SVAKOM Privacy Policy

Last Updated: March 19, 2024

Developer Contact Information: svakom688@163.com

Shenzhen SVAKOM Technology Co., Ltd. values your privacy. When you use our products (including services), we may collect and use your relevant information to improve service quality, and we will make every commercially reasonable effort to protect your privacy. We recommend that you carefully read this Privacy Policy to understand what information we collect and how we handle your personal information. This Privacy Policy applies to all registered and unregistered users of SVAKOM and may be updated or modified as necessary from time to time. By continuing to use our products or services, you are deemed to have agreed to the collection, storage, and use of your information in accordance with this policy and applicable local laws.

This Privacy Policy may include some technical terms, which we will explain in as simple a manner as possible to help you understand.

As a user or visitor of our software, you agree to be bound by all terms and conditions set forth in this Privacy Policy and consent to our collection, use, and disclosure of such personal information. If you do not accept the terms of this Privacy Policy, or do not agree to any subsequent modifications, changes, or updates, you must not access the software or use any services provided. You hereby agree that your sole remedy in such a case is to discontinue and cease further use of the services.

In addition, We value your privacy and process your personal data in accordance with:

• EU General Data Protection Regulation (GDPR)
• ePrivacy Directive (EU)
• California Consumer Privacy Act (CCPA)
• China Personal Information Protection Law (PIPL)
• Other applicable international privacy laws.

This document contains important terms and conditions that affect your privacy rights and your expectations regarding those rights. Using the application constitutes your acceptance of this Privacy Policy.

Third-Party SDK Integration

We integrate third-party SDK data services to enhance and improve the user experience of the application.

SDK Name: Google Firebase Analytics

Service Type: Statistical Analysis

Type of Personal Information Collected: Device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/IP address/SIM card IMSI information, etc.)

Privacy Policy Link: Google Privacy Policy

SDK Name: Google Firebase Crashlytics

Service Type: Statistical Analysis

Type of Personal Information Collected:

• Crash environment: Crash information and thread stack, ROM/RAM/SD card capacity, network/language status, etc.
• App information: Package name, version, associated process name
• Device information: Android ID, used to determine crash device statistics

Privacy Policy Link: Google Privacy Policy

Collection and Use of Information

We collect and store certain personal information to create a Shenzhen SVAKOM Technology Co., Ltd. account and provide necessary support for subsequent services. If you do not wish to provide this information, you may not be able to register or access certain services, or some features may not function optimally. Unregistered users can still access all functions, and we do not collect personal information from unregistered users.

The personal information we collect includes:

Name, email address, mailing address, phone number, uploaded profile pictures, or bank card numbers you provide when registering an account or using our services. Bank or credit card information is used for payment of SVAKOM products or services. Information you provide to us or others when using "Photo Stream Sharing" or other sharing services.

Other information we collect includes:

• Geographical region of the device you use when interacting with the service, your system language, and the type of device and software or operating system version. This information helps us better understand you and optimize services to improve your experience.
• Operational logs while using our products, including statistics, key action paths, error logs, crash records, etc., to help us better understand product performance and improve service experience.
• Geolocation information and file creation time contained in your photos (or similar files), rough personal features, and content. We use this information to provide "person aggregation," "geolocation aggregation," "content tagging," and other custom features built upon these core functionalities.
• Special Category Data (GDPR Article 9) – Important Legal Statement
  SVAKOM does not collect, process, store, infer, or analyze any form of “special category data,” including data revealing sexual behavior, orientation, or intimate activity, as defined under GDPR Article 9.
  All device interaction (e.g., vibration intensity, mode selection, patterns) is:
  • processed locally on the user’s device only ,
  • never transmitted to SVAKOM servers,
  • never used for analytics,
  • never logged in raw or aggregated form.
  This ensures that no special category data is ever processed by SVAKOM.

We DO NOT collect or store sexual behavior data, vibration patterns, or any data that could infer sexual activity.

Data Protection Officer (DPO) – GDPR Article 37

Due to the sensitive nature of data potentially associated with intimate device
use, SVAKOM designates a Data Protection Officer (DPO):

Data Protection Officer:
Email: dpo@svakom.com

The DPO monitors compliance and serves as the primary contact for supervisory authorities.

You may disable Shenzhen SVAKOM Technology Co., Ltd. Cloud Services, in which case we will not collect information related to photos (or similar files), but features requiring this information will also be unavailable.

You may disable GPS or device location collection, and we will not obtain your current geolocation. You need to use an email address or phone number to create a SVAKOM account to fully access SVAKOM’s services.

We may send notifications via email or system messages, which you can disable on the device or in the app if you do not wish to receive them.

