Privacy Policy

Last Updated: 25/12/2025

Chongqing Le Xiaobutu Technology Co., Ltd. (“we”, “us”, or “our”) has developed and operates the SpriteAi application (“SpriteAi” or the “App”) as a free software application. This Service is made available to you by Chongqing Le Xiaobutu Technology Co., Ltd. at no monetary cost and is offered strictly in accordance with the terms set out in this Privacy Policy.

This Privacy Policy explains, in a clear and transparent manner, how we collect, use, store, disclose and otherwise process your personal information when you access or use our Service. It is important that you read this document carefully so that you fully understand how and why your data is processed.

By downloading, installing, accessing or using our Service, you acknowledge that you have read, understood and agreed to be bound by this Privacy Policy. You also agree that we may collect and use your information as described herein for the purpose of providing and improving the Service. We will not use or disclose your personal information to any third party except as explicitly described in this Privacy Policy or as required by applicable law.

Unless otherwise defined in this Privacy Policy, the terms used in this document have the same meaning as in our Terms and Conditions, which are available within SpriteAi.

Legal Basis for Processing

We process your personal information based on the following legal grounds, as applicable under relevant data protection laws:

• Consent: Where you have provided your explicit consent for specific processing activities;
• Contract Performance: Where processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract;
• Legitimate Interests: Where processing is necessary for our legitimate interests, such as improving our services, ensuring security, and preventing fraud, provided that such interests are not overridden by your rights and interests;
• Legal Obligations: Where processing is necessary for compliance with a legal obligation to which we are subject;
• Vital Interests: Where processing is necessary to protect the vital interests of you or another natural person.

Information Collection and Use

To enable the full functionality of the Service and to provide you with a reliable and secure user experience, we may request that you provide certain personally identifiable information while using the App. The categories of information we may request, collect and process are limited to what is necessary for the purposes set out in this Privacy Policy.

The types of personal information we may collect include, but are not limited to:

• Account information (such as username, email address, and password);
• Device information (such as device identifiers, operating system, and device model);
• Usage data (such as features used, time spent, and interaction patterns);
• Content data (such as photos, images, and other content you upload or create);
• Technical data (such as IP address, browser type, and network information).

Any personal information that we collect will be handled with care and processed in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable privacy laws. We will retain such information only for as long as it is necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law. Generally, we retain personal information for the duration of your use of the Service and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods may vary depending on the type of information and the purpose for which it was collected.

The App may integrate third‑party services that, in the course of providing their functionality, may collect information that could be used to identify you. These third parties operate independently from us and are responsible for their own privacy practices.

For your convenience, below is a link to the privacy policy of a key third‑party service provider used by the App:

• Google Play Services

Log Data

When you use the Service, in the event that an error occurs within the App, we may collect data and information from your device (via third‑party products) referred to as “Log Data”. Log Data may include, but is not limited to, details such as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App at the time of the error, the time and date of your use of the Service, and other technical statistics relevant to diagnosing and resolving issues.

This Log Data is collected and processed solely for the purposes of monitoring the performance of the Service, identifying and correcting technical problems, maintaining security, and improving the overall quality and stability of the App.

Cookies

Cookies are small data files that are commonly used as anonymous unique identifiers. They are transmitted to your browser by websites you visit and may be stored on your device’s internal memory or other storage.

The Service itself does not intentionally deploy or manage first‑party “cookies”. However, the App may include or rely on third‑party code, software development kits (SDKs), or libraries that use cookies or similar tracking technologies in order to collect information and enhance their services. Such technologies may, for example, help measure usage, prevent fraud, or improve service reliability.

You may choose to configure your device or browser to accept or reject cookies, or to notify you when a cookie is being sent. Please note that if you disable or refuse cookies, certain features or portions of the Service may not function properly or may become unavailable.

Service Providers

We may engage carefully selected third‑party companies and individuals to perform functions on our behalf in connection with the provision and operation of the Service. These third‑party service providers may be engaged for, including but not limited to, the following purposes:

• To facilitate the provision and maintenance of the Service;
• To provide the Service on our behalf (for example, hosting, storage or infrastructure services);
• To perform services related to the core functionality of the App; or
• To assist us in monitoring, analyzing and improving how the Service is used.

Where such third parties have access to your personal information, they are permitted to use it solely for the purpose of performing the tasks assigned to them on our behalf and are contractually obligated to maintain the confidentiality and security of your information and to refrain from using it for any other purpose.

Security

We recognize the importance of the personal information entrusted to us and we are committed to protecting it. We implement commercially reasonable and appropriate technical and organizational measures designed to safeguard your personal information against unauthorized access, disclosure, alteration or destruction.

However, you should be aware that no method of transmission over the internet, and no method of electronic storage, is completely secure or error‑free. While we strive to use all reasonable means to protect your personal information, we cannot and do not guarantee its absolute security. You use the Service and provide information to us at your own risk.

