Avagram Privacy Policy

Zoka Technology Limited and its affiliates (collectively, “we” or “us”), as the operator of Avagram (hereinafter referred to as the “Service”), strictly comply with applicable laws and regulations to protect your personal information and privacy security.

This Avagram Privacy Policy (the “Policy”) is intended to explain how we collect, use, share, store, and protect your personal information when you use the Avagram application (hereinafter referred to as the “Product” or “Service”), as well as how you can manage your personal information.

Please read and understand this Policy carefully before using our Services so that you can make appropriate choices and decisions.

Introduction

This Policy explains how we process your personal information in different scenarios when you use our Product. We will strictly comply with applicable laws and regulations and, in certain circumstances, obtain your separate consent.

In addition to this Policy, we may also provide you with information regarding the purposes, scope, and methods of collecting and using your personal information through immediate notifications (including pop-ups, page prompts, etc.), feature update descriptions, and other methods in specific scenarios. Such immediate notifications, feature update descriptions, and related notices constitute part of this Policy and have the same legal effect as this Policy.

You may refuse our processing of certain personal information; however, this may result in our inability to provide you with the corresponding services. We will provide detailed explanations regarding such matters in this Policy.

If you have any questions, comments, or suggestions regarding this Policy, you may contact us through the contact information provided at the end of this Policy.

This Policy will help you understand the following:

How we collect and use your personal information
How we share, transfer, and publicly disclose your personal information
How we store and protect your personal information
How you can manage your personal information
Protection of minors
Updates and revisions to this Policy
Contact Us

We highly value the protection of your personal information and are committed to maintaining your trust in us. We promise to adopt appropriate security measures to protect your personal information in accordance with generally accepted industry security standards.

This Policy applies throughout your entire experience of downloading, installing, launching, browsing, using, and deleting your account (collectively, “using”) Avagram. The Avagram application is subject to this Avagram Privacy Policy, and we guarantee that the collection and use of your personal information will not exceed the scope specified in this Avagram Privacy Policy.

How We Collect and Use Your Personal Information

Registering, Logging In, and Using an Avagram Account

Registration and Login
When you register for, log in to, and use this Product and related services, we recommend that you register an Avagram account so that you can make full use of all features and functions provided by the Product and Services.

If you create an Avagram account, you are required to provide your email address to create the account. You may also complete your profile information, such as setting a nickname and profile picture. The nickname and profile picture you set will be publicly displayed.

Third-Party Account Login
Alternatively, you may use a third-party platform account to log in. If you choose to log in using a third-party platform account, you authorize Avagram to obtain your publicly available information from that third-party platform (including your profile picture, nickname, and other information you have authorized).

When creating an account through a third-party social platform, your platform nickname and profile picture may be automatically synchronized to this App. Such information may be publicly displayed in certain interactive scenarios. This type of information is non-essential personal information. If you refuse to provide such information, it will not affect your normal use of the App’s services.

During your use of this Product and the login process, we may collect your device information, including device platform, device manufacturer, device brand, device model, and operating system version. The term “device information” as used in this Policy refers to the information described above.

We may collect the above device information at a certain frequency as necessary to fulfill login authentication requirements. Such information is necessary for providing the Services. After collection, this information will be de-identified and will not be used to identify any specific user.

Providing Security Protection

To protect the security of your account, network, operations, and systems, and to prevent phishing website fraud and Trojan viruses, we may collect your device information at a certain frequency as necessary to meet security protection requirements during your use of this Product.

Such information may include device model, operating system version, device identification information (including immutable device identifiers) (referring to a string of characters embedded into a device by the device manufacturer to identify the device; the term “device identification information” as used in this Policy refers to the information described above), hardware serial number, MAC address, network operator and network type, network type, login IP address, and operation log information.

For Android devices, we may collect Android ID, OAID, and GAID.
For iOS devices, we may collect IDFA and IDFV.

Please note: When you switch the App to run in the background, due to limitations of the device model and operating system mechanisms, the information collection activities initiated while you were previously using App features may not stop immediately, which may result in brief background collection. If the App remains completely inactive in the background, no information will be collected.

Providing Other Related Product Features and/or Services

To provide the following product features and/or services, we may need to collect corresponding personal information from you. If you refuse to provide such information, you may not be able to use certain specific services.

