PhotoRenew Privacy Policy

Last Updated: October 20, 2026
Effective Date: October 20, 2026
Version: 2.4

This Privacy Policy describes how Perfect Pixel (Wuhan) Technology Co., Ltd ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use PhotoRenew (the "App"), our AI-powered photo restoration and enhancement application available on iOS and Android platforms.

Company Information:

By downloading, installing, or using the App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the App.

Table of Contents

  1. Definitions and Key Terms
  2. Information We Collect
  3. How We Use Your Information
  4. Legal Basis for Processing (GDPR)
  5. How We Share Your Information
  6. Your Privacy Rights
  7. International Data Transfers
  8. Data Retention
  9. Security Measures
  10. Children's Privacy
  11. Third-Party Services and SDKs
  12. Cookies and Tracking Technologies
  13. Changes to This Privacy Policy
  14. Contact Us and Complaints
  15. Region-Specific Disclosures
  16. Additional Information

1. Definitions and Key Terms

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

  1. "Cookie" means a small text file placed on your device by our App or website, which helps us recognize your device and remember certain information about your preferences or past activities.
  2. "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to your name, email address, device information, photos, and usage data.
  3. "Service" means the PhotoRenew mobile application and all related services, features, and functionalities provided by us, including but not limited to AI-powered photo restoration, colorization, enhancement, and photo animation.
  4. "Third-Party Service" means any service, product, or technology provided by a third party that is integrated into or used in connection with the App, including but not limited to cloud hosting, payment processing, and authentication services.
  5. "You" means any individual who accesses or uses the App.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide when using the App, including:

  1. Account Information:

  2. Photo Content:

  3. Payment Information:

  4. Photo Animation Content:

2.2 Information Collected Automatically

When you use the App, we automatically collect certain information, including:

  1. Device Information:

  2. Usage Information:

  3. Technical Information and Logs:

2.3 Device Sensors (Camera Features)

  1. The App requires access to your device camera and photo library to enable you to capture, upload, and restore photographs.
  2. Sensor data (such as accelerometer, gyroscope, or proximity sensor data) that may be accessed by the App is processed locally on your device and is not transmitted to our servers.

2.4 Information from Third Parties

We may receive information about you from third-party sources, including:

  1. Authentication Providers: Profile information (such as your name and email address) provided by Apple (Sign in with Apple) or Google (Google Sign-In) when you use these services to log in.
  2. Payment Processors: Transaction confirmations and purchase verification data from Apple In-App Purchase or Google Play Billing.

2.5 Image and Video Processing Rules

  1. Photographs and videos you upload are transmitted securely to our servers for AI-powered processing, including restoration, colorization, enhancement, and photo animation.
  2. All images and videos are encrypted in transit using industry-standard TLS encryption protocols.
  3. If you do not save a processed photo or video to your account, it will be deleted from our servers within 90 days of upload, or earlier if it is no longer needed to provide the requested result. If you request account deletion, any such content still linked to your account is deleted within the 30-day account-deletion period in Section 6.4.
  4. We do not use your photographs or videos to train, fine-tune, or improve any artificial intelligence or machine learning models.
  5. The App may analyze visible facial features to restore or animate a photograph. It does not create facial templates to identify or verify a person's identity, authenticate users by face, or compare identities across photographs. We do not use facial analysis for those identity-recognition purposes.
  6. Some uploaded images may reveal highly private information about a depicted person. Our Terms of Service require an adult uploader and the specific, informed consent of every identifiable person depicted before uploading or requesting processing of a private or intimate image; private or intimate images of minors are prohibited. A user's checkbox, upload confirmation, or statement about consent is that user's declaration, not our verification that any depicted person consented. We process submitted content as described in this Policy, including to provide the requested feature and, when necessary, to assess reports of unauthorized use.

3. How We Use Your Information

We use the information we collect for the following purposes:

  1. Service Delivery: To provide, maintain, and improve our AI-powered photo restoration, colorization, enhancement, and photo animation services.
  2. Account Management: To authenticate your account, verify your identity, and manage your account settings and preferences.
  3. Subscription and Payment Management: To process subscriptions, in-app purchases, and manage billing through Apple In-App Purchase and Google Play Billing.
  4. Photo Project Management: To save, store, and sync your photo projects across your devices and sessions.
  5. Communication: To send you service-related updates, notifications about new features, and responses to your support inquiries.
  6. Service Improvement: To analyze usage patterns, identify trends, and improve the performance, functionality, and user experience of the App.
  7. Security and Fraud Prevention: To detect, prevent, and address fraud, unauthorized access, and other illegal activities, and to ensure the security of our services.
  8. Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
  9. Marketing: With your express consent, to send you promotional communications about our products and services. You may opt out of marketing communications at any time through your account settings or by contacting us at support@wanmeixiangsu.cn.

