Privacy policy

Last Modified : August 2023

1. introduction

Shantu Technology . ( hereinafter referred to as "we" or "our" ) attaches great importance to your privacy. This Privacy Policy ( "Privacy Policy" ) explains our data protection policy and describes when you install and / or use the " CountCam App" software application ( "App", "Our App" on your mobile device ) ” ) , the types of information we may process.

When we refer to personal data ( or personal information ) , we mean any type of information relating to a natural person, in particular by reference to such data

means a natural person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors relating to his physical, physiological, psychological, economic, cultural or social status.

Our Privacy Policy applies to all users, as well as other users who access this application ( "Users" ) .

For GDPR purposes, we are the data controller unless otherwise stated.

Please read the following Privacy Policy carefully for information about how your personal information may be processed. When you use this application, you acknowledge that you have read, understood and agree to be bound by these terms.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE READ THE FOLLOWING IMPORTANT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) , California residents have the right to request :

the categories of personal information being processed;
the categories of sources from which the personal information was obtained;
Purposes for processing users' personal data;
The third parties with whom we may share your personal information;
Specific personal information that we may have obtained about a specific user, provided the data provided in the request is sufficiently reliable and allows the user to be identified.

Please use the navigation links through this Privacy Policy :

PERSONAL INFORMATION

Note that under the CCPA , personal information does not include de-identified or aggregated consumer information.

SHARING

Please note that all third parties engaged in the processing of user data are service providers and use such information on the basis of an agreement and for commercial purposes.

OPT-OUT OPTIONS

If you do not want us to process your personal information, please contact us by email . In most cases, further operation of the application cannot be maintained without functional data, so it is recommended to delete the application from the device.

If you do not want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out.

REQUESTS

To submit a verifiable consumer request to access, port or delete personal data, please contact us by email . Please include "Your California Confidentiality Rights" in the text of your appeal.

When submitting a verifiable request, you should be prepared to :

Provide sufficient information to allow us to reasonably verify that you are the person or authorized representative from whom we collected the personal information, which may include: name , address, city, state, zip code, and email address. We may use this information to verify your identity by asking you a series of security questions. If you are making a request through an authorized agent acting on you behalf, that authorized agent must provide written confirmation of authorization or a power of attorney signed by you.
Describe your request in detail so we can properly understand, evaluate and respond to it.

We will not be able to respond to your request or provide you with personal information under the following circumstances :

(i)Verify your identity or authority to make the request

(iI)Confirm that the personal information relates to you. We may ask you to provide additional information or documents to verify your identity. We may also perform checks, including checks with third party identity verification services, to verify your identity before taking any action with your personal information. This is considered a safeguard against disclosure of your personal information in the event of false or spammy requests.

We ensure that personal information provided in verifiable consumer requests will only be used to verify the requester's identity or authority to make the request and not for any other purpose. We will retain this information for as long as reasonably necessary for the above purposes and delete it after the purpose is achieved.

to respond to verifiable consumer requests within forty-five (45) days of receipt. If we need more time, we will notify you of the reason and the extension period in writing.

EQUAL RIGHTS

The way we handle your request should not be construed as discriminatory, which means we will not set you a different price or product, or a different level or quality of service, if you choose to exercise your rights. However, in some cases, we may not be able to provide the service if you choose to delete your personal information from our records.

SALE OF DATA

We will not sell any of your personal data to third parties.

2. INFORMATION WE PROCESS

There are several categories of information that can be processed.

FUNCTION INFORMATION

When you use the application, we request and process the following personal information. This information is necessary for the full performance of the contract between you and us. Without this information, it will not be possible to provide the full functionality of the application and perform the requested services.

----Activity information directly related to your use of the application. We may have technical access to your camera or camera roll ( gallery / photo library ) after you have set the relevant settings on your device . This is necessary in order to enable counting functions , analysis of files / photos taken and / or uploaded by you while using the application , and file / photo editing tools available . However, we cannot collect, store or use photos or files contained in your photo roll ( gallery / picture library ) unless you upload such photos or files to the application or otherwise share them.

----Content material ( images, documents, other files, etc. ) to the app that contains personally identifiable and / or confidential information of any type, including but not limited to sensitive data, is strictly prohibited .

----Contact information ( name, email address, and any other content included in the mail ) , you can fill in yourself when contacting us via email, support form. We collect, store and process this information via our cloud storage provider ( Amazon Inc. ) . We use this information to efficiently respond to your inquiries, fulfill your requests, send you the communications you have requested and perform requested services.

Information That Is Processed Automatically

On the basis of your consent, we use third-party automatic data processing technologies to analyze certain information sent by your device through our application (ldentity For Advertisers for iOS devices/ Advertising lD or Android ID foiAndroid devices) . Some integrated advertising or analytics tools ( see section IV for a list of them ) initiate automated processing of your personal data, including profiling, which refers to any form of personal data used to assess certain personal aspects relating to you Data are processed automatically, in particular to analyze or predict aspects related to your personal preferences, interests, behaviour, location or movement ( see list of data described below ) . Once you allow our application to track your activity, the processing of the information by means of automatic data processing technologies will automatically begin. You may withdraw your consent at any time - please see opt- out in Section VIII below .

