Privacy Policy of [SubtleAI]
Welcome to use [SubtleAI] (hereinafter referred to as "this Tool"). This Privacy Policy is intended to clarify how and to what extent this Tool collects, uses, stores, shares, and protects users' personal information, and to inform users of their rights regarding personal information and how to exercise such rights. Please read and fully understand this Policy before using this Tool. Your use of this Tool shall mean that you have agreed to all the terms of this Policy, which shall be legally binding on you and the operator of this Tool (hereinafter referred to as "we").
I. Information We Collect
To provide you with high-quality and secure services, we will collect the following types of information based on the needs of service functions, and only collect information necessary to achieve the purpose of the services:
(I) Information You Voluntarily Provide
1.Information related to function use: When you use the AI painting, image-to-video, or text-to-video functions of this Tool, you may need to upload images (e.g., reference images) and enter text descriptions (e.g., creative requirements); when you use the face-swapping or outfit-swapping functions, you may need to upload images or videos containing human faces (e.g., face-swapping materials, outfit-swapping character materials). We will collect such information you voluntarily provide for using the functions in accordance with the law.
2.Account registration information: If you need to use the personalized services of this Tool (e.g., saving creation history, synchronizing creation progress), you need to provide a mobile phone number or email address when registering an account, and you can set an account password independently. We only collect necessary information for account verification and identification, and will not force you to provide irrelevant personal information.
(II) Information Generated During Use
1.Creation and operation records: We will collect the "generated content" such as images and videos you create using this Tool, as well as operation records including usage time, type of function used, and creation parameters (e.g., selection of painting style, setting of video duration). This is to ensure the normal operation of the service (e.g., preventing loss of created content) and provide a basis for optimizing the service experience (e.g., recommending functions based on your creative preferences).
2.Device and network information: To ensure the stable operation of this Tool on your device, we will collect basic device information (e.g., device model, operating system version, unique device identifier, which is only used to identify device compatibility) and network information (e.g., IP address, network type, which is only used to troubleshoot network faults and ensure data transmission security). Such information does not include content that can directly identify your personal identity.
II. Methods and Purposes of Information Use
We will use the collected information strictly for the following purposes, and the scope of use will always be limited to what is necessary to meet service needs, not exceeding the scope agreed in this Policy or permitted by laws and regulations:
1.Provision of core services: We use the information you upload (such as images and text descriptions) to ensure the normal operation of functions like AI painting, image-to-video, text-to-video, face-swapping, and outfit-swapping, so that you can obtain generated content that meets your needs; we verify your identity through account information to ensure the normal login and use of your account.
2.Optimization of service experience: We conduct anonymization and de-identification analysis on the collected creation records and operation habits (information that can be linked to personal identity will be removed during the analysis) to understand users' preferences for different functions (e.g., the painting styles commonly used by most users), thereby improving function performance (e.g., increasing the generation speed of image-to-video), optimizing interface design, and providing you with services more in line with your needs.
3.Ensuring security and compliance: We use device information and network information to check for abnormal logins (e.g., login to your account from an unfamiliar device) and prevent malicious attacks (e.g., preventing mass malicious generation of non-compliant content) to protect the security of your account and the service of this Tool; we conduct compliance reviews on the user content you upload and the generated content to avoid illegal, non-compliant content or content that infringes on the rights of others, and maintain the security of the service ecosystem.
4.Restricted use of special functions: For the face-swapping function, the face-containing information you provide will only be used for the face-swapping operation you specify. It will not be used for model training, other users' face-swapping needs, or any other purposes without your explicit authorization; after use, the information will be handled in a timely manner in accordance with the storage period agreed in this Policy to maximize the protection of your right of portrait and that of others.
III. Sharing and Disclosure of Information
We attach great importance to the security of your information and strictly control the scope of information sharing. Except for the following circumstances required by law or authorized by you, we will never share your personal information with any third party:
1.Sharing with your explicit consent: If you take the initiative to authorize (e.g., authorizing this Tool to share your created content to a third-party platform), we will share necessary information with the third party you specify in accordance with the scope of your authorization (e.g., only sharing the generated content, not including your original materials or account information), and will clearly inform you of the type of information to be shared and the name of the third party before sharing.