For users in the European Economic Area (EEA), the United Kingdom, and Switzerland, we process your personal data only when we have a valid legal basis to do so. The legal bases we rely on include:

  1. Contract Performance: Processing is necessary for the performance of our contract with you, including providing the photo restoration and animation services you have requested.
  2. Legitimate Interest: Processing is necessary for our legitimate interests, such as improving our services, ensuring security, preventing fraud, and maintaining the integrity of our platform, provided that such interests are not overridden by your rights and freedoms.
  3. Legal Obligation: Processing is necessary to comply with a legal obligation to which we are subject, such as tax, accounting, or regulatory requirements.
  4. Consent: Where we rely on your consent for specific processing activities (such as marketing communications), you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to such withdrawal.

5. How We Share Your Information

We do not sell your personal data to any third party.

5.1 Service Providers

We may share your information with the following categories of service providers who perform services on our behalf:

  1. Cloud Services Provider:

  2. Payment Processors:

  3. AI Processing:

  4. Customer Support:

We may disclose your information when we believe in good faith that such disclosure is necessary to:

  1. Comply with applicable law, regulation, or legal process.
  2. Respond to lawful requests from public authorities, including law enforcement and government agencies.
  3. Protect our rights, privacy, safety, or property, or that of our users or the public.
  4. Investigate or prevent suspected fraud, security breaches, or violations of our Terms of Service.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal data may be transferred as part of such transaction. We will notify you via email or a prominent notice in the App before your personal data becomes subject to a different privacy policy.

6. Your Privacy Rights

6.1 Rights for All Users

All users have the following rights regarding their personal data:

  1. Access: You have the right to request access to the personal data we hold about you.
  2. Correction: You have the right to request correction of any inaccurate or incomplete personal data.
  3. Deletion: You have the right to request deletion of your personal data, subject to certain legal exceptions.
  4. Data Export: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format.

You may exercise these rights directly within the App (through your account settings) or by contacting us at support@wanmeixiangsu.cn. We will respond to all requests within 30 days of receipt.

If you appear in an image uploaded by another user and believe it was submitted or used without your consent, you may contact us at the same email address. Please provide enough information for us to locate the content. We may ask for information reasonably needed to verify your identity and assess the report, and will take action as required by applicable law. The uploader's declaration does not establish that you consented.

6.2 Rights for Users in the EEA, UK, and Switzerland (GDPR)

In addition to the rights listed in Section 6.1, users in the EEA, the United Kingdom, and Switzerland have the following rights under the General Data Protection Regulation (GDPR):

  1. Restriction of Processing: You have the right to request restriction of processing of your personal data in certain circumstances.
  2. Objection: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
  3. Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
  4. Withdrawal of Consent: Where processing is based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to such withdrawal.
  5. Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe that our processing of your personal data violates the GDPR.

6.3 Rights for California Residents (CCPA/CPRA)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

  1. Right to Know: You have the right to request information about the personal data we have collected, used, disclosed, and sold in the past 12 months.
  2. Right to Delete: You have the right to request deletion of your personal data, subject to certain exceptions.
  3. Right to Correct: You have the right to request correction of inaccurate personal data.
  4. Right to Limit Use of Sensitive Personal Information: You have the right to limit our use and disclosure of your sensitive personal information.
  5. Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal data. We do not sell personal data. However, we provide this opt-out mechanism in compliance with applicable regulations.

6.4 Account Deletion

  1. You may request deletion of your account at any time through the App settings or by contacting us at support@wanmeixiangsu.cn.
  2. Upon receiving a verified account-deletion request, we will delete your account and associated personal data, including saved photo projects and content still linked to the account, within 30 days. This timeframe also applies to associated copies under our control, including backups, unless retention is legally required as described below.
  3. We may retain only the specific records that applicable law requires us to keep, such as tax or accounting records, for the legally required period. Those records are separated from active account data and are not used for photo processing or marketing. We will explain any applicable exception when responding to your request. Deleting your PhotoRenew account does not cancel an Apple or Google subscription; cancel it separately through the applicable store.

6.5 Memorialized Accounts

In the event of a verified report of a deceased user, we may memorialize the account. Memorialized accounts are preserved but cannot be logged into or modified. We may also delete the account upon request from a verified legal representative or next of kin, subject to applicable legal requirements.

