Privacy Policy
Last updated: June 3, 2024
Okay, let’s talk privacy. We know this isn’t the most exciting read, but it’s important. This section outlines how we collect and use your information, with a focus on keeping you safe and in control. Think of it as the fine print that protects your awesome creations.
Lovie (“we”, “us” or “our”) is dedicated to protecting the privacy of our users (“users” or “you”). This Privacy Policy (this “Policy”) is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal information) as a controller and/or business under applicable data protection laws during your use of Lovie application including all its features (our “Services”). Please note that the scope of this Policy is limited solely to your user information (including your personal information) collected or received by us when you are using our Services. In this Policy, “personal information” refers to any information or combination of information that can be used to identify, contact or locate an individual to whom the collected information pertains. Such personal information may include your name, gender, phone number, email address, date of birth, images, geo-location, personal identity number and identifiable biological information. Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with our Services. Also, please note that, unless we define a term in this Policy, all capitalized terms used in this Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.
The Information We Collect
In order to provide and improve our Services, we will collect and process your personal information and user information in accordance with this Policy. If you do not provide this information, we may be unable to provide you with our products or Services. You should ensure that all personal information and user information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with all or some of our Services.
Account Information
When you use our Services, you will need to create an account, we will collect the following information for the purpose of identifying you and preventing abuse of our Services:
- Login method and associated information, which may include email addresses
- Method of payment which may be linked to an identity verification
Anyone can access our Services, but there are certain services that require a purchase or credits (“Credit Purchase”). If you choose to make a purchase on our Subscription Service, we will collect additional personally identifiable information, such as your device ID. A third-party app store or payment processor may receive, access or use your financial information and billing address for the purpose of processing transactions and renewals. If you purchased content through a third-party app store or a payment processor, you should refer to that third party’s terms for information on how it maintains and uses personal financial information for all purchases.
Mobile Device Information
When you use our Services on your mobile device, we may collect information about your device, including its International Mobile Equipment Identity (“IMEI”), Unique Device Identifier (“UDID”) or Android ID, Universally Unique Identifier (“GUUID”), Identifier for Advertising (“IDFA”) and Identifier for Vendor (“IDFV”), Integrated Circuit Card Identifier (“ICCID”), Media Access Control (“MAC”) address, the type of device you use, operating system version and resolution, which will be used by us for statistical and/or analytical reasons, including without limitation to improve our technical functionality, server load-balancing, analysis of technical data relating to your mobile device so as to optimize our Services and graphics adaptation.
As stated below in the “Location Information” section, we may collect your location-based information from your mobile device if you choose to share it with us. If you subsequently wish to stop sharing Location Information, you may do so at any time by editing the relevant setting on your mobile device.
In cases where our Services involve user-generated adult content, we may collect additional data to ensure compliance with age restrictions and content preferences. This data will be used exclusively for the purpose of enforcing our content policies and will not be used for any other purpose without your explicit consent.
Mobile Analytics
We use mobile analytics software to allow us to better understand and improve the functionality of our Services. Such software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
Location Information
We may collect your location-based information from your mobile device if you choose to share it with us.
This information will help us understand user distribution and usage scenarios and allow us to provide users with the correct version of our apps, correct language settings, and improve our Services. Unless we obtain your consent, location data WILL NOT BE ACQUIRED or USED to identify you individually. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device. Please note that we may still continue to receive some Location information, such as your Network Information, IP address and system time zone, as a result of you using our Services.
Log Information
When you use some of our Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in Lovie (“Log Information”). Log Information may include (i) details on when and how often you use our Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve our Services and is NOT USED to identify our users individually
Image Information
By choosing to use the AI generation features of our Services, you understand and agree that we must upload your photos to our server for processing before returning processed photos to you for the purposes of providing such service to you and continuous optimization and that we may also receive the EXIF data about your photos (EXIF data may contain GPS coordinates where photos were taken and processed, equipment type, ISO and information about the front and rear cameras and creation time, depending on the equipment manufacturer) for the purpose of further optimizing our Services, such as providing a better match of photo effects to your equipment. When processing images that may contain adult content, we apply additional safeguards to ensure compliance with legal standards and user consent requirements. All such images are processed with explicit user consent and are handled separately from other user images to maintain privacy and compliance with app store guidelines.
