Privacy Policy Effective
Date :2025/01/26
Introduction
Welcome to Photo2Any( APP ).
This Privacy Policy is delivered by kunda
LIMITED ( we , us , our , or Kunda), the developer and owner of Photo2Any .
The end user ( You , Your , or the User ) who download , install , register with , access , or use ( Use
or Using ) this APP should carefully read this Privacy Policy .
This Privacy Policy describes the privacy
practices of our APP and anywhere we display or reference this policy . Through our APP , we implement
the processing of Personal Data that can be used to identify you ( Personal Data ) listed below . We are
committed to protecting your Personal Data . We understand that the security of your Personal Data is
important . We provide reasonable administrative , technical , and physical security controls to protect
your Persona Data . We will only collect and use Personal Data from you as described in this Privacy
Policy . We will not sell your data to any third ge parties without your expressed consent .
Please note that your use of our APP
is also governed by our End User License Agreement ( EULA ), you should comply with the EULA during your
using of this APP .
We will not share your personal information with third parties.
If you do not want us to
collect and process your Personal Data , please do not use this APP .
1. Definition of Personal Data
Personal Data means any information relating to an identified or identifiable natural person (" data
subject "); an identifiable natural person can be identified , directly or indirectly , in particular by
reference to an identifier such as a name , an identification number , location data , an online
identifier or to one or more factors specific to the physical , physiological , genetic , mental ,
economic , cultural or social identity of that natural person . Depending on how you interact with us ,
we process different kinds of data in different ways . Some data is automatically processed if you visit
our website or use our APP . Other data is only processed if you actively submit it to us ( like using
our web forms to get in touch with us or uploading content to our website ).
2. Personal Data We Collect (1)
The Personal Data we collect falls into two categories " voluntarily provided " and " automatically
collected " as
follows :
A." Voluntarily provided " refers
to any data that you consciously and actively provide to us when using our APP
and affiliated services .
We will ask for your consent before collecting your Personal Data ;" Voluntary " allows you to choose
whether or not to provide such data .
B . "Automatically collected " refers
to the data automatically transmitted by your device when you visit our APP and related services . This
automatically collected Personal Data is essential for us to provide the App Services , and we will
collect this Personal Data to the minimum extent necessary to do so .
(2)
Personal Data we collect based on
different function:
A . When uploading your avatar ,
photos , or saving your work to your device , we must access your hardware device ' s camera , library /
album , and memory card modifications to collect the photo data you wish to upload or save . If you do
not grant us permission to obtain such Personal Data , you will not be able to use these services
.
B . When using the creation function ,
the content you enter and the corresponding generated content will be stored on our servers for 24h
. You can delete such content at any time . Please note that after 24h , we will no longer store
your User Generated Content as it will be automatically deleted from our servers .
(3)
. Types of Personal Data We Collect
A . Log data When accessing our
servers through our APP , we may automatically record standard data provided by your device . This may
include your device ' s IP address , device type , and version , activity , time and date in the APP ,
and other usage details . In addition , when an error is encountered during the use of the APP , data
about the error and the surrounding situation is automatically collected . This data may include
technical details about the device , actions taken when the error occurred , and other technical
information related to the issue . You may or may not be notified of such errors , their occurrence , or
their nature .Although this information itself may not identify an individual , combining it with other
data may identify an individual .
B . Personal Data We may ask for Personal
Data when using App features , which may require a login , which may include third - party Apple or
Google profiles When contacting us , this may include one or more of the following :
a . email
b . Your log data ( for debugging purposes
)
C . User Accounts To use the App ,
please register your account through a third - party account ( e . g ., Apple , Google ), collectively
referred to as the " Internet Platform ". When you registerforanaccount using the Connected Platform ,
you agree to grant us certain permissions to receive data and Personal Data collected by the Connected
Platform , which may vary from Platform to Connected Platform . We collect the data necessary to verify
your registration and ensure safe and secure use of the appliction . The privacy policy of the Internet
Platform also governs any Personal Data shared with it . Please note that public events , screen names ,
IDs , images , or photos may be public and no longer confidential .
D . User - Generated Content " User
Generated Content " means material ( text , images ) voluntarily submitted or created by the User . All
user - generated content is associated with the account used for the submission .
E . Payment Data
Purchase transactions are made through
the Google Play Store and Apple App Store . Take a closer look at their payment terms , terms of service
, privacy policy , and other relevant terms . We do not collect your payment Personal Data directly
.
F . Device Information
We may collect Personal Data about
your mobile device and internet connection , including your device ' s unique identifier , operating
system , browser type , and mobile network Personal Data .
3. How We Collect Your Personal Data (1)
Cookies ( and similar technologies ).When you use Photo2Any, we may use cookies ( small text files
placed on your computer or mobile device to identify your computer and web browser ) and other similar
technologies to collect or receive certain Personal Data about you and / or your use of Photo2Any. These
analytics tools collect Personal Data through the incorporation of Photo2Any' s third - party SDKs ,
including Personal Data about the Photo2Any features you access or use , your actions in
Photo2Any , and Personal Data about your subscriptions . This Personal Data may be used to provide
content , advertising , or features , or to measure and analyze the effectiveness of advertising on
Photo2Any or other websites or platforms . For the avoidance of doubt , we do not use image data for
advertising purposes .