7. International Data Transfers

  1. Your personal data may be transferred to and processed in countries other than your country of residence, including China, where our servers and operations are located.
  2. Before transferring personal data subject to EEA, United Kingdom, or Swiss transfer rules to mainland China or another country without an applicable adequacy decision, we will put in place a lawful transfer mechanism and any required supplementary measures. Where that cannot be done, we will not make the transfer. You may contact us for information about the mechanism and safeguards applicable to your data.
  3. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, as described below:

  1. Account Data and Saved Photo Projects: Retained while your account is active, unless you delete individual projects sooner. When you request account deletion, we delete the account and associated personal data, including saved projects, within 30 days after verifying the request, subject only to legally required retention described below.
  2. Payment and Tax Records: Retained only for the period required by applicable tax, accounting, consumer-protection, or other law. Store payment-card details are not held by us. Any legally retained records are separated from active account data and are not used for photo processing or marketing.
  3. Technical Logs and Crash Reports: Retained only as long as reasonably needed for security, troubleshooting, and legal compliance, then deleted or de-identified. Logs associated with a deleted account are deleted or de-identified within the 30-day account-deletion period unless a specific legal retention duty applies.
  4. Marketing Data: Retained only while you have consented to receive marketing. We stop using it for marketing when you withdraw consent and delete or de-identify data linked to a deleted account within the 30-day account-deletion period, unless legally required to retain a suppression record to honor your opt-out.
  5. Unsaved Content: Photographs and videos uploaded for processing but not saved to your account are deleted when they are no longer needed to provide the requested result and, in any event, within 90 days after upload. If they remain linked to an account for which we receive a verified deletion request, they are deleted earlier, within the 30-day account-deletion period.

9. Security Measures

We use technical and organizational safeguards designed to protect personal data against unauthorized access, loss, misuse, and alteration. These include encrypted transmission of data between the App and our servers, controls on personnel access to personal data, and procedures for investigating suspected security incidents. No system can be guaranteed completely secure. If a personal-data breach occurs, we will notify affected users and the competent authorities when and within the timeframes required by applicable law.

10. Children's Privacy

  1. The App is not intended for children under 13 or below any higher minimum age applicable in their location. A minor who meets the minimum age may use the App only with parental or guardian involvement and consent where local law requires it.
  2. Where applicable law requires verifiable parental or guardian consent before processing a minor's personal data, we will obtain that consent before processing. If the required consent mechanism is not available in the App, the minor may not use the App until they meet the applicable age threshold.
  3. If we learn that we collected a child's personal data without consent required by law, we will stop the processing and delete the data, subject to applicable legal requirements. Parents and guardians may contact us at support@wanmeixiangsu.cn about a minor's account or data.

11. Third-Party Services and SDKs

The App integrates the following third-party services and software development kits (SDKs):

  1. Apple In-App Purchase: For processing in-app purchases and subscriptions on iOS devices.
  2. Sign in with Apple: For authentication and account creation on iOS devices.
  3. Google Sign-In: For authentication and account creation on Android devices.
  4. Google Play Billing: For processing in-app purchases and subscriptions on Android devices.
  5. Apple Push Notification Service (APNs): For delivering push notifications on iOS devices.
  6. Alibaba Cloud: For cloud infrastructure, data storage, and AI processing services.

The device and usage information described in Section 2.2 is used for internal analytics, service operation, and fraud prevention as described in this Policy. The current App does not integrate third-party analytics, attribution, or crash-analysis SDKs. We do not provide advertising identifiers to third-party advertisers. If a new service provider receives personal data, we will update this Policy and provide any notice or choice required by applicable law before that processing begins.

Permissions: You may manage the permissions granted to the App (such as camera access, photo library access, and push notifications) through your device settings at any time. Please note that revoking certain permissions may affect the functionality of the App.

12. Cookies and Tracking Technologies

We use the following types of cookies and tracking technologies:

  1. Session and Preference Technologies: The App may use local storage and, where web content is displayed, cookies needed for sign-in, security, and preferences. Disabling these technologies may affect related functions.
  2. Internal Analytics: We analyze app usage and diagnostic information described in Section 2.2 to understand feature use, performance, and errors. We do not use cookies for third-party advertising.
  3. Advertising Identifiers: We collect your device's advertising identifier (IDFA on iOS or GAID on Android) for internal analytics and fraud prevention. We do not share this identifier with third-party advertisers. Where platform permission is required to access an identifier, we request it before access and respect your device-level choice.

