SHANGHAI TRANSSION CO., LTD. (“Moment”, “we”, “us” or “our”) is the provider and operator of the Moment application software and services (the “Software”). We fully respect your privacy and will do our best to keep your personal information secure. In providing you with products or services (collectively, the “Service”), we may collect and use your personal information based on your consent or in accordance with applicable laws and regulations. This Privacy Policy (the “Policy”) is intended to help you understand how we collect, use, disclose, process and protect the personal information you provide when using Moment products or services, the rights you have in respect of that personal information, and how we safeguard those rights. This Policy applies to the application software and related services provided by Moment.
Please note that this Policy does not apply to services provided to you by other third parties. You may receive content or web links provided by third parties; please be careful when deciding whether to access third-party links, content, products and services. Before submitting personal information to any third party, please read that third party’s privacy policy carefully.
To ensure that you fully understand this Privacy Policy and can make your own choices, we try to explain it in clear and easy-to-understand language, and we clearly mark or highlight key content (in particular in bold, capital letters, underlining and similar forms). We also display a pop-up prompt when you first use our services, guiding you to review the core content of this Privacy Policy.
Before using our products or services, submitting personal information to us or consenting to our collection of your personal information, please read this Policy carefully to understand our practices regarding your personal information, and please visit regularly to learn of updates to this Policy. If this Privacy Policy is updated, we will post a notice on the relevant products or websites so that you can learn of the updates. If you access or use our services after we issue such a notice, you will be deemed to have agreed to the updated Privacy Policy. You can check the “last updated” date at the top of the Privacy Policy to confirm when it was most recently updated.
If you have any questions, please feel free to contact us at:
privacy@transsion.com
You can also access this Privacy Policy at:
Moment APP > Capture page > Settings > Privacy Policy
This Privacy Policy will help you understand the following:
Moment firmly believes that basic privacy rights should not vary depending on where in the world you live. Therefore, regardless of where a natural person resides, Moment treats any information relating to an identified or identifiable natural person — in particular that person’s name, identity information, location data, online identifiers, or data specific to that person’s physical, physiological, genetic or mental characteristics, or related to them — as “personal information”.
We will only collect information necessary for specific, explicit and legitimate purposes, and will ensure that your information is not further processed in a manner incompatible with those purposes. If we intend to use your personal information for other purposes not set out in this Privacy Policy, we will obtain your consent again.
When collecting your personal information, we do so in three ways: 1) information you provide to us directly; 2) information we collect through automated means as you use the Software (for example, the necessary request information generated when you use online AI features); and 3) information we obtain from other sources.
You have the right to choose whether to provide personal information when using Moment products or services or when we request it. You are not required to provide personal information to Moment, but in some cases, if you choose not to, Moment will be unable to provide you with the relevant products or services, or to respond to or resolve issues you encounter. We will only collect and use your personal information for the purposes described in this Policy. The following gives examples of the personal information we collect:
The main business functions of the Software are to provide you with photo capture, an AI Share Assistant and similar features.
The Software currently does not integrate any third-party analytics, advertising or crash-analytics SDK, and does not track your usage behavior through event tracking. If we add such processing in the future, we will update this Policy and obtain your consent as required by law.
Personal information collected on the basis of your consent will be stored in accordance with the personal data protection laws and regulations of the relevant countries. Where not prohibited by local laws and regulations, we may also store the personal information we collect in countries or regions outside the country where our business is located.
Currently, Moment may store your personal information in: Singapore.
Whether personal information is stored in the country where our business is located or, where not in violation of the law, in other countries or regions, we will retain it in accordance with the data storage requirements of the relevant laws and regulations. We also take into account the characteristics, scope and purposes of personal information processing, the risks that may arise in processing, and the serious consequences that could result from any harm, and implement necessary security safeguards. For example, we use encryption and de-identification to store the personal information we collect. We will also store information for the shortest period required for our business, unless you agree to extend the retention period or the law permits otherwise. Data that has exceeded the retention period, or data you ask us to delete, will be deleted or otherwise appropriately handled by us where not in violation of applicable laws and regulations.
We will also take other necessary measures to keep your personal information secure, to prevent data from being misused, accessed without authorization, or modified, disclosed or destroyed without authorization.
We implement security measures designed to protect your personal information, regularly monitor our systems for possible vulnerabilities and attacks, and use administrative, technical and physical safeguards that take into account the nature of the personal information, how it is processed and its security. We continue to work to improve these safeguards to keep your personal data secure.
Of course, please be reminded that even the most comprehensive measures cannot absolutely guarantee that data storage security incidents will never occur. In the event of a security breach, we will report to the relevant regulators in accordance with applicable laws and regulations and, as regulators require, provide the types of personal data involved, the number of data subjects, the possible consequences of the breach and the remedial measures we propose to take. We will take every possible measure to remedy or mitigate the harm and consequences caused by the breach. Where permitted or required by laws and regulations, we will promptly notify you of the possible consequences or significant harm to you so that you can take appropriate measures to protect your rights as far as possible.