2.Disclosure required by laws and regulations: When facing legal inquiries from relevant authorities (e.g., judicial organs requiring access to relevant information for case handling) or mandatory disclosure obligations as stipulated by laws and regulations, we will provide necessary information to the competent authorities in strict accordance with legal procedures, and record the disclosure process to ensure the legality and compliance of the disclosure.
3.Necessary sharing with service partners: If it is necessary to share information with partners to realize service functions (e.g., using third-party servers for data storage, or third-party technical service providers for anti-fraud technical support), we will sign strict confidentiality agreements and data processing agreements with the partners, clearly specifying the scope of information use by the partners (only for providing services to us, not for their own business or other purposes) and their protection obligations (e.g., adopting encrypted storage, access permission control, etc.), and supervise the partners' information processing behaviors to ensure the security of your information.
4.Information transfer in corporate mergers and acquisitions: In the event of corporate asset changes such as merger, acquisition, or bankruptcy liquidation, your information may be transferred as part of the assets. We will notify you in advance through announcements on this Tool, text messages, or emails before the transfer, clearly inform you of the name and contact information of the recipient, and require the recipient to continue to comply with all terms of this Privacy Policy to protect your information rights and interests from being affected.
IV. Storage and Protection of Information
(I) Storage Period
We follow the principle of "minimum necessity and shortest storage" and reasonably determine the information storage period based on service needs and requirements of laws and regulations:
1.Face-related information: The images and videos containing faces you upload for the face-swapping function will be stored for 7 days (calculated from the date of upload). After you complete the face-swapping operation and confirm the result within 7 days, the information will be automatically deleted; if you do not complete the operation within 7 days, it will also be deleted upon expiration to avoid privacy risks caused by long-term storage.
2.Account and creation information: Your account information (e.g., mobile phone number, email address) will be stored during the validity period of your account. If you take the initiative to apply for account cancellation, we will delete your account information and associated creation records within 15 working days after the account cancellation (except as required by laws and regulations to be retained); the creation records of unregistered users will be deleted within 30 days after you use the function. If you need to store them for a long time, you can register an account and manually save them to the account space.
3.Device and network information: Only the device and network information of the most recent 3 months will be stored. Information older than 3 months will be anonymized (e.g., deleting the association between the unique device identifier and the IP address). The processed data will only be used for service optimization and will no longer have the ability to identify personal identity.
(II) Storage Location
Your information is stored in secure servers (including our own servers and entrusted third-party compliant servers), and will not be leaked; if it is necessary to transmit information externally due to business needs in the future, we will obtain your explicit consent in accordance with the requirements of laws and regulations such as the Personal Information Protection Law, and ensure the security of the information through security assessments and signing data transmission agreements.
(III) Protection Measures
We adopt dual technical and management measures to comprehensively protect the security of your information:
1.Technical security measures: We use encrypted storage for your information (e.g., irreversible encryption algorithm for user passwords, symmetric encryption technology for images and videos) and encrypted transmission (HTTPS protocol for data transmission) to prevent information from being stolen or tampered with; we set up access permission control (only authorized personnel can access necessary information, and access requires multi-factor authentication) to prevent unauthorized access to information by internal staff; we conduct regular security inspections and vulnerability repairs on servers and systems to prevent hacker attacks and virus intrusions.
2.Management security measures: We establish information security management systems (e.g., classified management of information, retention of operation logs) and clarify employees' responsibilities for information protection; we conduct regular information security training and assessments for employees who have access to information to improve their awareness of privacy protection; we formulate emergency plans for information security incidents. In case of information leakage, loss, or other security incidents, we will immediately activate the emergency response, take remedial measures (e.g., freezing the account, deleting the leaked information), and promptly notify you in accordance with the requirements of laws and regulations.
Please note: There are certain security risks in any network transmission. We will do our best to protect the security of your information, but we cannot promise absolute security of the information; if you find any account abnormalities, information leakage, or other situations, please contact us immediately through the "Contact Information" in this Policy, and we will assist you in handling the matter in a timely manner.
