1.WhatInformationWeCollect

Information about your use of the Platforms. We may collect information about your operation on the Platforms, mainly including information that you click, browse, download, share, and your search record, video editing acts, or any other information provided during your use of our Services, so that we could provide you with the functions of the Platforms.

Device and log information. When you use our Services through the Platforms, in order to make sure you use our Services normally and the functions operate smoothly and safely, improve and optimize your use experience, Carryout advertisement putting and message push， and protect your account security, we will collect your device and log information as follows: Include unique device identifier, GUID, device model, system language, country, advertising identifier, operating system, system version number, IP address, software version number, access network, network quality data, and service log information.

Feedback information. When you contact us for feedback or customer service, we will collect the information and material that you submitted, and your contact information (such as your phone number, and email address), so that we could contact you and answer your questions or provide other customer services to you.

In order to realize image and video processing quickly and accurately, we may need to upload the material or material tags to be processed to the cloud server for effect processing. The uploaded materials or tags are only used for image/video effect processing through related functions. We will not store the materials, tags and any related information for more than the necessary time, or use them for any other purpose besides this, or Provide to third parties.

2.Which permissions we might ask you to authorize

In order to provide you with more high-quality, efficient products and services and improve your service experience, we may ask you to authorize the corresponding terminal device permissions in the following additional services we provide to you. We collect the following permissions and corresponding information following the criterion of minimal data collection with your consent:

•Camera permissions: for video shooting；

•Microphone permissions: for video shooting and editing；

•Album: used to access photos for video editing or upload and download personal videos, photos, audios and subtitle data through the Cloud Disk Service Technology（when you use our cloud disk, you will be deemed to have agreed to abide by our Cloud Disk Service Agreement）；

•Apple Music: used to access the user's local and online music, which is convenient for users to add music for making videos;

•Receive notification messages: used to receive messages;

•Gets the current network status: to alert users whether they are currently using the mobile network or determine whether a user's wifi network is available；

•IDFA permission: for ad tracking.

If you access our Service through a device made by Apple, Inc. (“Apple”), this term will apply: Identifier for advertisers (“IDFA”) is analogous to an advertising cookie on Apple mobile devices (“iPhones”). Apple created the IDFA for ad tracking. It enables an advertiser to get notified when you have taken an action like clicking on their ad or installing their app. Starting with iOS14.5, You can choose whether to grant ad tracking. when you clicked the “Ask App Not to Track” button on your iPhone, we would not be able to access the device’s IDFA, so we could not use the IDFA to track you across apps and services. You also can turn off the ad tracking permission at your own discretion at any time in the system Settings of your terminal device. If you turn off the ad tracking permission, we will not track.

TrueDepth API: to get face data and track faces in our template functions.

Face recognition: For specific theme template editing and short video production services, VivaVideo collects the avatar photos you’ve uploaded or shot. To use some functions of the theme templates that need face matting, you can voluntarily permitVivaVideo to access the camera or photo album to obtain photos from your mobile device. Only after you confirm your permission, canVivaVideo access your camera and photo album. When you use some face recognition functions (including but not limited to theme templates), we automatically capture the positions and shapes of your five sense organs, analyze the facial feature information, store such information on our server for photo processing, and return the renderings to you. We will not store such processed photos, facial feature information, or renderings, or share them with any third party. Such information is processed only to run the face recognition function and provide you with better renderings.

You can check the status of the above permissions in the system settings of your terminal device, and you can turn on or off any or all above permissions at your own discretion at any time. Please note that when you open any permission. It means that you authorize us to collect and use the personal information corresponding to the permission to provide you with the above corresponding services. Once you turn off any permission, it means that you cancel or revoke the authorization of the permission, And we will no longer continue to collect and use the corresponding personal information based on this permission, nor will we be able to provide you with the services corresponding to this permission. However, your decision to turn off the permissions will not affect the previous collection and use of information based on your previous authorization.

3.How We Collect Your Information

We collect information in different ways.

We collect information directly from you. We collect information directly from you when you use the customer services on the Platforms.

We collect information from you passively. We use tracking tools like Google Analytics, browser cookies, and web beacons(see below for details)for collecting information about your usage of our Platforms.

