PicBuzz Privacy Policy

Effective Date: December 18, 2025

Welcome to the PicBuzz APP (hereinafter referred to as "this APP"). We highly value the protection of user privacy. This Privacy Agreement is intended to inform you about how we collect, use, store, share, and protect your personal information when you use the services of this APP (no registration or login process is required; an account will be automatically generated upon starting the service), as well as the rights you have regarding your personal information. Please carefully read and understand this Privacy Agreement before using the services of this APP. If you do not agree with any part of this Privacy Agreement, please do not use the services of this APP. By using the services of this APP, you acknowledge that you have fully understood and agree to all terms of this agreement.

1. Information We Collect

To provide you with better and more accurate picnic-themed video streaming services, we will collect necessary personal information and usage data based on the service functions you use. Details are as follows:

(1) Automatically Generated Account Information

After you start the service of this APP, the system will automatically and quickly generate a dedicated account (no registration or binding to any third-party account is required). We will collect basic device identification information necessary for account generation (used solely for unique account identification and does not contain personal sensitive information) to associate your usage records and ensure normal service connection and usage security.

(2) Video Content Stream Usage Information

1. Browsing and Interaction Data: When you use the video content stream function of this APP (including swiping up/down to switch videos, viewing categories such as picnic food preparation, location check-ins, decoration inspiration, and themed parties), we will collect your video browsing history (including viewing duration, watch progress) and interaction data (including liked, commented on, favorited, and shared video content and timestamps). This data will be used to analyze your interests and preferences to intelligently recommend quality picnic-themed videos for you.

2. Device and Network Information: To ensure the stability and smoothness of video playback, we will collect your device information (including device model, operating system version, device unique identifier) and network information (including network type, IP address, signal strength) for identifying playback issues and optimizing service performance.

(3) Content Creation and Publication Information

When you use the content creation and publication functions of this APP, we will collect the video content, titles, descriptions, and topic tags you add, to display your creative content within this APP, helping other users accurately locate your content through tags and increasing the exposure of your work. Simultaneously, we will collect device information and publication timestamps to trace content sources and ensure publication security.

(4) Social Interaction Information

1. Following Data: When you follow creators of interest, we will collect your following list information to push the latest works from followed creators to you, facilitating quick access to content you follow.

2. Private Message Data: When you use the private message function to communicate with other users, we will collect your private message content, send/receive times, and conversation partners to ensure normal private message communication, prevent spam, harmful information, and other non-compliant content, and maintain a safe social interaction environment.

(5) Permission-Related Information Collection

When you use specific functions of this APP, we may need to apply for relevant device permissions from you. We will only collect information through the following permissions with your explicit consent, and the collected information will only be used for the corresponding function scenarios:

1. Microphone Permission: When you use the feedback function to submit questions or suggestions (such as voice feedback), we will apply for microphone permission. This permission is only used to collect the voice information you actively record for feedback, to accurately understand your needs and handle related issues.

2. Camera and Album Permissions: When you use the content creation and publication functions to upload pictures or publish picture content (such as sharing picnic photos, adding picture materials to published works), we will apply for camera and album permissions. Camera permission is used to capture real-time pictures you need to publish; album permission is used to read the pictures you actively select from the device album. We will not automatically access or collect all pictures in the camera or album without your permission.

(6) Other Information

Other information you actively provide to us (such as contact details submitted when participating in community activities, feedback, etc.) will be collected and stored based on the content you provide.

2. How Information is Used

The information we collect will be used solely for the following purposes, in compliance with relevant privacy norms:

1. To Provide and Optimize Core Services: Including displaying and switching video content streams, intelligently recommending personalized picnic videos, supporting content creation and publication, and ensuring the normal operation of social interaction functions like following and private messaging.

2. To Improve Service Quality and User Experience: By analyzing collected user usage data, we understand user preferences for picnic-themed content, optimize video recommendation algorithms, and improve interface design, playback performance, etc., to provide you with more tailored services.

3. To Ensure Service Security: Identify device and network anomalies, prevent security risks such as content violations and network attacks, and maintain the normal operational order of this APP.

4. To Fulfill Compliance Obligations: In accordance with laws, regulations, regulatory requirements, or judicial rulings, cooperate with relevant authorities in information inquiries or provide necessary information.

5. Other Purposes with Your Explicit Consent: For example, if you agree to receive notifications about picnic activities or recommendations for quality content from us, we will use your contact information (such as the email or phone number you provided) to send you relevant content.

