颜习社隐私政策

Last Updated: October 2025

App Name: Yan Xi She

Developer: Game4play Limited

App Type: Beauty Analysis Application

Welcome to Yan Xi She. This Privacy Policy details how we collect, use, store, and protect your personal information, particularly regarding facial recognition and biometric data processing. We strictly comply with Apple App Store privacy requirements and relevant laws and regulations.

📋 Key Points Summary

This summary provides key points of our privacy policy, but you can find more detailed information about the section you're looking for by clicking the link after each point or using the table of contents below.

What personal information do we process? When you visit, use, or navigate our services, we may process personal information depending on how you interact with us, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information when necessary, with your consent or as permitted by law. Learn more about the sensitive information we process.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and manage our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

📋 Facial Data Information Quick Index

For detailed information about facial data, please refer to the following sections:

• Section 1: What information do we collect?
• Section 2: How do we process your information?
• Section 3: Facial data storage location and retention period
• Section 3.3: Data sharing policy
• Section 5: Your control rights over facial data
• Section 8: Facial skin analysis responsibility statement

🍎 Apple App Store Privacy Statement

This app uses the following data types:

• Camera Permission: For taking facial photos for beauty analysis
• Photo Library Permission: For selecting saved photos for analysis
• Biometric Data: Facial feature data (only for beauty recommendations, not for identity recognition)

Data Usage Purpose: - Provide personalized beauty analysis services - Generate beauty recommendations and care plans - Improve app functionality and user experience

Data Sharing: - Do not share or sell data to third parties for marketing or advertising purposes - Only share with Alibaba Cloud (Alibaba Cloud as a technical service provider, strictly bound by contracts, only for data processing and storage) - Alibaba Cloud may not use data for any advertising, marketing, or other commercial purposes

1. What Information Do We Collect?

In short: We collect personal information that you provide to us.

When you use our services, we collect personal information that you voluntarily provide to us, including when you participate in service activities or contact us.

Term Definitions

Facial Data: A general term for selfie photos and facial feature biometric information, used only for beauty analysis services, not for identity recognition or advertising purposes.

1.1 Information You Actively Provide

The personal information we collect depends on how you interact with us, the choices you make, and the products and features you use. The personal information we collect may include:

• Facial Data: Selfie photos and facial feature biometric information
• Sensitive Information: When necessary, with your consent or as permitted by law, we process the following categories of sensitive information:
  • Biometric data

⚠️ Important Note: Facial Data Collection

This app requires access to your camera permission to capture facial data, which will be used for beauty analysis services.

Data Collection Purpose: - Facial feature analysis (only for beauty recommendations) - Skin condition assessment - Personalized beauty recommendation generation - App functionality improvement (anonymized data)

Data Processing Method: - Facial data will be uploaded to Alibaba Cloud servers for analysis - No local facial recognition processing on the device - After analysis completion, original data will be deleted according to retention policy

User Control: - You can refuse to provide facial data at any time - You can delete uploaded data at any time - You can withdraw consent and delete account at any time

1.2 Automatically Collected Information

Certain information (such as your IP address and/or browser and device characteristics) is automatically collected when you visit our services.

The information we collect includes:

• Log and Usage Data: Log and usage data are service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information and settings, and information about your activities in the service (such as date/time stamps related to your usage, pages and files viewed, searches, and other actions you take, such as features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

2. How Do We Process Your Information?

In short: We process your information to provide, improve, and manage our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

2.0 Legal Basis

We collect and process your personal information based on the following legal grounds:

• Performance of Service Contract: Processing your facial photos to provide beauty analysis services
• Your Explicit Consent: You actively upload facial photos for beauty analysis
• Legitimate Interests: Improving algorithms and service quality (using anonymized data), this processing will not affect user rights and freedoms
• Legal Obligations: Complying with relevant laws and regulations

We only process your information when we have a valid legal reason to do so.

