ACCUPAI SNAP Privacy Policy

1.0Scope of Application

This Privacy Policy applies to the ACCUPAI SNAP App and its related services.

ACCUPAI SNAP is primarily provided for use by photographers who have established a cooperative relationship with Accuvally, with distributors or agents authorized by Accuvally, with Accuvally’s partners, or with other vendors authorized by Accuvally to provide ACCUPAI-related services.

Photographer accounts may be created with the assistance of Accuvally, of administrative personnel authorized by Accuvally, or of distributors, agents, partners, or other service providers authorized by Accuvally. You must log in with a valid account before you may view the albums on which you collaborate and use the photo capture, upload, and other functions.

Regardless of whether you use ACCUPAI SNAP directly through Accuvally or through a distributor, agent, partner, or other service provider authorized by Accuvally, this Privacy Policy shall apply to the collection, processing, use, storage, and protection of data involved in your use of ACCUPAI SNAP. The term “Photographer” as used in this Policy refers to the “User” as defined in the ACCUPAI SNAP Terms of Use.

2.0Types of Data We Collect

In order to provide the ACCUPAI SNAP services, we may collect, process, and use the following data:

2.1Account and Identification Data

In order to provide ACCUPAI SNAP login, identity verification, and collaborative album access services, Accuvally, administrative personnel authorized by Accuvally, or distributors, agents, partners, or other service providers authorized by Accuvally may assist cooperating photographers in creating accounts, and may collect, process, and use the following data:

• Username or display name
• Mobile phone number, which serves as the login account
• Password
• Records of account creation, activation, deactivation, or changes to permissions
• Login time and time of last login
• Device ID and device name
• IP address and User-Agent
• Login session and refresh token hashes
• Account creator
• Authorization information relating to collaborative albums or projects
• Information on cooperative relationships, project attribution, or service management relating to distributors, agents, partners, or service providers

Your mobile phone number will serve as the account identifier for logging in to ACCUPAI SNAP. Your password will be used for login authentication. We will adopt reasonable security measures to protect password data, for example by processing and storing it by means of encryption, hashing, or other secure methods, so as to avoid storage in plaintext.

The foregoing data will be used to create and manage photographer accounts; to verify login identity; to confirm the collaborative albums or projects that you may access; to confirm the scope of services and administrative permissions of distributors, agents, partners, or other service providers; to maintain system security; and to provide necessary customer service or technical support.

2.2Device and Usage Record Data

When you use ACCUPAI SNAP, we may collect the following data:

• Device model
• Operating system version
• App version
• Login time
• Time of use
• Activity logs
• Network connection status
• Records of photo uploads, including successes, failures, and retries
• Error logs and system diagnostic information
• The website or back-end system may use cookies, Google Analytics, or other tools to collect behavioral data concerning users within the system, including but not limited to pages browsed, URL parameters, and device or browser information

The foregoing data is used primarily to maintain the normal operation of the services, troubleshoot problems, improve the stability of the App, track the status of photo uploads, and safeguard system security.

2.3Camera and Photo Data

When you connect your mobile phone to a camera via a data cable and use ACCUPAI SNAP to shoot or capture photos, we may access, read, process, and upload the photo data stored on the camera’s memory card, including:

• Photo files stored on the camera’s memory card
• Photos generated at the moment of shooting by the camera
• Photo file names
• Photo file formats
• Photo file sizes
• Image content
• EXIF information and other photo metadata provided by the camera or the photo files

The EXIF information and photo metadata that the system may process may include, without limitation:

• Date and time of shooting
• Camera brand, model, and lens information
• Shooting parameters such as shutter speed, aperture, ISO, focal length, and exposure mode
• Image dimensions, orientation, color settings, and file-related information
• Other technical information provided by the camera or the photo files, and the ImageUniqueID
• Where recorded by the camera or in the photo files, geolocation information or other information capable of identifying the shooting environment

Upon obtaining photos, ACCUPAI SNAP will automatically upload the photos and the aforementioned EXIF information to our servers for purposes of subsequent album management, photo organization, retouching, display, download, troubleshooting, photo sorting, analysis of shooting information, or other services relating to the cooperative project.