3. Sharing, Sale and Disclosure of Information

We are committed to strictly protecting your personal information and will not arbitrarily share, sell or disclose your information. We clearly inform you of your rights regarding the sharing and sale of personal information and the corresponding exercise methods as follows:

(1) Provisions on Information Sharing and Your Rights

1. Circumstances of Information Sharing: We will only share your personal information in the following circumstances:

a. With Your Explicit Consent: We will share necessary information with third parties you designate after obtaining your written or oral consent. Before sharing, we will clearly inform you of the name of the third party, the scope of shared information, and the purpose of use, and obtain your confirmation.

b. Sharing for Entrusted Processing: We may entrust professional service providers (such as server hosting providers, data analysis service providers) to process part of the information. These providers may only use the information within the scope of our authorization and must adhere to strict confidentiality obligations, and shall not use the information for other purposes. We will sign formal data processing agreements with these partners and conduct regular supervision and inspection on their information processing activities.

c. Disclosure Required for Compliance: We may disclose your information to relevant authorities as required by laws, regulations, administrative supervision departments, or judicial rulings; to protect the legitimate rights and interests of us and our users, or public interests, we may disclose necessary information to relevant parties when discovering violations or security risks involving you.

2. Your Right to Know About Information Sharing: You have the right to inquire about the details of your personal information shared by us, including the categories of shared information, the names of third-party recipients, and the purposes of sharing.

3. Right to Opt-Out of Information Sharing: Except for the information sharing that is required by laws and regulations or necessary for the provision of basic services, you have the right to opt out of other information sharing behaviors. Exercise Method: You can submit an opt-out application via the customer service email specified in "10. Contact Us", indicating "Opt-Out of Information Sharing Request", and providing your device's basic identification information for identity verification. We will complete the verification within 15 business days and stop the relevant information sharing behavior after successful verification.

(2) Provisions on Information Sale and Your Rights

1. Stance on Information Sale: We will never sell your personal information to any third party for monetary or other valuable consideration.

2. Your Right to Know About Information Sale: You have the right to inquire about whether we have sold your personal information. If you have any such inquiries, you can contact us through the channels specified in "10. Contact Us", and we will truthfully respond to you.

3. Your Right to Opt-Out of Information Sale: Since we do not engage in the behavior of selling personal information, there is no need for you to exercise the opt-out right for information sale. If there is any change in our information sale policy in the future, we will notify you in advance and provide a clear opt-out channel.

4. Storage and Protection of Information

(1) Information Storage

1. Storage Location: User-related data of this APP adopts a hybrid storage mode of local device and our official server. Some data (such as unposted content drafts, local cache of viewed videos) will be stored locally on your device; while data necessary for realizing core services (such as video content you published, following list, interaction records, basic device information for account association) will be encrypted and uploaded to our official server. We will not upload your personal information to any irrelevant third-party servers without your explicit consent. You can manage local stored data through device settings, and manage server-stored data through the functional modules in this APP.

2. Storage Period: The storage period of data varies by storage location: 1. Local storage data: The retention period depends on your device's local data settings and active operations (e.g., the data will be immediately removed if you actively delete local data). 2. Server storage data: We will retain it during the period when you use the services to ensure the normal operation of functions such as content display and social interaction. After you cancel your account or request data deletion, we will promptly delete or anonymize the server-stored data in accordance with relevant regulations, except for the data that needs to be retained in accordance with laws, regulations and regulatory requirements. You can delete local data through device operations, and apply for deletion of server data through the "Account Deletion" function or customer service.

(2) Information Protection

We have established a full-link security protection system for hybrid storage data: 1. Local storage security: We adopt technical measures such as local data encryption to prevent unauthorized access, use, modification or disclosure of local data in the device; you can further strengthen protection through your device's own security settings. 2. Server storage security: We use industry-mature security technologies and measures (including transmission encryption, storage encryption, access authority control, regular security audits) to protect server-stored data, and strictly restrict the scope of personnel accessing the data to ensure data security. 3. Data transmission security: All data uploaded from the device to the server will be encrypted to prevent data leakage, tampering or interception during transmission. We will not transfer your data to other devices or third parties without legitimate reasons or your consent.

5. General User Rights

In accordance with relevant laws, regulations, and privacy provisions, you have the following rights regarding your personal information:

1. Right to Access and Inquire: You can view your automatically generated account information, following list, published content, interaction history, and other personal information stored locally and on the server through the "Personal Center" in this APP. You also have the right to inquire about the details of information sharing and whether information is sold as stipulated in Section 3 of this Agreement.

2. Right to Modify and Correct: When you find your personal information is inaccurate or incomplete, you can modify the associated information of your automatically generated account through relevant functional modules in this APP (e.g., "Edit Profile"), or contact our customer service to correct relevant information.

3. Right to Delete: You can actively delete content, comments, favorites, and other local and server information you have published;

4. Right to Account Deletion: You can apply to delete your automatically generated account through the "Account Deletion" function in this APP or by contacting customer service. After account deletion, we will promptly handle your related personal information (deletion or anonymization). Core content stored locally can be retained or deleted at your discretion. After deletion, you will no longer be able to access this APP's services with that account.