Available to users in the European Economic
Area , United Kingdom , and United States . You can opt out of the processing of personal data through
cookies , SDKs , and other tracking technologies by clicking Send Request to
customer_service@kunda.tech.
You may find that some parts of the
Application may not function properly if you reject cookies or similar tracking technologies , and you
should be aware that disabling cookies or similar tracking technologies may prevent you from accessing
some of our content .(2) Web Beacons .The pages of an application may contain small electronic files
called web beacons ( also known as clear GIFs , pixel tags , and single - pixel GIFs ), which allow ,
for example , to count the number of users who have visited those pages and generate statistics for
other related applications .
4. Purposes and Legal Basis for Collecting
and Processing Personal Data (1) When processing your Personal Data , we usually rely on your consent .
We collect , use and process your Personal Data for the following purposes :A . lanyotherpurposeyouprovide , and to obtain
services provided by the Application .B . Perform our obligations and entitle you to
any rights ( including billing and collection ) arising from any contract entered into between you and
us . C. We may notify you when App updates become
available and changes to any products or services we offer or offer through the App .
D.
We may send you Personal Data about surveys
, sweepstakes , promotions , newsletters , or other communications .(2) The usage and device Personal
Data we collect helps us improve our Services and provide a better experience , enabling us to
:
A . Estimate our audience size and
usage patterns .
B . Identify youself when using the
Application .
C . Optimize and upgrade the APP to
enhance the smooth use of the APP .
(4)
Please note that even if we take all
reasonable steps to protect your Personal Data , no system or network is risk - free . We will do our
best to protect your Personal Data in the event of unforeseen events , including but not limited to
server damage caused by phishing , viruses , identity theft , other cyber attacks , war or other
uncontrollable events , but we will not be liable for any risks , losses , or damages caused , related
to or caused by such unforeseen events . After chunpredictable events occur , we will promptly and
reasonably inform you of the basic situation , potential impact , and remedial measures we take in
response to the event . If a regulator creates further reporting obligations under applicable law , we
will comply with them .
(5)
.However , under some circumstances , we may
process your Personal Data without getting your prior consent , such circumstances may include : A .
processing is necessary for the performance of a contract to which you ( the data subject ) are a party
or in order to take steps at the request of the data subject prior to entering into a contract
;
B . processing is necessary for
compliance with a legal obligation to which we are subject ;
C . processing is necessary in order
to protect the vital interests of the data subject or another natural person ;
D . processing is necessary for the
performance of a task carried out in the public interest or in the exercise of official authority vested
in the controller ; E . processing is necessary for the purposes of the legitimate interests pursued by
the controller or by a third party , except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of Personal Data , in
particular where the data subject is a child .
(6)
If we rely on your consent to process your
Personal Data , you have the right to withdraw your consent at any time .
(7)
If we decide to change the aforementioned
purposes , we will notify you before using your Personal Data for the newly established purposes and ask
for your separate consent where required by applicable law .
5. Data Retention The original photos you
upload for generation will be stored on our servers for 24 hours . This is necessary so that you can
edit your photos more fluidly . Moreover , this method helps reduce your internet traffic and speed up
the processing of art style photos . The content you generate will be stored on our servers for 24 hours
. You can delete this Personal Data at any time . Please note that after 24 hours , we will no longer
store your User Generated Content as it will be automatically deleted from our servers .
6. Your Rights (1) You have the right to
access your personal data and data portability . This means that you have the right to request that the
application obtain your personal data in a structured , commonly used and machine - readable format .(2)
You have the right to request that the App correct your personal data . This means that you can request
the correction of all inaccurate personal data concerning you . If required , you can also complete your
personal data .(3) Withdraw Your Consent . You may withdraw your consent to our collection and
processing of your personal data at any time by contacting us via customer_service@kunda.tech, without affecting the lawfulness of the
processing carried out before the withdrawal . Upon receipt of your withdrawal request , we will process
it promptly and will no longer process your personal data unless otherwise required by law .(4) You can
share your work using the App to showcase them on social media networks and other websites . We have no
control over the actions of third parties with whom you may choose to share your creations . Therefore ,
we cannot and do not guarantee that your work will not be viewed by unauthorized persons , and we have
no control or responsibility over how others use your work once you publish or otherwise transmit it .
Therefore , you assume the risk that your work will be published and transmitted to others .
