privacyPolicy
Effective Date: December 5, 2025
Fomv, an AI-powered photo frame and photo wall design assistant. Your privacy is our top protection priority.
This Privacy Policy explains how we collect, use, disclose, and protect your information when you use the App. By accessing or using the App, you agree to the collection and use of information in accordance with this policy.
Use of Fomv is restricted to those who agree to our terms; if you do not, please do not access the platform.
I. Our Commitment to Your Privacy
We always take your privacy protection as the core principle of product operation, and handle relevant information in a transparent, prudent and responsible manner. Our specific commitments are as follows:
1. Commitment to Minimal & Purpose-Led Data Collection:
We do NOT collect any personal information (e.g., name, contact details, photos, chat records). The data we collect is non-personal environmental information such as Wi-Fi environment, which is solely for ensuring the App’s stable operation (e.g., optimizing network-dependent AI design preview loading) and has no correlation with your personal identity.
2. Commitment to Transparent Data Usage:
The collected Wi-Fi environment data is used for improving the App’s functional stability and user experience (e.g., adapting to different network conditions to avoid loading failures). We never use such data for commercial purposes like advertising, marketing or data sharing.
3. Commitment to Enhanced Data Security:
We adopt strict security measures for the collected Wi-Fi environment data, including anonymization processing immediately after collection (ensuring it cannot be linked to any individual) and encrypted storage. We also conduct regular security checks to prevent unauthorized access or misuse.
4. Commitment to User Right Protection
You can inquire about the scope and usage of the collected environment data at any time through our official contact channel. If you uninstall the App, all relevant anonymized data associated with your device will be automatically deleted.
5. Commitment to Compliance Assurance
We strictly comply with international and regional data protection regulations such as GDPR and CCPA. We have established a complete privacy protection mechanism and complaint response process to address your privacy concerns promptly and in accordance with the law.
We collect information exclusively to support the stable operation of the App’s core AI design services (including frame matching, layout planning, and style recommendation) and to optimize user experience. We strictly adhere to the principle of minimality and necessity—we do NOT collect any personal data that can identify, relate to, describe, or be associated with a specific natural person. All collected data is non-personal and cannot be used to trace or identify individual users.
2.1 No Collection of Personal Data
To fully protect your privacy, we explicitly refrain from collecting any personal information, including but not limited to:
○ Visual Personal Content: We do not store any photos uploaded or taken within the App for frame pairing, layout testing, or design preview purposes. All such visual content is processed locally on your device and will be completely cleared once you exit the relevant design session (unless you actively choose to save the design draft locally on your device, which is stored only in your device’s local storage and not uploaded to our servers).
○ Identifiable Interaction Content: We do not collect or store chat records generated when you interact with AI characters (e.g., FrameMix, StyleFrame, LayoutPro). Your design needs (such as "recommend a vintage-style frame") are processed in real-time locally or via temporary session connections, and no chat logs are retained after the session ends.
○ Personalized Scene Information: We do not collect or store any room decor details, wall type descriptions, space dimensions, or other scenario-specific information you provide during the design process. This information is only used to generate real-time personalized recommendations and is discarded immediately after the design task is completed.
○ Traditional Personal Identifiers: We never collect names, contact information, email addresses, device IDs, account credentials, or any other data that can directly or indirectly identify individual users.
2.2 Necessarily Collected Non-Personal Data
The only data we collect is non-personal, operational, and environmental information that is essential for ensuring the App’s stable operation and service quality. All collected data is anonymized immediately upon collection to eliminate any potential association with individual users:
2.2.1 Automatically Collected Environmental & Operational Data
○ Wi-Fi Environment Information: We collect basic Wi-Fi network status (e.g., network connection type, signal strength) to optimize the loading speed of AI design previews (such as layout mockups and frame style renderings) and to avoid service interruptions caused by unstable networks. We do not collect Wi-Fi SSIDs, MAC addresses, or other network identifiers that may be associated with your location or device identity.
○ Basic Device & App Operational Data: We collect anonymized device and App runtime information, including Android OS version, App version number, and general device model (e.g., "Android 14", "Fomv v1.2.0", "smartphone"), solely for the purpose of fixing technical bugs, ensuring compatibility with different devices, and updating functional adaptations. No unique device identifiers (such as IMEI, Android ID) are collected.