5. Right to Withdraw Consent: You may withdraw your consent to the collection, use, or sharing of information at any time (e.g., unfollow, refuse to receive push notifications). However, after withdrawing consent, we may not be able to provide you with some services that rely on that information.

6. Additional Rights and Exercise Methods for Users in Specific Regions

For users in specific regions (including but not limited to the EU/European Economic Area, the UK, California, USA, Brazil, Virginia, USA, etc., hereinafter referred to as "Specific Regions"), in accordance with locally applicable privacy laws and regulations (such as GDPR, CCPA/CPRA, VCDPA, LGPD, etc.) and relevant service requirements, users in these regions enjoy the following additional rights besides the general rights stipulated in Section 5 of this agreement. Specific exercise methods are as follows:

(1) Legal Basis for Data Processing (Applicable to Users in the EU/European Economic Area and Other Regions Requiring Such Disclosure)

We strictly abide by the provisions of relevant regional data protection laws and regulations when processing your personal information, and ensure that every data processing activity has a legal basis. The main legal bases for our processing of your personal information include the following aspects:

1. Consent: For data processing activities that are not necessary for the provision of basic services, we will obtain your explicit consent in advance. You have the right to withdraw your consent at any time, and the withdrawal of consent will not affect the legality of the data processing activities carried out before.

2. Performance of Contracts: When it is necessary to process your personal information to perform the service agreement implicitly formed by your use of our services (such as providing account services, displaying video content, etc.), we will process the data based on the need to perform the contract.

3. Legitimate Interests: When processing your personal information is necessary to safeguard our legitimate business interests (such as optimizing service functions, improving user experience, preventing fraud, ensuring service security, etc.), and does not violate your legitimate rights and interests, we will process the data based on legitimate interests.

4. Compliance with Legal Obligations: When it is necessary to process your personal information to comply with the provisions of laws and regulations (such as responding to legal inquiries, fulfilling regulatory obligations, etc.), we will process the data based on the need to comply with legal obligations.

(2) Right to Data Portability

You have the right to request that we provide you with the personal data generated during your use of this APP's services (such as aggregated versions of your creative content, interaction records, and other data stored locally and on the server) in a structured, commonly used, and machine-readable format, and you have the right to transmit this data to a third party of your designation. Exercise Method: Submit an application via the customer service email specified in "10. Contact Us," indicating "Data Portability Request," and provide your device's basic identification information (for identity verification) and the specified method/third-party information for receiving the data. We will provide the data file within 30 business days after successful verification.

(3) Right to Restrict or Object to Data Processing

1. Right to Restriction: You have the right to request that we restrict the processing of your relevant personal data (only retaining storage functions, suspending operations like analysis and association) when you contest the accuracy of the data, the processing is unlawful, or you have objected to processing while the dispute is pending verification.

2. Right to Object: You have the right to object at any time to data processing based on legitimate interests (such as personalized recommendations). We will immediately cease such processing and adjust the service mode (e.g., turn off personalized recommendations and display general content instead). Exercise Method: Contact customer service stating your request. We will provide feedback on the processing result within 15 business days; objection to personalized recommendations takes effect immediately upon submission.

(4) Right Not to be Subject to a Decision Based Solely on Automated Processing

You have the right to object to decisions based solely on automated processing (such as recommendation algorithms) that produce legal effects concerning you or similarly significantly affect you. Personalized recommendations in this APP are solely for service optimization and do not have legal effect. If you believe recommendation behavior significantly affects you, you can request manual review. Exercise Method: Contact customer service indicating "Request for Manual Review of Automated Decision-Making." We will arrange a manual assessment and adjust the recommendation logic within 20 business days.

(5) Additional Rights Under Regional Laws

1. For California Residents (Applicable to CCPA/CPRA): You have the right to opt out of the sale of personal data (though we do not sell your data) and targeted advertising; you have the right to request deletion of your personal information (subject to legal exceptions); you have the right to know the categories and details of personal information we collect, use, share or sell; you have the right to exercise your privacy rights without facing discrimination.

2. For Virginia Residents (Applicable to VCDPA): You have the right to opt out of targeted advertising, sale of personal data, and profiling that produces legal or similarly significant consequences; you have the right to appeal our decision if we deny your rights request.

3. For Brazilian Residents (Applicable to LGPD): You have the right to inquire about the organizations with whom we share your data, the reasons for sharing, and the scope of such sharing; you have the right to revoke consent for specific data processing activities at any time; you have the right to file a complaint with the National Data Protection Authority (ANPD) if you believe your data rights have been violated.

