We are committed to providing excellent service and a safe environment to use. This Privacy Policy details the types of information we collect, why we collect it, and how it is used and shared to help consumers (i.e., you) better understand our privacy practices. We undertake to collect your personal information only when it is lawful and necessary. While we do not obtain information about you directly from third parties, we recognize that third parties may share such information with us in certain circumstances. Please note that this Privacy Policy does not apply to the actions of third parties and we are not responsible for the actions of third parties. For information on the privacy practices of these third parties, please refer to their respective privacy policies.

Purpose of information collection

In order to continuously improve and optimize our service experience, we need to collect your personal information. The following are specific purposes for which we collect and use personal information:
1. Service support and maintenance: To ensure that you can enjoy high quality service, and the necessary maintenance of the service, while handling and meeting your individual needs.
2. Product and Service Improvement: Your information will help us to continuously improve our services. For example, your device may record hardware or software-related error messages and automatically send them to our servers to help us identify problems and optimize products based on feedback.
3. Development of new services: The data collected in existing services will be used to assist us in developing new services to meet the future needs of you and your users.
4. Customer Communication and care: We may use your contact information (such as email address) to maintain communication with you, including but not limited to informing you of service updates, changes, or responding to your inquiries and feedback, while providing necessary customer support.
5. Security and protection: The use of your information to enhance the security and reliability of the Services, including to prevent, detect and deter fraud, unauthorized access or illegal acts that could cause harm to us, our users or the public.
6. Legal Compliance and Procedural compliance: We may use your information to comply with legal obligations and respond to legal proceedings as required by applicable laws and regulations.

The specific content and use of information collected

The purpose of collecting information is to improve the quality of our services and ensure that all users can enjoy personalized and efficient services. Please be assured that any photos and schedule information shared through the App will not be collected or viewed by us or any third party. The type of information we collect will vary depending on how you use the service and how you manage your privacy Settings.
Specifically, we may collect the following types of information:

1. Device information

To ensure that you have access to basic smart device services, we may collect the following device information when you use the Services: The device's MAC address, model, brand, system language, system version number and system Settings, device unique identifier, Wi-Fi network information and connection status, language and country set on the device, server access records including time stamps and dates, error logs, program crash reports, and software version information.

2. Information created or provided by the user personally

In the process of creating an account, you are required to provide us with the following personal information: email address, country of residence, etc. In addition, during the registration process, we will guide you to set up an account password to ensure the security of your personal data. Your personal information will only be combined with your username (i.e. email address) and your own password to ensure the uniqueness and security of your account. When registering an account, we will send a verification email to the email address you provide to verify its validity.

What do we do with the information we collect

1. Improve service experience

The information we collect will be used to improve the quality of our services and customer satisfaction. By analyzing user feedback and behavioral data, we continuously optimize our service processes to meet user needs.

2. Information sharing policy

We promise that without your express consent, we will not disclose your personal information to any unaffiliated company, institution or individual. However, we may share your information with third parties in the following specific circumstances:
(1) Based on your consent
When you expressly consent to the sharing of your personal information with third parties, we will follow your instructions. For the sharing of sensitive information, we will ensure that we obtain your express permission.
(2) Legal requirements
We will share your Personal Information with third parties other than us if we have reasonable grounds to believe that it is necessary to access, use, retain or disclose your personal information for the following purposes:
a. Compliance with laws and regulations: We will share your information if we believe it is necessary to comply with any applicable law, regulation, legal process or mandatory request from a government agency.
b. Enforcement of our Terms of Service: In order to enforce our Terms of Service, including to investigate potential violations, we may need to share information with third parties.
c. Security protection: When fraud, security or technical issues are detected, we may share information to prevent or resolve them.
To the extent permitted by law, we may disclose your personal information to protect the rights, property, or safety of us, our users, or the public.

3. Entrusted processing of information

We may share your personal information with affiliated companies and our trusted partners or service providers, provided that they process this information in accordance with our express instructions and in accordance with our privacy policy and all applicable confidentiality and security protocols. We use the information we collect about you from our services, devices or other channels in order to improve your experience. You have control over your personal information and can exercise your rights. For more information on this, please refer to the "Your Rights" section of this document.
On the basis of your consent to this Privacy Agreement, you have the right to withdraw your consent at any time in response to your request in accordance with the procedures described in the "Contact Us" section of this Agreement. Please note that withdrawing consent may affect our ability or quality to provide you with services.