Customer Service
When you submit a complaint, make an inquiry, or file an appeal with Avagram, we may need you to provide personal information such as your user ID, email address, or other valid contact information in order to contact you conveniently or assist you in resolving issues. If you refuse to provide such information, we may not be able to contact you in a timely manner or provide you with feedback regarding the handling results.
Content Delivery Optimization
We may also collect information about your device type and device status to help provide you with content that has already been cached locally when you are in an environment without a network connection or with a weak network connection. This helps reduce your data consumption during content delivery.
Providing Region-Specific Versions
We may access your SIM card status to determine your approximate region and provide you with an App version adapted to your language preferences and usage habits in your region.
Maintaining Product Security and Troubleshooting
To maintain the normal operation of our Services, protect your account security, troubleshoot product issues, and improve and optimize our Services, we may collect your EXIF data, device identification information, device model information, login IP address, operation log information, device brand, system version, CPU information, and running processes.

Such information is necessary for providing the Services. After collection, this information will be de-identified and will not be used to identify any specific user.

Account Security Protection
When you use functions such as password changes, security verification, or account appeals, and abnormal behavior is detected during such operations, we may require you to provide valid identity information to ensure the security of these operations.
AI Cloud Processing Features
When you use cloud processing features (such as AI Enhancement, AI Expand, AI Motion Imitation, and other AI image generation, image editing, and video generation features), we may collect non-identifiable image characteristics (such as landscapes, food, portraits, etc.) and perform image feature analysis through algorithms to help you achieve better cloud processing results.

To use these features, you need to upload your image information to our backend servers for processing and generation. The generated content will be returned to your device. The upload and processing of such information are necessary to provide this feature.

In accordance with applicable laws and regulations, we will implement strict encryption measures during the transmission and storage of your information to ensure its security. Such information will only be used to provide this feature. We only provide image processing services, and after the service is completed, the system will automatically delete the above information without retaining it.

AI Content Generation Features
When you use AI-related features (such as AI Enhancement, AI Expand, AI Motion Imitation, and other AI image generation, image editing, and video generation features), we need to upload your original images to our servers so that artificial intelligence models can generate new content for you, which can then be saved locally on your device.

The upload and processing of such information are necessary to provide this feature. If you refuse to provide such information, you will not be able to use this feature.

If you agree, we will implement strict encryption measures for your uploaded content during transmission and storage in accordance with applicable laws and regulations to ensure content security. Such content will only be used to provide this feature. We only provide image processing services. After the service is completed, the system will automatically delete the above content without retaining it.

Message Notifications and Content Recommendations

Message Notification Push
We may send one or more types of notifications to the App, including product promotions, subscription renewal reminders, task reminders, and other notifications.

If you do not wish to receive such notifications, you can disable them through the following path:
My Page → Tap Settings in the upper-right corner → Notifications → Turn off “Allow Notifications”

Personalized Content Recommendations and Advertising
To improve your user experience, recommend community content that may interest you, and match your needs in material tools and advertising recommendations, thereby reducing the cost of filtering through large amounts of online content, we may collect device identifiers (Android: Android ID, OAID, GAID; iOS: IDFA, IDFV), IP address, and system language for personalized advertising recommendations.

We May Obtain Your Personal Information Indirectly from Third Parties

When you use a third-party account (such as Facebook, Twitter, Apple Account, Google Account, etc.) to log in to Avagram, you may choose to authorize Avagram, in compliance with applicable laws and regulations, to access and obtain publicly available information that you have registered, disclosed, or recorded on such third-party platforms (including your nickname and profile picture).
Avagram requests your authorization to obtain the above information from third parties in order to remember your identity as an Avagram user and provide you with better products and/or services. We will only collect and use your personal information within the scope authorized and consented to by you.

For the personal information we obtain indirectly from third parties as described above, we will only collect and use such information within the scope of your authorization and consent.

Use of Your Personal Information by Avagram Under Other Special Circumstances

If you believe that your rights have been infringed, you may file a complaint or report through our infringement complaint process or by contacting us through the contact information provided by us.

During this process, we may require you to provide valid personal identity information to verify the authenticity of your complaint or report.

Meanwhile, if you apply to remove the abnormal status of your Avagram account, we may also require you to provide valid identity information for verification purposes.

Such information constitutes sensitive personal information. We will adopt strict confidentiality measures to protect such information and will not share it with any third party.