(6) Additional Notes on Exercising Rights

1. Identity Verification: To prevent abuse of your rights, when exercising the above rights, we may require you to provide information such as device identifiers, usage record fragments, etc., for identity verification. Verification methods will follow the principles of minimal necessity and security, without collecting additional sensitive information.

2. Free of Charge and Remedies: Exercising the rights specified in this section is free of charge. If you believe we have not lawfully responded to your rights request, you may complain to the local data protection supervisory authority (e.g., EDPB in the EU, AG in California, ANPD in Brazil, etc.) or seek recourse through dispute resolution channels designated by relevant authorities.

3. Data Breach Notification: In the event of a personal data breach involving users in Specific Regions that is likely to result in a high risk to your rights, we will notify you via in-app pop-ups, email (if you have provided one), or designated channels within 72 hours of discovery, explaining the breach's content, risks, and countermeasures.

7. Minors' Privacy Protection

This APP strictly adheres to relevant privacy requirements and globally applicable laws and regulations on minors' data protection (including but not limited to the U.S. Children's Online Privacy Protection Act (COPPA), the EU GDPR's children's provisions, Google Play's Families Policy, etc.), implementing strict restrictions and special protection for minors' use of services. Specific details are as follows:

Age Applicability Definition: According to different regional regulations and relevant requirements, this APP does not provide services to "children" (generally defined as under 13 years old, or under 16 in regions like the EU/European Economic Area; specific definitions are subject to applicable laws in the user's location) and does not actively collect any personally identifiable information of children (including name, age, contact information, location, etc.).

Usage Prevention and Guidance: Upon first launch, this APP will display an age confirmation prompt, guiding users to truthfully declare their age. If it is detected or there is reasonable suspicion that a user is a child, service usage will be immediately restricted (including blocking core functions like content publication, social interaction, and personalized recommendations), retaining only basic exit and contact guardian channels.

Handling of Minor's Accidental Use: If a guardian discovers that a minor (especially a child) has accidentally used this APP, they may submit a written application via the customer service email specified in "10. Contact Us" (throwingmastr@gmail.com). The application must include guardian identity information (e.g., ID scan), proof of guardianship, and the minor's device basic identification information. We will complete identity verification within 7 business days of receiving the application. Upon verification, we will immediately: ① Permanently stop providing all services to that minor; ② Comprehensively delete all related data of the minor stored locally on the device and on our official server (including browsing history, creative content, interaction information, account information, etc.); ③ Provide the guardian with the processing result and data deletion confirmation.

Guardian Rights and Assistance: Guardians have the right to submit inquiries regarding whether a minor is using this APP and the storage status of related data. They can submit queries and supporting documents via the above email. We will provide free inquiry services and cooperate in implementing data protection measures. If it is discovered that this APP has accidentally collected a child's information, the guardian can request immediate deletion and explanation. We will respond and rectify within 3 business days.

Compliance Commitment: We will not disclose minors' personal information to any third party, nor use minors' data for any commercial purposes. We have established a dedicated minor data protection verification mechanism, regularly checking for risks of accidental child use and data retention, ensuring compliance with relevant minors' privacy protection requirements.

8. Updates to the Privacy Agreement

As this APP's services upgrade and in response to changes in laws, regulations, and relevant privacy policies, we may update this Privacy Agreement. When significant changes occur to this Privacy Agreement, we will notify you via in-app pop-ups, announcements, etc. You can view the updated Privacy Agreement at any time. If you continue to use this APP's services after the Privacy Agreement is updated, it signifies your acceptance of all the updated terms.

9. Data Controller and Data Protection Officer (DPO) Information

(1) Data Controller Information

PicBuzz acts as the data controller responsible for managing your personal information in connection with our services. If you have any questions or concerns regarding the handling of your personal data, please reach out to us using the following contact details:

- Email: throwingmastr@gmail.com

- Address: Room 502C, 5F, Ho King Commercial Centre, 2 - 16 FA YUEN STREET, YAU TSIM MONG DISTRICT, KOWLOON

(2) Data Protection Officer (DPO) Information

If you have questions, concerns, or requests related to the processing of your personal data, or if you wish to learn more about your privacy rights, you may contact our Data Protection Officer (DPO), who also serves as the data controller. Contact details are as follows:

- Name: Mateo Rossi

- Email: throwingmastr@gmail.com

Our DPO is dedicated to addressing your inquiries and ensuring compliance with applicable data protection laws.

10. Contact Us

If you have any questions, comments, suggestions regarding this Privacy Agreement, or need to exercise your personal information rights, please contact us via:

Customer Service Email: throwingmastr@gmail.com

We will process and respond to your feedback promptly (generally within 15 business days; for complex matters, we will notify you of the progress and expected processing time).

This Privacy Agreement is effective as of the date of its publication.

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