○ Anonymized Usage Metadata: We collect aggregated, anonymized data about App feature usage—such as the frequency of access to different AI characters (e.g., "LayoutPro is accessed by 45% of users") or average session duration for design functions. This data is used to optimize feature logic (e.g., improving the response speed of AI layout recommendations) and to prioritize function updates based on user behavior. No individual usage traces are recorded.
○ Camera Permission Disclosure:The Fomv App may request access to your device's camera permission solely for the purpose of enabling you to capture photos directly within the App for frame matching, layout preview, and other design-related functions. We will only access the camera when you actively initiate the photo-taking function (e.g., when using StyleFrame to match frames with on-site room decor photos). We do not access or activate the camera without your explicit consent, nor do we collect, store, or transmit any photos or video content captured by the camera beyond the scope of real-time design processing. You can manage or revoke this permission at any time through your device's "Settings" > "Apps" > "Fomv" > "Permissions" menu.
○ Device ID Collection and Usage:We may collect your device's unique identifier (Device ID) solely for the following limited purposes: (1) Ensuring App compatibility with different device models and troubleshooting technical issues (e.g., locating the root cause of App crashes on specific device models); (2) Preventing fraudulent use and ensuring account security (e.g., identifying abnormal login attempts from unrecognized devices). The collected Device ID is encrypted and stored, and will not be linked to any personal identifiable information (PII) or shared with third parties for commercial purposes. We will retain the Device ID only for as long as necessary to fulfill the aforementioned purposes, and will delete it immediately once the purposes are achieved or when you uninstall the App.
○ Advertising IDs Disclosure:We may collect your device's Advertising IDs (a unique identifier provided by your device's operating system for advertising-related purposes) solely for the purpose of delivering relevant, non-intrusive in-app advertisements and measuring the effectiveness of such advertisements. The Advertising IDs is used to understand your preferences for advertising content based on your in-app usage behavior (e.g., the frequency of accessing AI design features related to home decor) and to avoid repeatedly displaying the same advertisements to you.
We strictly adhere to the advertising guidelines of Android and relevant regional regulations when using the Advertising IDs. Specifically:
○ We will not link the Advertising IDs to any personal identifiable information (PII) such as your name, contact details, or photos, ensuring that your identity remains anonymous in the advertising process;
○ We only share the Advertising IDs with trusted third-party advertising partners who are contractually obligated to protect the ID and use it exclusively for delivering and analyzing advertisements on our behalf. These partners are prohibited from using the Advertising IDs for any other purposes or sharing it with other third parties;
○ We will not retain the Advertising IDs indefinitely. It will be retained only for as long as you use the App and will be deleted within 30 days after you uninstall the App.
○ External Storage Permission Disclosure:The Fomv App may request access to your device's external storage (e.g., SD card) permission solely for the purpose of enabling you to import photos from external storage for design needs or export AI-generated design drafts (e.g., layout plans, frame matching schemes) to external storage for backup. We will only access external storage when you actively initiate import/export operations, and will not access, read, or modify any other files or data in external storage without your explicit consent. You can manage or revoke this permission at any time through your device's "Settings" > "Apps" > "Fomv" > "Permissions" menu. All imported/exported data is processed locally on your device, and we do not upload it to our servers.
2.2.2 Temporary AI Processing Data
During your use of AI design features, temporary data (such as frame style preview drafts, layout mockup parameters, or style matching algorithms) may be generated to support real-time service delivery. This data is:
○ Processed either locally on your device or via temporary server connections (for complex AI calculations);
○ Not stored permanently—all temporary data is automatically deleted immediately after you exit the design session or close the App;
○ Anonymized and disassociated from any device or user-related markers during processing.
III. How We Use Your Information
We use the limited, non-personal data we collect exclusively to ensure the stable operation of Fomv’s core AI photo frame and photo wall design services, optimize user experience, and maintain the functionality of the App. We never use any collected data for commercial purposes (such as targeted advertising, data monetization, or third-party sharing) or to identify individual users. All data usage adheres to the principle of “minimization” and complies with GDPR, CCPA, and Google Play privacy standards.
