Imou Privacy Policy

Last modified: January 10, 2023

About Us

Huacheng Network (HK) Technology Limited and its affiliated companies (hereinafter refer to as “Huacheng”, “Imou”, “we”, “our” or “us”) take your privacy very seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal data collection and usage practices, while ensuring that ultimately, you have control of your personal data provided to us.

Please take a moment to read and understand our Privacy Policy, accessible via the headings below, and let us know if you have any questions.

About this Privacy Policy

This Privacy Policy explains how we collect, use, disclose, process and protect any personal data that you give us or that we collect from you. Should we ask you to provide certain information by which you can be identified when you use our applications, and/or products or services or interact with us on our websites, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Under this Privacy Policy, “personal data” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information we have access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal data strictly in accordance with this Privacy Policy.

 

This Privacy Policy includes the following contents:

1. How we collect and use your personal data

2. Cookies and other Technologies

3. How we process children’s personal data

4. How we store and protect your personal data

5. How we disclose personal data

6. Third Party Suppliers and Their Services

7. International Transfers of your personal data

8. Your rights to your personal data

9. Updates to our Privacy Policy

10. How to contact us

11. Special Section for Certain Jurisdictions

 

1. How we collect and use your personal data

A Personal data collected and used by Huacheng

We collect several types of information from and about users of our Services, including information that you directly provide to us and it identifies you personally, such as, without limitation, name, postal address, e-mail address and telephone number.

 

We may also automatically collect certain information as you navigate through the website or use our Services, such as usage details, equipment profiles and IP addresses, by means of cookies, web beacons and other tracking technologies.

 

We have set out below, in a table format, a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We will only collect the personal data that is necessary for its specified, concrete, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the data we have requested, but in most cases, if you do not provide your personal data, we may not be able to provide you with our services or respond to your queries.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Activity

Type of data  

Processing purposes

Lawful basis for processing 

A. Use of Imou App, Devices and Cloud

1a. When you sign up with Imou App for the first time

Email address; telephone number (only of customers who sign up with Imou App via their telephone number); country or region you choose; nickname you use (if uploaded); password (encrypted); profile photo (if uploaded); your User name, nickname and profile photo on a third party platform when you choose to log in to Imou App with other app account such as Facebook and Apple.

To allow us complete your registration, communicate with you and administer your account. Profile photo and nick name can be uploaded on a voluntary basis if you desire to have a more personalized account, omission to do so, does not affect the running of Imou App 

Performance of contract for Imou Registration Agreement and legitimate interests to maintain our contractual relationship with you, provide you with services in accordance with the legal requirements of the country/region you have chosen, allow you enjoy the services features as described in the user guide , keep our products updated and relevant, to develop our business and ensure security of products and that your use of our products are in compliance with the accepted terms and conditions

1b. When you change the details you used for registration

If you choose to change any of the above information, the new entries will be collected in replacement of the old ones.

To allow the changes you have requested for. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imou Apps other functions

2. When you log in and use our services

Apart from the information mentioned under item 1, we process data related to the terminal (such as your smartphone) you use to log in, like GPS, terminals operating system, model, its unique identifier, MAC address

To offer our services to you, maintain our servicesnormal operations, optimize our services and secure the safety of your account

3. When you add device (on the Device interface, you can view and add devices like IP cameras, storage devices, and doorbells, to Imou App)

Device SN; Device QR code, Device model; wifi info; Device Name; precise geographical location; Device password (encrypted); device time zone and DST status on/off, camera permission that provide access to the camera on the device 

To process your request to add a device to your account and allow configuration of your device. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imous other functions.

4. When you use Live View function which provides you a real-time video display

Device SN; Device IP; Device Port Information; Video Stream

To provide you with the basic services of video display through Imou App

5. When you use Playback and Video Recording functions

Device SN, Devices Channel ID, Record Files Path

To store your history record and allow you view  it

6. When you activate and configure the settings of the added device such as IP camera, doorbell and storage device

Mac address; IP address; Device SN; Device model; Device firmware version; Country information (via IP address); Device location (via IP); Date of device register; Device channel information; Device offline/online status; Device configuration information

To allow activation of your Imou device and its registration with our server

7. When you set device name and cover image

Cover image; Device name; Channel information; Device model; Device SN

You can set device name, change cover image, and view channel name, device model and SN. The processing of such information is needed for us to allow the changes you have required for and to inform you about the details of the device added on your Imou account. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imou Apps other functions.