🎯 Sole Purpose of Facial Data Processing

Your uploaded facial data is used only for the following purposes:

1. Beauty Analysis Services: Analyze facial features to provide personalized beauty recommendations
2. Skin Condition Assessment: Assess skin health and provide care recommendations
3. App Functionality Improvement: Use anonymized data to improve algorithms (does not contain personal identification information)

We strictly commit to:

• ❌ Not used for identity recognition or authentication
• ❌ Not used for advertising targeting or marketing
• ❌ Not sold to third parties
• ❌ Not used for any commercial purposes
• ✅ Only used for beauty analysis services you actively request

We process your personal information for various reasons, depending on how you interact with our services, including:

2.1 Core Service Functions

• Personal Aesthetic Feature Analysis:
  • Personal aesthetic feature assessment based on facial data
  • Analyze facial contours, skin tone, temperament and other aesthetic indicators
  • Generate personalized aesthetic analysis reports
  • Provide personal image enhancement recommendations
• Personalized Recommendation Services:
  • Provide hairstyle recommendations based on aesthetic analysis
  • Recommend suitable personal styles
  • Provide beauty and image guidance content
  • Generate personalized enhancement plans

2.2 Technical Improvement and Optimization

• Algorithm Optimization:
  • Improve aesthetic feature analysis algorithm accuracy
  • Optimize personal image analysis model performance
  • Enhance personalized recommendation generation quality
• Product Development:
  • Develop new aesthetic analysis features
  • Optimize user experience and interface design
  • Add personalized image enhancement service features

2.3 Operations and Security

• Service Operations:
  • Send image enhancement reminders and service notifications
  • Provide customer support and technical services
  • Troubleshoot technical issues and system failures
• Security Protection:
  • Prevent fraud and abuse
  • Protect user account security
  • Comply with biometric data-related laws and regulations
  • Ensure facial photos are used only for aesthetic analysis, not for other purposes

3. Facial Data Storage and Transmission

3.1 Data Storage Location

📍 Storage Location Description

Your facial photos and biometric data are securely stored on [Alibaba Cloud] servers located in [Mainland China].

Specific Storage Information: - Storage Country/Region: Mainland China - Cloud Service Provider: Alibaba Cloud - Data Center Location: Alibaba Cloud Mainland China Data Center - Data Protection Certifications: ISO 27001, SOC 2, Level 3 Protection Certification

Important Notes: - All facial photos are encrypted end-to-end during transmission and storage - Only authorized technical personnel can access this data - We do not store facial data on your device - Data is stored within Mainland China, complying with data localization requirements, ensuring data does not leave the country

• Storage Security Measures:
  • Use AES-256 encryption standard for facial data storage
  • Facial feature data protected with special encryption algorithms
  • Strict access control, only authorized technical personnel can access
  • Regular security audits and vulnerability scans
  • Data encrypted throughout transmission and storage process

3.2 Data Retention Period

In short: We retain your data to allow you continued access to your historical reports. You have complete control and can delete at any time. For long-term inactive accounts, we will perform automatic cleanup.

Our data retention policy aims to provide you with continued service value (such as accessing historical reports, tracking changes) while strictly adhering to the principle of data minimization.

1. User Active Control: You have complete control over the data in your account. You can actively delete any of your facial data or the entire account at any time through the app's features. When you choose to delete your account, all personal information associated with your account (including facial data and all analysis reports) will be permanently and irreversibly cleared from our servers within 30 days.

2. Data Retention for Active Accounts: As long as your account remains active (defined as having logged in or used the app within the past year), we will continue to retain your facial data and analysis results. This is to ensure you can access your complete historical records at any time, which is part of our core service to you.

3. Automatic Cleanup Policy for Inactive Accounts: To protect your privacy and effectively manage data, if an account has no activity for a continuous year (for example, no login, no new analysis), we will consider it an "inactive account." At that time, the system will automatically and permanently delete all facial data and analysis reports under that account.

Specific Retention Periods

• Personal Data (facial data and analysis reports):

  • For active accounts: Continuously retained during your account's active period, so you can access historical records at any time.

