Privacy Policy

This Privacy Policy (the “Privacy Policy”) for NOCAM APP describes how NOCAM TECHNOLOGIES INC (“we”, “us”, or “our”) collects, uses, and discloses your personal information when you visit or use our services, make a purchase through the NOCAM App (the “App”), or otherwise communicate with us in connection with the App (collectively, the “Services”). For purposes of this Privacy Policy, “you” and “your” refer to you as a user of the Services, whether you are a user, an App visitor, or another individual whose information we have collected in accordance with this Privacy Policy.

In this Privacy Policy, the terms “personal information” and “personal data” are used interchangeably and refer to information relating to an identified or identifiable natural person. Under applicable U.S. laws, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Please read this Privacy Policy carefully. By accessing or using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use any of the Services.

The App is intended for use solely by adults (or by individuals who have reached the age of majority under applicable laws).

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we do, we will post the revised Privacy Policy within the App, update the “Last Updated” date, and take any other steps required by applicable law.

How We Collect Your Personal Information

In order to provide the Services, we collect personal information about you from a variety of sources, as described below. The categories of information and the specific information we collect and use vary depending on how you interact with us.

In addition to the specific purposes described below, we may use the information we collect about you to communicate with you, to provide or improve the Services, to comply with applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

We collect the following categories of personal information, depending on how you interact with the Services.

1.1 Information that you directly submit to us through our Services

Account and Registration Information. When you create an account or log in, we collect your email address and password. We also generate and process information associated with your account, including your user ID, login credentials, and login channel, in order to create and verify your identity, maintain your login session, and support registration verification and password recovery/reset.

Third-Party Login Information. If you choose to log in with your Google or Apple account, we receive an identity token (id_token) from the relevant platform, which may include your email address and other information provided by that platform. Upon successful login, we create or link your account profile, including your user ID, nickname, avatar, and email address.

Profile Information. When you edit your profile, we collect your nickname, avatar image, and the corresponding storage URL of your avatar, in order to display and update your profile.

Image and Video Information. The App provides automated photography and AI-assisted shooting features, including AI-based automatic subject detection, and automatic capture of suitable moments. To enable these features, we collect:

• Real-time video streams (including low-frequency preview frames). During shooting, your device continuously captures real-time preview frames, which are temporarily cached locally on your device for on-device real-time analysis (such as pose and subject analysis). In addition, to enable AI voice-guided shooting and scene understanding, we may upload compressed, low-frequency preview frames to our cloud services and/or to third-party real-time AI voice and image-analysis services that we engage as service providers (such as Google Gemini Live). Such uploaded frames are used solely for real-time interaction, shooting guidance, and scene assessment. We do not retain these frames in the form of complete, continuous high-definition video recordings on our servers. Uploaded frames are retained only for the duration necessary to complete real-time processing. Locally cached frames are cleared upon completion of analysis or expiration of the cache period;
• Photographs and images: the photos you capture, or that are automatically captured by the App, together with associated upload metadata (file name, content type/format, file size, shooting scene identifier, user ID, and session/event ID), are uploaded to our cloud servers for AI-assisted photo selection, scene understanding, and image post-processing. Depending on the processing pipeline, we may also upload corresponding thumbnails or original images as needed for processing, delivery, and in-app display. After processing, we generate a storage URL for the processed image and deliver the final image to you. Uploaded photographs are retained for 7 days, after which they are deleted;
• Local album information: to display the shooting and delivery timeline on your device, we process album metadata locally on your device (such as photo ID, session identifiers, timestamps, source/category, local file path, image dimensions, selection/editing status, and processed-image URL). When you choose to export, the final images will be saved to your device’s system album.

Audio Information. The AI shooting-guidance feature provides simple shooting and posing suggestions through voice or on-screen prompts. To enable this feature, we collect real-time audio streams in order to understand and respond to your spoken instructions. Such audio is transmitted to third-party real-time AI voice services that we engage as service providers for real-time processing only. We do not store your guidance-session audio for recording or playback purposes; audio is retained only for the duration necessary to complete the real-time interaction.

AI-Generated and AI-Processed Content. The Services use artificial intelligence to make autonomous decisions and to process or enhance your content, including basic image-quality optimization, light/color optimization, facial-skin/feature/body retouching, background blur, AI cropping and AI outpainting for composition, stylized filters, scene recognition, aesthetic scoring, and automatic shutter decisions. In some scenarios, the Services may use AI to generate content based on your actual photographs. Such AI generation is based on real images and does not create wholly fictitious individuals or fabricated content.