8. When you enter device password or use the reset function

Device SN; user name, telephone number, Email address, current password (encrypted) and new password (encrypted)

To allow you enhance the security of your device by adding a password or reset your password. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imous other functions.

9. When you use Device Share function

Device SN; User name, Email address and (or) telephone number of the other user you share your device with

To allow you the sharing of your device with another user of Imou App as requested by you. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imous other functions.

10. When you use Delete Device function

Device SN; Email address and (or) telephone number (only of customers who sign up with Imou App via their telephone number).

To allow the removal of the device from your account on Imou App and matched accessory as you requested us for. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imous other functions.

11. When you receive notification

Device SN, Device unique identifier, MAC address; Push notice ID/alarm snapshot; your User name on a third party platform when you choose to log in to Imou App with other app account such as Google

To send you alarm notifications and provide you the services you have requested us for

12. When you use Imou Apps cloud services to extend your storage capability

Device SN; messages and video record; Device channel information

To allow you use of the cloud storage service (either free or added value version). Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of Imous other functions.

13. When you buy cloud storage plan or redeem gift card or Imou Protect plan

Details of the purchased cloud storage plan or Imou Protect plan; payment method; order date; Email address

To process your order and invoice you for the purposes of cloud storage plan

14. When you transfer your cloud storage plan

Device name the plan is transferred from; device name the plan is transferred to; plan information

To transfer the activated cloud service to a specific device added to your account. Refusing to provide such information may only result in your being unable to use the user experience program, but does not affect your normal use of Imous other functions.

15. When you use Device audio collection function

Your user name, telephone, Email address and permission that provide access to the microphone on the Device

To allow you to conduct audio data collection. Devices with microphones enable audio capture by default, and you can disable it on the device details page. After the audio collection is turned off, the real-time preview and recording of the device will have no sound.

16. When you use Device Geofencing function

Your precise geographical location, User name, telephone, Email address, Device SN; your User name on a third party platform when you choose to log in to Imou App with other app account such as Google

To allow you to receive alarm notifications when you go out of the designated fence area

17. When you use AI detention function

Event-based video record

To improve the accuracy of the AI detention for the event-based video record.

Consent

18. When you use the device

Media Access Control Address (MAC), network access method and type, operation log information, network log or device log information, error or abnormal service data, System operating status, performance data, etc. of abnormal equipment

To timely and effectively solve the failure problems you encounter when using our devices, to ensure the safe operation of the devices and the safe use of our services

Consent

19. When you use Device AI function

Device SN, and personal data captured by the camera, i.e. car license number

To allow you to receive alarm when detecting particular targets, i.e. human shape, motor vehicles, and pets, and intelligent summary push

Consent

20. When you use User Experience Plan function

Browsing history & clicking behavior

When you enable user experience plan, you give us consent to collect such information and help us improve our products and services and analyse your usage of different functions. Refusing to provide such information may only result in your being unable to use the user experience program, but does not affect your normal use of Imou Apps other functions.

Consent

21. When you communicate with us through email or Feedback function

Content of your communication with us

To communicate with you, provide you with information you request about us, answer your questions or handle your complaints

Our legitimate interests to communicate with you and reply your inquiries/comments

22. When you de-register from Imou App and cease to use Imou device and our service

Your telephone number (only of customers who sign up with Imou App via their telephone number),  and (or) Email address.

To allow us to complete your deregistration, and to delete all your personal data collected by us during the period of your use of Imou App.

 Performance of contract

23. device log

Your user name, telephone number, Email address, Device SN, and permission that provide access to the storage on the Device

To allow us to improve our Imou App and device service and provide you with better user experience

Consent

24. Device Label Figure and name

Your user name, telephone number, Email address, Device SN, and permission that provide access to the storage on the Device

To allow you to save QR code with Device detail at your terminal

Consent

B. When you take part in our marketing activities

When you take part in our marketing activities either offline or online, including but not limited to exhibitions, prize draws, competition or surveys

Email address; telephone(only of customers who sign up with Imou APP via their telephone number); location; your feedback and replies to a survey (if applicable); profile details on a third party platform (if you choose this way for registration)

To register your interest to our products and services

Consent

To communicate with you and inform you about the progress and result (if applicable) of the marketing activity you have opted in for

Consent

To ask you to leave a review or take a survey

Consent

To inform you about similar events if you have opted-in for this

Consent

When you take part in our marketing activities happening   offline, including but not limited to exhibitions, prize draws, competition or surveys

Photographs or videos taken during the event

To promote our activity and event

Legitimate interests to promote our business products and services

When the Imou Life App launch

Your user name, telephone number, Email address.