Please note that photo content may contain information capable of identifying natural persons, such as event participants, staff, photographers, venues, or objects; the EXIF information of photos may likewise contain the time of shooting, camera information, or, in certain circumstances, geolocation or other information. Before capturing and uploading photos through ACCUPAI SNAP, the Photographer shall confirm that his or her acts of shooting, providing, and uploading the photos and related metadata comply with the agreements reached with the event organizer, the persons photographed, or other relevant third parties, as well as with applicable laws and regulations.

2.4Facial Recognition, Face Search, and Facial Feature Data

For albums in which the face search function is enabled, the system will detect faces in photos and generate or obtain facial recognition data, the coordinates of facial bounding boxes, the service provider’s face identifiers, and model versions, which are used to locate, within the same album, photos that may contain the same individual. Where a visitor uploads a selfie to conduct a search, the visitor shall first read and consent to the personal data collection notice displayed by the system; the query image will be transmitted to the facial recognition service provider for comparison; and unless otherwise notified, the system will not retain the query image as an album photo.

2.5Image Text Recognition

For albums in which the text or serial-number search function is enabled, the system may recognize text, serial numbers, markings, or other legible content within photos, and may retain the recognition results, confidence scores, and text coordinates for purposes of in-album search, classification, and operational processing.

2.6Use of Device Permissions

In order to provide the photo capture and upload functions, ACCUPAI SNAP may require the use of permissions on your device, for example:

• Permission to connect to external cameras or to read data from external devices
• Permission to read photos, media files, or data on external storage devices
• Permission for network connectivity
• Notification permission, used to alert you to upload status or service-related messages

We will use the foregoing permissions only to the extent necessary to provide the functions of ACCUPAI SNAP.

2.7Consequences of Declining to Provide Data or Permissions

You are free to choose whether to provide the foregoing data or to grant the necessary device permissions. If you do not provide a login account or password or do not grant the necessary device permissions, you may be unable to log in to ACCUPAI SNAP, view collaborative albums, or use the photo capture, upload, and synchronization functions.

3.0Purposes of Data Use

The purposes for which we collect, process, and use data include:

1. To create, manage, and verify photographer accounts.
2. To enable photographers to log in to ACCUPAI SNAP by means of a mobile phone number and password.
3. To display the albums or projects on which the photographer collaborates.
4. To obtain photos stored on the camera’s memory card by connecting to the camera.
5. To capture photos generated at the moment of shooting by the camera.
6. To automatically upload photos and the aforementioned EXIF information to the servers.
7. To perform photo backup, organization, retouching, classification, display, download, or album management.
8. To generate thumbnails and display images, apply watermarks, and create download versions.
9. To perform face search, face indexing, and text or serial-number recognition in accordance with album settings.
10. To conduct the display of public albums, information security audits, and detection of anomalous logins.
11. To use photo file information, shooting times, camera information, and other EXIF information for photo sorting, classification, comparison, troubleshooting, analysis of shooting information, or service management.
12. To record photo upload status, such as successes, failures, retries, or causes of error.
13. To maintain the security of the services, detect anomalous use, and prevent unauthorized access.
14. To improve the functionality, stability, and user experience of ACCUPAI SNAP.
15. To contact photographers in connection with cooperation, customer service, technical support, or system notification matters.
16. To assist distributors, agents, partners, or other service providers authorized by Accuvally in carrying out cooperative project management, photographer management, album management, customer service support, or technical support.
17. To confirm the scope of authorization, scope of services, and access controls of distributors, agents, partners, or other service providers.
18. To perform obligations lawfully required by law, by the competent authorities, or by judicial authorities.

4.0Data Sharing and Disclosure

We will not arbitrarily sell, rent, or exchange your personal data.

However, under the following circumstances, we may share or disclose data to the extent necessary:

4.1Where Necessary for the Provision of Services

In order to carry out functions such as photo upload, storage, album management, retouching, display, download, photo sorting, analysis of photo information, or troubleshooting, photos, EXIF information, and related data may be provided to our relevant internal personnel or to authorized cooperating personnel for processing.

