Zhemin Technology Co., Ltd. ("we," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our FaceCert APP ("Application"). Please read this Privacy Policy carefully. By accessing or using the Application, you acknowledge that you have read, understood, and agree to be bound by all the terms outlined in this Privacy Policy.

1. INFORMATION WE COLLECT

1.1 Personal Information

We may collect personal information that you voluntarily provide when using our Application, including but not limited to:

1.2 Device Information

When you access the Application, we automatically collect certain information about your device, including:

2. HOW WE USE YOUR INFORMATION

We may use the information we collect for various purposes, including but not limited to:

3. DATA SECURITY

We implement advanced security measures to protect your personal information, including:

While we implement safeguards to protect your information, no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

4. DATA SHARING AND DISCLOSURE

We may share your information with third parties only in the following circumstances:

4.1 International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. These countries may have different data protection laws than your country. By using our Application, you consent to the transfer of your information to countries where we operate, including but not limited to China, Japan, and the United States.

5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The specific retention periods vary depending on the type of data:

Data Type Retention Period
Facial recognition data Until account deletion or after 2 years of inactivity
PIN code Until changed by user or account deletion
Passport information Until passport expiry or account deletion
Authentication records 5 years for compliance and security purposes
Device information 2 years after last use

When your data is no longer required, we will securely delete or anonymize it in accordance with our data retention policies.

6. YOUR RIGHTS

Depending on your location, you may have certain rights regarding your personal information, including:

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. Please note that these rights may be limited in some circumstances by local law.

6.1 How to Log Out from FaceCert APP

1
Click on the avatar icon located in the bottom navigation bar or on the top right corner of the home screen.
2
Navigate to Personal Center which will display your account information and settings.
3
Tap on "Logout account" at the bottom of the Personal Center page to sign out from your FaceCert account.

7. CHILDREN'S PRIVACY

The Application is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information as soon as possible. If you believe we might have any information from or about a child under 18, please contact us.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated version will be indicated by an updated "Effective Date" at the top of this Privacy Policy. We will notify you of any material changes through a notice in the Application or by other appropriate means. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.

9. THIRD-PARTY SERVICES

The Application may contain links to third-party websites or services that are not owned or controlled by us. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods, or services available on or through any such websites or services.

10. COMPLIANCE WITH LAWS

We are committed to complying with all applicable data protection laws, including but not limited to:

11. THIRD-PARTY SDK USAGE

FaceCert APP integrates several third-party Software Development Kits (SDKs) and libraries to provide our core functionality. This section details how these components are used and their impact on your data.

11.1 Registered SDKs (Google Play SDK Management Center Compliant)

11.2 Platform Native Components

11.3 Core Functionality Libraries

Library Purpose Data Access
com.blankj:utilcodex Provides common utility methods for Android development No direct access to personal data
com.github.getActivity:XXPermissions Manages device permission requests Helps request access to camera, location, and other device features
com.squareup.retrofit2:retrofit Facilitates secure API communication Transmits encrypted data between the app and our servers
BackgroundLibrary:libraryx UI enhancement for visual elements No access to personal data
com.github.bumptech.glide:glide Image loading and caching Processes facial images locally for display purposes

11.4 Security & Authentication Libraries

These libraries are essential for our core identity verification and document authentication functionality:

Library Purpose Data Processing
CustomKeyboard Secure PIN entry interface Processes PIN input securely on-device to prevent keylogging
MLKit text-recognition Passport data extraction Processes passport MRZ data locally on your device
MLKit face-detection Facial liveness verification Processes facial data on-device to verify authenticity
Passport Reading Suite (jmrtd, scuba-sc-android, spongycastle, jp2-android) Comprehensive passport chip reading Securely reads data from passport NFC chips
SenseTime SenseID SDK Advanced biometric verification Processes facial data for liveness detection
pcscnfc NFC interface for passport reading Enables secure communication with passport chips

11.5 User Experience Libraries

Library Purpose Data Access
renderscript-intrinsics-replacement-toolkit Image processing enhancement Processes images locally to improve quality
Huawei scanplus QR code scanning functionality Processes camera data to read authentication QR codes
BaseRecyclerViewAdapterHelper4 Efficient list display management No direct access to personal data
Lottie Animation rendering for user interface No access to personal data
LiveEventBus In-app communication framework Facilitates data exchange between app components

11.6 Data Usage & Retention

All third-party libraries and SDKs used in FaceCert APP adhere to our privacy and security standards. Important considerations:

For more information about specific SDK data practices, you can refer to the respective privacy policies of these service providers.

12. CONTACT US

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

Email: support@transcarton.com

Zhemin Technology Co., Ltd.

Last updated: May 15, 2025