Because no website, Internet transmission, computer system or wireless connection is absolutely secure, in addition to the necessary security measures we take, users also need to increase their awareness of privacy and security risks. For example, for the security of any data collected by websites, links, products or services to which you are redirected through our services, please be careful and read the terms of those websites, links, products or services carefully; we do not bear any legal liability for data security issues caused by such third parties. If you find that certain content or features of our websites, products or services may be provided by third parties and may endanger your personal privacy and security, please contact us promptly and we will handle it as a priority in accordance with the law.
In sharing, transferring and disclosing your personal information, we adhere to the principles and requirements of minimization, necessity and legal compulsion. In general, we do not share, transfer or disclose your personal information externally, but where relevant laws and regulations apply or permit, we may share, transfer or disclose your personal information in the following circumstances:
We do not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with Moment’s affiliates. We will share your information within Moment’s affiliates only for lawful and explicit purposes, only to the extent necessary to provide the services, and subject to the purposes stated in this Privacy Policy. If the relevant purposes are not covered by this Policy, we will explain them in the privacy policy or notice for the specific product or service concerned.
We may share necessary personal information with authorized third-party partners (including technical service providers and data storage providers) in order to perform certain functions or to provide you with better services and user experience. For example, to enable you to use AI-related features, we will provide your data to AI service providers and content moderation providers in order to provide the relevant services and ensure compliance; to ensure the operation of the services, our data storage providers will provide cloud storage services.
We conduct such sharing in accordance with the principles of minimization, necessity and legal permissibility. Before sharing information, we will sign strict confidentiality agreements with authorized partners, requiring them to handle personal information with confidentiality and security measures in accordance with this Policy and the laws applicable in your jurisdiction. In addition, we will require them to provide data security capabilities and information security qualifications (such as classified protection assessments and information security management systems).
In transactions involving merger, acquisition, bankruptcy liquidation, asset transfer and the like, if personal information is to be transferred, we will, by agreement or other appropriate measures, require the company or organization that newly holds your personal information to remain bound by this Privacy Policy and to handle the personal information with confidentiality and security measures no less stringent than those required by this Policy.
Unless in the following circumstances, Moment will not transfer your information to any other party:
Moment may need to disclose your personal information as required by law, legal process, litigation and/or requests from government departments and authorities. We may also disclose information about you if disclosure is necessary or appropriate for national security, law enforcement or other matters of public importance.
In addition, we may share your personal information with the following persons:
For the purposes described in this Privacy Policy, subject to the applicable laws and regulations of your region and with your authorization and consent, we may transfer your personal information to the resources or servers mentioned in Section 2 of this Policy for storage or processing, and we may also transfer your personal information to third-party service providers and business partners, so your data may also be transferred to other countries or regions. The privacy protection laws of those countries or regions may differ, and the jurisdictions where those servers are located may or may not protect personal information to the same standard as your jurisdiction. Nevertheless, we will still endeavor to comply with our privacy policy to protect your personal information, and we will carry out the corresponding cross-border transfers and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.
If we transfer personal information to a region outside your jurisdiction, whether to our affiliates or to third-party service providers, we will comply with the relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers comply with the requirements of applicable local data protection laws.
As a data subject, you have a range of rights over your personal information, including confirmation, access, correction, deletion, withdrawal of consent and complaint (hereinafter “requests”). We fully understand and respect these rights and, under applicable law, such rights are also subject to specific exclusions and exceptions. We will also take active measures to ensure that your rights are effectively protected. Please understand and note, however, that for security reasons we may need to verify your identity before handling your request. For your lawful and reasonable requests, we do not in principle charge a fee. However, for requests that are repeated multiple times or exceed reasonable limits, we will, depending on the circumstances and to the extent permitted by applicable law, charge a reasonable fee based on actual administrative costs. We may refuse requests that are unreasonably repetitive, require excessive technical means (for example, developing a new system or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical, as well as requests that violate mandatory provisions of law.
5.1 Right of confirmation and access: We inform you how we collect and process personal information through this Privacy Policy or the privacy policy or notice for a specific product or service scenario. You have the right to confirm or refuse such collection and processing, for example by ticking a box. However, if you refuse, some functions that require your explicit authorization and consent may become unavailable. For personal information you have already provided to us, you can query it directly in the interface of our products or services. Where it cannot be queried, you can send an email to privacy@transsion.com, and we will handle it promptly after receiving your email.
5.2 Right of correction and deletion: When your personal information changes, or when you find that the personal information we have collected and processed about you is incorrect or incomplete, you have the right to ask us to correct or supplement it. For some of your personal information, you can correct or modify it directly on the relevant feature pages of the product or service. When the purpose of collecting your personal information has been achieved or it is no longer necessary, or when you find that we have collected or processed your personal information in violation of laws or administrative regulations or of this Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal information for which we have not yet provided a channel for correction or deletion, you can contact privacy@transsion.com to request correction or deletion.
