Privacy Policy

1. Introduction

Sino BiofiberSuger Limited ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our I Magic C mobile application ("App"), an AI-powered photo editing app that allows you to take photos and change hairstyles using artificial intelligence.

The Company is registered in Hong Kong. We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and other applicable laws and regulations in the place where the Company is registered.

This policy applies to all users of the I Magic C App, regardless of how you access our services. By using our App, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect and How We Collect It

2.1 Information You Provide Directly

• Name and Account Information: Name, email address, username, password, and profile information when you create or update an account
• Address Information: Billing address, contact address, or other address information you provide for purchases, invoices, customer support, or legal compliance
• Payment and Purchase Information: Purchase history, subscription status, transaction identifiers, billing information, payment method type, and payment confirmation. Full card numbers and bank account details are processed by Google Play and Google payment services and are not stored by us
• Communications: Messages you send to our customer support or feedback
• User Content: Photos, images, ratings, reviews, style preferences, and other content you submit or process in the App

2.2 Information Collected Automatically Through the App

• Device Information: Device type, operating system, unique device identifiers, IP address
• Usage Data: Photo editing history, style preferences, feature usage statistics, and app interaction patterns
• Location Data: General location based on IP address (for internal app analytics and service optimization)
• Performance Data: App crashes, loading times, and technical diagnostics

2.3 Information Collected from Google Play

• App download, installation, purchase, subscription, refund, and payment status information from Google Play Store
• Payment confirmation and transaction information needed to verify purchases and provide paid features
• We currently do not collect personal information from third-party analytics providers, advertising networks, social media platforms, or other third-party integrations

3. How We Use Your Information

We use collected information for the following purposes:

3.1 Service Provision

• Creating and managing your account
• Providing AI-powered hairstyle transformation features
• Processing payments and managing Diamond purchases
• Verifying Google Play purchases, subscriptions, refunds, and payment status
• Delivering personalized style recommendations

3.2 Service Improvement

• Analyzing usage patterns and style preferences
• Improving AI hairstyle transformation accuracy
• Developing new hairstyle options and features
• Conducting internal research and analytics

3.3 Communication

• Sending service updates and notifications
• Responding to customer support inquiries
• Sending marketing communications, promotions, and product recommendations with your consent or where permitted by applicable law
• Managing your marketing preferences and opt-out requests
• Providing important security information

3.4 Legal Compliance

• Complying with legal obligations
• Protecting our rights and preventing fraud
• Enforcing our Terms of Service
• Responding to legal requests

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. At present, our App is distributed through Google Play Store only, and we do not share personal information with third-party analytics providers, advertising networks, social media platforms, or other commercial third parties.

4.1 Google Play and Google Payment Services

We may share or receive limited information with Google Play Store and Google payment services when necessary to:

• Process purchases, subscriptions, refunds, and payment status
• Verify entitlement to paid features, including Diamond purchases
• Prevent fraud, chargebacks, unauthorized transactions, and payment abuse
• Comply with Google Play policies, tax, accounting, and legal obligations

Google may process payment details under its own privacy policy and payment terms. We do not receive or store full credit card numbers, bank account numbers, or other complete payment credentials.

4.2 No Other Third-Party Sharing

Except for Google Play and Google payment services described above, we currently do not share your name, address, payment information, photos, or account information with any other third party for analytics, advertising, marketing, or independent commercial use.

4.3 Legal Requirements

We may disclose information when required by law, court order, or government request, or to protect our rights and safety.

4.4 Future Changes

If we introduce additional third-party service providers in the future, we will update this Privacy Policy and provide notice where required by applicable law before sharing personal information with them.

5. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes described in this policy:

• Account Data: Retained while your account is active and for a reasonable period after deactivation
• Usage Data: Typically retained for 2 years for internal analytics and service improvement
• Payment Data: Retained as required for tax and accounting purposes
• Communications: Retained for customer service and legal purposes

You may request deletion of your account data at any time, subject to legal retention requirements.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

6.1 Technical Measures

• Encryption of data in transit and at rest
• Secure server infrastructure
• Regular security audits and updates
• Access controls and authentication

6.2 Organizational Measures

• Employee training on data protection
• Limited access to personal data
• Incident response procedures
• Regular privacy impact assessments

7. Your Rights and Choices

Subject to applicable law, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you have certain rights regarding your personal information:

7.1 Access and Portability

You can request a copy of the personal information we have about you in a portable format.

7.2 Correction

You can update or correct your account information through the App settings, or request correction of inaccurate personal data we hold about you.

7.3 Deletion

You can request deletion of your account and associated data, subject to legal requirements.

7.4 Opt-out

You can opt out of marketing communications and direct marketing use of your personal data at any time.

7.5 Restriction

You can request limitation of how we process your information in certain circumstances.

7.6 How to Exercise Rights

To exercise these rights, contact us using the information provided below. We will respond to your request within 30 days.

8. Cookies and Tracking Technologies

8.1 Cookies

The App may use local storage, device settings, and similar technologies to enhance your experience:

8.2 Tracking Technologies

• Device Identifiers: Unique device IDs for app functionality
• Internal Usage Records: To understand feature usage and improve services
• No Third-Party Advertising Tracking: We currently do not use third-party advertising identifiers, advertising networks, or third-party analytics tools

8.3 Control Options

You can manage cookie preferences through your device settings or app privacy controls.

9. Children's Privacy

I Magic C is not intended for children under 13. We do not knowingly collect personal information from children under 13. Our app involves photo processing, and we take special care to protect the privacy of minors.

9.1 COPPA Compliance

If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

9.2 Parental Controls

We recommend that parents monitor their children's use of our App and use parental control features available on their devices.

9.3 Age Verification

We may use reasonable methods to verify age when necessary.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for international transfers, consistent with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and other applicable laws, including:

• Standard contractual clauses approved by relevant authorities
• Adequacy decisions by data protection authorities
• Your explicit consent where required

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy in the App
• Sending a notification through the App
• Providing notice through other reasonable means

Your continued use of the App after changes take effect constitutes acceptance of the updated policy.

12. Contact Us