User Uploaded Photos
In order to generate realistic photos, we require users to upload photos or selfies for AI model training purposes only. Uploaded photos will be immediately deleted from our servers after the user’s dedicated AI model is created.
AI Model Data Management
Storage
Upon AI model training completion, Users’ dedicated AI model data is exclusively accessible to the user self, no third-party access will be permitted. AI model data will be stored in their country/region for compliance with international and/or local regulations.
For more information, please refer to the “Current Server Location List” section for the exact locations of our servers.
Retrain
Users have the option to retrain their AI model at any time. Once users choose to retrain their AI models, the previous AI model will be immediately overwritten and the previous model will be deleted and unretrievable.
Model Deletion
Upon account deletion request by the user, all AI model related data will be immediately deleted in an unrecoverable way from our servers. AI Model Data of accounts with inactivity period of 6-months will also be automatically deleted in an unrecoverable way.
User Generated Photos
User generated photos are stored alongside the AI Model Data Storage, is only accessible to the user themself (unless shared by the User to Lovie’s social features). User Generated Photos will be immediately deleted from the cloud when the user deletes their account and when an account has an inactive period of 6-months.
Privacy and Adult Content
User-generated content that falls under the category of adult content is subject to stringent privacy controls. Users have complete control over the visibility and sharing of such content, and we employ advanced security measures to prevent unauthorized access or distribution.
Facial Feature Information
In order to provide image generation Services, we may collect your facial feature information. We may detect and use facial marks to provide facial manipulation, AI training, and censorship features. This information is not shared with any third parties. We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.
Cookies
We use “cookies” that store and retrieve information of user’s usage from time to time to provide customized Services for each user. Cookies are small amounts of information that the server uses to operate the app/website, sends to the user’s device and are also stored on the hard disk in the user’s device. You may refuse the installation of cookies. Information collected may include information about your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating system, dates and timestamps, and clickstream data.
- Purpose of use of cookies: Cookies are used to provide information optimized for each user by identifying the visit to and use type of each service and website that the user has visited, popular search terms, secure access status, etc.
- If a user refuses to store cookies, he or she may experience difficulties in using customized Services.
Advertising-Related Information
We and our third-party service providers may include advertisements within our Services, and with your consent, we may collect and use information about you such as your Advertising ID, geographic location and IP address for the purpose of delivering and tracking these advertisements. If your device does not have Advertising ID, we may use other persistent identifiers. We may also access your App list and collect the application package names of the applications installed on your device. We use the above information to help us better count, track and provide advertisements based on suitability, language, geographic location and other details.
Information Collected by Third Party Services
Our Services provided to you may contain our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which may have tracking tools of such service providers. These third parties may use cookies, APIs and SDKs on our Services and collect and analyze user information. In addition, some third-party SDKs may allow advertisers to collect information in order to provide content that is more relevant to you. Third parties may access your information such as your device identifiers, region (defined as the location where a given language is used), location information and IP address under their respective privacy policies.
Other Information
We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you.
Adult Content Information
We collect and process data related to user-generated adult content, consistent with our Terms of Service and app store policies. This includes information necessary to verify age and consent, and to ensure that adult content is appropriately labeled and segregated from other content in accordance with user preferences and legal requirements.
HOW WE USE INFORMATION
In addition to the uses listed above, we collect and use your user information and personal information for the following purposes:
- To provide, process, maintain, improve and develop our Services provided to you, including customer support, and other services provided through our products.
- 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.
- To create an account. The personal information that we collect when you use our Services to create an account will be used by us to create your account and profile.
- To provide location-based services. When you use our Services, we or third party service providers may take advantage of your location information to provide you with advertising, the correct version of our Services and help you gain good user experience.
- To improve user experience. Certain optional features such as user experience programs allow Lovie to analyze data regarding the use of our products and our Services and improve user experience.