Do Not Track: Some browsers and devices offer a "Do Not Track" (DNT) feature. We currently do not respond to DNT signals, as there is no universally accepted standard for how to interpret DNT signals. However, we respect your privacy choices as described in this Privacy Policy, and you may opt out of marketing communications at any time.

13. Changes to This Privacy Policy

  1. We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
  2. If we make material changes to this Privacy Policy, we will notify you by one or more of the following methods, as appropriate and required by law:
  3. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
  4. Continued use of the App does not, by itself, constitute consent to a new purpose of processing where applicable law requires a separate choice. Where required, we will obtain that choice before the new processing begins.

14. Contact Us and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

We will acknowledge your inquiry and respond within the period required by applicable law, and ordinarily aim to respond within 30 days of receipt. If an extension is permitted and needed, we will explain the reason and the expected response date. The separate 30-day account-deletion commitment in Section 6.4 still applies after we verify your request, subject to the stated legal exceptions.

Complaint Channels:

If you believe that we have not adequately addressed your privacy concerns, you may lodge a complaint with the relevant data protection authority in your jurisdiction:

  1. EEA/UK: Your national data protection supervisory authority, or the UK Information Commissioner's Office if you are in the United Kingdom.
  2. California: California Attorney General's Office (https://oag.ca.gov/privacy).
  3. Australia: Office of the Australian Information Commissioner (OAIC) (https://www.oaic.gov.au).

15. Region-Specific Disclosures

15.1 California (CCPA/CPRA)

  1. Under the CCPA and CPRA, California residents have the right to know what personal data is collected, to request deletion of personal data, to correct inaccurate personal data, and to opt-out of the sale of personal data.
  2. We do not sell personal data. We have not sold, and do not intend to sell, personal data to third parties.
  3. In the 12 months preceding the Effective Date, we have not sold any personal data.
  4. California residents may submit requests under the CCPA/CPRA by contacting us at support@wanmeixiangsu.cn.
  5. We will not discriminate against you for exercising your rights under the CCPA/CPRA.

15.2 Nevada

  1. Under Nevada Revised Statutes Chapter 603A, Nevada residents have the right to opt-out of the sale of certain covered information.
  2. We do not sell personal data. Accordingly, no opt-out is necessary, but we honor this disclosure in compliance with Nevada law.

15.3 EEA, UK, and Switzerland

  1. For users in the EEA, the United Kingdom, and Switzerland, we process personal data in accordance with the General Data Protection Regulation (GDPR) and the UK GDPR, respectively.
  2. Your rights under these regulations are described in Section 6.2 of this Privacy Policy.
  3. International transfers are subject to the requirements and safeguards described in Section 7.
  4. You have the right to lodge a complaint with your local supervisory authority if you believe our processing of your personal data violates applicable data protection laws.

15.4 Brazil (LGPD)

  1. For users in Brazil, we process personal data in accordance with the Lei Geral de Protecao de Dados (LGPD - Law No. 13,709/2018).
  2. Under the LGPD, you have the right to confirm the existence of processing, access your personal data, correct incomplete or inaccurate data, anonymize, block, or delete unnecessary or excessive data, port your data to another service provider, delete personal data processed with your consent, obtain information about the sharing of your data, and revoke consent at any time.
  3. You may submit LGPD-related requests by contacting us at support@wanmeixiangsu.cn.
  4. The ANPD (Autoridade Nacional de Protecao de Dados) is the supervisory authority responsible for overseeing data protection in Brazil.

15.5 Canada

  1. For users in Canada, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
  2. Under PIPEDA, you have the right to access, correct, and withdraw consent for the collection, use, and disclosure of your personal data.
  3. You may submit privacy-related requests by contacting us at support@wanmeixiangsu.cn.
  4. If you believe we have not adequately addressed your privacy concerns, you may file a complaint with the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca).

15.6 Australia

  1. For users in Australia, we comply with the Privacy Act 1988 and the Australian Privacy Principles (APPs).
  2. Under the Privacy Act, you have the right to access, correct, and request deletion of your personal data in certain circumstances.
  3. You may submit privacy-related requests by contacting us at support@wanmeixiangsu.cn.
  4. If you believe we have not adequately addressed your privacy concerns, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au.