However, in some cases we may not approve your deletion request, for example when you ask us to delete transaction data and Moment is legally obliged to retain a record of that transaction in order to comply with applicable local law. Please also note that if you request deletion of your information from our products and services, due to certain applicable local laws and technical limitations we may not immediately delete the corresponding information from backup systems, but we will securely store your personal information and prevent it from being further processed until the backup systems are updated, your information can be deleted, or your information is anonymized.
5.3 Right to withdraw consent: For our different products or services to achieve their corresponding functions, we will, in accordance with applicable local laws, require necessary personal information. “How We Collect and Use Your Personal Information” in this Privacy Policy explains this. You may withdraw consent previously given to us for a specific purpose, including the collection, use and/or disclosure of your personal information that we hold or control, by deleting information, turning off device functions or submitting a withdrawal request. You can contact us to do so by email to privacy@transsion.com. We will process your request within a reasonable time after you send it, and thereafter will not collect, use and/or disclose your personal information in accordance with your request.
If you withdraw your consent, you may no longer be able to obtain some and/or all of the features of Moment products and services. Withdrawing your consent or authorization will not affect the validity of any processing we carried out previously on the basis of your consent.
5.4 Right to complain: You have the right to contact us by emailing privacy@transsion.com to make a complaint. We will respond promptly after receiving your complaint. If you are not satisfied with our response, especially if our personal information processing has harmed your legitimate rights and interests, you may also file a complaint or report with the local statutory personal data protection authority, or bring a lawsuit in a court with jurisdiction.
5.5 Right to manage privacy settings: You have the right to control your privacy settings. Through these settings you can limit our collection, use, disclosure or processing of your personal information — for example, you can choose to turn the “Camera” and “Microphone” functions and permissions on or off, and you can turn the online photo upload authorization on or off at “Capture page > Settings > Online photo analysis”. If you previously agreed to enable the corresponding permissions or agreed to our use of your personal information in the business scenarios described above, you can turn them off through the app permission management page in your phone’s system settings, or contact us at privacy@transsion.com to change your decision.
5.6 Rights in certain jurisdictions: Please note that, under the applicable laws of certain jurisdictions, you may have the following data subject rights:
We have the right to refuse to process your request, and where exemptions apply or where permitted by applicable law, we have the right to refuse certain of your requests. For example, some requests are manifestly unfounded or clearly excessive, or would require the disclosure of third-party information.
Moment’s products and services are not provided to children under the age of 14 or the equivalent age prescribed by the laws of your jurisdiction (the age at which a person is considered a child differs under the laws of different countries or regions, and we will primarily define a child in accordance with the laws and regulations of the country or region where the specific business is located). We do not proactively collect children’s personal data, nor do we use children’s personal information for marketing purposes. If you find that such children’s information has been passed to us, please contact us by email at privacy@transsion.com and we will delete the relevant information as soon as possible. If we discover that we have collected a child’s personal information, we will also try to delete the relevant content as soon as possible.
When you use Moment products or services, you may receive website links from third parties other than us, or content and services provided by third parties, and some third-party products or services may be provided through SDKs or other means. You may choose, based on your own judgment, whether to access or accept websites, products and services provided by third parties. Our privacy policy does not apply to any products or services provided by third parties. Because we cannot substantively control third parties, we cannot be responsible for such third parties’ collection and processing of your personal information. When you submit any information to such a third party, please carefully review that third party’s privacy policy and take care to protect your personal information.
In light of changes in our business, technology, applicable laws and operations, we reserve the right to update or modify this Policy from time to time. If this Policy is modified, we will notify you by way of a separate announcement. Please follow this page or the notices we send you regularly to stay informed of updates to this Privacy Policy. Although this Privacy Policy may be adjusted, we will not diminish the rights you enjoy under this Privacy Policy without your express consent.
When we collect other personal information from you, or when we use or disclose your personal information for new purposes, we will seek your explicit consent again in accordance with applicable law. If you continue to use products and services on websites, mobile devices and/or any other devices, you will be bound by the updated Privacy Policy.
The content of the Moment products or services described in this Agreement may vary depending on the type of product you use, the system version, or the requirements of local laws and regulations.
If you have any suggestions, questions or concerns about our privacy policy or our personal information protection practices, please contact us at:
Email: privacy@transsion.com (Note: this mailbox is used only to receive emails relating to our privacy policy or our personal information protection practices)
We will review your privacy or personal information request as soon as possible and respond to you within 15–30 days after verifying your identity as a user. If your request itself involves complex or significant issues, we may ask you to provide more information.
If you are not satisfied with our response, especially where your legitimate rights and interests have been harmed by us, you may seek a resolution from the relevant data protection regulator in your jurisdiction. If you make such an inquiry to us, we will provide information on the complaint channels that may be available to you, depending on your circumstances.
Thank you for taking the time to read our Privacy Policy!