VisionKey
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Privacy Policy

Date of Revision: [01/2026]

Foreword

Welcome to VisionKey. Our steadfast commitment is to protect and honor your privacy. We place great importance on your privacy and will only collect, process, and utilize your personal information for service provision after obtaining your consent.

Please review this notice carefully to understand our practices. If you have any questions regarding our Privacy Policy, feel free to contact us as outlined at the end of this policy. Note that your use of our APP is also subject to our Terms of Service.

Coverage and Third-Party Links

This Privacy Policy applies exclusively to the information we collect on and through the APP. The APP may include links to third-party websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of these other third-party websites. We encourage you to exercise caution when leaving our APP and to review the privacy statements of every website that collects personal information.

1. Information We Gather

1.1 Information Classifications

The information we collect can be categorized into two primary types: "voluntarily-submitted" information and "automatically-collected" information. "Voluntarily-submitted" information refers to any data you intentionally and actively provide when using our APP and its related services. We will request your consent when collecting such information. "Voluntarily" signifies that you have the choice not to provide this information, based on your personal preference. "Automatically-collected" information refers to any data automatically transmitted by your device while accessing our APP and its associated services. This automatically-collected information is necessary for us to deliver the APP services, and we will collect it to the minimum extent required.

1.2 Information Collection Based on Diverse Functions

a. When you upload videos, pictures, or other media files for video creation or save your generated videos (referred to as "Creations" as defined in clause 1.3d) on your device, we need to access the camera, media library/album, and memory card of your hardware devices to collect the media information you wish to upload or save. If you do not grant us access to such information, you will not be able to use the aforementioned services.

b. When you utilize the video-creation function, the text you input, the audio you add, and the resulting generated content (termed "User Created Content" as defined in clause 1.3d) will be stored on our server in Hong Kong for 30 days. You may delete this information at any time. Please note that we will no longer retain your User Created Content after 30 days, and all stored content will be automatically removed from our server.

1.3 Types of Information We Obtain

a. Log Data

When you access our servers through our APP, we may automatically record standard data from your device. This may include your device's Internet Protocol (IP) address, device type and version, your activities within the APP, time and date, and other usage information. Additionally, when you encounter errors during APP usage, we automatically collect data about the error and its circumstances. This data may include technical details of your device, what you were attempting to do when the error occurred, and other relevant technical information. You may or may not be notified of these errors, either at the time of occurrence, after they have occurred, or regarding the nature of the error.

Please be aware that although this information may not be personally identifiable by itself, it could potentially be combined with other data to identify individuals.

b. Personal Information

We may request personal information in the following circumstances:

When you use APP functions, you may need to log in, which may involve one or more of the following:

• Email
• Third-party profiles such as those on Facebook or Twitter

When you contact us, which may involve one or more of the following:

• Email
• Phone number (if provided)

c. User Account

To use the APP, you can register an account using a third-party account, such as those on Facebook or Twitter (each referred to as a "Connected Platform" and collectively as the "Connected Platforms"), or you can register directly through the APP.

Third-party Account

If you register using a Connected Platform's account, you agree to grant us certain permissions to receive data and information collected by that Connected Platform. The data may differ for each Connected Platform. We collect the data necessary to verify your registration with the Connected Platform and to enable you to use the APP securely.

Any personal information you share through the Connected Platform is also governed by the Connected Platform's privacy policy. Note that any information you disclose in public activities, along with your screen name or ID, or any image or photo, becomes public and is not protected as confidential.

Email Address

If you register directly through the APP, we need to collect your email address from the registration form and then send a verification code to complete your registration.

d. Payment Data

Purchase transactions are processed through third-party payment platforms. You should carefully review their payment terms, service terms, privacy policies, and any other relevant terms. We do not collect your payment information.

e. Device Information

We may collect information about your mobile device and internet connection, including your device's unique device identifier, operating system, browser type, and mobile network information.

2. How We Collect Information

When you access and use the APP, we may obtain various types of information. Note that the collection technologies are provided by third-parties, and the automatic information-collection technologies they use may include:

a. Cookies (and Similar Tech)

When you visit our APP, we send one or more "cookies" to your computer or other device. A cookie is a small file with a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows the site to recognize your browser. Cookies can store unique identifiers, user preferences, and other information. You can configure your browser to reject all cookies or to notify you when a cookie is being sent. However, some website features or services may not function properly without cookies.

b. Web Beacons

The APP's pages may contain small electronic files called web beacons (also known as clear gifs, pixel tags, and single-pixel gifs) that enable us, for example, to count the number of users who have visited those pages and perform other APP-related statistics.