We may process some information about your device and your user behavior based on our legitimate interests. This information falls within the categories of data described in the "Information Processed Automatically" section above, it is generally non-personal information, i.e. it does not allow itself to be directly linked to any specific individual and we only have access to it in aggregated form. We use this information to improve our apps and provide the best experience for our users.

Details of the device. When you access our app using a mobile device (tablet/phone/smartwatch), we report some details of your device, including a "device identifier". A device identifier is a small data file or similar data structure stored on or associated with your mobile device that uniquely identifies your mobile device (but not your personality ) . Device identifiers enable common reporting by third parties
What data can be processed :
Information about the device itself : device type, operating system type and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
Information about Internet connection : mobile operator, network provider, network type, IP address, timestamp and session duration, speed, browser.
Location-related information : IP address, country code / region / state / city associated with your SIM card or device , language setting, time zone.
Other device identifiers : such as user identifiers ( if set by the app developer ) .
Information about the application. Our application's name, API key ( app identifier ) , version, attributes can be reported for automatic processing and analysis. Some services also record a list of applications and processes installed or running on your device.
Cookies and Similar Technologies. When you use the App, cookies and similar technologies ( pixels, web beacons, scripts ) may be used . A cookie is a text file containing small amounts of information that is downloaded to your device when you visit an application. This text file is sent back to the server each time you use the application. This allows us to operate the application more efficiently. For example, we will know how many users visited a particular area or function within our application and which links they clicked. We use this aggregated information to understand and optimize how our Apps are used, improve our marketing efforts, and deliver content and features that are of interest to you. We may ask other partners to provide services to the application, and these services may use cookies or similar technologies.
Log file information. Log file information is reported automatically with each request to access the app, and can also be provided when the app is installed on the device. When you use our app, the analytics tool automatically records certain log file information, including the time and date you start and stop using the app, and how you interact with the app.
Application events. When you use our app, analytics tools automatically record information about your activities ( tutorial steps, upgrades, payments, in-app purchases, custom events, progress events, ways to limit user data processing ) .
affairs. We may obtain technical information about your in-app purchases, namely information contained in Apple receipt files.

Information automatically provided to advertising or analytics tools is generally not under our control and we cannot be responsible for the processing of such information. Please note that some services involve personal data analysis and may obtain information related to your personality and / or your device through the use of technologies for which we are not responsible . If your user ID is associated with your Facebook account, Facebook may associate your device information with categorized data already recorded in its database ( for example : your age, gender, or other demographic data ) . We do not control, monitor or guarantee how third parties process your personal data that may be collected through their own means ( other than through our application ) . Any information requests regarding the disclosure of your personal information should be directed to such third parties ( see Section IV ) .

Payment Information

Our e-commerce provider ( Apple / Google ) is responsible for billing, processing and charging of in-app purchases, handling your personal information and keeping it absolutely secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information. You may access applicable "in-app" purchase rules and policies directly from the App Store.

3.PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to continuously improve our app and provide you with new experiences. As part of this mission, we will use your information for the following purposes :

To provide our services. We use functional information and automatically processed information to provide you with all requested services.
improve, test and monitor the effectiveness of our applications. We use automatically processed information to better understand user behavior and trends, to detect potential outages and technical issues, and to operate, secure, improve and optimize our applications.
To provide you with interest-based ( behavioral ) advertising or other targeted content.We may use automatically processed information for marketing purposes ( to display advertisements that may be of interest to you based on your preferences ) . We provide you with personalized content and information, which may include online advertising or other forms of marketing.
Communicate with you. We use the contact information we have to communicate with you through newsletters, i.e. to send you marketing notices, to receive your feedback on your experience with our apps, and to keep you informed about our policies and terms. We will also use your information to respond to you when you contact us.
To prevent fraud and spam, and to enforce the law.We really want our app to be free from spam and scam content and make you feel safe and free. We may use your information to prevent, detect and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use.

If any new purposes of processing your personal data arise, we will notify you by making corresponding changes to this Privacy Policy and we will start processing information for other purposes.

4.SHARING YOUR INFORMATION

We will only share your information with third parties as described in this Privacy Policy. We adhere to the Digital Advertising Alliance's self-regulatory principles for the mobile environment.