Face and Body Detection (No Biometric Data Collected). Certain features of the App—such as subject detection, automatic capture, and composition assistance—detect the presence and location of persons within the camera frame. This processing does not measure, map, or analyze facial geometry or extract facial landmarks or keypoints, and does not create, derive, or store any faceprint, facial-geometry template, feature vector, or other biometric identifier capable of identifying any individual.

1.2 Information that we collect automatically

Device and Technical Information. Device brand and model, operating system type and version, ROM version (Android), screen resolution, device identifiers (Android: ANDROID_ID; iOS: identifierForVendor), locale settings, network type, App version and build information, App state, App launch identifier, and trace session identifier. Certain of the foregoing is transmitted as common parameters with network requests to support authentication, troubleshooting, configuration delivery, and the operation of the Services.

Usage Information. Information about how you use the Services, such as features used, page names, deeplink sources, and business event parameters (such as events relating to image uploads, album operations, and push-notification interactions). Certain sensitive fields are hashed on the client side before transmission. We also process identifiers used for A/B experiment assignment and remote configuration delivery, in order to conduct product experiments and staged feature rollouts.

Crash and Diagnostic Information. Crash stack traces, non-fatal exceptions, and custom diagnostic context (such as device health status, memory, and battery/thermal state), which may be associated with your user ID, in order to identify crashes and stability issues.

Product Trace Information. Structured trace data relating to shooting, decision-making, and conversation processes (including capture/decision/pipeline records, and chat traces which may contain voice transcripts and assistant response text), together with device context (device model, operating system, memory, battery level, etc.), used for product analytics, troubleshooting, and experience optimization.

Push Notification Information. Push tokens (FCM / APNs), platform type, and notification-display fields (such as title, message ID, and action URL), which may be linked to your user ID, in order to deliver notifications to your device.

Purchase Information. When you make in-app purchases, we collect your user ID, transaction ID, store transaction receipts (signedPayload), and entitlement query results, in order to verify the authenticity of purchases and activate or query your entitlements. Your payment card information is processed directly by the Apple App Store or Google Play and is not collected by us.

Sharing Information. When you voluntarily choose to share content (such as images, links, or text) to third-party social platforms (such as Facebook, WeChat, or TikTok), we process the content you choose to share. The SDKs of such third-party platforms may collect device information and sharing-behavior information in accordance with their own privacy policies.

How We Use Your Personal Information

We use the personal information we collect for the following purposes.

• We use your information to create and manage your account, authenticate your login, operate the App, and deliver the core photography and editing features you request, including automated photography, AI-assisted shooting guidance, and AI selection and post-processing of your photos.
• We process real-time video streams, image data, and body/pose information to provide AI-based subject detection, automatic capture of suitable moments, scene recognition, and automatic shutter decisions.
• We process real-time audio and video streams to understand your spoken instructions, respond to you, and provide shooting and posing suggestions through voice or on-screen prompts.
• We process your image data (excluding facial keypoint detection) to provide basic image-quality optimization, light/color optimization, facial-skin/feature/body retouching, background blur, AI cropping and AI outpainting, stylized filters, aesthetic scoring, and related editing features, and, in certain scenarios, to generate enhanced content based on your actual photographs.
• The Services use artificial intelligence to make automated decisions during the shooting process (such as automatic capture of suitable moments, and automatic shutter decisions) and to process or enhance your content as described above. In certain scenarios, the Services may use AI to generate or synthesize content based on your actual photographs; for example, AI outpainting may generate image areas that do not exist in the original photograph. Where required by applicable law, AI-generated or AI-modified content will include appropriate disclosures. We do not use AI to create wholly fictitious individuals.
• Where applicable, we process facial and body related information (such as face detection, human-body detection, and pose estimation) solely to operate the photography and guidance features described above. We do NOT use such information to identify, verify, or match the identity of any individual.
• We use your contact information to send you service-related notices, respond to your inquiries, and provide customer support.
• We use information to protect the security and integrity of the Services, detect and prevent fraud or abuse, and protect the rights, property, and safety of us, our users, and others.
• We use information to comply with applicable laws, regulations, and legal processes, and to enforce our terms of service and other applicable agreements.

Cookies and Similar Tracking Technologies

Our App is a mobile application and does not rely on traditional browser cookies for its core functionality. However, we and our service providers use other tracking technologies that serve purposes similar to cookies in order to operate, analyze, and improve the Services. These technologies may include device identifiers, software development kits, local storage and caching technologies.

We use these technologies to authenticate users, remember your preferences and settings, maintain the security of the Services, understand how the Services are used, and maintain and improve the performance of our features.