3.1 Use of Non-Personal Environmental & Operational Data
The anonymized, non-personal data we collect (including Wi-Fi environment information, basic device/App runtime data, and aggregated usage metadata) is used solely for the following operational and optimization purposes:
1. Ensure Stable AI Service Delivery
○ We use Wi-Fi environment data (network connection type, signal strength) to adjust the loading strategy of AI-generated design previews (e.g., frame style mockups, layout plans). For example, if a weak network is detected, the App will switch to low-resolution preview mode to avoid loading failures or delays, ensuring the AI design tools (such as LayoutPro and StyleFrame) function smoothly during your session. We do not use this data to track network location or device identity.
2. Maintain App Compatibility & Fix Technical Bugs
○ Basic device and App runtime data (Android OS version, Fomv app version, general device model) is used to identify and resolve compatibility issues (e.g., optimizing the App for older Android versions) and fix technical bugs (e.g., addressing crashes when accessing the WallFit AI character). This data helps us roll out targeted updates to improve the App’s stability for all users, without linking the data to individual devices or users.
3. Optimize Feature Functionality & User Experience
○ Aggregated, anonymized usage metadata (e.g., the popularity of different AI characters, average session duration for design tasks) is used to refine the App’s core features. For example, if data shows that most users frequently use ThemeFrame for family milestone-themed walls, we may enhance the AI’s ability to recommend cohesive frame styles for this theme. We may also adjust feature placement (e.g., making LayoutPro more accessible) based on aggregated usage trends. This data is never used to track individual user behavior or create user profiles.
3.2 Use of Temporary AI Processing Data
Temporary data generated during AI design sessions (such as layout parameter drafts, frame style matching algorithms, or mockup renderings) is used only for real-time service delivery and is never retained for long-term use:
1. Real-Time Design Recommendation Generation
○ Temporary AI processing data is used to power the App’s core design tools (e.g., SizeSync’s frame-photo size coordination, HueFrame’s color-matching logic) and generate personalized recommendations in response to your in-session needs. For example, the data may be used to calculate the optimal 2-5cm spacing between frames (per LayoutPro’s guidelines) or match wooden frames to vintage-themed photos (per StyleFrame’s rules).
2. Immediate Data Disposal After Session Completion
○ All temporary AI processing data is automatically deleted immediately after you exit the design session, close the feature, or uninstall the App. No temporary data is stored on our servers or your device beyond the duration of your active use of the relevant feature, and it cannot be used to trace back to individual users or their design preferences.
3.3 Prohibition of Unauthorized Data Use
We explicitly prohibit the use of collected data for any purposes outside the scope outlined above, including:
• No use of data to identify, track, or profile individual users;
• No use of data for targeted advertising, marketing campaigns, or promotional outreach to users;
• No use of data for data sales, licensing, or sharing with third parties for commercial gain;
• No repurposing of data for unrelated services or products beyond Fomv’s core photo frame and wall design functionality.
3.4 Null Data Handling
With respect to null data (i.e., empty or unidentifiable data generated during App operation, such as incomplete temporary operation logs or unrecognized network signal data), we have established a dedicated processing mechanism. Null data will be automatically filtered and cleared during data transmission and storage processes to avoid occupying storage resources or interfering with normal service operations. We will not attempt to restore or use null data for any purpose, and such data will not be retained in any form.
IV. How We Share Your Information
We strictly limit the sharing of the limited, non-personal data we collect, and never share any data that could be linked to individual users or their personal activities. All data sharing adheres to applicable laws (including GDPR, CCPA, and Google Play Privacy Policies) and is solely for the purpose of maintaining the App’s core functionality and service stability. No data is shared for commercial, marketing, or advertising purposes.
4.1 No Sharing of Personal or Identifiable Data
First and foremost, we do not collect any personal data (such as photos, chat records, room/wall details, or unique device identifiers) that could identify or be associated with individual users. As such, there is no personal or identifiable data to share with any third party under any circumstances. This includes:
• No sharing of user-uploaded visual content (photos, design drafts) with third-party services, partners, or advertisers;
• No sharing of chat interactions with AI characters (e.g., FrameMix, LayoutPro) with external entities;
• No disclosure of user-specific design preferences or scenario details to any third party.