4.How We Use Your Personal Information

We may use the information you have provided pursuant to this Policy to provide our Services or to communicate with you. Specifically, we may use your information for the following purposes:

•We use information to improve our Services. We use your information to help us create, develop, operate, deliver, and improve our Services. For example, we might look at usage trends to make sure the Platforms is easy to use.

•We use information for security purposes. We may use information for account and network security purposes, including in order to protect our Services for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content. We may use your information for security prevention, customer security services, etc.

•We use information to send important notices, such as alerts about your account and changes to our terms, conditions, and policies.

•We store and maintain your information for our legal obligations. For example, we may record, audit, analyze and dispose your information according to applicable laws in case of emergency.

5.Use of Cookies and Similar Technologies

When you use our Services, certain information may be stored locally on your mobile device using“cookies” or similar technologies such as Google Analytics and web beacons.

5.1 Cookies.

A cookie is a small text file or data file used to store limited information about the user of the device and is stored on your device. “Cookies” are identifiers we transfer to your mobile device that allow us to recognize your device and tell us how and when the Services or website are used or visited, by how many people, and to track movements within our app. Cookies also link to information regarding what items you have clicked or pages you have viewed. Cookies are also used to deliver content specific to your interest and to monitor website usage. It helps us to identify how our users use our Services so that we can continuously evolve and improve them. We use information collected from cookies to improve users' experience and the overall quality of our Services. If you are uncomfortable with cookies, you can decline cookies at any time by modifying your browser settings. Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered.

5.2 Google Analytics.

Google Analytics. Google Analytics is a service provided by Google, Inc. ("Google"). We use Google Analytics to collect anonymized statistics in order to improve the Site. You may refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.

6.Storage and Retention of Your Information

6.1 Storage of Your Information

The information that we collect from you may be transferred to, and stored at, a destination inside or outside of your country, for the purposes as described in the Policy. By submitting your information, you agree to this transfer, storing or processing. We will take reasonable steps to secure your information and treat it in accordance with the Policy and applicable laws.

6.2 Retention of Your Information

We retain personal information for as long as necessary to provide our Services or fulfill the original or directly related purpose for which such information was collected, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your personal information is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.

7.How We Share Your Information

Whenever selling any personal information to third parties, although it may be shared only when necessary to perform a legitimate business function.

We may share your necessary personal information data to third-party service providers to help us deliver and improve Services, marketing, push/deliver notification bar messages, and to help you to share content to third-parties media website, and other legitimate business functions. We will confirm on what basis each third-party will use your personal information and we will ensure that there are adequate safeguards and processes in place to protect your personal data.

We will disclose or transfer your Information, only if required to do so by law, or we have acquired consent from you, or in the good faith belief that any such action is necessary to: (a) comply with any legal requirements or comply with the legal process served on us or the Platforms; (b) protect and defend the rights or property of us, and (c) act under exigent circumstances to protect the personal safety of our users, or the general public.

We will not share, transfer or disclose your personal information in a way of violating this Policy or applicable laws. In the event of a transfer of information that may result from a possible merger, division, acquisition, asset sale, or bankruptcy liquidation by us, we will require the successor to protect your personal information in accordance with laws, regulations, and standards not lower than those set forth in this Policy.

8.How We Protect Your Information

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect from your using of our Services on the Platforms. We will use all reasonable efforts to safeguard your personal information.

We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements. These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.For example, when you send or receive data fromVivaVideo App, we make sure they are encrypted using Secure Sockets Layer ("SSL")or other algorithms.

If we become aware of any breach that affects the security of your personal information, we will provide you with notice as required by applicable laws. By using thePlatforms, you agree to accept notice electronically.

9.Your Rights

Your local laws may permit you to request that we:

•provide access to and/or a copy of certain information we hold about you

•prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling)

•update information that is out of date or incorrect

•delete certain information which we are holding about you

•restrict the way that we process and disclose certain of your information

•transfer your information to a third-party provider of services

•revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable laws. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with the information necessary to confirm your identity before responding to your request.

1)How to request data access, correction and query

You can click the personal center to enter your personal information editing page so as to access and correct your nickname information.

You can click“More”or“…”through“My Projects”on the home page to access the audio and video information completed/unfinished by you, and can also copy or rename the projectthrough“…”.

You can access the account, setting and product information of the third party that is boundin "Settings".

For other personal information generated during your use of our products or services, if you would like to access or correct it, you can contact us by adopting the methods specified in the privacy policy. As long as we do not require excessive investment, we will reply to your request within 15 days.

