Last updated: 2026-05-02
This Privacy Policy explains how InkJoy Frame Technology Co., Limited ("InkJoy," "we," "us," or "our") collects, uses, and shares information when you use our InkJoy frame, companion mobile applications (iOS and Android), and related cloud services for photo syncing and device management (collectively, the "Services").
This Privacy Policy applies to individual consumers who use the Services.
If you do not agree with this Privacy Policy, please do not use the Services.
The Services include:
This Privacy Policy does not apply to third-party services you may use in connection with the Services (for example, app stores, your mobile operating system provider, or third-party integrations, if any). Those third parties handle information under their own terms and privacy policies.
We collect information in a few different ways: (a) information you provide, (b) information collected automatically when you use the Services, and (c) information collected from service providers or platforms (such as app stores) in connection with your use of the Services.
The types of information we collect depend on how you use the Services and which features you enable.
An account is required to use the Services, as core features rely on cloud-based functionality such as device management and photo syncing. If you create or use an account, we collect:
Contact details such as an email address are used solely for account-related purposes, including authentication and service-related communication. We do not use this information for advertising or marketing.
When you use the Services, we may collect information about the frame and the device running the mobile app, such as:
During setup, you may provide connectivity details (such as Wi-Fi network information) so the frame can connect to the internet.
This information may be processed by the device and, where necessary, transmitted to our servers to operate, maintain, and support the Services (for example, to monitor device status or diagnose connectivity issues).
It is not used for tracking or advertising purposes.
Certain features of the Services, such as weather canvas and moon phase widgets, require approximate location (coarse location) information to function.
Coarse Location information may be obtained in the following ways:
Coarse Location data is used solely to provide app functionality, such as displaying accurate weather canvas and moon information. Coarse Location data used by the Services is processed in a privacy-preserving manner.
Any location coordinates used for functionality such as weather canvas or moon phase display are reduced in precision (for example, rounded to two decimal places) to avoid the use or storage of precise location information.
If you choose not to use features that require location information (such as weather canvas or moon phase widgets), coarse location information is not transmitted to our servers.
We do not use coarse location information for advertising, tracking, analytics, or profiling.
Coarse Location information is not used to identify you and is not retained longer than necessary to provide the requested functionality.
The Services are designed to store and display photos and related content that you choose to upload.
To provide the core functionality of the Services, we process:
Photos you upload may contain metadata embedded by your device or camera (for example, EXIF data, timestamps, or location metadata). We do not rely on this embedded metadata to provide the Services and do not extract, read, use, analyze, or otherwise process it separately from the uploaded file itself. This includes location metadata such as EXIF GPS data.
If embedded metadata is present in a file you upload, it may be transmitted to and stored by our systems only as part of that file. We do not separately extract or use it as a distinct data field.
If you prefer not to include embedded metadata in uploaded files, you can remove it before uploading.
You retain ownership of your photos and other content you upload ("User Content"). We do not claim ownership of your User Content.
To operate the Services, we may create technical copies and versions of User Content (for example, resized images or cached versions) to support syncing, storage, backup, and efficient display on the frame and in the apps.
We may collect limited technical information necessary to maintain and improve the reliability of the Services, such as:
This diagnostic and crash information is collected for App Functionality (stability, debugging, and reliability) and is not linked to your identity. For example, we do not attach your email address, account User ID, photos, or frame identifier to crash reports or performance metrics.
We do not use this information to track individual user behavior, to build usage profiles, or for advertising.
We do not use analytics services to track individual user behavior, feature usage patterns, or in-app activity for advertising, marketing, profiling, or user segmentation purposes.
The Services do not perform behavioral analytics or build usage profiles about individual users.
Limited technical information may be processed solely for app functionality and service reliability purposes, such as identifying crashes or performance issues, as described in Section 2.4 (Performance diagnostics and crash reporting).
If you contact us (for example, for support), we may collect:
The table below explains the legal bases under the GDPR for processing the personal data described above.
| Data Category | Purpose | Legal Basis (GDPR) |
|---|---|---|
| Account information (email, account identifier, credentials, settings) | Account creation, authentication, and access to core cloud features | Performance of a contract (Article 6(1)(b)) |
| Device and connectivity information | Device management, connectivity, diagnostics, and support | Performance of a contract (Article 6(1)(b)); Legitimate interests (Article 6(1)(f)) |
| Approximate location (coarse location), where enabled | App functionality, such as providing weather canvas and moon phase widgets based on user-selected or device-provided location | Performance of a contract (Article 6(1)(b)) |
| Photos and user-uploaded content | Storage, syncing, and display of content on frames and apps | Performance of a contract (Article 6(1)(b)) |
| Technical copies of content | Efficient delivery, caching, and display | Legitimate interests (Article 6(1)(f)) |
| Crash reports and performance diagnostics | Service stability, debugging, and improvement | Legitimate interests (Article 6(1)(f)) |
We use the information we collect to:
The Services are currently free to use and there are no paid features at this time. Optional features may be introduced later, potentially involving additional data processing.