  • For inactive accounts: Automatically and permanently deleted after one year of account inactivity.

• Anonymized Data:

  • To continuously improve our AI algorithms to provide better services, we may continue to retain a completely anonymized version of your personal data after it has been deleted. This data has undergone irreversible technical processing and can no longer be associated with any personal identity, and is used only for macro statistical analysis and algorithm training.

• User-Initiated Deletion:

  • When account is deleted: When you actively delete your account, all identifiable personal data will be permanently deleted within 30 days and cannot be recovered.

3.3 Data Sharing

We do not share or sell your data with any third parties for marketing or advertising purposes. The only exception is that to achieve the app's core functionality, your facial data needs to be processed and stored by our technical service provider - Alibaba Cloud. Alibaba Cloud, as a technical service provider, is bound by strict data protection agreements and can only process data according to our instructions, and may not use it for any advertising, marketing, or other commercial purposes.

Specific Sharing Situation: - Sharing Recipient: Alibaba Cloud - Technical Service Provider - Sharing Purpose: AI analysis processing, cloud storage (only for providing beauty analysis services) - Data Protection Measures: Use Standard Contractual Clauses (SCC) to protect data transmission, ensuring recipients provide equivalent level of data protection - Usage Restrictions: Alibaba Cloud can only process data according to our instructions and may not use it for any advertising, marketing, or other commercial purposes

3.4 Data Transmission and Cross-Border Transfer

• Transmission Security:
  • Use TLS 1.3 encrypted transmission
  • End-to-end encryption for facial data protection
  • Data cannot be intercepted or tampered with during transmission
• Cross-Border Transfer:
  • Data is mainly stored in Mainland China, complying with data localization requirements
  • All data for Mainland China users is stored within Mainland China, involving no cross-border transfer
  • If cross-border transfer is involved, Standard Contractual Clauses (SCC) will be used to protect data transmission
  • Ensure recipients provide equivalent level of data protection

4. Information Security Measures

In short: We protect your personal information through organizational and technical security measure systems.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.

Specific security measures we take:

• Data Encryption: All facial photos and biometric data are encrypted end-to-end during transmission and storage
• Access Control: Strict access control, only authorized technical personnel can access
• Identity Authentication: Multi-factor authentication protects data access
• Regular Audits: Regular security audits and vulnerability scans
• Employee Training: Regular data protection training for employees
• Incident Response: Comprehensive data security incident response plan
• Anonymization Processing: Facial photos processed with anonymization technology
• Special Protection: Biometric data protected with special encryption algorithms

5. User Rights

In short: In certain regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you to better access and control your personal information. You can review, change, or terminate your account at any time.

In certain regions (such as EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These rights may include: (i) the right to request access and obtain a copy of your personal information; (ii) the right to request rectification or deletion; (iii) the right to restrict the processing of your personal information; (iv) if applicable, the right to data portability; and (v) the right not to be subject to automated decision-making. In some cases, you may also have the right to object to the processing of your personal information.

Specific rights you have:

• Right of Access: Obtain a copy of your personal data that we hold, including facial data and analysis results
• Right of Rectification: Correct inaccurate personal data
• Right of Erasure: Request deletion of your personal data, including facial data
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to our processing of your data, especially facial data processing
• Right to Withdraw Consent: Withdraw your consent at any time
• Right to Complain: If you believe we have illegally processed your personal information, you have the right to complain to the relevant data protection supervisory authority

How to exercise your rights: The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

6. Algorithm Transparency

In accordance with DSA requirements, we maintain transparency in the following areas:

• Principles and operations of facial recognition and skin feature analysis algorithms
• Technical methods for facial feature extraction and skin condition assessment
• Skin condition trend analysis and beauty recommendation mechanisms
• Users understand that facial analysis features require upload to Alibaba Cloud servers for cloud processing
• Facial data processing workflows and data flows

7. Child Privacy Protection

In short: We do not knowingly collect data from or market to children under 18.