4.2 Limited Sharing of Anonymized, Non-Personal Data
The only data we may share is aggregated, fully anonymized, non-personal data that has been stripped of all identifiers and cannot be traced back to any individual user or device. This sharing is restricted to the following scenarios, with strict contractual safeguards in place:
1. Trusted Service Providers for App Operations
We may share anonymized operational data (e.g., aggregated Wi-Fi network performance metrics, overall App feature usage trends, or general device compatibility data) with third-party service providers who assist in maintaining the App’s technical infrastructure (e.g., cloud computing providers for temporary AI processing, or bug-fixing vendors for compatibility testing). These providers are contractually obligated to:
○ Use the shared data exclusively to perform the specific operational tasks we request (e.g., optimizing server response speeds for AI design previews);
○ Not attempt to re-identify or link the data to individual users;
○ Implement the same level of data security measures as we do, and delete the data once the task is completed.
2. Legal and Regulatory Compliance
We may disclose anonymized, non-personal data if required to do so by applicable law, court order, or government/regulatory authority request. In such cases, we will:
○ Only disclose the minimum amount of data necessary to comply with the legal requirement;
○ Ensure the disclosed data remains fully anonymized and cannot be used to identify individual users;
○ Notify users of such disclosures (to the extent permitted by law) when the request does not involve a threat to public safety or national security.
3. Aggregated Data for Product Improvement (Non-Identifiable)
We may share aggregated, statistical data (e.g., “60% of users access the App in high-signal Wi-Fi environments” or “LayoutPro is the most frequently used AI character”) with industry research partners or our internal product teams for the sole purpose of improving Fomv’s core design features and service quality. This data is completely detached from any user or device identifiers and cannot be used to track or target individuals.
V. Our Multi-Layered Security Approach
We implement a comprehensive, multi-layered security framework to protect the limited non-personal data we collect and ensure the privacy and integrity of your in-app design experience. Our security measures align with global standards (including GDPR, CCPA, and Google Play’s security requirements) and are tailored to the App’s core functionality, with a focus on minimizing data exposure and mitigating potential risks at every stage of data handling.
5.1 Local-First Data Processing & Zero-Personal Data Storage
The foundation of our security approach is eliminating the need to store sensitive personal data in the first place, via a local-first processing model:
1. On-Device Design Data Handling
All user-provided design-related content (including photos for frame pairing, room decor descriptions, and chat interactions with AI characters) is processed locally on your Android device. No such content is uploaded to our servers, meaning there is no risk of personal design data being exposed via server breaches or unauthorized access. Temporary design previews and mockups are cached only on your device’s local storage and are automatically cleared when you exit the App or manually delete drafts.
2. No Persistent Identifiable Data Retention
We do not store any unique device identifiers, network location data, or user-specific behavior logs on our servers or your device. The only data retained on our infrastructure is fully anonymized, aggregated operational data (e.g., Wi-Fi signal strength trends) that cannot be linked to individual users or devices.
5.2 End-to-End Protection for Anonymized Operational Data
For the limited non-personal operational data that is transmitted to our servers (e.g., network performance metrics for AI preview optimization), we deploy end-to-end security protocols to safeguard data in transit and at rest:
1. Encrypted Data Transmission
All data exchanged between your device and our servers uses encryption to prevent interception, tampering, or eavesdropping during transmission. Wi-Fi environment data and device compatibility metrics are encrypted before leaving your device, with decryption only possible on our secure, access-restricted servers.
2. Secure At-Rest Storage
Anonymized operational data stored on our servers is protected via encryption . Data is segregated into isolated storage environments, with strict logical and physical access controls to prevent cross-contamination or unauthorized retrieval.
3. Automatic Data Purge
All collected non-personal data has a predefined retention period (no longer than 30 days) and is automatically purged from our servers once it has served its operational purpose (e.g., after completing a compatibility update for the App). There is no indefinite data retention, and no archived data is accessible for secondary use.