(5) You have the right to request to delete
your Personal Data , you can :A . Find and delete specific Personal Data . We have provided you with
some tools that you can use to remove certain Personal Data . For example , you can use the Delete
button to delete your Work . Take a closer look at what happens when you choose to delete or delete
content .B . Permanently delete your account . If you decide to permanently delete your user account ,
please contact us to do so and we will delete all of your data in the App , including but not limited to
all authoring and purchasing history . Once your account is permanently deleted , you will not be able
to revoke the " deleted account " or recover your data .7. GDPR Rights for European Residents 1. If you
are an EU resident , you benefit from any mandatory legal provisions in your country . You may have
certain additional rights in relation to your Personal Data under the General Data Protection Regulation
( Regulation ( EU )2016/679)(" GDPR "). Nothing in this Agreement , including the paragraphs above ,
affects your rights under such mandatory local law . You may exercise any of the above rights by
contacting us via customer_service@kunda.com.2.Pursuant to the GDPR , if you are
Resident in the EU , you have the following rights regarding your Personal Data .
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The Right to Be Informed
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The User has the right to be rovided with clear, transparent and easily
understandable information about how kunda collects and uses Personal Data and its rights. This is the reason why
Photo2Any is providing the User with the The Right to Be Informedinformation in this privacy policy.
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The Right of Access
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The User has the right to obtain access to its Personal Data (if
Photo2Any is processing it), and other certain information (similar to that provided in this
privacy policy)
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The Right to Rectification
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The User is entitled to have its Personal Data corrected if it's
inaccurate or incomplete
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The Right to Restrict Processing
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Under certain circumstances, the User has the right to 'block' or
suppress further use of its Personal Data
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The Right to Data Portability
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The User has the right to receive its Personal Data provided to
Photo2Any in a structured, commonly used and machine readable format and has the right to
transmit those data to another controller
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The Right to Object to Processing
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The User has the right to object, on grounds relating to its particular
situation, at any time, to the processing of its Personal Data.
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The Right to Lodge a Complaint
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The User has the right to lodge a complaint about the way Photo2Any
handles or processes its Personal Data with its national supervisory authority (in France,
the CNIL).
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The Right to Withdraw Consent
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If the user has given its consent for a specific processing of its
Personal Data implemented by kunda, the User has the right to withdraw its consent at any time. In
case the User does so, it does not mean that anything Photo2Any has done with the User's
Personal Data with its consent up to that point is unlawful).
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The Right to Define Instructions
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The User has the right to define general or specific instructions
regarding the storage, deletion and use of its Personal Data after death.
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8. CCPA Rights for California Residents(1)
If you are a California resident, you benefit from any mandatory legal provisions in the California
Consumer Privacy Act (CCPA). You may have certain additional rights in relation to your Personal Data
under the CCPA. Nothing in this Agreement, including the paragraphs above, affects your rights under
such mandatory local law.You may exercise any of the above rights by contacting us via
[email protected].(2)Pursuant to the California Consumer Privacy Act (CCPA), if you are a
California resident, you have the following rights regarding your Personal Data:
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The Right to Know
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You have the right to request information about the personal data we
collect, use, and disclose during the past 12months, including the categories and specific
pieces of personal data collected, our purposes for collecting such data, and the categories
of third parties we have shared your personal data with
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The Right to Delete
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You have the right to request that we delete the personal data we have
collected from you, subject to certain exceptions as outlined by the CCPA.
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The Right to Opt-Out
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You have the right to opt-out of the sale of your personal data, if
applicable. Please note that we do not sell your personal data as defined under the
CCPA.
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The Right to Non-Discrimination
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We will not discriminate against you for exercising any of your CCPA
rights, including but not limited to, denying you goods or services, charging you different
prices or rates, providing a different level of quality of goods or services, or suggesting
that you may receive a different price or rate for goods or services or a different level of
quality of goods or services.
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9.Children's Policy(1) General Age
Restrictions. This Application is not intended for children under the age of 13 (in some cases, this age
may vary depending on the legal requirements of your jurisdiction, collectively, the "Minimum User
Age"), and we do not knowingly collect Personal Data from children below the Minimum User Age. If you
have not reached the minimum user age, please do not attempt to register for this application or provide
us with any Personal Data about yourself. If we learn that we have collected or received Personal Data
from a child under the minimum user age without parental consent, we will delete that Personal Data.If
you believe we may have any Personal Data from a child under the minimum user age,please contact us via
customer_service@kunda.com.(2) Age Limt for EU Residents. As
required by the EU General Data Protection Regulation, you must be at least 16 years old to use our
services. To the extent prohibited by applicable law, we do not permit EU
residents under the age of 16 to use our Services without parental/guardian permission.
10.
Cookes and Tracking Tools
11.
11.Changes to the Privacy Policy
12.
We may update our Privacy Policy from time
to time in order to provide our services in a timely manner and to comply with applicable laws. Notices
shall be displayed or otherwise communicatedto you.Therefore,pleasevisitthis privacy Policy page
periodically to check for any changes. If you do not agree to the revised Privacy Policy, you have the
right and should immediately stop using the App. If you continue to use the Services within a reasonable
time after notification of the update, you will be deemed to have accepted all modifications made,
unless applicable law requires the Application to obtain your express consent.
13.
12.How to contact us
14.
Questions or comments regarding this Privacy
Policy and our privacy practices are available to contact us at
[email protected]