We do not knowingly collect data from or market to children under 18. By using the services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the services. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.

Special protection measures we take:

• Age Verification: Require users to declare they are 18 or older to use the service (app has age confirmation mechanism)
• Guardian Consent: Users under 18 require explicit guardian consent
• Data Deletion: If child data is mistakenly collected, all related data will be immediately deleted
• Feature Restrictions: Facial analysis features for minor users will be subject to additional restrictions
• Guardian Control: Guardians can request deletion of their children's data at any time

If you are a guardian, please ensure your children understand these privacy protection measures.

8. Facial Skin Analysis Responsibility Statement

Regarding facial skin analysis features:

• We provide users with technical tools for facial photo-based skin feature analysis, aimed at providing aesthetic reference and inspiration
• The analysis results of this app are intended to provide aesthetic reference and inspiration and cannot replace professional medical or beauty advice
• We encourage you to consult professionals before making important decisions
• We take reasonable security measures to protect user data, but are not responsible for risks caused by users uploading inappropriate data, and we do not assume responsibility for their portrait rights or privacy
• If users believe their facial data or privacy has been violated, they may contact us through the following methods:
  • Complaint email: [email protected]
  • Please provide relevant evidence and detailed descriptions
  • We will handle valid complaints promptly and take appropriate measures
• We encourage users to only upload their own facial photos and consult professional beauticians or medical personnel as needed

9. Third-Party Service Providers

We use the following third-party services, but do not provide them with facial photos or biometric data:

• Firebase:
  • Purpose: Application performance monitoring, crash analysis
  • Data Processing: Only collects anonymized technical data
  • Facial Data: Not collected, not stored, not processed
  • Details: Firebase Privacy Policy
• Adjust:
  • Purpose: Installation and usage statistical analysis
  • Data Processing: Only collects device identifiers and usage statistics
  • Facial Data: Not collected, not stored, not processed
  • Details: Adjust Privacy Policy

Data Processing Transparency: - Data Processing Location: Alibaba Cloud Mainland China servers, all facial data must be uploaded to Alibaba Cloud servers - Data Access Permissions: Only our authorized technical personnel can access (for technical maintenance), Alibaba Cloud can only process data according to our instructions - Access Records: Complete data access records are maintained, Alibaba Cloud may not use data for any other purposes

10. Complaints and Appeals

If you believe our data processing has violated your rights:

• You can directly contact our Data Protection Officer
• File a complaint with the relevant data protection supervisory authority
• We promise to respond to your request within 30 days

Regarding facial data and skin analysis data privacy complaints:

• Complaint email: [email protected]
• Please provide the following information in your email:
  • Your identity proof and contact information
  • Detailed description of the violated facial data or skin analysis data
  • Specific circumstances and timing of the violation
  • Relevant evidence materials
• We will handle valid complaints promptly and may require you to provide additional materials

11. Contact Information

For data protection related inquiries, please contact:

Company Name: Game4play Limited
Registered Address: UNIT 225-22, 2/F, MEGA CUBE, 8 WANG KWONG ROAD, KOWLOON BAY, HONG KONG
Data Protection Officer Email: [email protected]
General Inquiry Email: [email protected]
Response Time: We will respond to your request within 30 days of receipt

Important Note: This service is provided by Game4play Limited, registered in Hong Kong. To comply with Mainland China's laws and regulations and provide the best service to users, we choose to store and process all data for Mainland China users on Alibaba Cloud servers within Mainland China, ensuring data does not leave the country and complies with data localization requirements.

Apple App Store Related: - We strictly comply with Apple's privacy policy requirements - If you have privacy-related questions, you can also contact us through Apple App Store's feedback channels

Last Updated: October 2025

This privacy policy complies with the following regulatory requirements: - Apple App Store privacy policy requirements - EU General Data Protection Regulation (GDPR) - California Consumer Privacy Act (CCPA) - China's Cybersecurity Law and Data Security Law - China's Personal Information Protection Law - Other applicable data protection laws and regulations