3. How We Use Your Information

3.1 Purposes of Information Collection

a. To fulfill any other purpose for which you provide the information and to deliver the services provided by the APP.

b. To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collection.

c. To notify you when APP updates are available and of any changes to the products or services we offer through it.

d. To send you information about surveys, promotions, contests, as well as newsletters or other communications.

3.2 Improving Services with Collected Information

The usage and device information we collect helps us enhance our services and provide a better experience by enabling us to:

a. Estimate our audience size and usage patterns.

b. Recognize you when you use the APP.

c. Optimize and upgrade the APP, improving the smoothness of APP usage.

If we decide to modify the purposes of processing as specified above, we will inform you of these changes before using your personal information for the new purposes and request your separate consent if required by applicable laws.

3.3 Security Notice

Please be aware that even though we implement all reasonable measures to protect your information, no system or network is entirely without risk. In case of unforeseen events, such as phishing, viruses, identity theft, other cyber-attacks, and server damages due to war or other uncontrollable events, we will do our utmost to protect your information but will not be responsible for any risks, losses, or damages resulting from these unforeseen events. Following such events, we will promptly notify you about the basic situation, potential impact, and the remedies we have implemented in an easily accessible manner. If further reporting obligations arise due to regulatory authorities or applicable laws, we will disclose the incident and relevant details to the authorities.

4. Third-Party Information Collection

4.1 Third-Party Data Collection During APP Use

When you use the APP, certain third-parties utilize automatic information-collection technologies to gather data about you or your device. The primary third-parties involved in collecting data on APP users are:

a. Google: It serves as an identity verification provider. When you log in with your Google account, it helps us confirm your identity. Additionally, Google's analytics tools provide insights into how you interact with the APP, such as which features you use most.

b. Firebase: Firebase Crashlytics, a component of Firebase, is essential for tracking and resolving APP stability issues. It automatically collects data when an error occurs in the APP, such as the actions you took before the error and device-related details.

These third-parties, Google and Firebase, may use tracking technologies such as cookies or web beacons to collect information while you're using the APP.

4.2 Lack of Control over Third-Party Tracking

We do not have control over these third-parties' tracking technologies or how they are used. Please carefully review their privacy or data policies to protect your information and privacy. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

5. Data Retention and Transfer

5.1 Data Retention Periods

The "Creations" that you have not shared on the APP community will be stored on our server in Hong Kong for only 30 days. Once this period expires, they will be automatically deleted. Content you post, such as your profile picture, username, text, and "Published Videos" on the APP community, will be stored on a remote server in Hong Kong until you voluntarily delete them.

We retain your personal information only for as long as necessary. This time period depends on the purpose for which we are using your information, as outlined in this privacy policy. For instance, if you provided personal information when creating an account, we may retain it for as long as your account exists on our system. If your personal information is no longer needed for this purpose, we will delete it or anonymize it by removing identifying details.

We hereby ensure that all data and information collected under this Privacy Policy will be retained for the shortest time necessary to achieve the purpose for which it is provided, in accordance with the requirements of the Personal Data (Privacy) Ordinance.

5.2 Data Location and Transfer

The APP is maintained in the Hong Kong Special Administrative Region. You acknowledge that data stored in Hong Kong may be subject to legal requests from local courts or law enforcement authorities in Hong Kong. Any information you provide via the APP may be stored, processed, transferred, and accessed within the Hong Kong Special Administrative Region. If information transfer outside Hong Kong is required due to business needs, we will ensure that reasonable measures are taken to protect your information security and comply with relevant laws. Additionally, you hereby expressly consent and agree to such transfer, storage, and/or processing of your information as may be involved in the data processing.

5.3 Data Transfer for EU Users

If you are from the EU, it's important to note that the transfer of your data to recipients in other regions will be conducted in accordance with the standard contractual clauses adopted by the European Commission to satisfy the requirements of EU data protection laws. By using our Services, you consent to such transfer and processing within the purposes stated here.

