Effective date: 28 March 2024.

1.1. BDream. (hereinafter referred to as "BDream", "Company", "us", "our" or "we") is dedicated to protecting the privacy rights of our users (hereinafter referred to as "User(s)", "you"). This Privacy Policy (hereinafter referred to as "Policy") describes how and why we collect, store, use, and manage the information, and data, including personal data, that you provide or we collect when you use any BDream's application provided on any mobile platform (for example, iOS and Android) (hereinafter collectively referred to as the "Service(s)"). It also tells you how you can access and update personal information and/or data and make certain choices about how personal information and/or data that you provide to BDream is used.

1.2. Please note that the scope of this Policy is limited to information and data collected or received by BDream through or in relation to your use of the Service. BDream is not responsible for the actions of third parties, the content of third-party websites, the use of information or data you provide to third parties or any products or services they may offer. Any link to third-party websites does not constitute our sponsorship of, or affiliation with, such third parties.

1.3. BDream acts as a Data Controller in relation to personal data that you provide to us.

1.4. By using our Services you agree to our Privacy Policy and confirm that you are at least 13 years old. We do not knowingly collect or solicit personal data from or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under the age of 13, please do not send any personal data to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal data from an individual under 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about an individual under the age of 13, please contact us by sending an email to apppledevtvn@gmail.com.

1.5. BDream. as Data Controller does not and will not process any special categories of personal data.

1.6. From time to time, we can update this Privacy Policy. We may notify you about changes to this Policy by placing a notice via the Services or Site. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically check back and review this Policy so that you always know our current privacy practices.

2.1. We collect and combine different types of information and/or data (including personal data) together. Here you can find more about what information and/or data we collect about you when we collect it and what information and/or data we do not collect about you:

2.1.1. Registration, account, and sign-up information. We collect data in the course of your use of, or registration with BDream. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal data. This type of personal data can include name (first name, last name, pseudonym or nickname) or email address (e.g., in cases when you request individual technical support or assistance, see “Customer enquiries” section).

2.1.2. Product/ service purchase. When you make a purchase, we provide you with third-party services for purchasing and your payment data (e.g. credit/debit card, billing information and delivery address) is not collected by us. Information about the user such as name (first name, last name, pseudonym or nickname), email address, telephone number and the purchased product is retained by us for further action on the product subscription.

2.1.3. From other sources. We, on occasion, combine data we receive online with other information, including usage information from our other websites and our online advertising and media. We also supplement or combine data with data from a variety of other sources or outside records, such as demographic and transaction history, and we use that combined data in accordance with this Privacy Policy.
Some types of other sources with which we share your data are:
- IT companies. We work with businesses that support our website and other business systems.
- Marketing companies (See “Social media” section). We work with marketing companies that help us manage our electronic communications with you or carry out product reviews.
- Payment processing. We work with trusted third-party payment processing providers in order to securely take and manage payments.

2.1.4. Social media. You can engage with some of our content and offerings, such as videos, applications, and other offerings on or through third-party communities, forums, and social media websites, services, plug-ins, and applications ("Social Media Sites"). When you link to or interact with us or our content through Social Media Sites, you allow us to receive certain data from your social media account (e.g., your name, user ID, email address, profile photo, photos and videos, gender, date of birth, your list of friends and their contact details, people whom you follow and/or who follow you, the posts or the 'likes' you make). We also receive data from your interaction with our content (e.g., data regarding content viewed). Where permitted by law, by providing this data or otherwise interacting with our websites through Social Media Sites, you consent to our use of data from Social Media Sites in accordance with this Privacy Policy.

2.1.5. Location information. We have access to certain data about your location, such as your country or address, when you provide it to us directly or when we receive it via device information (such as an IP address). With your consent (where required by law), we may also collect data about your location (e.g. geolocation via a mobile device(s)) for the purpose of tailoring content specific to your area (such as area-based content packages), and match your device location to certain points of interest for purposes of interest-based advertising as described in this Policy. Please note, participation in this part of the Service is not a requirement for all our applications. You may at any time opt out from sharing your location by turning it off in the settings of your device.