Depending on your device, you may be able to limit or reset advertising identifiers, or otherwise manage tracking, through your device settings. On supported platforms, we will request your permission to track in accordance with applicable platform requirements.

To the extent the App displays web-based content through an in-app browser (WebView), or you access our related website, traditional cookies and similar technologies may be used in that web content.

How We Disclose Your Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

• Our affiliates. We may disclose personal information to our corporate affiliates for purposes consistent with this Privacy Policy.
• Business Transfers. In connection with, or during negotiations of, any merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, we may disclose personal information to the relevant parties and their advisors.
• Service providers. We disclose personal information to third-party service providers and vendors who perform services on our behalf, such as cloud hosting and storage, data analytics, crash reporting, customer support, third party AI and technology provider and communications. These service providers are permitted to use your personal information only to provide services to us and are contractually required to protect it.
• Legal Compliance and Protection of Rights. We may disclose personal information if we believe in good faith that such disclosure is necessary to: comply with applicable laws, regulations, legal processes, or governmental requests; enforce our terms of service and other agreements; detect, prevent, or address fraud, security, or technical issues; or protect the rights, property, or safety of us, our users, or others.
• Professional advisors: Where permitted or required by applicable law or regulation, we may also have to transfer your personal information to external professional advisors as necessary to defend our legal interests.
• Other lawful reasons provided by law: We may share your personal information with third parties based on other legitimate reasons authorized by applicable law.
• With Your Consent: We may disclose personal information for any other purpose disclosed to you at the time we collect the information, or otherwise with your consent.

We require recipients of your personal information to handle it in a manner consistent with this Privacy Policy and applicable law. We do not authorize our service providers to use or disclose your personal information except as necessary to perform services on our behalf or to comply with legal requirements.

The Third-Party Websites and Links

The Services may contain links to websites or other online platforms operated by third parties. If you choose to follow a link to any site that is not affiliated with or controlled by us, we encourage you to review that site’s privacy and security policies, as well as its other terms and conditions, before providing any information. We do not control, guarantee, or assume responsibility for the privacy or security practices of such third-party sites, nor for the accuracy, completeness, or reliability of any information made available on them.

Please also be aware that any information you provide in public or semi-public venues—including information you share on third-party social networking platforms—may be viewable by other users of the Services and/or by users of those third-party platforms, and may be used by third parties without restriction.

The presence of a link on the Services does not, in and of itself, constitute our endorsement of the linked platform, its content, or its owners or operators, except as expressly stated within the Services.

Third-Party AI and Cloud Service Providers

To deliver the AI features of the App, we transmit certain personal information—including photographs, image content, voice audio, voice transcripts, and associated metadata—to the third-party service providers, who process such information as our service providers / processors under written agreements that (i) restrict use of the data to providing services to us, (ii) prohibit sale of the data, and (iii) prohibit combining the data with data from other sources except as permitted by law.

AI Model Training

We do not provide your personal information to any third-party AI model provider for the purpose of training, fine-tuning, or otherwise improving their foundation models. In addition, we require our third-party AI model service provider to retain inputs strictly to the period necessary to provide the requested service to us (which, under our current data-processing terms, does not exceed 30 days for monitoring, abuse-prevention, and quality purposes), and to delete such inputs upon expiration of that retention period.

Face Detection and Biometric Data Processing

This section explains how the App handles face-detection information and addresses U.S. state laws that govern biometric and health-related data.

Scope of face detection. The App uses Google LLC’s open-source MediaPipe face-detection SDK, which runs on-device only and which the App configures in detection-only mode. The only output produced by the SDK is the coordinates of a rectangular bounding box surrounding any detected face; the App does not extract facial landmarks, keypoints, or other facial-geometry measurements, and does not create, derive, or store faceprints, facial-geometry templates, feature vectors, or any other biometric templates used to identify an individual.

Processing of the bounding-box coordinates. The bounding-box coordinates are used solely for two in-app purposes: (i) cropping assistance (determining where to crop a photograph when the user requests image cropping using the thumbnail-size selection); and (ii) face-area ratio calculation (determining face-to-frame ratio, used for composition scoring in the on-device thumbnail-size selection). The App does not persistently store the bounding-box coordinates on the device. The coordinates are transmitted to our cloud only as part of the image-retouching workflow described under “How We Use Your Personal Information” above, where they are forwarded to our third-party AI model service provider as a cropping/ratio input together with the uploaded image. The cloud-side copy of the coordinates is deleted promptly after the retouching step, and is not retained beyond that step.

What the App does not do. For clarity, the App: (i) does not perform facial recognition and face matching; (ii) does not build or maintain a faceprint database, gallery, or watchlist; (iii) does not use face-detection information to infer characteristics about an individual user; and (iv) does not use face-detection information for targeted advertising or profiling.