Circumstances Where We May Process Personal Information Without Authorization as Permitted by Law

According to applicable laws, regulations, and national standards, we may process your personal information without obtaining your authorization or consent in the following circumstances:

a) Where processing is necessary for the conclusion or performance of a contract to which you are a party;

b) Where processing is necessary for us to fulfill our statutory responsibilities or legal obligations;

c) Where processing is necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;

d) Where processing is conducted within a reasonable scope for purposes such as news reporting and public opinion supervision in the public interest;

e) Where processing is conducted within a reasonable scope in accordance with applicable laws regarding personal information that you have voluntarily disclosed or that has otherwise been lawfully made public;

f) Other circumstances provided for by laws and administrative regulations.

How We Share, Transfer, and Publicly Disclose Your Personal Information

Information Sharing

Entrusted Processing

For scenarios involving entrusted processing of personal information, we will enter into relevant processing agreements with entrusted partners in accordance with applicable laws and regulations, and supervise their activities involving the use of personal information.

Joint Processing

For scenarios involving joint processing of personal information, we will enter into relevant agreements with our partners in accordance with applicable laws and regulations, specifying each party’s respective rights and obligations, to ensure compliance with legal requirements and protection of data security during the processing of relevant personal information.

Sharing Scenarios

We will not share your personal information with any company, organization, or individual, except in the following circumstances:

a) Where processing is necessary for the conclusion or performance of a contract to which you are a party;

b) Where processing is necessary for us to fulfill our statutory responsibilities or legal obligations;

c) Where processing is necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;

d) Where processing is conducted within a reasonable scope for purposes such as news reporting and public opinion supervision in the public interest;

f) Other circumstances provided for by laws and administrative regulations.

A. Sharing with Our Affiliates

The products and/or services we provide to you generally cannot be completed independently. Therefore, your personal information may be shared with our affiliated companies of Zoka Technology Limited.

We will only share necessary personal information for the purpose of providing you with relevant features and services of this Product, and such sharing will be subject to the purposes stated in this Policy.

If any affiliate company intends to change the purpose of processing your personal information, it will obtain your consent again in accordance with applicable laws and regulations.

B. Sharing Personal Information with Partners

Only for the purposes stated in this Policy, certain services may be provided by authorized partners, such as technical support services and product analytics services.

We may share certain personal information with our partners to ensure the successful delivery of services to you and to help us provide better customer service and user experience.

We will only provide your personal information based on the principles of legality, legitimacy, necessity, and good faith, and we will only share personal information necessary for providing the relevant services.

At the same time, we will enter into strict confidentiality agreements with companies, organizations, and individuals receiving personal information, or require them to process personal information in accordance with this Avagram Privacy Policy and other applicable confidentiality and security measures.

Our partners are not authorized to use the personal information they receive for any other purposes.

Our partners include the following types:

For example: Technical Support Partners
Partners providing technical support services may collect relevant personal information from our users to provide the services they support.

In addition, partners providing analytics services may collect a limited amount of personal information from our users that has been de-identified in accordance with their information security requirements. This helps us analyze user distribution, evaluate product promotion effectiveness, and improve our services.

Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

1) We will transfer your personal information to other parties only after obtaining your explicit authorization and consent;

2) Where such transfer is required to comply with applicable laws and regulations, legal procedures, mandatory requirements from government authorities, or judicial decisions;

3) In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of personal information, we will require the new entity holding your personal information to continue to be bound by this Avagram Privacy Policy.

If the methods of collection, processing, or purposes of use of personal information specified in this Policy are changed, we will require the relevant company, organization, or other entity to obtain your authorization and consent again.

Public Disclosure

We will only collect or publicly disclose your personal information in the following circumstances:

1) After obtaining your separate consent;

2) Where disclosure is required by applicable laws and regulations, or by mandatory requirements from judicial authorities or administrative authorities, we may disclose your personal information as required.

How We Store and Protect Your Personal Information

Storage of Information

Storage Location

In accordance with applicable laws and regulations, we will store personal information collected from users within the relevant domestic territory.

