about our personal information protection, please contact us through the contact methods specified in this policy. If you discover a leak of your personal information, please contact us immediately using the contact methods outlined in '9: How to Contact Us' of this policy, so that we can take appropriate measures.
We highly value your attention to Personal Data and strive to protect your rights to access, transfer, modify, delete, request explanations of this policy, and withdraw your consent. This ensures you have the full ability to safeguard your privacy and security. Your rights include:
You can access your Personal Data through the following methods:You may contact us using the means outlined in the "9. How to Contact Us" section of this policy.
If you find that the Personal Data we process about you is incorrect, you have the right to request corrections. You can correct your Personal Data in following ways: You may contact us using the means outlined in the "9. How to Contact Us" section of this policy.
6.3.1 You can request the deletion of your Personal Data by contacting us using the methods outlined in this policy under the following circumstances:
a. If our processing of Personal Data violates laws or regulations;
b. If we collect or use your Personal Data without your consent;
c. If our processing of Personal Data severely violates our agreement with you.
6.3.2 If we decide to respond to your deletion request, we will also notify any entities that have received your Personal Data from us to delete it promptly, unless otherwise required by laws and regulations, or your independent authorization is needed.
6.3.3 After deleting your information from our services, we may not immediately removed it from backup systems but will delete it during backup updates.
6.4.1 You can withdraw your consent by:
a. Disabling certain device permissions through Settings in your mobile device;
b. Deleting certain Personal Data within PawPic;
c. Contacting us using the methods outlined in this policy.
6.4.2 Please note that certain features of PawPic’s AI services may require specific permissions and the collection of necessary Personal Data. Withdrawing your consent may prevent us from providing services corresponding to your withdrawal, but it will not affect any prior processing conducted under your consent.
7.2.1 Regarding children’s Personal Data, we comply with the provisions of this policy, and adhere to principles of legality, necessity, informed consent, specific purpose, security, and lawful utilization in the collection, use, and disclosure of children’s information, strictly following child protection laws. Personal Data will not be retained beyond the necessary period, after which it will be deleted or anonymized.
7.2.2 If you are the guardian of a minor, please ensure if your child uses our AI services after obtaining your consent. If you have any concerns about the minor’s Personal Data, please contact us using the methods outlined in this policy.
7.2.3 Children or their guardians have the right to access, correct, and request the correction and deletion of children’s Personal Data anytime. For any feedback, suggestions, or complaints related to children’s information, please contact us as outlined in Section 9, and we will assist you promptly.
a. Major changes to our service model, such as the purpose, type, or using method of processing Personal Data;
b. Significant changes in our ownership structure and organizational framework, such as changes in ownership due to business adjustments, bankruptcy, mergers and acquisitions, and other similar events;
c. Changes to the main recipients of Personal Data sharing, transfer, or public disclosure;
d. Changes to your rights regarding Personal Data processing and how to exercise them;
e. Changes to the departments responsible for Personal Data security, contact methods, or complaint channels;
f. High risks indicated in a Personal Data security impact assessment report.
If you have any questions, comments, or suggestions regarding this policy, please contact us via:
Personal Data Protection Contact Email: service@pawpicstudio.com
We generally respond to and resolve inquiries within fifteen days.