Minors

The Services are intended solely for use by adults (or individuals who have reached the age of majority under applicable law). The Services are not directed to children, and we do not knowingly collect, use, or disclose personal information from children under the age of 13.

Children under the age of 13 are not permitted to use the Services. We do not knowingly permit such children to create an account, provide personal information, or otherwise use the Services.

If we become aware that we have inadvertently collected personal information from a child under the age of 13 without verifiable parental consent, we will take reasonable steps to delete such information as soon as practicable. If you are a parent or legal guardian and believe that we may have collected personal information from your child, please contact us at contact@nocam.ai, and we will promptly investigate and, where appropriate, delete the information.

Security and Retention

We employ multiple methods of data protection to minimize the risk of misuse, unauthorized access or disclosure, and loss of data. These safeguards may include pseudonymization, data encryption, data hashing, and permission-control technologies. When our personnel access your personal information, they do so on secured networks and under fine-grained permission controls that limit who can access your information. Information you provide to us is encrypted and stored with third-party storage providers. With respect to your photos and any face- or body-related information processed through the photography, guidance, and post-processing features, we apply enhanced access controls and restrict internal access to authorized personnel only.

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, information you transmit to us may not be secure while in transit. We recommend that you do not use insecure channels to send sensitive or confidential information to us.

Retention. How long we retain your personal information depends on a number of factors, such as whether we need the information to maintain your account, provide the Services, comply with legal obligations, resolve disputes, or enforce our applicable contracts and policies. With respect to your photos and any face- or body-related information:

• where such data is processed locally on your device and is not uploaded to our servers, it remains on your device, and you may delete it at any time through the App;
• where such data is uploaded to our servers to provide a feature you have requested, we will retain it only for as long as necessary to provide that feature (and for uploaded photographs, for 7 days), after which it will be deleted or de-identified; and
• upon deletion of your account, or upon your request, we will take steps to delete such data within a reasonable period, subject to any applicable legal retention obligations.

Your Rights

Subject to applicable law and certain legal limitations, you may have the following rights regarding your personal information. You can exercise these rights through the options provided in the App or by contacting us using the details in the “Contact Us” section below.

• Right to know/Access. You may request information about the personal information we have collected about you, including the categories of information, the sources, the purposes for collecting or sharing it, the third parties with whom we share it, and a copy of the specific personal information we hold about you.
• Right to Delete: You may have the right to request that we delete personal information we maintain about you.
• Right to Correct: You may have the right to request that we correct inaccurate personal information we maintain about you.
• Right to Take Your Data with You / to Request A Copy of Your Data: You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Right to Withdraw Device System Permissions. You may have the right to withdraw the permissions previously granted to the App to access your device’s camera, photo library, or microphone at any time through your device operating system settings.
• Right to Revoke AI Processing and Facial Data Authorization. You may have the right to revoke your consent for automated facial analysis and algorithmic processing at any time. This allows you to exercise control over AI-driven features by utilizing the “Revoke AI Burst Authorization” toggle to immediately terminate the underlying facial structure scanning and selection logic.
• Right to Clear Local Algorithmic Cache. You may have the right to request or execute the immediate deletion of transient biometric data or temporary residual photos stored on your local device.
• Right to Opt-out Sales of Your Data. You have the right to direct us not to sell your personal information to third parties. This allows you to exercise control over who has access to your data and how it’s used. When you exercise this right, we will cease selling your information upon receiving your request, subject to certain exceptions permitted by applicable privacy laws.
• Right to Opt-out Targeted Advertising or Profiling. You may have the right to opt-out targeted advertising (as defined under applicable privacy law) or profiling (as defined under applicable privacy law) if we process your personal information for such use.
• Appeals. Where required by law, you may appeal a decision we make regarding your request by following the instructions in our response to you.
• Non-discrimination. We will not discriminate against you for exercising any of these rights.
• Verification and Authorized Agents. Before responding, we may need to verify your identity using information such as your email address or account details. You may also use an authorized agent to submit a request on your behalf; we may require proof of authorization and may ask you to verify your identity directly with us. We will respond within the time period required by applicable law.

Advertising. At present, we do not send you promotional advertisements. If this changes, you will be able to opt out by following the instructions in those messages or by adjusting your preferences in the App. Please note that even if you opt out of promotional messages, we may continue to send non-promotional messages necessary to provide the Services, such as messages about your account.

Limitations. In certain circumstances, we may be unable to fulfill your request—for example, where we are legally required to retain the information, or where doing so is necessary to prevent fraud, ensure security, or protect the rights and privacy of others.