2.1.6. Technical and usage information. We also collect certain technical and usage information such as your application data (including interaction with in-app facial mapping tools used for facial manipulation features inside the application via server log files and your user ID), access, session times and in-app purchases, device type, browser (if using our website), and operating system you are using, your Internet service provider and/or mobile carrier, unique device ID (persistent/non-persistent), device hardware type, IDFA or IDFV, MAC address, IP address, device and browser settings (if using our website), the webpages and apps you use, advertisements you see and interact with, and certain site usage information. This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for interest-based advertising as described elsewhere in this Policy. See the "Cookies and Other Technical Information" section for more information on how we may use these technologies to collect this data.

2.1.7. Customer enquiries. When you contact us through one of our customer helpdesks or customer support centres, we may collect and process the contents (including data) of your correspondence with us and/or your contact details.

2.1.8. Tracking Technologies. We and our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify User's computer/device and to "remember" things about your visit, such as your preferences or a user name (pseudonym or nickname). Information contained in a cookie may be linked to your personal data, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable all cookies apart from the cookies necessary for the functioning of the site and/or an app.

For collecting the above-mentioned data and making statistics and analysis we may use the following software and programs:

Google Analytics, Google Ads, Firebase (Google LLC.) 1600 Amphitheatre Parkway Mountain View, CA 94043, USA Web analytics service that tracks and reports traffic on our website. Marketing services (provision of personalized marketing).

Apphud Inc. 850 New Burton Rd, Ste 201, Dover, DE 19904, USA Payment service provider, handling and management of financial transaction data, and processing data for purposes such as customer service, record keeping, and regulatory compliance, transferring of personal information by encrypted connection.

AppsFlyer Ltd. 111 New Montgomery St Ste 400 San Francisco, CA, 94105-3616, USA Analytics service provider, handling and analysis of data for the purpose of promoting a product and/or service, analyzing data on consumer behaviour and preferences, transferring of such personal information by encrypted connection.

Facebook Ads (Meta Platforms, Inc.) 1601 Willow Road, Menlo Park, CA 94025, USA

Apple Search Ads (Apple Inc.) One Apple Park Way, Cupertino, CA 95014, USA

TikTok Ads (TikTok Pte. Ltd.) 1 Raffles Quay, #26-10, South Tower, Singapore 048583

Marketing provider, handling and analysis of data for the purpose of promoting a product and/or service, analyzing data on consumer behaviour and preferences, as well as creating and implementing marketing strategies to target specific audiences.

Snowplow Analytics Limited 17 Bevis Marks, Floor 6, London, EC3A 7LN, United Kingdom Analytics service provider, analyzing data on consumer behaviour, transferring of such personal information through local database.

2.1.9. We understand the importance of protecting your privacy and want to provide transparency regarding the collection and usage of Face Data. Please see the "Face Data" section for more information on how we may use Face Data.

3.1. We use collected information and/or data (including personal data) for the following purposes:

3.1.1. Providing and marketing products and services. We use the information and/or data that we collect about you in order to analyze your use of our products, applications, services, and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalize, protect, and improve your experience and our offerings. For example, we use information and/or data that we collect from you to enable you to:
(i) get entertainment news and updates;
(ii) get information about our products, services, and content;
(iii) locate and access personalized information, ads or functionality based on your interests ;
(iv) engage with interactive features, activities, and Social Media Sites; and
(v) content, reviews, or enter promotions and contests.

In addition to this, we use this information and/or data for us and our affiliates, business partners, and third parties to target, offer, market, or advertise products, programs, or services.

Lawful basis for processing including basis of legitimate interest:
• Fulfilling contractual obligations (e.g., receive, process, and confirm your subscription or registration, and communicate with you about your account);
• Legal obligations; and
• Your consent (where required) due to:
- maintaining our services as much as improving and developing new products (to ensure our services are working as intended, such as tracking outages or troubleshooting issues that report to us);
- being more efficient; and
- preventing fraud and other misconduct.