4.2Distributors, Agents, Partners, or Other Service Providers

Where ACCUPAI or ACCUPAI SNAP is made available to you, or used in connection with a relevant cooperative project, through a distributor, agent, partner, or other service provider authorized by Accuvally, Accuvally may, to the extent necessary for the provision of services, cooperative project management, account management, album management, customer service support, technical support, permission management, or performance of contractual obligations, share with or disclose to such service providers your account data, cooperative project information, album information, photos, EXIF information, upload records, usage records, or other necessary data.

Such distributors, agents, partners, or other service providers may use the relevant data only to the extent necessary for the authorized services, the cooperative project, or the contractual purposes, and shall be subject to confidentiality, data protection, and security maintenance obligations in accordance with their agreements with Accuvally or with the relevant cooperating parties.

4.3Outsourced Service Providers

We may engage third-party service providers to assist in providing ACCUPAI SNAP–related services, including but not limited to cloud hosting, data storage, content delivery, system operation and maintenance, error tracking, data analytics, push notifications, image processing, retouching, or other technical services.

Such service providers may, to the extent necessary for the provision of their services, access or process account data, device and usage records, photos, EXIF information, upload records, or error diagnostic information. Such providers may process data only in accordance with our instructions and for the purposes of the services, and shall be subject to confidentiality and data security obligations in accordance with their agreements.

4.4Parties Related to Cooperative Projects

In accordance with the needs of a cooperative project, photos, EXIF information, and related data may be provided to event organizers, project management personnel, retouching personnel, or other authorized persons for purposes of album production, photo organization, retouching, delivery, display, download, troubleshooting, or other purposes related to the cooperative project.

4.5Requirements of Law or the Competent Authorities

Where required by laws and regulations, court orders, or the competent authorities, or where necessary to protect the lawful rights and interests of Accuvally, of users, or of third parties, we may provide the relevant data in accordance with law.

5.0Data Storage and Retention Period

We will retain your data for the period necessary to accomplish the purposes of collection.

Photographer account data will ordinarily be retained until the cooperative relationship is terminated, the account is deactivated, or continued retention is no longer necessary. If you use the services through a distributor, agent, partner, or other service provider authorized by Accuvally, the relevant account data may also be retained in accordance with the requirements of the cooperative project, the service contract, the distribution or agency relationship, administrative needs, or laws and regulations.

Photos, EXIF information, and related upload records will be retained in accordance with the cooperative project, album settings, contractual stipulations, service needs, or the requirements of laws and regulations. When the retention of data is no longer necessary, we will, within a reasonable period, delete or anonymize the data or otherwise handle it in an appropriate manner.

Where photos, EXIF information, or other data are involved in legal disputes, payment matters, audits, information security incidents, the administration of distribution or agency cooperation, performance of contractual obligations, or other legitimate retention needs, we may extend the retention period to the extent necessary.

6.0Data Security

We will adopt reasonable and appropriate technical and organizational security measures to protect your data against unauthorized access, disclosure, alteration, damage, or loss.

Such measures may include:

• Account login and identity verification
• Password encryption, hashing, or other secure storage methods
• Access controls
• Encryption of data in transit
• Restrictions on access to servers and databases
• System logging and anomaly detection
• Management of internal personnel access rights
• Necessary permission and data-access management with respect to authorized distributors, agents, partners, outsourced service providers, or other service providers

Nevertheless, no method of transmission over the internet or of electronic storage can be guaranteed to be one hundred percent secure. In the event of a data security incident, we will handle the matter in accordance with applicable laws and regulations and our internal procedures, and will, where necessary, notify the affected data subjects or the competent authorities.

7.0Your Rights

In accordance with applicable personal data protection laws and regulations, you may, with respect to your personal data, make the following requests to us:

1. To make an inquiry of and to review your personal data.
2. To request a copy of the relevant data in accordance with law.
3. To request that your personal data be supplemented or corrected.
4. To demand the cessation of the collection, processing, or use of your personal data.
5. To request the erasure of your personal data.

If you wish to exercise any of the foregoing rights, please contact us through the contact channels set forth in this Policy. If you use ACCUPAI SNAP through a distributor, agent, partner, or other service provider authorized by Accuvally, you may also convey your request through such service provider, or contact Accuvally directly.

We may ask you to provide the information necessary to verify your identity, and will handle your request in accordance with applicable laws and regulations and within a reasonable period.