6. Disclosure of Your Information

6.1 Situations of Information Disclosure

We may disclose personal information that we collect or that you provide without restrictions in the following circumstances:

a. To our subsidiaries and affiliates, with your explicit consent.

b. To contractors, service providers, and other third-parties we use to support our business, who are contractually obligated to keep personal information confidential and use it only for the purposes for which we disclose it to them.

c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, where personal information about our APP users is among the transferred assets.

d. To fulfill the purpose for which you provided it.

e. For any other purpose disclosed by us when you provided the information.

f. With your consent, as required by applicable laws.

g. To comply with any court order, law, or legal process, including to respond to any government or regulatory request (within the scope of the Hong Kong Special Administrative Region, following the relevant laws and regulatory requirements in Hong Kong).

h. To enforce our rights arising from any contracts between you and us.

i. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

7. How You Can Manage or Delete Your Information

7.1 Right to Access and Data Portability

You have the right to access your personal data and the right to data portability. This means you can request the APP for your personal data in a structured, commonly used, and machine-readable format.

7.2 Right to Rectify Personal Data

You have the right to request the APP to correct your personal data. This means you can require the correction of any inaccurate personal data about you and the completion of any incomplete personal data if necessary.

7.3 Withdrawing Consent

You can withdraw your consent for the collection and processing of your personal data at any time by contacting us at feedback@visionkey.net. This will not affect the lawfulness of processing based on consent before its withdrawal. After receiving your withdrawal request, we will process it promptly and will no longer process your personal data, unless otherwise required by law.

7.4 Sharing and Risks of User-Created Content

You may share your Creations through the APP for publication or display on social media networks and other websites. We cannot control the actions of third-parties with whom you choose to share your Creations. Therefore, we cannot guarantee that your Creations will not be viewed by unauthorized individuals, and we have no control or liability regarding how your Creations are used by others after you post or transmit them. Consequently, sharing and transmitting your Creations is at your own risk.

7.5 Deleting Information

a. Finding and Deleting Specific Information

We provide you with tools to delete certain information. For example, you can use the "Delete" button to remove your "Creations". Once you delete the content, other users will not be able to see it. Please be aware of the consequences of choosing to delete or remove content.

b. Permanently Deleting Your Account

If you decide to permanently delete your user account, click the "Delete Account" button. We will delete all your data in the APP, including but not limited to all Creations, purchase records, and collections. Once your account is permanently deleted, you cannot undo the deletion or retrieve your data.

If you registered with an email address, once you delete your APP account, you cannot use that email address to log in anymore.

8. European Privacy Rights

8.1 Rights for EU Residents

If you are a resident of the European Union, you will benefit from any mandatory provisions of the law of your country. You may have certain additional rights regarding your personal information under the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"). Nothing in this Agreement, including the above paragraph, affects your rights to rely on such mandatory local law provisions.

8.2 Exercising Rights

You can contact us at feedback@visionkey.net to exercise any of the above rights. We may ask you for specific information to confirm your identity, and in some cases, we may charge a reasonable fee for access to your information.

8.3 Complaint-Filing

If you believe that our processing of your information violates your data protection rights under the GDPR and we have not addressed your concerns adequately, you have the right to file a complaint with the data protection supervisory authority of your country.

9. Children's Policy

9.1 General Age Limitation

The APP is not intended for children under 18 years (in some cases, this age may vary according to legal requirements in your jurisdiction, collectively referred to as the "Minimum User Age"). We do not knowingly collect personal information from children under the Minimum User Age. If you are under the Minimum User Age, do not attempt to register for this APP or provide any personal information about yourself to us. If we discover that we have collected or received personal information from a child under the Minimum User Age without parental consent verification, we will delete that information. If you believe we might have information from or about a child under the Minimum User Age, contact us at feedback@visionkey.net.

9.2 Age Limitation for EU Residents

Due to the requirements of the EU General Data Protection Regulation, you must be at least 18 years old to use our Services. To the extent prohibited by applicable law, we do not allow EU residents younger than 18 years old to use the Service without parental/guardian permission.

10. Changes to Our Privacy Policy

We may update our privacy policy from time to time to appropriately provide our services and comply with applicable laws (in the Hong Kong Special Administrative Region, primarily in accordance with the Personal Data (Privacy) Ordinance and related regulations). Additional notifications will be displayed or otherwise communicated to you. Please regularly check this privacy policy page for any changes. If you do not agree with the revised privacy policy, you have the right to immediately stop using the APP. If, after a reasonable time following the update notification, you continue using the Services, it will be considered that you have accepted all the amendments, unless the APP is required by applicable law to obtain your explicit consent to the amendments.

11. How to Contact Us

To ask questions or provide comments about this privacy policy and our privacy practices, contact us at feedback@visionkey.net.