5.3 Proactive Vulnerability Management & Compliance Audits
We maintain ongoing security hygiene to address emerging threats and ensure compliance with global data protection standards:
1. Regular Security TestingThe App and our backend infrastructure undergo quarterly penetration testing and vulnerability scans, conducted by independent third-party security firms. We also perform regular code audits for the App’s local processing modules to identify and patch potential on-device security gaps (e.g., local cache vulnerabilities).
2. Rapid Incident ResponseWe have a dedicated security incident response team with a documented protocol for addressing potential breaches (e.g., unauthorized access to anonymized data). In the unlikely event of a security incident, we will:
○ Contain the issue within 24 hours of detection;
○ Notify relevant regulatory authorities as required by law;
○ Communicate transparently with users (to the extent permitted by law and without causing unnecessary alarm, given the absence of personal data exposure).
5.4 User-Controlled Security Settings
We empower you to manage local security for your design data via built-in App settings:
• You can manually clear all local design caches and temporary previews at any time via the App’s Privacy & Security menu;
• You can disable non-essential network data transmission (e.g., for Wi-Fi environment monitoring) to use the App in offline mode (with limited AI preview functionality);
• All local design drafts are protected by your device’s native security features (e.g., screen lock, biometric authentication), giving you full control over physical access to your content.
We fully respect and protect your rights to control the data related to your use of Fomv. Given that we do not collect or store any personal data, your core rights focus on the limited non-personal operational data we collect and the local design content processed on your device. All rights can be exercised easily through in-app settings or official contact channels, and we commit to responding to your requests within the timeframe required by laws such as GDPR and CCPA (generally 30 days).
6.1 Core Rights Over Local Design Content (Full Control)
All design-related content is processed and stored exclusively on your Android device (not uploaded to our servers). You have absolute control over this content, with the following rights:
○ Right to Access & Manage: You can view all local design drafts, saved layouts, and cached previews at any time. You can rename, organize into folders, or mark favorites for easy management—all operations take effect locally without any server interaction.
○ Right to Delete Local Content: You can delete any local design content.
○ Right to Export Local Designs: You can export any saved design draft (e.g., layout plans, frame matching schemes) as an image file (JPG/PNG) or PDF to your device’s photo gallery or file manager. This allows you to back up your designs or share them with third parties (e.g., frame retailers) at your discretion—we do not restrict or monitor such exports.
6.2 Rights Over Non-Personal Operational Data
For the limited anonymized, non-personal operational data we collect (e.g., Wi-Fi signal strength metrics, aggregated usage trends), you have the following rights to ensure transparency and control:
○ Right to Access & Obtain Information: You can request a clear, easy-to-understand report on the scope of non-personal data we have collected related to your device (e.g., types of network data, retention period). To exercise this right, send a request to our official privacy email (provided in Section X) with your App version and device model—we will provide the report within 15 days.
○ Right to Request Deletion of Operational Data: You can request the immediate deletion of all anonymized operational data associated with your device.
○ Right to Opt-Out of Non-Essential Data Collection: You can disable non-essential operational data collection (e.g., aggregated usage metadata) through the App’s settings:
Go to “Settings” > “Privacy & Security” > “Data Collection”;
○ Toggle off “Allow Aggregated Usage Analytics” to stop the collection of feature usage trends;
○ Toggle off “Network Performance Monitoring” to disable Wi-Fi environment data collection (note: this may cause AI preview loading failures in unstable networks).
Essential operational data (e.g., basic OS version for compatibility) cannot be opted out of, as it is necessary to ensure the App’s core functionality—but we only collect the minimum required amount.
Right to Data Portability (For Anonymized Data): If you request, we can provide the non-personal operational data we have collected about your device in a machine-readable format (e.g., CSV file) for you to review or transfer to other services. This data will be fully anonymized and cannot be linked to your identity.
6.3 Additional Rights Under Regional Laws
In compliance with regional regulations such as GDPR (for EU users) and CCPA (for California users), you have the following additional rights:
○ Right to Correct Inaccurate Data: If you believe the anonymized operational data we have collected contains inaccuracies (e.g., incorrect device model information), you can request correction. We will verify and update the data within 10 days of receiving your request.
○ Right to Restrict Processing: EU users can request that we temporarily restrict the processing of operational data related to your device (e.g., during a security incident investigation). We will comply with this request within 5 working days and resume processing only with your consent or as required by law.