4. Third party data processing

In order to improve service quality, performance and user experience, we may use third-party analysis tools for evaluation. We promise that your personal information will not be disclosed to any third party during this process.
Specifically, we use the following third party services:
(1). Alibaba Cloud ECS server service was used for transferring images and sending schedules
(2). Alibaba Cloud object storage OSS service is used to transfer images for remote transmission
(3). cloudflare domain name resolution service is used to speed up service access
(4). The image production function of Alibaba Cloud Vision intelligent open platform is used, mainly for coloring and image sharpness optimization
(5). Use Ali Cloud vision intelligent open platform face human body function, mainly used for photo sharpness optimization
(6). Use engagelab's Push service for photo frames to receive push messages
(7). Used Google fcm service for android phones and Apple phones to receive push messages
(8). Utilizes the Google Calendar API service to enable real-time synchronization of Google Calendar events with photo frames, Android phones, and iPhones.

5. Transfer your personal information

You should be aware that we may transfer your personal information from your country to other companies that belong to us or to our service providers around the world. Such data transfers only take place where we have established appropriate and legal contractual terms and safeguards to ensure the protection of your personal data. For EU residents, we guarantee that we will not transfer your personal data outside of Europe.
We have servers in several countries around the world, and the information you provide may be processed on servers in countries other than your country of residence. Given the differences in data protection laws in different countries, some countries may offer a higher standard of protection. You agree that we may transfer information outside your country for the purpose of the service, although data protection regulations there may differ from those in your country. We guarantee that the same protections described in this policy will be applied wherever the information is processed. At the same time, we will also follow the legal framework related to the cross-border transfer of data to ensure compliance.

Information sharing

We may share your personal information with our subsidiaries, branches, and third party service providers who provide services as necessary. We have strict restrictions on the use of personal information by our service providers, and they may only use or disclose your information to provide services on our behalf or to comply with legal requirements. In addition, we may also share your personal information with business partners, such as wireless carriers, and third party applications and services associated with our services.
We may share personal information collected through our services with your express consent or otherwise. We may also disclose information about you when: (1) we are required to do so by law or legal process; (2) Providing information to law enforcement agencies or other government officials; (3) We believe the disclosure is necessary to prevent personal injury or financial loss, or in connection with the investigation of suspected or actual fraudulent or illegal activity; And (4) if we sell or transfer all or part of our business or assets, this may include events such as a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation.

The security of your personal data is our top priority

We are committed to adopting industry-recognized security standards to protect the electronic storage of your personal information. Nevertheless, we must remind you that no system, including ours, can completely eliminate security risks associated with personal information. To enhance your personal security, we recommend that you set a password that is hard to crack and avoid using the same password as your other accounts. At the same time, please keep your username and password safe to prevent unauthorized individuals from accessing your account and our services.
Our products are equipped with advanced security features designed to continuously protect your data. During service maintenance, we collect the necessary information that helps us identify and automatically defend against potential security threats. If we become aware of any risks that may affect your security, we will notify you promptly and provide guidance on the steps necessary to ensure that your information is adequately protected.
In the event of data breaches or similar incidents, we will report to the affected users in a timely manner in accordance with Articles 33 and 34 of the GDPR, and take necessary remedial measures to mitigate the damage.
We are committed to taking all possible steps to prevent your information from being accessed, tampered with, disclosed or destroyed by unauthorized third parties. This includes but is not limited to the following practices:
(a) Apply encryption technology to ensure the security and privacy of your data during transmission;
(b) Regularly review our information collection, storage and processing processes to prevent unauthorized access to our systems;
(c) Strictly control access to personal information and grant access only to those employees who need to process the information. These employees are bound by strict confidentiality agreements, and violations are subject to disciplinary action or dismissal.
However, we would also like to point out that although we have taken reasonable precautions, the security of websites, Internet transmissions, computer systems or wireless network connections is not 100%. Therefore, we encourage you to take additional personal security measures and work with us to protect your privacy and data security.

How long your personal information is stored

We undertake that the storage of your personal information will be strictly limited to the shortest period necessary to achieve the purpose for which it was collected. Once the purpose for which the information was collected no longer exists, we will ensure that the information is securely destroyed or completely deleted in our systems.
To ensure that our processing and retention of your information follow appropriate procedures, we have adopted the following standards and procedures:
1. Service provision period: We will retain your personal information at least until the end of the service we provide for you;
2. Legal and contractual requirements: We will determine the retention period of information in accordance with applicable laws and regulations, contract terms or our obligations under the law;
3. Time for Purpose: We will retain the information only for as long as is necessary to achieve the purpose for which it was collected, or, in the case of statistical or other specific purposes agreed upon under the contract, for as long as is necessary to meet those purposes, with appropriate protective measures in place throughout the process.
We are committed to maintaining the security and privacy of your personal information and ensuring that your information is properly managed and protected during storage. Our goal is to balance the availability of information with the protection of your privacy rights.