If we introduce new features that materially change how we collect or use information, we will update this Privacy Policy and/or provide additional notices as appropriate.
Different laws use different terms for the legal bases that allow processing of information. In general, we process information only when we have an appropriate basis to do so, such as:
To provide the Services (for example, to perform our agreement with you and deliver core functionality like syncing photos and managing devices).
Legitimate interests, where processing is necessary for purposes such as:
When we rely on legitimate interests, we assess and balance those interests against the rights and freedoms of users, and we only process information where such interests are not overridden by your interests or fundamental rights.
Consent, when you choose to enable optional features or permissions (for example, allowing the app to access photos on your phone). You may withdraw consent at any time through available app or device settings, without affecting the lawfulness of processing before withdrawal.
Legal obligations, when we need to comply with applicable law, a lawful request, or to protect rights and safety.
We share information only as described below.
We use third-party vendors to help operate the Services (for example, cloud hosting, data storage, content delivery, email delivery, customer support tooling, and similar providers). These providers process information on our behalf under contractual restrictions appropriate to their role. These service providers act as processors on our behalf, and we have entered into Data Processing Agreements with them in accordance with Article 28 of the GDPR, which impose appropriate data protection obligations.
We may use a third-party crash reporting service (such as Sentry) to help us understand app performance, diagnose errors, and improve service reliability. This processing is based on our legitimate interests in maintaining and improving the stability and security of the Services.
You can opt out of crash reporting at any time through the app’s privacy settings.
Where enabled, these services may collect limited technical information, such as app version, operating system version, device model, timestamps, and error logs. We configure these services so that crash reports and performance metrics are not linked to your identity (for example, they do not include your email address, account User ID, or frame identifier). These providers process data only on our behalf and under contractual obligations that require data protection measures consistent with this Privacy Policy and applicable law.
If you choose to share access to a frame (for example, with family members), we may share your User Content and related device information with the people you authorize, depending on your settings and how the sharing feature works.
We may disclose information if we reasonably believe it is necessary to:
If we are involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction, subject to applicable law and appropriate confidentiality protections.
For more information about international data transfers and safeguards, see Section 9 (International Data Transfers).
We do not sell your personal information.
We retain personal data only for as long as necessary to provide the Services, to fulfill the purposes described in this Privacy Policy, to comply with legal obligations, and to protect our legitimate business interests (such as security, fraud prevention, and dispute resolution).
Retention periods can vary depending on the type of information:
In some cases, limited information may be retained for longer periods where required to comply with applicable law, to respond to legal claims, or to meet regulatory or accounting obligations.
We apply data retention practices designed to minimize the amount of personal data we store and to retain data only for as long as necessary for the purposes described above.
Depending on where you live and how you use the Services, you may have rights and choices regarding your information. These may include the ability to:
You can often control certain data collection through your device or app settings, such as:
We do not use automated decision-making, including profiling, that produces legal or similarly significant effects on you.
To request access, correction, or deletion, contact us using the details in the Contact Information section. We may ask you to verify your identity and/or your relationship to an account or device before fulfilling a request.
We will respond to verified requests without undue delay and in any event within one month, as required by applicable law.
You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data infringes applicable data protection laws.
We use reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction.
However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.
You are responsible for maintaining the security of your account credentials and for using the Services in a secure manner (for example, choosing a strong password and keeping your devices up to date).
We primarily process and store personal data within the European Economic Area (EEA).
In limited circumstances, personal data may be transferred outside the EEA, for example when we use third-party service providers that operate in other regions. Where such transfers occur, we ensure that appropriate safeguards are in place in accordance with applicable data protection laws. These safeguards may include reliance on an adequacy decision adopted by the European Commission or the use of the European Commission’s Standard Contractual Clauses (SCCs).
You may request additional information about international data transfers and obtain a copy of the applicable safeguards by contacting us using the contact details provided in this Privacy Policy.
The Services are not intended for children under 16 (or the minimum age required in your country to use online services without parental consent).
We do not knowingly collect personal information from children in a way that requires parental consent. If you believe a child has provided us personal information, please contact us and we will take appropriate steps to address the situation.
We may update this Privacy Policy from time to time. If we make material changes, we will provide reasonable notice (for example, through the app, through the Services, by email to registered account holders, or by posting an updated version with a new "Last Updated" date).
The "Last Updated" date at the top of this Privacy Policy indicates when it was most recently revised.
Your continued use of the Services after the updated Privacy Policy takes effect means you accept the updated Privacy Policy.
If you have questions or requests about this Privacy Policy, you can contact:
InkJoy Frame Technology Co., Limited
HongKong
Kowloon
TSIM SHA TSUI, NO.34 ASHLEY ROAD
999077
Email: [email protected]