Storage Period

We will only retain your personal information for the period necessary to achieve the purposes described in this Policy and within the retention period required by applicable laws and administrative regulations.

a) Images uploaded by users to our servers are protected by encryption protocols throughout transmission and storage and are only used for AI image generation. User-generated images will be stored in the corresponding data centers in accordance with applicable regulations (users may view their historical generation records after changing devices). After a user actively deletes such content, the system will automatically remove the relevant data within 24 hours.

b) User-created works will be retained for a maximum of 30 days. If published as a post, they will be permanently stored (user-published posts will only be visible to others after passing review).

We determine the retention period of personal information primarily based on the following criteria, and the longest applicable period shall prevail:

a) The necessary period required to complete services related to you;

b) The period necessary to respond to your potential inquiries or complaints;

c) The period necessary to ensure the security and quality of the services we provide to you;

d) Whether you have agreed to a longer retention period;

e) Whether there are other specific agreements or provisions regarding retention periods under applicable laws and regulations.

For personal information that exceeds the retention period, we will promptly delete it or anonymize it.

How We Protect the Security of Your Information

Security Technical Measures and Management Systems

We have adopted security protection measures that comply with industry standards to protect the personal information you provide and prevent data from unauthorized access, public disclosure, use, modification, damage, or loss.

We take all reasonably practicable measures to protect your personal information through continuously improving technologies. For example:

Data exchanged between your browser and the “Service” is protected through SSL encryption;
We provide HTTPS secure access for the supporting web services of our Product;
We use encryption technologies to ensure data confidentiality;
We use trusted protection mechanisms to prevent malicious attacks on data;
We implement access control mechanisms to ensure that only authorized personnel can access personal information and require them to strictly comply with confidentiality obligations;
We provide security and privacy protection training programs to enhance employees’ awareness of the importance of protecting personal information.

Response to Personal Information Security Incidents

If our physical, technical, or management protection measures are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information, and causing damage to your legitimate rights and interests, we will promptly activate our emergency response plan and take reasonable and necessary measures to minimize the impact on you.

If a personal information security incident unfortunately occurs, we will notify you in a timely manner in accordance with applicable laws and regulations, including:

The basic circumstances of the security incident and its possible impact;
The measures we have taken or will take;
Recommendations for you to independently prevent and reduce risks;
Remedial measures available to you.

We will promptly inform you of relevant incident details through SMS, email, postal mail, telephone calls, push notifications, and other reasonable channels. If it is difficult to notify each personal information subject individually, we will publish an announcement through reasonable and effective means.

At the same time, we will actively report the handling of personal information security incidents to regulatory authorities as required.

Security Reminders

The Internet is not an absolutely secure environment. Please properly protect your personal information and only provide it to others when necessary to avoid information theft or potential telecommunications and online fraud.

Please note that emails, instant messaging services, and other communication methods with users are not encrypted. We strongly recommend that you do not send personal information through such channels.

Please use a strong and complex password to help us maintain the security of your account.

The online environment cannot be guaranteed to be 100% secure. We will do our best to ensure or guarantee the security of any information you send to us.

How You Can Manage Your Personal Information

In accordance with applicable laws, regulations, and standards, during your use of Avagram and its services, we provide you with corresponding management options within the Product design, allowing you to conveniently access, copy, correct, and delete your personal information, while also ensuring your rights to withdraw consent for personal information processing and to delete your account. The available paths are as follows:

Accessing, Copying, Correcting, and Deleting Your Personal Information

Accessing and Correcting Personal Information
You can access and correct personal information such as your nickname, gender, and profile picture in your Avagram account through the following path:

My Page → Tap Settings in the upper-right corner → Profile

Withdrawing Your Authorization
If you wish to withdraw your consent for us to collect, use, or disclose your personal information, or if you wish us to correct, update, or delete your personal information, you may contact us through the contact information provided in this Policy.

We will process your request within a reasonable period after receiving your email or registered mail and will stop collecting, using, and disclosing your personal information accordingly.

However, please understand and agree that withdrawing certain authorizations may result in the unavailability of related Product features. We may no longer be able to provide specific features and/or services corresponding to the withdrawn consent or authorization. Your decision to withdraw authorization will not affect the personal information processing activities that were conducted based on your authorization before the withdrawal.

Deleting Your Personal Information
You may request deletion of your personal information in the following circumstances:

A. The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose;

B. We stop providing products or services, or the retention period has expired;

C. You withdraw your consent;

D. We process your personal information in violation of laws, administrative regulations, or agreements;

E. Other circumstances provided by laws and administrative regulations.

Deleting Your App Account

You can delete your Avagram account through the following path:

My Page → Tap Settings in the upper-right corner → Delete Account

After submitting a deletion request, if you do not log in again within 3 days, the system will proceed with account deletion.