- To provide push services. 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.
- To verify your identity. Verifying your identity using a text message when you log in to your account helps prevent unauthorized logins to your account.
- To collect feedback from you. Your feedback is of great value in helping Lovie improve our Services. To keep track of your feedback, Lovie may use the personal information provided by you to contact you and retain the records.
- Other purposes. We will collect, store, maintain and use information about you for purposes under the “The Information We Collect”, and for purposes of running our operations, pursuing our legitimate interests (e.g., research (including marketing research), network and information security, and fraud prevention), and satisfying our legal obligations.
INFORMATION SHARING AND DISCLOSURE
We may share certain redacted information with third parties who provide services on our behalf to help with our business activities. These services may include:
- Fulfilling orders and delivering packages;
- Providing you with advertising;
- Payment processing;
- Providing customer services;
- Fulfilling subscription services;
- Conducting research and analysis;
- Providing cloud computing infrastructure.
We will not share with or disclose to third parties (other than our service providers) your personal information in whole or in part except for the purposes of:
- preventing or dealing with fraud
- complying with laws, rules and regulations or requests by government departments, judicial authorities, law enforcement, or private parties; and/or
- on a redacted basis, evaluating or completing a transaction where we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or other event where your information may be sold or transferred.
Handling of Adult Content Data
Any data related to user-generated adult content is handled with heightened privacy measures. We will not share this data with third parties except where necessary for compliance with legal obligations, or for the direct operation and security of our Services. All such data sharing will be conducted in accordance with the highest standards of privacy and data protection.
BASES FOR USING YOUR INFORMATION
We will only collect and process personal data where we have lawful bases and we typically rely on one of the following four legal bases: –
consent(where you have given consent);
contract (where processing is necessary for the performance of a contract with you, for example, to – operate the site or deliver any services you have requested);
legitimate interests (for example we need to use your information to provide and improve our Services, – including protecting your account, providing customer support); and
legal obligations (to comply with the laws, rules and regulations or requests by government departments, judicial authorities or law enforcement).
THIRD PARTY WEBSITES AND SERVICES
Our Services may contain links to other websites and services. In addition, other websites and services may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about third party websites or services. We encourage our users to read the privacy policies of each and every website and service with which they interact. Visiting these other websites or services is at your own risk.
INFORMATION SECURITY
We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal information. However, you understand and accept that (in the Internet industry) even though we take reasonable security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. Further, you understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control. Special measures are in place to protect the privacy and security of data related to adult content. This includes enhanced encryption and access controls to ensure that such data is accessible only to authorized personnel and in compliance with legal and policy requirements.
INFORMATION ACCESS AND CONTROL
We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity in order to protect the security of your account.
DATA RETENTION
Subject to applicable laws, rules and regulations and the fulfilment of our business or legal purposes, we will delete your information (including your personal information, generated photos, and AI model) promptly upon your termination of your account with us.
PRIVACY RIGHTS
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (right to data portability); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. We will process your request in line with applicable laws within a reasonable period of time after receiving your email or mail, and will cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law.
To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act.
INFORMATION ABOUT CHILDREN
We will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under 16, please do not send your personal information to us, including but not limited to your name, address, phone number or email address. If you believe we may have any information about children under 16, please contact us. If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information and terminate the associated account.
CROSS-BORDER DATA TRANSFERS
You understand and agree that all information collected via or by us may be transferred, processed, and stored anywhere in the world, including but not limited to Japan, South Korea, Singapore, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide our Services. When transferring data that includes adult content, we adhere to strict international data protection standards. We ensure that such data is processed and stored in jurisdictions that provide adequate protection for this type of sensitive information.
IF YOU ARE A RESIDENT OF CALIFORNIA
The California Consumer Privacy Act (“CCPA”) provides California residents with the right to know what categories of personal information we have collected about them:
Category of Personal Information
Collected by us?
