Draft: 29 August 2019
- In providing our services, we may collect and use your Information , including Personal Information ( both as defined in the “The Information We Collect and How We Collect It” section below) , on our services. We do not collect any payment information (such as credit card numbers) from you. Any payment information is collected and processed by third party payment service provider in accordance with the respective third party’s own privacy policies and terms .
- To the extent you provide any Personal Information as part of any Shared Information you make available on our services, such Personal Information will only be retained locally on your device , except as other wise required by applicable law . If you share content to other third party services, its collection, use and retention will be governed by the third party’s own privacy policies. To the extent you provide any Personal Information as part any Social Connect Information you use to login to our services, its collection, use and retention will be governed by the relevant third party’s privacy policies .
- We may retain certain Location Data and Log Data (both as defined in the “The Information We Collect and How We Collect It” section below) that cannot be used to directly or indirectly identify a specific individual .
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
In providing our services, we collect and process the following Information relating to you:
“ Information ” is Personal Information and Non-Personal Information;
" Personal Information " is any information or combination of information that relates to you, and can be used to identify you. Personal Information we collect and process :
- information which you make available to our services as you use them, including Shared Information you make available through our services and Social Connect Information ;
- Shared Information that others using our services make available about you, such as information contained in images or videos they upload and make using our services; and
- information we collect as you use our services, such as certain Location Data and Log Data.
“ Location Data ” is information that we collect regarding your location (when you use a location-enabled service), including:
- the location of your device when you use our services, such as from the GPS, WiFi , compass, accelerometer or other sensors in your device;
- the IP address of the device or internet service you use to access our services ; and
- other information made available by you or others that gives an indication as to where you are or have been located, such as Shared Information you or others provide indicating your location, such as any geotag information that is embedded in any photos or videos you make available to us .
- technical information such as your mobile carrier, configuration information made available by your device, web browser or other programs you use to access our services, your IP address and your device’s version and identification number ;
- information about your use of our services such as the number of times you click on certain features or functionality ; and
- metadata, which means information related to items you have made available through our services, such as the date, time or location that a shared photograph or video was taken or posted.
“ Non-Personal Information ” is any information that relates to you but from which it is unable to directly or indirectly identify you.
“ Shared Information ” is information about you or relating to you that is voluntarily shared on our services, including photos and videos you upload or as accessed by our services with your prior consent through your device’s camera and including Location Data and Log Data associated with these photos and videos . Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.
“ Social Connect Information ” is a third party ID (such as your WeChat ID or QQ ID ) and associated name and profile picture which you provide to facilitate login to our services via a third party platform (such as WeChat or QQ ) .
HOW WE USE YOUR INFORMATION
We may use your Information for any of the following purposes:
- to provide our services to you;
- for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services;
- to provide you with advertising and assess the effectiveness of and improve advertising and other promotional activities related to our services (as set out in more detail under the “Advertising” section below) , and allow you to participate in surveys and other activities related to our services;
- to better understand how you access and use our services, for the purposes of trying to improve our services and to respond to customer desires and preferences, including language and location customisation, personalised help and instructions, or other responses to your and other customers’ usage of our services;
- to help us develop our new services and improve our existing services; and
- for the purposes of software verification or administering software upgrades .
If you login to our services using a third party platform (such as WeChat or QQ ) , we use your Social Connect Information to facilitate login to our services using your third party account. Once you have logged in using your third party account, we generate a unique ID which will allow you to be remembered and identified on our services without using other Personal Information (such as your name or email address). The collection, use and retention of any Personal Information forming part of the Social Connect Information will be governed by the relevant third party privacy policies , as applicable.
Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Non-Personal Information collected through our services may, subject to user privacy controls (where available), be used by our other services.
COOKIES, WEB BEACONS AND SIMILAR TECHNOLOGIES
We implement reasonable security practices and procedures in accordance with the international standard IS/ISO/IEC 27001 on "Information Technology - Security Techniques - Information Security Management System - Requirements".
In the event that we use your Information for advertising purposes, we will do so in accordance with this section. We may use your Information to try to offer advertising that is more relevant to you.
We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. Such products and services (of ours or third parties) include the following:
- our products and services and the products and services of our affiliate and subsidiary companies and joint venture partners, including messaging services, online media services, interactive entertainment services, social networking services, payment services, internet search services, location and mapping services, application software and services, data management software and services, on-line advertising services and other social media, entertainment, e-commerce, information and communications software and services (“ Internet Services ”); and
- third party providers of Internet Services and products and services relating to dining, food and beverages, sports, music, film, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewellery, cosmetics, personal health and hygiene, electronics, collectibles, housewares, appliances, home decoration and furnishings, pets, automobiles, hotels, transport and travel, banking, insurance and financial services, loyalty and reward programs and other products and services that we think may be relevant to you.
We will honor your request for us to not use your Personal Information for the marketing purposes noted above. If you wish to make such a request, please: ( i ) notify our Privacy Officer; (ii) follow the relevant instructions on our marketing communications; or (iii) follow the instructions as set out in certain service-specific guidance (in relation to the relevant service).
Please note that we do not share your Personal Information with advertisers. We may , however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.
SHARING OF YOUR PERSONAL INFORMATION
We will not share your Personal Information to any third parties for any purposes.
COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use our services, we may send you push notifications to your device. If you no longer wish to receive these communications, you can do so by opting out of notifications at the device level.
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
A WORD ABOUT SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs , videos or information about your social activities, may reveal your sensitive Personal Information to others. Please do not share any sensitive Personal Information on or through our services.
THIRD PARTY SERVICES ON OUR SERVICES
Our services may include, or they may link you to, social media or other services (including websites) provided by a third party. For example:
- you may be able to share content on our services using services provided by third parties. The third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer or device to enable such third party services to function properly; and
- we may (whether in advertisements or otherwise within our services) provide you with links that allow you to access third party services or websites.
TRANSFER OF YOUR PERSONAL INFORMATION
We will not transfer any of your Personal Information to any third parties .
RETENTION OF YOUR PERSONAL INFORMATION
We may retain certain Location Data and Log Data that cannot be used to directly or indirectly identify you . Moreover, it is important to note that communications made by you using our services may put your Personal Information in the hands of third parties that we cannot control – for example, if you have made your Personal Information public via our services (for example , by sharing your photos or videos on third party services or platforms made available via links on our services) . In such case, the collection, use and retention of such Personal Information will be governed by the relevant third party’s privacy policies.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL IMFORMATION
You may have c ertain rights in relation to your Personal Information we hold depending on where you are located, such as the right to access, correct, delete , or request a copy of your Personal Information as well as the right to request to stop or to limit the processing of your Personal Information . To exercise any rights that you may have under applicable laws, please contact us via the contact details below.