15.7 Thailand (PDPA)

  1. If you are in Thailand, the Personal Data Protection Act (PDPA) may give you rights to withdraw consent where processing is based on consent, access and obtain a copy of your personal data, request portability where applicable, object to certain processing, and request correction, deletion, or restriction in the circumstances provided by law.
  2. You may exercise these rights by contacting us at the email address in Section 14. We may need to verify your identity and may explain an applicable legal exception if we cannot fulfill a request. You may lodge a complaint with Thailand's Personal Data Protection Committee (PDPC).
  3. As stated in Section 7, personal data, including uploaded photographs, may be processed outside Thailand, including in China. Such transfers are subject to applicable Thai law. You may contact us for information about the recipients, purposes, destination, and safeguards applicable to your data.

15.8 Philippines (Data Privacy Act of 2012)

  1. If you are in the Philippines, the Data Privacy Act of 2012 may give you rights to be informed, access and rectify your personal information, object to certain processing, request erasure or blocking in applicable circumstances, obtain data portability where applicable, seek damages, and file a complaint with the National Privacy Commission (NPC).
  2. You may exercise these rights by contacting us at the email address in Section 14. We may verify your identity before responding. You may also contact the NPC through its official complaint channels at https://privacy.gov.ph/.
  3. Sections 5, 7, and 8 describe the categories of service providers, processing outside your country, and retention periods. You may request further information about how your photographs or other personal data are handled.

15.9 Vietnam (Law on Personal Data Protection)

  1. If you are in Vietnam, you may exercise the rights provided by Vietnam's Law on Personal Data Protection, including rights relating to notice, consent and withdrawal, access, correction, deletion, restriction or objection, and complaints, subject to statutory conditions and exceptions.
  2. You may contact us at the email address in Section 14 to make a request. We may verify your identity and will handle the request under applicable Vietnamese law.
  3. As stated in Section 7, personal data, including uploaded photographs, may be processed outside Vietnam, including in China. We will handle any applicable Vietnam-specific notice, consent, cross-border transfer, assessment, and recordkeeping requirements in accordance with law. You may request further information about the relevant recipients and processing locations.

15.10 India (Digital Personal Data Protection Act, 2023)

  1. If you are in India, the Digital Personal Data Protection Act, 2023, and its implementing rules, as their relevant provisions come into force, may give you rights to information about your personal data, correction, completion, updating and erasure, grievance redressal, and nomination.
  2. You may contact us at the email address in Section 14 to exercise an applicable right or make a grievance. We may verify your identity and will respond under the provisions then in force. Where required, we will provide information about the personal data processed, the purposes, how to withdraw consent, and how to escalate a grievance.
  3. As stated in Section 7, personal data may be processed outside India, including in China. Such processing is subject to applicable Indian law and any relevant government restrictions. You may request further information about the recipients and processing locations.
  4. As the relevant provisions of Indian law come into force, we will obtain verifiable parental or guardian consent before processing a child's personal data where required. We will not engage in tracking, behavioral monitoring, or targeted advertising directed at children where prohibited by applicable law. If the necessary age and consent process is not available, the child may not use the App until they meet the applicable age threshold.

16. Additional Information

The App may contain links to third-party websites, services, or platforms. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party services you access through the App. This Privacy Policy applies only to our collection, use, and disclosure of information through the App.

AI Content Disclaimer

The photo restoration, colorization, enhancement, and animation results generated by our AI services are provided for reference and personal enjoyment purposes only. AI-generated outputs may not perfectly replicate the original appearance of the subjects in your photographs. We make no guarantees regarding the accuracy, completeness, or historical fidelity of AI-processed results.

User-Generated Content (UGC)

  1. If you choose to share your restored or animated photos with other users or on public platforms, those photos may be visible to others.
  2. You grant us only the limited license described in Section 6.2 of our Terms of Service to process content for features you request, including storage and sharing you choose. Public marketing or advertising use of private photos or outputs requires your separate, affirmative permission.
  3. You and any other applicable rightsholders retain the rights you hold in photographs and other content uploaded to the App. Our limited license does not transfer ownership to us and ends for deleted content as described in the Terms and the deletion rules above.

Automated Decision-Making

We do not engage in automated decision-making, including profiling, that produces legal effects or similarly significant effects on you. Any processing of your personal data is conducted with appropriate human oversight where required by applicable law.

If you encounter any broken links in this Privacy Policy (including links to third-party privacy policies), please contact us at support@wanmeixiangsu.cn and we will provide you with the correct information or an updated link. We periodically review the links in this document to ensure their accuracy, but third-party URLs may change without notice.

This Privacy Policy is effective as of October 20, 2026 and applies to all users of the PhotoRenew application worldwide.