Your rights

You have the right to access, correct, and delete your personal data at any time (Art. 15-22 GDPR), and you are entitled to data portability, the right to restrict processing, and the right to object. We respect your choices and will respond promptly to your requests. Here are some of the key rights you can exercise:
1. Right of access to information: You have the right to request a detailed explanation of the personal information we collect.
2. Right to data correction: You have the right to request that we correct personal data that you believe to be inaccurate.
3. Right to data erasure: If certain conditions are met, you have the right to request that we delete your personal data.
4. Data limitation and right of objection: You have the right to request that we limit the processing of your personal data or object to such processing in certain circumstances.
5. Right to be forgotten: You have the so-called "right to be forgotten", that is, in certain circumstances, to ask us to completely erase your personal data.
6. Right to portability of data: You have the right to receive a copy of your personal data so that you can transfer it to other service providers.
7. Right to withdraw consent: You have the right to withdraw your consent to our processing of your personal data at any time. Please note that the withdrawal of consent does not affect the processing of data based on your consent prior to your withdrawal.
8.Cookies and login information management: You can use the relevant functions provided by our software to delete all Cookies and login information.
9. Restrictions on Service use: Please note that exercising your right to delete personal information may affect your use of our services.
10. Legal retention requirements: We may retain certain data in accordance with the law, even if you make a deletion request.
We are committed to respecting and protecting your privacy rights while complying with applicable privacy laws and regulations. Our goal is to provide you with transparency and control to ensure that your personal information is handled properly.

Children's privacy

Unless otherwise stated, our services are generally designed for general users and are not specifically designed for children. In the course of providing our services, we undertake not to knowingly obtain or request personal information from children unless we have received the express consent of their parents or legal guardians. If we accidentally collect personal information from a child without the prior consent of the parent or legal guardian, we will seek the consent of the parent or legal guardian or delete the information in a timely manner and we will delete the relevant personal information as soon as possible and within a reasonable time limit.
We take children's privacy rights seriously and strictly comply with relevant laws and regulations. If you are a parent or legal guardian and suspect that your child has provided us with personal information without your consent, please contact us by referring to the "Contact Us" section of this Privacy Policy. We will respond promptly to your concerns and take appropriate steps to protect your child's privacy.
We encourage parents and legal guardians to actively participate in and guide children's online activities to ensure the safety of their personal information. We are committed to creating a secure, privacy-respecting online environment that serves all users. If you have any questions or suggestions about the protection of children's privacy, please feel free to contact us.

Permission application and application scenarios

Data processing is based on user consent (Art. 6(1)(a) GDPR), fulfillment of a contract (Art. 6(1)(b) GDPR), or legitimate interests (Art. 6(1)(f) GDPR). We commit to processing personal data only on these legal bases.
When you use a particular product feature, we will ask you what permissions you need to use that feature, and if you do not agree to enable that permission, click "Do not Allow". We would like to provide you with a list of the types of permissions that may be collected by this Product and the purposes for which these permissions are used.
When you use a specific product feature, we will ask you to use the specific product feature required permissions, if you do not agree to enable the permission, please click "do not allow", refusing the request will only affect your use of the specific product feature. We would like to provide you with a list of the types of permissions that may be collected by this Product and the purposes for which these permissions are used.

APP Permission	Client-side	Description of permission and obtaining information	Purpose of permission
Network access rights	iOS	Access local network information	You need to enable the local network to discover local network services to search for devices
	Android	Access network information	Request background service
	Frame	Access network information	An Internet connection is required to use features such as photo/video transfer, art gallery functions, and schedule syncing
Storage permission	Android	Reads and writes to external storage	We need you to enable this permission in order to read photos and videos from your memory card
	Frame	Reads and writes to external storage	We need you to enable this permission in order to read photos and videos from your memory card
Camera permission	iOS	Camera allowed	We need you to authorize our camera permissions in order to:
	Android	Camera allowed	1. Identify the photo frame QR code and bind the photo frame
Photo permission	iOS	Allow access to photos	2. Take photos and videos that can be sent to a frame
Microphone permission	iOS	Microphone allowed	We need you to authorize our camera permissions in order to:
Schedule authority	iOS	Allows access to local schedule data	1. Identify the photo frame QR code and bind the photo frame
	Android	Allows access to local schedule data	2. Take photos and videos that can be sent to a frame
	Android iOS Frame	Allow access to Google Calendar data	3. Allow access to Google Calendar data We require your authorization to access your Google Calendar data in order to enable real-time updates and synchronization of your calendar information, allowing you to conveniently view and manage your schedule on your scheduling management device.

Renewal

This Privacy Policy may be updated periodically to reflect changes in the protection of personal information by our services or changes in applicable law. To ensure that you are kept informed of these changes, we will notify you of any important updates to the Privacy Policy through our official website and push notifications to your device, and clearly mark the specific date of the update.

Contact us

You can contact us through after-sales service. In addition, if you require us to provide a copy of your personal data, or if you wish to change or delete your personal data, please inform us in advance, and we will take appropriate measures according to your request.

Updated on August 17, 2025