○ Right to Lodge a Complaint: If you believe we have violated your data rights, you can lodge a complaint with a local data protection authority (e.g., ICO in the UK, CNIL in France for EU users; CCPA enforcement agencies for California users). We will fully cooperate with regulatory authorities to resolve your concerns.
6.4 How to Exercise Your Rights
Exercising your data rights is simple and free of charge. You can choose one of the following methods:
a. In-App Operation: For rights related to local content (delete, export) and opt-out of non-essential collection, use the dedicated menus in “My Designs” and “Settings” > “Privacy & Security” (operations take effect immediately).
b. Official Email Request: For rights such as accessing operational data, requesting deletion of server-side data, or correcting inaccuracies, send an email to gogoldweb@gmail.com with the subject line “Data Rights Request - [Your Device Model]”. Please include your App version (found in “Settings” > “About”) and a brief description of your request—we will confirm receipt within 3 working days and complete processing within the legal timeframe.
VII. Region-Specific Privacy Rights
We comply with regional data protection laws worldwide, and users in specific jurisdictions may be entitled to additional privacy rights based on local regulations. Below is a detailed overview of key region-specific rights, which supplement the general data control rights outlined in Section VI and are fully enforceable through our designated request channels.
7.1 Rights for Users in the European Union (EU) and European Economic Area (EEA) – GDPR Compliance
For users located in the EU/EEA, we strictly adhere to the General Data Protection Regulation (GDPR), which grants you the following enhanced rights in addition to those in Section VI:
○ Right to Withdraw Consent (Where Applicable): If you have previously given consent for non-essential data collection (e.g., aggregated usage analytics), you may withdraw this consent at any time. This can be done instantly via “Settings” > “Privacy & Security” > “Data Collection” (toggling off relevant options) or by sending a withdrawal request to our privacy email. Withdrawal of consent will not affect the lawfulness of data processing conducted before withdrawal.
○ Right to Object to Processing: You have the right to object to the processing of non-personal operational data for purposes such as feature optimization. To exercise this right, submit a written request to our privacy email—we will cease the relevant processing within 14 working days unless we can demonstrate compelling legitimate grounds for processing that override your interests.
○ Right to Not Be Subject to Automated Decision-Making: All AI design recommendations (e.g., frame pairing, layout planning) are provided as suggestions only and do not involve automated decisions with legal or similarly significant effects. You retain full discretion to accept or reject any AI-generated design, and we provide clear options to modify recommendations manually. If you have concerns about AI processing, you may contact our support team for human review of your design needs.
○ Right to Lodge a Complaint with a Supervisory Authority: If you believe our data processing practices violate the GDPR, you have the right to lodge a complaint with your local data protection authority (e.g., ICO in the UK, CNIL in France, BfDI in Germany). We will fully cooperate with supervisory authorities to resolve any complaints.
7.2 Rights for Users in California, United States – CCPA/CPRA Compliance
For users residing in California, we comply with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), which afford you the following additional rights:
○ Right to Know About Personal Information (No Applicability Here): As we do not collect or store any personal information (as defined by the CCPA, including names, contact details, or identifiable device data), there is no personal information to disclose under this right. We confirm in writing that no personal information is maintained in our systems upon request.
○ Right to Delete Personal Information (No Applicability Here): Consistent with our “no personal data collection” policy, there is no personal information to delete. However, we honor requests to delete any associated anonymized operational data as outlined in Section VI.2.
○ Right to Opt-Out of Sale/Sharing of Personal Information: We never sell or share personal information with third parties for commercial purposes. Since we do not collect personal information, this right is inherently protected, and no opt-out action is required. We maintain a “Do Not Sell My Personal Information” link in the App’s “Privacy & Security” menu, which directs to a confirmation that no personal data is sold or shared.
○ Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. This includes not denying you access to App features, charging higher fees, or providing lower-quality services because you requested deletion of operational data or opted out of non-essential collection. Limited functionality due to opt-outs (e.g., slower previews without Wi-Fi monitoring) is not considered discrimination, as it directly results from reduced data availability for service optimization.