V. Your Rights
You have the right to inquire about, correct, delete, and withdraw consent to your personal information, and we provide you with convenient ways to exercise these rights:
1.Right to inquire and correct: You can inquire about your account information, creation records, and uploaded materials through the "Personal Center - My Information" page of this Tool; if you find any errors in the information (e.g., incorrect mobile phone number bound to the account), you can directly submit a correction application on the page or contact customer service for assistance. We will review and provide feedback within 1-3 working days.
2.Right to delete: You can independently delete the user content you uploaded (e.g., deleting unnecessary materials or generated content in "Creation History"); if you need to delete account information (e.g., canceling the account), you can submit an application through "Personal Center - Account Security - Cancel Account". After verifying that the operation is performed by you, we will delete the relevant information in accordance with the period agreed in this Policy; if you believe that the information we collect exceeds the necessary scope, you can also contact customer service to apply for the deletion of redundant information.
3.Right to withdraw consent: You can withdraw your consent to this Policy at any time (e.g., turning off camera and album permissions in "Settings - App Permissions" on your mobile phone to disable information collection authorization). However, after withdrawing consent, you may not be able to use the functions that require such permissions (e.g., you cannot upload face-swapping materials after turning off album permissions). We will stop collecting the corresponding information after you withdraw consent, but the information already collected will be handled in accordance with the storage period agreed in this Policy.
4.Right to obtain copies of information: If you need to obtain copies of your personal information (e.g., account registration information, list of creation records), you can contact customer service to submit an application. After verifying your identity, we will provide you with the information copies through the method you specify (e.g., email) free of charge.
5.Right to complain and suggest: If you have objections to the information processing behavior of this Tool (e.g., believing that the review result is unreasonable), discover information security issues, or have suggestions on privacy protection, you can complain or provide feedback to us through the "Contact Information" in this Policy. We will communicate with you within 5 working days and provide a solution.
VI. Special Provisions
1.Compliance requirements for face-swapping and outfit-swapping functions: When using the face-swapping function, you must ensure that you have obtained explicit and written authorization for the right of portrait of the person in the uploaded images/videos. You shall not use others' faces for face-swapping without authorization, nor create or spread "Deepfake"-type false face content (e.g., forging others' portraits for fraud or defamation); when using the outfit-swapping function, you shall not upload materials containing illegal, non-compliant, or vulgar and pornographic elements, nor use the outfit-swapping function to generate content that infringes on others' intellectual property rights (e.g., using others' original clothing patterns). If your actions cause disputes due to infringing on the legitimate rights and interests of others (e.g., right of portrait, copyright), you shall bear all responsibilities, which have no connection with us.
2.Rights and responsibilities for generated content: You shall own the intellectual property rights to the content generated using this Tool, but you must ensure that the generated content complies with laws and regulations (e.g., not violating the Cybersecurity Law or Copyright Law), does not violate public order and good morals (e.g., not generating violent or pornographic content), and does not infringe on the rights of others; we have the right to conduct compliance reviews on the generated content. If non-compliant content is found, we may take measures such as deleting the content, restricting the use of functions, and banning the account, without bearing any compensation liability; if you use the generated content for commercial purposes (e.g., for advertising and promotion), you shall independently ensure the legality and compliance of such use and bear corresponding legal responsibilities.
VII. Changes to This Policy
We may modify this Privacy Policy in accordance with updates to laws and regulations (e.g., amendments to the Personal Information Protection Law) and adjustments to the services of this Tool (e.g., additional information collection required for new functions). The revised Policy will be published on the "Settings - Privacy Policy" page of this Tool, and we will notify you through pop-ups, text messages, or emails (if you have registered an account); your continued use of this Tool after the modification of the Policy shall mean that you have agreed to the revised Policy; if you do not agree to the modified content, you may stop using this Tool, and we will handle your information in accordance with the Policy before modification.
VIII. Governing Law and Dispute Resolution
Any dispute arising from or in connection with this Policy (e.g., compensation disputes caused by information leakage) shall first be resolved through friendly negotiation between the parties; if negotiation fails, either party shall have the right to file a lawsuit with the competent court in the place where the operator of this Tool is located.
IX. Contact Information
If you have questions about this Privacy Policy, need to exercise your rights regarding personal information, or complain about and provide feedback on information security issues, you can contact us through the following method:
[Email]: [Davidmind6518@Outlook.com]
This Privacy Policy shall take effect from the date of publication.