February 18, 2020

General Information

Application Crystaliq ("App") and website ("Website") are the property of Lifelonglearning Limited, a Hong Kong limited company ("Company", "we", "us", "our"). We created this privacy policy ("Privacy Policy") to explain how we treat, collect, use, maintain and disclose your personal information collected and received from your visiting our Website and using our App and from your use of our services as defined in our Terms of Use of Crystaliq ("Terms") provided through our Website and App ("Services"), or third parties websites, services, platforms and products we use such as Revenue Cat, etc. Terms not defined herein have the meanings set forth in the Terms. Third parties websites`, services`, products`, platforms` collection, use, and disclosure of your personal data will be subject to their own privacy policies, and not this Privacy Policy.

Please read this Privacy Policy as well as our Terms and Cookies Policy carefully.

In this Privacy Policy, your information is sometimes called "personal data" or "personal information". We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as "processing" such personal information.

This Privacy Policy applies to any personal data provided to us, and any personal data created in connection with our Services. You should provide personal data only of yourself.

If required by applicable law, we will seek your explicit consent to process you personal information collected by us or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your personal data, the use of our Services may not be possible.

You may revoke your consent to process your personal data any time by email to our Data Protection Officer at

LIfelonglearning Limited, a Hong Kong limited company is the data controller of your personal data. Please see the "Contact Information" section below for additional details.

Some our Services may have their own privacy policies that differ from this one and/or contain additional information as required under local law. Please refer to the Privacy Statements relating to the relevant Services in order to understand how they process your data.

Agreement With this Policy and Use of Services

Your agreement with this Privacy Policy means that you consent to use our Services including but not limited to Website and App and and/or submit any information to us, understanding that we may collect, use, disclose, record, analyse and retain such information in accordance with this Privacy Policy, and as permitted or required by law.

By using our Services and providing personal information to us, you acknowledge that you have read this Privacy Policy, and subject to your explicit consent which we may separately seek from you as may be required by applicable law, you consent to the terms of this Privacy Policy (including international transfers of your personal data as set out in this Privacy Policy to countries outside where you are located).

Please be acknowledged that If you do not agree with these Privacy Policy, then do not provide any information to us and do not use our Services.

Purpose of Processing Your Personal Data

We use the collected data to customize our Services for visitors, to show ads on other websites to visitors, and to improve our Services by analyzing how visitors navigate.

We may also share such information with service vendors or contractors in order to provide a requested service or transaction or in order to analyze the visitor behavior while using our Services.

What Data We Collect

When you use our Services, we may collect personally identifiable information about you either directly from you, or from social medias or other third-party sites including through cookies and analytics tools.

We may gather the following information about you:

  • Emails;
  • Information of how you use our App, namely what filters and parameters user uses, extension to which user exported ready-work, removal of watermarks, chosen payment model etc;
  • Cookies (web request, IP address, browser type, browser language, the date and time of your request) when you visit our Website;
  • Identifier of mobile device (Advertising Identifier for iOS);
  • Information about your customer service and maintenance interactions with us;
  • Information from third parties about you in connection with any referral programs we may offer;
  • Any other information you voluntarily choose to directly provide us for instance, when you use any "Contact Us" features of our Services, as part of the registration process, register a user account, and/or create and update your user profile.

Please take into account that just using our App does not not allow us to collect any information to identify you due to we access to your information in third-party services in anonymized form.

We also do not collect, store, or transmit any of your financial information. Instead, we use a third-party payment processor such as Revenue Cat to process your payments.

How We Collect Your Data

Information You Provide or May Provide Us Directly

We collect information that you provide directly to us. In general, we collect information from you through:

  • Using any of our Services;
  • Making a purchase from us;
  • Signing up for email updates;
  • Submitting requests or questions or your customer experience to us via forms or emails;
  • Requesting customer support and technical assistance.
Information We Collect Through Automated Means

Cookies and Analytics Information. Please read our Cookies Policy for detailed information. Briefly, when you use our Services, we and our service providers may use functionality, advertising and other cookies (text files placed on your devices) and similar technologies to track, collect and aggregate certain information of how anonymized user used our Services, including what features did user use, what options did user choose, what payment model did user choose, which hyperlinks were "clicked" etc. Collecting such information may involve logging the device, IP address, operating system and browser software used by each user. Through such information, we may be able to determine from an IP address a user's Internet Service Provider and the general geographic location (city/state) of his or her point of connectivity.

We also use or may use these technologies to help us determine and identify repeat visitors, the type of content and sites to which a user of our Services links, the length of time each user spends at any particular area of our Website and App, and the specific functionalities that users choose to use.

We use third-party web analytics services (such as those of Firebase and Google Analytics) on our App and Website to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. We may also use third-party services, as a medium for communications, either through email, or through messages within our Services. The use of these any such medium may be subject to the terms and conditions and privacy policy for those service providers and you should carefully review those terms and conditions. If you would like to opt out of having this information collected by or submitted to such third parties or have questions about other third-party service provider's collection of your information for this purpose, please contact us.