7.3 Virginia Consumer Data Protection Act (VCDPA) Compliance
For users residing in the Commonwealth of Virginia, USA, we strictly comply with the Virginia Consumer Data Protection Act (VCDPA). Pursuant to VCDPA requirements, you have the right to access, correct, delete, and obtain a copy of your personal data (to the extent we collect it); the right to opt out of the processing of your personal data for targeted advertising or profiling; and the right to not be discriminated against for exercising your VCDPA rights. To exercise these rights, please send a request to gogoldweb@gmail.com with the subject line "VCDPA Rights Request - [Your Device Model]". We will verify your identity and respond to your request within 45 days as required by VCDPA.
7.4 Rights for Users in Other Key Regions
○ Brazil: For users in Brazil, we adhere to the Lei Geral de Proteção de Dados (LGPD). You have the right to access, correct, and delete operational data, as well as the right to request portability of data in a structured format. To exercise LGPD-specific rights, contact our local representative (if applicable) at [Insert Brazil Representative Contact].
○ Canada: For Canadian users, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA). Since we do not collect personal information, PIPEDA’s core requirements for personal data handling are not applicable, but we honor requests for transparency regarding operational data processing as outlined in Section VI.
7.5 How to Exercise Region-Specific Rights
Region-specific rights can be exercised through the same channels as general rights (Section 6.4):
a. In-App Actions: Rights such as consent withdrawal or opt-out of non-essential collection can be completed instantly via the App’s settings.
b. Regional Request Channels: For GDPR, CCPA, or LGPD-specific requests (e.g., objecting to processing under GDPR, confirming no personal data sales under CCPA), send a request to gogoldweb@gmail.com. with the subject line “[Region] Data Rights Request – [Your Device Model]”. For EU/UK users, you may also contact the DPO directly. We will provide a response within the region-specific legal timeframe (e.g., 30 days under GDPR/CCPA, 15 days under LGPD).
VIII. Protection of Minors' Personal Information
We attach great importance to the protection of minors' privacy and strictly comply with international and regional laws and regulations regarding minors' data protection, including but not limited to the Children's Online Privacy Protection Act (COPPA) of the United States, the General Data Protection Regulation (GDPR) Children's Clause, and relevant local minors' privacy protection regulations. We recognize that the legal definition of a minor varies across jurisdictions. For example, regulations such as the GDPR in Europe protect users under 16, while COPPA in the United States protects children under 18. Notwithstanding these differences, Fomv uniformly applies the standard by prohibiting anyone under the age of 18 from using our services. Given this strict usage restriction and Fomv's operation feature of not collecting any personal data, we have formulated the following specific protection measures:
8.1 Uniform Age Restriction and Compliance Basis
To implement the highest standard of minors' privacy protection, Fomv explicitly stipulates that our services are not available to individuals under the age of 18, regardless of the minor age definition specified in local laws. This uniform standard not only meets the requirements of COPPA (which focuses on children under 18) but also aligns with the core spirit of GDPR and other regional regulations that emphasize minors' privacy protection. We have set up a usage confirmation prompt on the App's first launch page, requiring users to confirm that they are 18 years of age or older before using the service.
8.2 Core Protection Principle: No Collection of Personal Information & Strict Access Control
Combined with our uniform age restriction, the protection of minors' privacy is further guaranteed through the "no personal data collection" principle, which specifically includes:
○ No Collection of Identifiable Information: We never collect any personal information that can identify an individual, including minors' names, dates of birth, contact information (such as phone numbers, email addresses), school information, family information, or unique identifiers (such as device IDs, social security numbers). Even in the event of accidental access by underage users, there is no risk of their personal information being collected.
○ No Collection of Content Data Involving Minors: For any user (including potential underage users who bypass the confirmation prompt), photos, room descriptions, and other content uploaded for design purposes are processed exclusively on the user's device and will not be uploaded to our servers. Temporary design drafts and previews are stored locally and automatically cleared after the session ends or the App is uninstalled, leaving no trace of content involving minors.
○ No Tracking of Individual Usage Traces: The only data we collect is anonymized, non-personal operational data (such as Wi-Fi signal strength, App version), which is aggregated and cannot be linked to any individual, including minors. We do not track or record the usage behaviors of any specific user, so there is no possibility of forming usage profiles for minors.