Language

Except as otherwise set out by law, in the event of any inconsistency between the English version and local language version of this Privacy Policy (where applicable), the English version shall prevail.

Contact Us

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at contact@nocam.ai.

NOCAM TECHNOLOGIES INC.
Privacy Contact: Liora
Email: contact@nocam.ai
Address: 573 BELLEVUE ROAD, SUITE D

Jurisdiction-Specific Terms

Additional Terms for California Users

Under the California Consumer Privacy Act (as amended, the “CCPA”) and California’s “Shine the Light” law, consumers residing in California are afforded certain additional rights with respect to their personal information. If you are a California resident, this section applies to you.

Our collection and use of personal information (“Notice at Collection”)

We have described how we collect, use, and disclose your personal information in the “How We Collect Your Personal Information,” “What Personal Information We Collect,” “How We Use Your Personal Information,” and “How We Disclose Your Personal Information” sections of this Privacy Policy above. As required under applicable California law, the table(s) below (which serve as our “Notice at Collection”) set out this same information in further detail, including the categories of personal information we collect (and have collected over the preceding 12 months), the categories of recipients to whom we disclose such information, and the purposes for which we use each category.

Categories of personal information we collected

As described in the “Security and Retention” section of this Privacy Policy above, we retain your personal information for as long as necessary to fulfill the purposes set out in this Privacy Policy, subject to any legal obligations to retain it for longer, the needs of legal claims or investigations, or as otherwise described in this Privacy Policy. We are required by law to retain certain types of information for specified periods (for example, to comply with applicable statutes of limitations). Where your personal information is no longer necessary for the legal or business purposes for which it was processed, we will generally delete or anonymize it.

Processing of Sensitive Personal Information

We may process sensitive personal information—such as face- or body-related information used by the photography, guidance, and post-processing features—only to provide the features you have requested, to maintain the quality and security of the Services, and for other purposes permitted under applicable law. We do not use Sensitive Personal Information to infer characteristics about you. We do not use or disclose sensitive personal information for purposes that would, under applicable law, give rise to a right to limit such use or disclosure. Accordingly, we do not currently process requests to limit the use and disclosure of sensitive personal information.

“Do Not Track” Signals

Under California law, operators of online services must disclose how they respond to “Do Not Track” signals or similar mechanisms that allow consumers to exercise choice over the collection of their personal information over time and across third-party online services, to the extent the operator engages in such collection. At this time, we do not respond to “Do Not Track” signals. We also do not knowingly permit third parties to collect personal information about your online activities over time and across different online services.

Your California Rights

Right to Know; Right to Delete; Right to Correct; Right to Opt-Out of Sale/Sharing; Right to Limit Use of SPI; Right to Non-Discrimination; Right to Data Portability.

Exercising your consumer rights

If you are a California resident, you have the right to request, as applicable:

• To know your personal information the business has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you;
• To correct your personal information (for example, if it is inaccurate or incomplete);
• To delete your personal information; and
• To opt out of the sales or “sharing” (as defined under CCPA) of your personal information.

Further details on how to submit these requests are set out in the “Your Rights” section above. You may also email us at the address provided in the “Contact Us” section to submit a request, or designate an authorized agent to submit a request on your behalf. We may request additional information to verify the authenticity of your request, or of a request submitted by an authorized agent. We will not discriminate against you for exercising your rights under the CCPA.

Notice of Right to Opt-out of Sale/Sharing

You have the right, at any time, to direct a business that sells or “shares” your personal information with third parties not to sell or share it. This is the right to opt out of sale/sharing. The terms “sell” and “share” are broadly defined under the CCPA and may include disclosing your information in exchange for any economic benefit.

To the extent any third party is not treated as a “service provider” or “contractor” under the CCPA/CPRA, such that any of our activities could be interpreted as a “sale” or “sharing” of personal information, and to the extent you wish for us not to sell or share such information, you may submit your request using the methods below:

Email: contact@nocam.ai
Mailing Address: 573 BELLEVUE ROAD, SUITE D

Shine The Light Law

For consumers residing in California, we do not share your personal information with third parties for those third parties’ direct marketing purposes.

Additional Terms for Nevada Residents

Under Nevada law, you may direct a business that operates an internet website not to sell certain personal information that the business has collected or will collect about you. We do not sell your personal information as defined under Nevada law. However, Nevada residents have the legal right to opt out of the sale of their personal information, even if their information is not currently being sold.

For more information about how we handle and share your personal information, or to submit an opt-out request under Nevada law, please contact us at contact@nocam.ai or by mail at 573 BELLEVUE ROAD, SUITE D.