3.1.2. Communicating with you. We use information and/or data that we collect about you to communicate with you, in order to:
(i) notify you when we make changes to our policies or terms of use;
(ii) respond to your inquiries;
(iii) communicate with you about your purchases or transactions;
(iv) contact you about your account; or
(v) send you information about promotions, offerings, and our features. You may also choose to receive push notifications from us on your mobile device.

Lawful basis for processing including basis of legitimate interest:
• Fulfilling contractual obligations;
• Legal obligations; and
• Your consent (where required) due to:
- Communicating important information;
- Improving and developing actual and prospective products and services; and
- Compiling statistics.

3.1.3. Third-party social networks. We use information and/or data that we collect about you when you interact with third-party social networking features to serve you with advertisements and engage with you on third-party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third-party social network.

Lawful basis for processing including basis of legitimate interest:
• Your consent (where required); and
• Legal obligations due to:
- Defining types of customers for new products or services;
- Developing a profile on you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you; and
- to study how you use our products/services, to develop them, to grow our business and to improve our marketing strategy.

3.1.4. Use of technical and usage information. We use technical and usage information to improve our design, functionality and content and to enable us to personalize your experience with our content and offerings. We use this information in order to:
(i) provide, develop, maintain, personalize, protect, and improve our products, applications, and services, and to operate our business;
(ii) perform analytics, including analyzing and reporting on usage and performance;
(iii) protect against, identify, and prevent fraud and other unlawful activity, and
(iv) create aggregate data about our Users.

Lawful basis for processing including basis of legitimate interest:
• Fulfilling contractual obligations;
• Legal obligations due to:
- running our business, provision of administration and IT services, network security, to prevent fraud as much as to comply with a legal obligation; and
- to define types of customers for our products and services, to keep our website updated and relevant.

3.1.5. Compliance. We use information and/or data that we collect about our Users to detect, investigate, and prevent activities that violate our terms of use, could be fraudulent, violating copyright or otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our Users and third parties.

Lawful basis for processing including basis of legitimate interest:
• Legal obligations due to:
- Protecting our business interests and rights, privacy, safety and property, or that of the public; and
- Sharing your data with third parties in order to permit us to pursue available remedies or limit damage that we may sustain.

4.1. We are committed to delivering different tools. Our Services may use modern approaches and settings including machine learning or artificial intelligence algorithms to provide you with personalized solutions that meet the needs of your creativity. While using face effects we need to show them in the right place in your photos to realize the final result of how the tool works. This information is not used to identify you.

4.2. Our Services explicitly do not utilize facial recognition, biometric templates, or any other systems regulated by law. These functionalities are not permitted within the scope of our application. We stick to strict compliance with applicable regulations, ensuring that no activities involving facial information (hereinafter referred to as "Face Data") or the creation and storage of biometric templates take place. Our focus is on maintaining compliance and upholding user privacy within the authorized and permissible parameters of the app.

4.3. When you use our application, we may collect information about you, including photographs you provide when you use the application, via your camera or camera roll. This may include capturing and storing images or videos containing Face Data. We obtain only the specific images you chose to modify using the application; we do not collect your photo albums even if you grant us access to them.

The data we gather as part of our services does not encompass biometric information, as photographs are expressly excluded from the category of data classified as biometric identifiers. However, we acknowledge that photographs, especially those containing Face Data, merit the same or an even more protective level of care as we apply to the storage, transmission, and protection of other confidential and sensitive information.

In compliance with the law, we are committed that:

4.3.1. The Face Data is solely used for the purpose of providing specific features and functionalities within the application. Thus, we may store Face Data for general technical purposes without involving automated or systematic processing for unique identification aims. We refrain from extracting Face Data, as well as from extracting or storing face geometry, including Biometric identifiers.

4.3.2. Consent and User Control. We herein obtain your explicit consent before collecting and processing any personal data including photographs containing Face Data. You have the right to control and manage the face data shared with our application. We will seek additional consent if we intend to use your information for any other purpose not mentioned herein.