You may stop using our services at any time. When you delete your data, due to system operations and ongoing backup and archiving, residual copies on the server may take some time to be removed.

We may also collect:

• Non-identifiable data:When you interact with the company through the service, we may receive and store certain non-identifiable personal information. This information is passively collected using various technologies and cannot currently identify you. The company may store this information on its own or in databases maintained by its affiliates, agents, or service providers. The service may use this information combined with other data to track, for example, total visitors to our services, page-specific visitor numbers, and domain names of visitors' network service providers. No personal data is involved in this process.
• Aggregated personal data:To better understand and serve users, the company may analyze customer demographics, interests, and behaviors based on personal data provided and other information. This research may be aggregated, and the company may share aggregated data with affiliates, agents, and business partners. Aggregated information cannot identify you. The company may also disclose aggregated user statistics to introduce services to current and potential business partners or for other legitimate purposes.
• Technical Data (including IP Addresses): To ensure the security of the App and analyze operational performance, we process device identifiers and IP addresses. However, this data is primarily used to derive rough geolocation (e.g., country/region level) for localized services and is processed with strict security measures.

We collect location data only when:

• You enable background location access in the app settings.
• You use Bluetooth control features.

We guarantee:

• We protect your data using technical measures such as encryption.
• Without your consent, we do not share or use your data for any purpose.
• We only collect necessary data and regularly clean outdated information.
• Minimum-privilege access control
• Regular audits and penetration testing
• Secure TLS communication
• Hashing + salting for passwords

We never store raw device usage patterns or sexual behavior data.

SVAKOM does not collect, process, store, infer, or analyze any form of “special category data,” including data revealing sexual behavior, orientation, or intimate activity, as defined under GDPR Article 9.

User-Generated Content and Public Activities (Including Comments)

We allow you to post content that other users can read (e.g., comments or product reviews). Anyone may read, collect, and use any personal information attached to the content you post. Please read our Terms and Conditions for Posting Comments for more information. We are not required to publish any content you submit. If the law requires us to remove, delete, or edit your personal information, we will comply to the extent required.

Public Information

When you use SVAKOM products or services, we assume that you have permitted and agreed to these terms by default. Therefore, we will not share your information with any third party, nor sell, rent, or otherwise distribute it, except in the following circumstances:

• Explicit consent:You have clearly consented to our sharing of information.
• Necessary reasons: For example, completing payment transactions or purchasing SVAKOM products, we may share information with third-party service providers involved in such actions. These service providers are authorized to use your personal information only to the extent necessary to provide their services.
• Legal protection: To protect the legal rights of the company, partners, or customers, we may disclose your personal information within the limits permitted by law.
• Compliance with law and public interest: To comply with local laws, safeguard public interests, or for other legally necessary reasons to protect others’ rights, we may carefully disclose personal information within the legal framework.
• Mergers, acquisitions, or similar transactions:Your personal information may be considered an asset of the transaction. In such cases, we will inform you in advance regarding the transfer or deletion of your personal information.

In addition, when using our services, we reserve the right to allow third-party analytics providers and advertising partners to collect personally identifiable information about your online activities across different websites, as described in this Privacy Policy. We cooperate with third parties to provide certain support services to our users, while attempting to limit how these third parties use the information collected from you or provided by us. Any processing or storage of information by such third parties, including information they may collect directly from you, is not governed by this Privacy Policy. You should review the privacy and cookie policies of these third parties and consent separately if required.

Like many businesses, the company sometimes contracts with other entities to perform certain business-related functions, such as mailing information, maintaining databases, and processing payments. When we engage another entity to perform these functions, we only provide the information necessary for that entity to fulfill its specific role.

Legal Requirements

If the law requires disclosure of your personal data, or if we reasonably believe such action is necessary to:

• 1. Comply with legal obligations;
• 2. Protect and defend the rights or property of the company;

Act in urgent situations to protect the personal safety of service users or the public; or prevent legal liability, we may disclose your personal data.

Data Security

Please understand that due to limitations of Internet technology, even with the use of all advanced security techniques, we cannot guarantee 100% security of information. Therefore, you should acknowledge and accept the risks of transmitting information to us.

Once your data is stored on our servers, we ensure its security through policy, physical, and logical measures. Data stored on your computer or other electronic devices depends largely on the security of your device. We recommend that you take necessary measures to protect your local data.

1. How long we store your data

We will retain your personal information for the period necessary to achieve the purposes outlined in this Privacy Policy and in compliance with applicable legal and regulatory retention periods and statutes of limitations. The retention period depends on the nature of the information, reasons for collection and processing, legal or operational retention requirements, and other obligations.

• Technical logs: 90 days (Crashlytics default)
• Usage analytics: 12 months (if consented)
• Account data: deleted after account deletion request
• Cloud-stored content: deleted instantly upon user request

Backup systems may retain encrypted copies for a short transitional period.

