Roli Camera Privacy Policy
Welcome to Roli Camera (the “App”). This Policy explains how we process personal information when you use the App and related services, and how you may exercise your rights.
Please read and understand this Policy before using the App. If you do not agree with any part of it, please stop using the relevant service. You may contact us using the details at the end of this Policy to ask questions, make a complaint, or exercise your privacy rights.
1. Data Controller
Data controller: TOCHAT LABS LIMITED (圖洽創新科技有限公司)
Email: huye@tochat.online
Address: Unit 903, 9/F., Cameron Commercial Centre, 458-468 Hennessy Road, Causeway Bay, Hong Kong
Primary server location: Mainland China
2. App Functions and Processing Principles
Roli Camera is a photography and local photo-editing app offering live camera effects, exposure and color-temperature controls, aspect ratios, grids, timers, timestamps, photo importing, an in-app album, and local editing. Basic shooting and editing do not require an account.
- Photos you capture, import, and edit are processed and stored locally by default.
- We do not proactively upload your photos, and we do not use them for face recognition, identity recognition, advertising profiles, or AI training.
- The App does not integrate advertising networks, track you across apps or websites, or sell personal information.
- We process information only to the extent necessary for a clearly stated function.
3. Information We Process
| Context | Information | Purpose | How it is processed |
|---|---|---|---|
| Basic network services | App version, Bundle ID, a randomly generated device identifier, client platform, device brand and model, operating-system version, request time, random request identifier, channel information, IP address, and request logs generated while serving requests. | Provide online configuration, camera and filter catalogs, material downloads, API security, troubleshooting, and abuse prevention. | Transferred to Roli servers over an encrypted connection. The random device identifier is generated by the App, is not IDFA, and is not used for advertising tracking. |
| Sign in with Apple or WeChat | Sign-in method, authorization credential, account identifier, and any nickname, avatar, or email you authorize the provider to share. | Create and identify an account, maintain the session, synchronize membership benefits, and protect account security. | After authorization, necessary credentials are sent to Roli servers for verification. We do not receive your Apple ID or WeChat password. |
| Purchases and restoration | Product identifier, Roli order number, App Store transaction identifier, subscription status, membership tier and expiry, and purchase or restoration result. | Complete and verify purchases, activate or restore benefits, and resolve order issues. | Payment is processed by the Apple App Store. We do not receive card numbers or complete financial-account information; transaction results are sent to Roli servers to validate benefits. |
| Capturing, importing, and editing photos | Photos, creation time, local editing parameters, and local file paths. | Capture, apply camera effects, edit, display photos in the in-app album, and save them to the system photo library at your request. | Processed and stored locally by default and not uploaded to Roli servers. |
| Device orientation | Real-time device-orientation and motion-sensor results. | Rotate capture controls and correct photo orientation. | Processed locally and only while the camera screen is active; not stored, uploaded, or used to identify you. |
| Feedback and support | Your contact details, feedback, screenshots or images you choose to provide, device model, system and app versions, and necessary error logs. | Communicate with you, troubleshoot issues, handle complaints, and improve the service. | Used only as needed to handle your request, not for advertising, profiling, or personalized recommendations. |
4. System Permissions
| Permission | Purpose | Effect of refusal |
|---|---|---|
| Camera | Preview the camera view and capture and process photos. | Live capture will not work; functions that do not require the camera remain available. |
| Photo read access | Let you select and import photos for filters, timestamps, or editing, including limited photo-library access provided by the system. | You cannot import photos from the system library. |
| Photo add access | Save captured or edited photos to the system library. | Photos may remain in the in-app album but cannot be saved to the system library. |
| Orientation / accelerometer | Recognize portrait and landscape orientation, rotate capture controls, dialogs and timestamps, and correct photo orientation. | Orientation detection, interface rotation, or photo correction may not work correctly. |
Orientation and accelerometer details: The App may use system-provided orientation information to recognize portrait and landscape shooting, rotate controls, and correct photo orientation. It is used only in real time while the camera screen is active. We do not record, store, upload, or share raw accelerometer data, and do not use it for identity, advertising, profiling, or recommendations.
You may change permissions at any time in iOS Settings. Withdrawing permission does not affect processing already performed with your authorization.