Please note that where your request concerns cooperative project photos, EXIF information, the rights and interests of event organizers, the administration of distribution or agency cooperation, performance of contractual obligations, statutory retention obligations, or the rights and interests of third parties, and the circumstances fall within the proviso of Paragraph 3, Article 11 of the Personal Data Protection Act—namely, where the processing or use is necessary for the performance of a business duty or has been agreed to by you in writing—we may, in accordance with law, decline to erase or defer the erasure of the relevant data, and will assist in handling the matter to the extent permitted by law.

8.0Photographer Responsibilities in Use

ACCUPAI SNAP is a working tool provided for use by cooperating photographers. When using this App to capture, upload, or provide photos, the Photographer shall ensure that:

1. The necessary authorizations for shooting, use, upload, delivery, or processing have been obtained.
2. The content photographed does not violate any law, contract, event rules, or the rights and interests of third parties.
3. The provision, upload, and use of photos and of their EXIF information or other metadata comply with the agreements reached with the event organizer, the persons photographed, or other relevant third parties, as well as with applicable laws and regulations.
4. Where the Photographer is engaged through, or uses the services through, a distributor, agent, partner, or other service provider authorized by Accuvally, the Photographer shall also comply with the cooperation agreements between such vendor and the Photographer, the event organizer, or other relevant parties.
5. ACCUPAI SNAP shall not be used to upload photos unrelated to the collaborative album or project.
6. The Photographer shall not use another person’s account without authorization, nor provide his or her account to any unauthorized person for use.
7. The Photographer shall properly safeguard login credentials, passwords, and connected devices.
8. If the Photographer discovers that the account has been misappropriated, that the password has been compromised, or that any other anomalous use has occurred, the Photographer shall immediately notify Accuvally or the distributor, agent, partner, or other service provider with whom the Photographer deals.

If a third-party dispute, damage, or legal liability arises from the Photographer’s violation of any of the foregoing, the Photographer shall bear sole responsibility therefor; Accuvally may also, in accordance with the cooperation agreement or the service rules, restrict, suspend, or terminate the Photographer’s right to use the account.

9.0Data of Children and Minors

ACCUPAI SNAP is not designed for independent use by children or minors.

Nevertheless, event photos may contain images of children or minors. Photographers, event organizers, or relevant cooperating parties shall confirm that the necessary consents have been obtained, or that the shooting, provision, upload, and use of such photos and the related metadata otherwise comply with applicable laws and regulations and event rules.

Where the face search, public album, or download functions are enabled, the event organizer or project party shall have appropriate notice and authorization mechanisms in place for communication to the legal representatives of the minors concerned.

10.0Cross-Border Transfer

In order to provide stable services, we may use cloud services, data storage, or technical service providers located in Taiwan or abroad. Accordingly, your data may be stored or processed in Taiwan, as well as in the jurisdictions where the cloud or technical service providers engaged by us are located, for example, Singapore.

Where data is transferred across borders, we will protect the security of the data so transferred and processed in accordance with applicable laws and regulations and by means of reasonable security measures.

11.0Amendments to This Privacy Policy

We may revise this Privacy Policy from time to time by reason of adjustments to the services, changes in laws and regulations, technological updates, operational needs, or adjustments to the service models of distributors, agents, or partners.

The updated Privacy Policy will be published in the ACCUPAI SNAP App, on the official website, or in another appropriate location. In the event of any material change, we will notify you by reasonable means.

You are advised to review this Privacy Policy periodically to stay informed of its most current contents.

12.0Contact Us

If you have any questions regarding this Privacy Policy or our handling of personal data, or if you wish to exercise your rights with respect to personal data, please contact us through the following channels.

If you use ACCUPAI SNAP through a distributor, agent, partner, or other service provider authorized by Accuvally, you may also raise the relevant questions or requests with such service provider, which will, as circumstances warrant, assist in conveying or handling them.

Company Name: Accuvally Inc. (盈科泛利股份有限公司)

Contact Us: service@accupass.com

Your request will be handled by our customer service or by the personnel responsible for personal data protection, and, upon receipt of your request, we will respond to and process it in accordance with applicable laws and regulations and within a reasonable period.