Online Advertising. We may allow third party companies, including advertising companies (such as Facebook, Google), to place cookies on our App and Website. These cookies enable such companies to track your activity where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These Cookies store information about the content you are browsing together with an identifier linked to your device or IP address.

These Cookies also allow us and third parties to know whether you've seen an ad or a type of ad, and how long it has been since you've last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads. For more information about online advertising and how you can control or disable these cookies, please see our Cookies Policy.

How We Use The Data We Collect

We use your information for various purposes depending on the types of information we have collected from and about you and the specific services you use, in order to:

  • Process your orders;
  • Respond to your communications and requests either as a technical support or subject to your customer experience;
  • Contact you by email regarding our products, services, surveys, research studies, promotions, offers, special events and other subjects that we think may be of interest to you;
  • Customize the technologies and content we provide through the Services;
  • Help us better understand your interests and needs, and improve the Services;
  • Engage in analysis, research, and reports regarding use of the Services;
  • Secure the Services;
  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others;
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/Anonymous Data. We may aggregate and/or anonymize any information collected through the Website so that such information can no longer be linked to you or your device ("Aggregate/Anonymous Information"). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, statistical analyses of Services usage, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

Sharing and Disclosure Your Data. If you agree with this Privacy Policy then you consent your agreement that the Company will share your data in the following ways:

  • Service Providers. We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, test proctoring, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
    Please be aware that we have necessary data processing agreements with data processors providing sufficient guarantees to implement appropriate technical and organizational privacy measures meeting GDPR requirement and with them.
  • Business Partners. With your consent, the Company may share information that can be used to directly contact you with third party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you.
  • Protection of the Company and Others. By using our Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or law; (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of the Company, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, compliance with applicable law, and spam/malware prevention, and similar purposes.
  • Related Entities and Affiliates. We may share information with our affiliated companies that are under the common ownership or control of Lifelonglearning Limited company.
  • Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of Company's assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, the Company will comply with such restrictions.
  • Aggregate/Anonymous Information. From time to time, the Company may share Aggregate/Anonymous Information about use of the Services, such as, but not limited to, publishing a report on usage trends or survey results. The sharing of such data is unrestricted.
  • International transfers. As we a global company with third party service providers located around the world, your personal information may be transferred to and stored outside the China. Our service providers and sub-processors they engage may use servers and other resources in various countries and territories to process your information.
How We Store Your Data

We store information about users on servers located in the United States of America. By using our Services, you consent to the storage of your information inside the United States of America. If you are using the Services from outside the United States and the European Union, please know the information you submit will be transferred to and stored in servers in the United States of America or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our Services, you acknowledge the transfer, storing, and processing of your information in and to the United States of America.

As described above, we may also subcontract the processing of your data to, or otherwise share your data with, service providers and others in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to any such non-European Union entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses or signing or accepting Data Processing Agreement in accordance with data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as detailed in the "Contact Information" section below.

Marketing Communications

You may instruct us not to use your contact information to contact you by email and all other means you provided us with regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Your Data Protection Rights

You have certain rights with respect to your data as further described in this section.

You have a right to request us that we:

  • provide you access to and/or a copy of certain information we hold about you;
  • prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
  • update your information which is out of date or incorrect;
  • delete personal information (if any) which we are holding about you;
  • restrict the way that we process and disclose certain of your information;
  • transfer your information to a third-party provider of services;
  • revoke your consent for the processing of your information.
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation.

We may require certain information to help verify your request and prevent fraudulent information and removal requests.

Retention and Deletion of Your Information

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

For example, all your information that is being collected through third-party web analytics services (such as Firebase or Google) is retained during the term stipulated by privacy policy of such third-party services.

We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request.

You can send us the request to delete your personal data any time to the

Third Party Links and Features

The Services may contain links to third-party websites also may contain third-party integrations (such as the Facebook "like" button) and functionalities. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function.

We are not responsible for the privacy practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy We urge you to read the privacy and security policies of these third-parties.

Children's Privacy

We are intended for general audiences and not for children under the age of 16. If we become aware that we have inadvertently collected "personal information" (as defined by the United States Children's Online Privacy Protection Act) from children under the age of 16 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

How We Protect Your Information

We consider the confidentiality and security of your information to be of the utmost importance. We take a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. Please note that we do not guarantee the whole security of information, as no method of internet transmission or storage is completely secure. Also note that we may retain and store your information in our databases and systems even after your account is deactivated as long as we have a legitimate purpose to do so and in accordance with applicable law.

Changes to Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting through our Services. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the "Updated" included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

Lifelonglearning Limited Contact Information

If you have any questions, requests, comments or complaints about this Privacy Policy, please contact us:

If you have any questions, requests, comments or complaints about this Privacy Policy, please contact us:

Attn: Data Protection Officer of Lifelonglearning Limited Company
Room 1206 Eastern Commercial Building 397
Hennesy Road Wan Chai
Hong Kong

© 2016–2019 Lifelonglearning Limited Company
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