5. Third-Party Services and Sharing
We use the following services only as needed for their stated functions:
| Service | Provider | Purpose | Information involved |
|---|---|---|---|
| Sign in with Apple | Apple Inc. | Optional account sign-in. | Authorization credential and the name or email you choose to share. |
| App Store / StoreKit | Apple Inc. | Subscription purchase, transaction validation, and purchase restoration. | Product and transaction identifiers, subscription status, and purchase result. |
| WeChat OpenSDK | Shenzhen Tencent Computer Systems Company Limited | Optional WeChat sign-in. | Authorization credential and public WeChat profile information you authorize. |
| Server hosting and content delivery | TOCHAT LABS LIMITED and its hosting providers | Provide Roli APIs, camera catalogs, and material downloads. | Basic network, account, and transaction-validation information described in Section 3. |
Except as described above, where required by law, to protect users or the public, or with your separate consent, we do not provide personal information to other parties. Third parties process information under their own privacy policies. Open-source interface, networking, image-processing, and local-storage components run on the device and do not mean their maintainers independently receive your information.
6. Legal Bases
Depending on applicable law, we process information to perform our agreement with you, based on your consent, for legitimate interests in providing and protecting the service, and to comply with legal obligations. Where processing relies on consent, you may withdraw it at any time.
7. Retention
- Local photos and editing data remain on your device until you delete them or uninstall the App. Closing an account does not automatically delete photos stored on the device.
- Account information is retained while the account exists and deleted or anonymized within 30 days after closure, unless law requires longer retention.
- Order and transaction-validation records are retained for five years, or for the period required by tax, accounting, consumer-protection, or other applicable law.
- Device, network, and server request records are generally retained for no more than 180 days, except where needed for security incidents, disputes, or legal requirements.
- Feedback records are generally retained for no more than two years after resolution, or as long as necessary for disputes, complaints, or legal obligations.
When a retention period ends, we delete or anonymize the relevant information.
8. International Transfers
Our primary servers are located in Mainland China. If the App is offered to users in other countries or regions, information may be processed outside your location. Where an international transfer occurs, we use contracts, encryption, access controls, or other safeguards required by applicable law and obtain consent where required.
9. Your Rights
Depending on applicable law, you may have rights to access, copy, correct, delete, restrict or object to processing, withdraw consent, receive portable data, and complain. We do not sell personal information or use it for cross-context behavioral advertising.
- Manage camera and photo permissions in iOS Settings.
- Delete local photos in the App album or the system Photos app.
- Close your account in App Settings → Account → Close Account.
- For other privacy requests, email huye@tochat.online. We may verify your identity to protect account security.
Closing a Roli account does not automatically cancel an Apple App Store subscription. Use “Manage Subscription” in the App account page or Apple’s subscription-management page to cancel.
10. Information Security
We use encrypted transmission, access controls, data minimization, and security audits. No internet service can guarantee absolute security. If an incident may affect your rights, we will notify you and take remedial action as required by law.
11. Children’s Privacy
The App is intended for general photography users and is not directed to children under 13 or the minimum digital-consent age in their location. We do not knowingly collect children’s personal information. A guardian who believes a child has provided information may contact us to request deletion.
12. Regional Notices
European Economic Area, United Kingdom, and Switzerland
You may request access, correction, deletion, restriction, objection to legitimate-interest processing, and a portable copy, and may complain to your local data-protection authority. International transfers use safeguards required by applicable law.
Certain U.S. States
We do not sell or share personal information for cross-context behavioral advertising, or make inferences from sensitive information. Eligible residents may request access, correction, deletion, or a copy and will not be discriminated against for exercising their rights.
Mainland China
We follow the principles of lawfulness, legitimacy, necessity, and good faith. Where sensitive personal information, disclosure to another processor, or cross-border provision is involved, we will provide notices and obtain separate consent or meet other legal requirements as applicable. Children under 14 should use the App only with guardian consent and guidance. Children or guardians may contact huye@tochat.online to exercise applicable rights.
13. Policy Updates
We may update this Policy when features, processing, or legal requirements change. Material changes will be announced in the App or by another prominent method, and we will obtain renewed consent where required. The latest update and effective dates appear at the top of this page.
14. Contact Us
Data controller: TOCHAT LABS LIMITED (圖洽創新科技有限公司)
Privacy email: huye@tochat.online
Address: Unit 903, 9/F., Cameron Commercial Centre, 458-468 Hennessy Road, Causeway Bay, Hong Kong
We normally respond to valid privacy-rights requests within the period required by applicable law.