If you wish to deactivate your registered profile or delete personal information you have provided to us, please follow the relevant instructions in your account, or contact us by email: svakom688@163.com.

Please note that any content you send to other recipients is outside the scope of personal information collected under this Privacy Policy. The company explicitly disclaims any obligations or liabilities arising from third parties (including recipients) obtaining, storing, or using user information.

2. Minors should not submit personal information

The company does not knowingly collect personal data from individuals under 18. If you are under 18, please do not use the services or submit any personal data through the services. We encourage parents and legal guardians to monitor their children’s internet usage and instruct children under 18 not to provide personal data to the services. If you have reason to believe that someone under 18 has provided personal data through the service, please contact us at svakom688@163.com, and we will make efforts to remove such information from our database.

3. How We Protect Your Information

The company takes commercially reasonable steps to protect personal data provided through the services from loss, misuse, unauthorized access, disclosure, alteration, or destruction. The company implements security measures for any personal or account data (e.g., email addresses, phone numbers) stored. Data that identifies accounts or users collected through the service may be encrypted and stored in our internal or third-party hosted databases. The company does not sell or transfer account-identifiable data to third parties.

Unless you provide your account login credentials, no one can access all data associated with your account or profile. Please note that internet or email transmission and data storage are not completely secure or error-free, so information sent via the service may still be accessed, disclosed, or altered. Email sent to and from servers may be particularly insecure. Therefore, you should exercise caution when sending information to us.

Payment Processing: All product and service payments are handled by third-party providers. The company strives to use third-party companies that implement proper protection for private information. However, we do not control these companies and, therefore, assume no responsibility or liability for their processes or security measures.

4. GDPR Rights Regarding Your Personal Data

If you are located in the European Union, you have the following rights under the GDPR regarding how our company uses your personal data:

4.1 Right to Withdraw Consent

You may notify the company that you no longer wish us to process or use your personal data. Contact: svakom688@163.com.

4.2 Right to Data Portability

You have the right to obtain a copy of your personal data stored and processed by the company and to instruct the company to transfer your personal data to another controller in a structured, commonly used, and machine-readable format. Contact: svakom688@163.com.

4.3 Right to Erasure / Right to be Forgotten

You have the right to request deletion of any personal data the company stores or processes. However, while we can delete personal data from our current records, copies of your data may remain in the company’s inactive or archived records and will be deleted according to the company’s document management policies. In some cases, if required by law, your personal data may continue to be stored in archived records of transactions or activities.

4.4 Right to Restrict Processing

You may request that the company restrict the processing of your personal data. In such cases, your ability to navigate or use the service may be affected.

4.5 Exercising Your Rights

To exercise any of the rights above, contact the company at: svakom688@163.com. Exercising these rights may affect your ability to use the services, as certain operations and functions require the use of your personal data.

4.6 Right of Access

You have the right to obtain confirmation from us on whether your personal data is being processed. In such cases, you have the right to access your personal data and additional supplementary information. Contact: svakom688@163.com.

4.7 Right Not to Be Discriminated Against

We will not deny you goods or services, provide lower quality products or services, or charge different prices for exercising these rights.

5. Viewing and Editing Your Information

You may review and consent to the personal information we collect and store while you use the services. Upon receipt of a written request, we will delete or modify any personal data you assert is inaccurate in accordance with your request and applicable law. However, information about you may come from multiple sources, so any inaccuracies are not necessarily the company’s fault.

6. International Data Transfers

Data may be processed in China, the United States, or other locations used by our cloud service providers.
To comply with GDPR Chapter V:

• Standard Contractual Clauses (SCCs) are implemented,
• Data is encrypted in transit and at rest,
• Access is strictly limited to authorized personnel.

We conduct Transfer Impact Assessments (TIAs) where required.

Terms Updates

By continuing to use our products or services, you are deemed to accept the terms valid at that time. For legal compliance or changes in our business operations, the company reserves the right to modify, change, or otherwise update this Privacy Policy when deemed necessary and appropriate.

If our data processing model and/or this Privacy Policy undergoes significant changes, we will make best efforts to notify you, for example, by posting a notice on this website or sending you an email, and by updating the “Last Updated” date at the top of this Privacy Policy.

After we release any revised Privacy Policy, your continued use of the services constitutes confirmation of your acceptance of the revised Privacy Policy. If you do not agree with the updated Privacy Policy, do not use our services.

For privacy concerns, rights requests, or legal inquiries:

Shenzhen SVAKOM Technology Co., Ltd.

Email: privacy@svakom.com

DPO Email: dpo@svakom.com

EU Representative: eurenp@svakom.com