Account deletion is irreversible. After deletion, your account cannot be logged in to or recovered, and all information associated with the account within the App will be permanently removed. Please proceed with caution.

Once your deletion request has been processed, we will also make reasonable efforts to notify entities that obtained your personal information from Zoka Technology Limited and require them to delete the corresponding information promptly, unless otherwise required by applicable laws and regulations or such entities have obtained your independent authorization.

After you delete information from our services, we may not immediately remove the corresponding information from our backup systems. We will delete such information or anonymize it when backup systems are updated.

Response to Your Requests for Management of Personal Information

To ensure security, when you exercise the above rights, you may be required to submit a written request or provide other proof of your identity. We will process your request only after verifying your identity.

Under normal circumstances, we will respond to your request within 15 days.

We generally do not charge fees for reasonable requests. However, for repeated requests or requests that exceed reasonable limits, we may charge a reasonable fee at our discretion.

We may refuse requests that involve information not directly associated with your identity, unreasonable repeated requests, requests requiring excessive technical efforts (such as developing a new system or fundamentally changing existing practices), requests that may create risks to the legitimate rights and interests of others, or requests that are impractical to fulfill.

In the following circumstances, as required by applicable laws and regulations, we may be unable to respond to your request:

1) The request is related to national security or defense security;

2) The request is related to public security, public health, or significant public interests;

3) The request is related to criminal investigations, prosecutions, trials, or enforcement of judgments;

4) There is sufficient evidence indicating that the personal information subject has acted with malicious intent or abused their rights;

5) Responding to your request would result in serious harm to your or other individuals’ or organizations’ legitimate rights and interests;

6) The request involves trade secrets.

Protection of Minors

1. Due to the nature of this Product, we have not developed features to identify your actual age. Our Product is primarily intended for adults.

Without the consent of a parent or guardian, minors should not create their own personal information accounts. If you are under the age of 18, please read this Policy carefully with the assistance of your guardian before using our Products and/or Services, and ensure that you have obtained your guardian’s explicit consent before using our Services.

2. Where we collect personal information from minors who use our Products or Services with the consent of their guardians, we will only process such information when permitted by applicable laws and regulations, with the explicit consent of the guardian, or when necessary for the protection of minors.

3. If your guardian does not agree with your use of our Services or the provision of personal information to us in accordance with this Policy, please immediately stop using our Services and notify us promptly.

4. If you are a parent or guardian and have any questions regarding the use of our Products/Services by a child under your guardianship or the user information provided by such child to us, please contact us promptly.

5. If we discover that we have collected personal information from a minor without obtaining the consent of their guardian, we will take reasonable steps to delete such minor’s personal information as soon as possible.

Updates and Revisions to This Policy

This Policy may be updated from time to time due to adjustments to our business operations, service updates, or changes in applicable laws, regulations, or policies.

Without your explicit consent, we will not reduce your rights that you are entitled to under the current version of this Policy.

After this Policy is updated, we will release the updated version and, before the updated terms take effect, notify you of the changes through private messages, notifications, announcements, pop-up windows, or other appropriate methods, so that you can stay informed of the latest version of this Policy.

If the changes to this Policy involve modifications to the purposes of personal information processing, methods of processing, or types of personal information processed, we will obtain your consent again in accordance with applicable laws and regulations.

If you do not agree with the revised Avagram Privacy Policy, you have the right and should immediately stop using our Products and/or Services.

If you have any questions or concerns regarding updates to this Policy, please contact us through the contact information provided in this Policy.

Contact Us

1. Our company, Zoka Technology Limited, is the sole operator of Avagram. Our registered address is: Room 12, 20/F, Hoi King Commercial Centre, 2–16 Fa Yuen Street, Mong Kok, Hong Kong. The developer of this Product is Zoka Technology Limited.

2. If you have any questions, comments, suggestions, or complaints regarding the content of this Policy, you may contact us through the following method:

Please send an email to our Personal Information Protection Officer at: service@zokaai.com

We will review your questions or suggestions as soon as possible and respond within fifteen (15) days after verifying your user identity.