2)How to request data deletion

You can click“More”or“…”through“My Projects”on the home page to access the audio and video information completed/unfinished by you, or conduct the deletion operation through“…”.

Cancel accountto delete or anonymize your personal information. If you have registered a relevant account, you can choose to cancel your account at any time. You can cancel your account in "Settings" - "Account and Security" - "Cancel Account". Before you cancel your account, we may need to verify your personal identity, security status, device information, etc. You know and understand that the act of canceling your account is irreversible. When you cancel your account, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations.

In addition, under the following circumstances, you can put forward the request of deleting the personal information by sending a deletion request to the email address: support@vivavideo.tv:

a.Our handling of personal information violates the relevant laws and regulations.

b.We collect or use your personal information without your consent.

c.Our handling of personal information violates the agreement with you.

d.You no longer use our products or services, or you cancel your account.

e.We no longer provide you with products or services.

If we decide to respond to your deletion request, we will notify the entities that obtain your personal information from us, and ask them to timely conduct the deletion, unless otherwise specified by laws and regulations, or unless these entities are independently authorized by you.

After you delete the relevant information from our services, we may not immediately delete the corresponding information in the backup system, but we will delete it when the backup is updated.

When you access, modify or delete the relevant information, we may ask you to perform the identity verification so as to ensure the security of the account.

3)Other requests

If you need to exercise other rights or make other requests to us, you may contact us by adopting the methods specified in the privacy policy. As long as we do not require excessive investment, we will reply to your request within 15 days.

10.Minor’s/Children’s Privacy

The Platform is not intended for Children. Children under the age of 16(or any other age specified by the law applicable to your region) must not use the Platform for any purpose without first obtaining parental/guardian’s consent to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personally identifiable information from children.

It is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category. We do not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided us with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of our applicable Services.

11.Modification of This Policy

The effective date of this Policy is set forth at the top of this webpage. We reserve the right to amend this Policy at any time with or without notice and will place any updates on this webpage. The amended Policy supersedes all previous versions. Your continued use of Services on the Platforms will be taken as acceptance of the updated Privacy Policy.

12.How to Contact Us

If you have any question/complain/suggestion/request regarding this Policy, you may also contact us directly at:【Hangzhou Xiaoying Innovation Technology Co., Ltd】Email: support@vivavideo.tv.

Address:【22/F, Building A, Huaxing Times Square, 478 Wensan Road, Xihu District, Hangzhou City, Zhejiang Province, China】

SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction Specific that is relevant to your jurisdiction from which you access or use the Services, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms – Jurisdiction Specific will supersede and control.

Addendum for EEA and Switzerland Residents

If you are using the Services in the European Economic Area (“EEA”) and Switzerland, the following additional terms apply:

Your Special Rights

You have the following rights:

•The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;

•The right to request proper rectification or removal of your personal data or restriction of the processing of your personal data;

•Where the processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible (data portability);

•Where the processing of your personal data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal;

•The right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorized by Union or Member State law or this is necessary for the performance of a contract;

•The right to object to processing if we are processing your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing;

•The right to object to processing your personal data for direct marketing purposes; and

•The right to lodge complaints before the competent data protection regulator.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Please send an e-mail to us if you would like to exercise any of your rights support@vivavideo.tv.

Addendum for California Residents

The terms of this Addendum apply to residents of California under the California Consumer Privacy Act (“CCPA”) and other applicable laws. The CCPA provides California residents with certain legal rights such as “do not sell.” These rights are not absolute and are subject to certain exceptions.

In the past 12 months, we have not sold the personal information of California residents within the meaning of “sold” in the CCPA.

We collect, use, store and share your personal information in the same way as described in the main body of this Privacy Policy.

Your Special Rights Under the CCPA

Request we disclose to you free of charge the following information covering the 12 months preceding your request:

•the categories of personal information about you that we collected;

•the categories of sources from which the personal information was collected;

•the purpose for collecting personal information about you;

•the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you;

•the specific pieces of personal information we collected about you.

Request we delete personal information we collected from you, unless CCPA recognizes an exemption.

Be free from unlawful discrimination for exercising your rights including providing a different level or quality of Services or denying goods or Services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

Please submit your request via the following method: support@vivavideo.tv