Links to Other Sites

The Service may contain links to websites or services that are operated by third parties and are not under our control. If you click on a third‑party link, you will be directed to that third‑party site or service. We strongly encourage you to review the privacy policies and terms of any third‑party websites or services that you visit.

We do not endorse, and are not responsible or liable for, the content, privacy practices, data‑processing activities or security measures of any third‑party sites or services. Your interactions with such third parties are solely between you and the relevant third party.

Children's Privacy

Our Service is not directed to, and is not intended for use by, individuals under the age of 13 (or under the age of 16 in the European Economic Area, or such other age as may be specified by applicable law in your jurisdiction). We do not knowingly collect or solicit personally identifiable information from children below the applicable minimum age. If we become aware that we have inadvertently collected personal information from a child below the applicable minimum age without appropriate parental consent, we will take prompt steps to delete such information from our records in accordance with applicable law.

If you are a parent or legal guardian and you believe that your child has provided personal information to us in connection with the Service, please contact us using the details provided in the "Contact Us" section so that we can investigate and take appropriate action, including deletion of such information if required by law.

Your Rights and Choices

Depending on your jurisdiction and applicable data protection laws, you may have certain rights regarding your personal information. These rights may include:

• Right of Access: You have the right to request access to and obtain a copy of the personal information we hold about you;
• Right of Rectification: You have the right to request correction of inaccurate or incomplete personal information;
• Right of Erasure: You have the right to request deletion of your personal information under certain circumstances, subject to applicable legal requirements;
• Right to Restrict Processing: You have the right to request restriction of processing of your personal information in certain situations;
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another controller, where technically feasible;
• Right to Object: You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes;
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable data protection laws.

To exercise any of these rights, please contact us using the contact information provided in the "Contact Us" section. We will respond to your request within the timeframes required by applicable law, typically within 30 days, though this may be extended in complex cases. We may need to verify your identity before processing your request to ensure the security of your personal information.

Data Transfers and International Processing

Your personal information may be transferred to, stored, and processed in countries other than your country of residence, including but not limited to the United States, China, and other jurisdictions where our service providers or we operate. These countries may have data protection laws that differ from those in your jurisdiction.

When we transfer personal information across borders, we implement appropriate safeguards to ensure that your personal information receives an adequate level of protection, including:

• Standard contractual clauses approved by relevant data protection authorities;
• Other legally recognized transfer mechanisms, such as adequacy decisions or binding corporate rules;
• Ensuring that third-party service providers are contractually bound to protect your personal information in accordance with applicable data protection standards.

By using the Service, you consent to the transfer of your personal information to these countries and jurisdictions.

Data Breach Notification

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority without undue delay, in accordance with applicable data protection laws. Such notification will include, where feasible, information about the nature of the breach, the categories and approximate number of data subjects affected, the likely consequences of the breach, and the measures we have taken or propose to take to address the breach.

Face Data Policy

For what purposes are we collecting this information?

To provide you with “similar face” effects and other face‑processing functionalities, the App must temporarily identify and analyze facial feature points in the photos you choose to upload. The process generally operates as follows:

• You upload or transmit your photo to our server via the App.
• Our server analyzes your photo and generates the necessary facial data processing results.
• The App automatically combines the facial data processing results with specific materials or effects to generate the final output that you see.
• The photo and the associated processing data are temporarily stored in encrypted storage hosted on Amazon Web Services (AWS) solely for the duration necessary to complete the synthesis process, after which your photo and related data are automatically deleted.

Will the data be shared with any third parties? Where will this information be stored?

Facial photos and related processing data are not shared with any third parties for their own purposes such as marketing, advertising or user profiling. The photos you upload and the corresponding processing data are used exclusively to provide the requested effect and are deleted once the processing is complete, as described above. Temporary storage occurs only within our secure, encrypted infrastructure (for example, on AWS) and is subject to strict access controls.

Changes to This Privacy Policy

We may revise or update this Privacy Policy from time to time in order to reflect changes in our practices, the Service, or applicable legal requirements. Any such changes will be effective when the revised Privacy Policy is posted on this page, unless otherwise specified. We encourage you to review this Privacy Policy periodically so that you remain informed about how we handle your personal information.

Your continued access to or use of the Service after any changes to this Privacy Policy have been posted will constitute your acknowledgment of the updated policy and your agreement to be bound by the revised terms.

Data Protection Officer

If you are located in the European Economic Area or have questions specifically related to data protection matters, you may contact our Data Protection Officer (if applicable) or our privacy team at the contact information provided below.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, our data‑processing practices, or to exercise your rights as described above, please contact us at:

We will use reasonable efforts to review and respond to your inquiry in a timely and appropriate manner, typically within 30 days of receipt, in accordance with applicable data protection laws. If your request is complex or we receive a high volume of requests, we may extend this timeframe and will inform you of any such extension.