Identifiers
yes
Personal information categories listed in Cal. Civ. Code § 1798.80(e
yes
Characteristics of protected classifications under California or federal law
yes
Commercial information
yes
Biometric information
yes
Internet activity or electronic network activity information
yes
Geolocation data
yes
Audio, electronic, visual, thermal, olfactory, or similar information
yes
Professional or employment-related information
yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
yes
Inferences drawn from other personal information to create a profile
yes
The CCPA also provides California residents with the right to opt out of the “sale” of their personal information. Under the CCPA, a “sale” is broadly defined as making available personal information to a third-party for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information.
For purposes of the CCPA, a “sale” may include using targeted advertising services to deliver targeted advertising on our Services or other sites. Like most mobile applications, we use these services, which enable us to provide our Services and relevant offers to you. As a result, Lovie may “sell” the following categories of personal information: identifiers (e.g., advertising IDs); internet activity; geolocation data; and inferences drawn to create a profile.
We do not sell personal information of California residents.
IF YOU ARE A RESIDENT OF NEVADA
We do not sell personal information of Nevada residents.
GOVERNING LAW
This Policy is established, comes into force, and will be enforced and interpreted under the laws of Hong Kong, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.
AMENDMENTS TO THIS POLICY
You agree that we may update this Policy according to relevant laws and regulations or based on our business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on Lovie or notify you by other means as required by law.
FOR USERS IN JAPAN
Right to data disclosure, correction, erasure or suspension of use
If you are in Japan, as a data subject, you have the right to request the disclosure, correction, erasure or suspension of use of your personal data, and we are obliged to meet your request without undue delay.
FOR USERS IN SOUTH KOREA
International Data Transfers
We process the personal information of users only within the scope specified under HOW WE USE INFORMATION, and in principle, will not provide personal information of users to a third party. However, with your consent, for purposes of providing our Services described under INFORMATION SHARING AND DISCLOSURE to you, we may collect your personal information from, transfer it to, and store and process it elsewhere.
- Personal information transferred: please refer to the section “The Information We Collect” of this Policy above
- Transfer date and method: transferred on submission for storage and processing
- Country to which personal information is transferred: please refer to the section “Cross Border Data Transfers” of this Policy
- Retention of personal information: please refer to the section “Data Retention” of this Policy
Also, we may transfer your personal information to the following third parties located outside of South Korea:
Name of the person providing personal information |
Purpose of the use of personal information |
Particulars of personal information to be collected |
Period for retaining and using personal information |
|
Subscription payment services |
IDFA, IP User’s UID, location |
For such period as stated in the privacy policy of the relevant third-party platform |
|
IDFA, GAID, Android ID, IP User’s UID, location | ||
|
IDFA, GAID, Android ID, IP User’s UID, location | ||
|
IDFA, GAID, Android ID, IP User’s UID, location |
Whenever we share information outside of where you live, we ensure that the transfer complies with your local law so that your personal information is adequately protected.
If you do not wish to have your personal information transferred outside of South Korea, we will be unable to provide you with our products or Services.
Also, we may receive your personal information from the following third parties:
Name of the person providing personal information |
Purpose of the use of personal information |
Particulars of personal information to be collected |
Period for retaining and using personal information |
|
Subscription payment services |
IDFA, IP User’s UID, Location |
Until your termination of your account with us |
|
IDFA, GAID, Android ID, IP User’s UID, location | ||
|
Android ID, IDFA, GAID, User’s UID | ||
|
Android ID, IDFA, GAID, User’s UID |
Data Retention
Subject to applicable laws, rules and regulations and the fulfilment of our business or legal purposes, we will delete your information (including your personal information) promptly upon your termination of your account with us. We will destroy your personal information according to the following procedures and methods.
Procedures for Destruction: We select personal information subject to destruction and destroy them with approval of our data protection officer.
Method of Destruction: We will destroy personal information stored and filed electronically in a way that can be deleted by using a means that renders the record irrecoverable as far as possible.
Appendix
Current Server Location List
As of the date of this policy: we utilize multiple cloud storage services in multiple regions which include, amongst others, China Mainland, European Union, United States, and Korea to store and safekeep user data in accordance with international and local laws.
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