8.3 Guardians' Supervision Rights and Reporting Mechanism
We encourage guardians to supervise minors' online activities and provide the following channels for guardians to fulfill their supervision responsibilities:
○ Right to Review and Manage Local Content: If a guardian finds that a minor has used the App, they can view all local design drafts, cached photos, and temporary previews through the "My Designs" and "Privacy & Security" menus on the minor's device, and delete any inappropriate content with one click. Uninstalling the App will completely clear all local data related to the App.
○ Right to Request Account Restriction: If a guardian confirms that a minor under 18 has used the App, they can contact our privacy team via official email to request assistance in restricting the App's use on the relevant device. We will provide detailed operation guidelines to help guardians limit access to the service.
○ Reporting Channel for Violations: Guardians can report cases of underage users using the App or potential privacy risks to our official email. We will verify the situation within 3 working days and take measures such as providing technical support for use restriction to prevent further use by minors.
IX. Updates to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in applicable data protection laws and regulations (such as amendments to GDPR, CCPA, or local privacy laws), adjustments to our App’s functional features (including AI design services and data processing methods), or improvements to our privacy protection measures. We are committed to notifying you of material updates in a timely manner and ensuring your right to know and choose is protected.
9.1 Circumstances for Updates
This Privacy Policy will be updated in the following circumstances, and we will ensure that the updated content is consistent with the latest legal requirements and service realities:
▪ Legal and Regulatory Changes: When there are revisions to international, regional, or national data protection laws (e.g., updates to GDPR’s enforcement guidelines, amendments to CCPA’s rights scope), we will adjust the policy to comply with the new regulatory requirements.
▪ Service Function Adjustments: When we add or optimize core functions (e.g., introducing new AI design tools, adjusting local data processing modes, or updating non-personal data collection types), we will update the policy to clearly explain the impact of such changes on data handling.
▪ Privacy Protection Mechanism Improvements: When we enhance data security measures (e.g., upgrading encryption protocols, optimizing access control systems) or adjust data retention rules, we will update the relevant clauses to keep users informed of the latest protection measures.
▪ User Feedback and Practical Needs: When we receive reasonable suggestions from users or regulatory authorities regarding privacy policy clarity or compliance, we will revise the policy to improve readability and enforceability.
9.2 Effective Date and User Choices
▪ Effective Date: The updated Privacy Policy will take effect on the "Last Updated Date" marked at the top of the document. For material updates, the effective date will be at least 7 days after the notification is sent, giving you sufficient time to review the changes.
▪ User Choices: If you do not agree to the updated Privacy Policy, you may stop using the App and uninstall it. Uninstalling the App will automatically delete all local data related to the App. Your continued use of any function of the App after the effective date of the updated policy will be deemed as your acceptance of the revised content.
9.3 Access to Historical Versions
We will retain historical versions of this Privacy Policy for at least 2 years from the date of the update. If you need to view the historical version of the policy, you can send a request to our official privacy email gogoldweb@gmail.com with the subject line "Request for Historical Privacy Policy Version". We will provide you with the corresponding version within 5 working days and explain the key changes between the historical version and the current version.
X. Data Protection Officer (DPO)
For any inquiries regarding your personal data protection, privacy rights, or data processing activities, please contact our designated Data Protection Officer Bowie at gogoldweb@gmail.com.
Our DPO oversees all matters related to GDPR, CCPA, LGPD and other privacy regulations compliance, ensuring your personal information is handled in accordance with applicable data protection laws.
The controller responsible for managing your personal information in relation to this service is Fomv. We are in charge of the collection, usage, storage, and disclosure of any personal data you provide while using our services. For any inquiries regarding your personal data, feel free to reach us at gogoldweb@gmail.com.
Address:
25 Western Circle
MANCHESTER - M19 1LZ
United Kingdom (GB)
For any questions, concerns or requests regarding this Privacy Policy or your personal data, you may contact us through the following channels within 15 days:
• Email: gogoldweb@gmail.com
• Post:
25 Western Circle
MANCHESTER - M19 1LZ
United Kingdom (GB)