4.3.3. Storage and Security. We store photographs containing Face Data securely on our servers or locally on your device, ensuring appropriate technical and organizational measures are in place to protect it from unauthorized access or disclosure.

Photographs containing Face Data will be retained for the duration necessary to fulfill the purposes for which it was collected. We have established a retention and deletion schedule in accordance with applicable laws. Once the purpose has been fulfilled or your consent is withdrawn, we will take steps to securely delete and destroy your data.

4.3.3.1. In the case of generating features using Artificial Intelligence, additional configurations based on deep learning and text-to-image mechanisms may be required. As a result, processing activities are carried out on our server.

4.3.3.2. We store your original source photographs containing Face Data for no longer than 60 (sixty) calendar days. Your content is stored on our servers so that they remain accessible to you in the application at any time and from any device until you decide to delete them.

4.3.3.3. We implement industry-standard security measures to protect information from unauthorized access, disclosure, alteration, and destruction. Our commitment to security includes encryption and access controls.

4.3.4. Third-Party Access and Data Sharing. We do not share or disclose your photographs containing Face Data to any third parties unless explicitly stated otherwise and with your prior consent.

4.3.5. Data Retention. You have the right to request the deletion of your photographs containing Face Data at any time. For detailed information regarding common provisions of Data Retention please see Section 8 herein.

4.3.6. Please notice we do not use the photographs you provide when you use the application for any reason other than to provide you with the editing functionality of the application and the goals and purposes mentioned above (see 3 "How we use the information" section).

4.4. We do not sell, lease, trade, or otherwise profit from your biometric identifier or biometric information.

4.5. If you have any questions or concerns about our practices, please contact us:

5.1. We share and disclose information and/or data (including personal data) for the following purposes:

5.1.1. Law enforcement bodies and courts. We disclose information and/or data when provided by law, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose information and/or data to third parties:
(i) in connection with fraud prevention activities;
(ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities;
(iii) in situations that can involve violations of our terms of use or other applicable rules and policies;
(iv) to protect our rights and the rights and safety of third parties; and
(v) as otherwise required by law.

5.1.2. Change of control. We will transfer information and/or data regarding our Users in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.

5.1.3. Service providers. our agents and contractors have access to information and/or data regarding our Users in order to carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, marketing, processing of payments, email and order fulfilment, administration of contests, research and analytics, and customer service.

5.1.4. Advertising networks. We share certain information and/or data regarding our Users with third parties to provide advertising to you based on your interests. For more information, please see the "Cookies and Other Technical Information" and "Ad Choices" sections below.

We use the data processing services of the following companies:



5.2. When sharing information with third parties, we ensure that they assume responsibilities no less than what is outlined in this Privacy Policy. We require these third parties to adhere to the information-sharing practices and standards described herein to uphold the same level of privacy protection.

6.1. Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from Us, and our sharing of information and/or data relating to you with our trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at apppledevtvn@gmail.com.

6.2. Ad Choices. We work with reputable third parties to present advertisements and engage in data collection, reporting, ad delivery and response measurement, and website analytics on our websites and applications and on third-party websites and applications. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from your device(s) and browser(s) (if using our website) in order to help serve advertising that will be more relevant to your interests on and off our sites and across your device(s) and browser(s) (if using our website). This type of advertising is known as interest-based advertising. For more information about interest-based advertising on your desktop or mobile browser (if using our website), and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please contact apppledevtvn@gmail.com. You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, and Android for Android devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.

7.1. Cookies and other technologies:

7.1.1. We, and our affiliates, third-party service providers, and trusted partners send "cookies" to your device and use similar technologies in order to analyze and enhance your user experience with us, as well as for advertising purposes and social features.

7.1.2. Cookies are small text files placed in your browser (if using our website). We may also use pixels or "web beacons" that monitor your use of our website. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser (if using our website) that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.