Please note that when integrating external services, we have selected third parties who are able to ensure that they apply all necessary technical and organizational measures to protect users' personal data. However, we cannot guarantee the security of any information transmitted from us to any such third parties. We are not liable for accidental loss of or unauthorized access to your personal data due to the fault of third parties.
We do not rent or sell your personal data to any third parties, but we may share information from tools such as cookies , log files, device identifiers, and location data with third-party organizations that provide automatic data processing technologies for the app. We do not control or influence these third parties' tracking technologies or how they are used.

certain information, such as cookie data , with third-party advertising partners . This information allows third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of greatest interest to you. We may engage the following third-party service providers in order to provide us with the necessary infrastructure to deliver and improve our services :

Entity Name Services Performed Entity Location Link to Privacy Policy

Entity Name	Services Performed	Entity Location	Link to Privacy Policy
umeng	analysis service provide	China	https://developer.umeng.com/docs/
bugly	analysis service provider	China	https://bugly.qq.com/docs/user-guide/instruction-manual-privacy/?v=1.0.0
GooglePlay	login service provider	U.S.A	https://developers.google.cn/android/guides/overview?hl= en
Facebook Login	login service provider	U.S.A	https://developers.facebook.com/docs/facebook-login/

If you would like to learn more about the Services and privacy options , including opting out , please refer to the appropriate website and privacy policy.

Our Apps may contain links to third-party websites / services, or you may access the Apps from third-party websites. We are not responsible for the privacy practices of those third-party sites or services linked to or from our App, including the information or content contained therein.

We may disclose your personal information if required for objective reasons, public interest or other unforeseen circumstances :

- as required by law ;

- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request ;

- If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we will notify you of any change in ownership or use of your personal information, as well as any choices you have regarding your personal information, through a prominent notice on the app.

5.INTERNATIONAL DATA TRANSFER

We work across borders and provide our applications to users worldwide.

We and third-party organizations that provide automatic data processing technology for the App or our third-party advertising partners may transfer automatically processed information across borders, from the country or jurisdiction in which you are located to other countries or jurisdictions around the world district.

If you are located in the European Union or other jurisdictions where the laws governing data processing may differ from those of the United States, please note that we may transfer information, including Personal Information , to countries and jurisdictions that do not have the same data protection laws as your jurisdiction district.

This means that your personal information may be transferred to a third country, a region within that third country or to one or more designated authorities, or to data protection and confidentiality regulations which may not provide the same level of personal data as in your country international organization for protection.

We attempt to ensure that recipients of any personal data provide appropriate protections for the personal data received in accordance with current laws protecting such information. By using the App, you agree that we may transfer your personal data to any third country, a region or one or more designated authorities within that third country, or to an international organization.

For data storage purposes, we turn to the services of hosting organizations. We take your privacy very seriously and therefore, where possible, we encrypt your personal data before sending it to a hosting organization for storage. Note that we only work with those hosting organizations that pass our security and reliability checks.

6.HOW LONG WE USE YOUR PERSONAL DATA

Generally, we retain your personal information for as long as is necessary to perform the functional services of the app and to comply with our legal obligations. If you no longer want us to use your information that we have actually accessed and stored, you can ask us to delete your personal information and close your account.

However, some data may still be stored for a period of time ( but not for more than the time required by the purpose ) .

7.EXERCISING YOUR RIGHTS

Applicable data protection laws give you certain rights with respect to personal information. You have the following choices regarding the personal information collected about you :

Data Access and Portability. You may request a copy of your personal information.
Change or correct data. If you are unable to update the data yourself through your account, you have the right to request that your data be corrected, altered, updated or corrected.
Data Retention and Deletion. User data will generally be retained as long as your user profile exists, or when it is necessary to provide related services. However, the exact retention time may vary depending on the context of the processing being performed. You have the right to request erasure of all or some of your personal data.
Processing Limits. In certain circumstances, you may have the right to limit how your personal information is used.

To exercise any of the above rights, you can contact us by email . Please keep in mind that we only ensure the above rights with respect to the information we actually access and store.

When your personal information is processed automatically, you can object to this processing in certain circumstances. If your personal information is processed for direct marketing purposes, you can request that your data be stopped for these direct marketing purposes. In order to exercise your rights, please contact the third-party services listed in Section IV of this Privacy Policy to find out how you can object to the processing of your data. Most of them are clearly stated on the privacy page, function API or other options.

8. SAFETY

The security of your personal information is very important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after we receive it.

Taking into account the risks involved in processing and the nature of personal information, we take reasonable and appropriate steps to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We implement appropriate technical and organizational measures aimed at effectively implementing data protection principles such as data minimization and integrating necessary safeguards into the processing. We seek to encrypt your personal data using appropriate and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. We do our best to protect your personal data, however, we cannot guarantee its absolute security. If your personal information is compromised due to a breach of security, we will promptly notify you in accordance with applicable law.

If you have any questions about the security of our application, you can contact us by email .

9. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is updated periodically.

Whenever we make changes to this Privacy Policy, we will post those changes in this Privacy Policy and elsewhere as we deem appropriate. We may provide you with other forms of notification of modifications or updates as appropriate.

10. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us by email .