7.1.3. We may also integrate "Software Development Kits" ("SDKs"), javascript or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with our app.

7.1.4. Our websites may use local stored objects ("LSOs") to provide certain content, such as video on demand, video clips, or animation, and better user experience.

7.2. We can use cookies and other technologies to help recognize your browser (if using our website) or device, maintain your preferences, provide certain features, and collect information and/or data about your online interactions with us, and your communication(s) with us. For example, when corresponding with you via HTML-capable email, web beacons and other technologies let us know about your activity, including whether you received and opened our email, clicked through a link, or otherwise interacted with our content, and this information can be associated with Information previously collected.

7.3. We also use cookies and other technologies:
(i) to provide, develop, maintain, personalize, protect, and improve our websites, products, apps, services and video games, and to operate our business;
(ii) to perform analytics, including to analyze and report on usage and performance of our content and marketing materials;
(iii) to protect against, identify, and prevent fraud and other unlawful activity;
(iv) to create aggregate data about our users;
(v) to synchronize users across devices, affiliates, and trusted partners; and
(vi) for us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps or services. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through us.

7.4. We use the following types of cookies and similar technologies:

7.4.1. Strictly necessary cookies or similar technologies. They are essential in order to enable you to move around our websites and apps and use their features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.

7.4.2. Performance cookies or similar technologies. They collect information about how you use our websites and apps so that we can analyze traffic and understand Users' interactions. We may use third-party service providers such as Google Analytics, who may use their own cookies or similar technologies, for this purpose.

7.4.3. Functionality cookies or similar technologies. They allow our websites and apps to remember choices that you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide the services you have asked for.

7.4.4. Social media cookies or similar technologies. They are used when you share information using a social media sharing button or "like" button on our websites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The corresponding social network will record that you have done this. This information may be linked to targeting/advertising activities.

7.4.5. Advertising cookies or similar technologies.Some of our websites or apps may use third-party advertising networks to deliver targeted advertising. They may also have the capability to track your browsing across websites (if using our website), apps and Social Media Sites.

8.1. We will only retain your personal data for as long as is necessary for the purposes described in this Policy. This means that our data retention periods will vary according to the reason for collection. Generally, your service-related personal data will be kept for as long as you remain our User (this way, in the event that you delete your account on the Services, we will immediately delete any personal data (with the exception of data specified in clause 7.2 of this Policy), provided under such account, including, but not limited to, your name, gender, profile picture, logs, and any information on and from social networks, linked to the such account).

In some circumstances, you can request the erasure of your personal data. This enables you to ask us to delete or remove personal data without a good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes: by analyzing anonymized data, we are able to build safe and valuable products and features, and better detect security threats all while protecting user identities. We can also safely share anonymized data externally, making it useful for others without putting the privacy of our users at risk.

8.2. Yet, some personal data relating to the provision of Services to you will be kept for a longer period, as long as necessary to comply with various finance- and tax-related legal obligations. After a retention period has elapsed, the personal data is securely deleted.

9.1. Under certain conditions, you have the right to ask us for a copy of your personal data, as well as to correct it, delete it or restrict its processing, and obtain the personal data that you provided to us in a structured, machine-readable format. You have the right to object to the processing of personal data on the basis of our legitimate interests. Where we have asked for your consent to process your personal data, you have the right to withdraw this consent at any time.

9.2. To exercise any of the above rights, please contact us at apppledevtvn@gmail.com.

9.3. In addition to the above rights, as a resident of the EU/EEA you also have a right to lodge a complaint to your local supervisory authority.

9.4. In cases permitted by law we reserve the right not to allow access to your personal data or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal data even if you withdraw your consent.

10.1. We maintain servers around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data.

10.2. When we transfer your Information to our group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your personal data to third parties outside the EEA. You may obtain a copy of the documents we use to protect your personal data when it is transferred outside the EEA by contacting us via email at apppledevtvn@gmail.com.

If you have any questions about this Privacy Policy you can contact us at: apppledevtvn@gmail.com.