To register your interest to our products and services. Ad push is turned on by default in the app, you can turn it off in the [My/Settings/Ad] option.

Legitimate interests to promote our business products and services

C. When you request after-sales services

1. When you register with our RMA platform

Name; Email address or third party account that you use for registration; country; password (encrypted); language

Assist you completing Imou registration and protect your Imou account security

Performance of contract for provision of after sales services;
Legitimate interests to provide you better services and facilitate the exercise of your rights to after sales services.

2. When you submit an RMA request through the APP, website or our third party hotline

Device model; SN of the device; MAC address, IP address; details indicated on the evidence of purchase;
Telephone; address for return of the device after repair and details of recipient; details for the return of devices and tracking number

Receive and deal with your request for after sales services;

Performance of contract for provision of after sales services or adherence to legal obligation we might have in regard to consumers guarantee.

Recommend you the nearest repair center (if applicable);

Send the device after repair to the recipient and address indicated by you

Communicate with you for any clarifications we or you might need

Legitimate interests to clarify your request and improve our services

Ask you for feedback and the degree of your satisfaction for our services

3. When you reset your password

SN of the device; MAC address; email

To assist you with resetting your password and proceed with the modifications you have requested for

Legitimate interests to provide adequate services

D. When you use our website

1. When you subscribe for newsletter

Email address

To send you newsletters, promotions or other marketing communications, including invitations to our exhibitions.

Consent

2. When you use our website

Technical details
Usage behaviour
(More info on Cookies statement)

To use analytics to improve our website, products/services, marketing, customer relationships and experiences, and to administer and protect our websites

Legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and ensure security of our website. 

E. Other uses of your information

We use the information we collect to provide or improve services provided by us, our partners, or other trusted third-party vendors, such as providing, evaluating, improving, or upgrading services; participating in market research activities related to our services, developing new services, providing customer support, etc. To improve the services, we may also analyze product usage, but these statistics will not include any of your identifiable personal data.

Performance of contract and legitimate interests to keep our services updated and improve them

We use your contact details to communicate with you, provide you with information you request about us, answer your questions or when we handle your complaints. We might use these details to send important notifications to you, such as changes in our relevant terms, conditions and policies. Since this information is very important for you to communicate with us, it is suggested that you receive and read such information

Performance of contract and legitimate interests to administer the contractual relationship with you

We may be required by law to collect and share your identifying information and personal data with public or governmental organizations for the purpose of compliance with the law, a court order, or to respond to any government or regulatory request.

Compliance with a legal obligation

 

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our website or applications, or transmitted to other users of our services or third parties (collectively, “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. We cannot control the actions of other users of our services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

B Collection and use of non-identifiable data

We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal data according to applicable local laws. Such information may include statistical data generated when you use a specific service (e.g. daily usage events, page access events, page access time events and session events); network monitoring data (e.g. request time, number of request or error request etc.); application crash events. The purpose for such collecting is to improve the services we provide to you. The type and amount of information collected depends on how you use our services. Such data is not personal data as it cannot be used to identify you. However, if we combine non-personal data with personal data, such information will be treated as personal data.

2. Cookies and other technologies

 

Our website and apps use cookies and similar technologies. We use functional cookies to ensure that our website and services operate properly and analytical cookies to make your user experience optimal. Third-party cookies may collect data outside our websites as well. As you navigate through and interact with the website and our services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, traffic data, logs and other communication data. You can find more information on our Cookie Statement. 

Our Privacy Policy does not cover the use of cookies by others, including, without limitation, our partners, affiliates, tracking utility company and service providers. We do not have access or control over these cookies.

 

3. How we process children’s personal data

 

Our websites, products and services are not primarily intended for children. A child must not create a Huacheng account without the consent of a parent or guardian. If a child's personal data is collected with prior parental consent, we will only use or disclose the data as permitted by law, with the explicit consent of the child's parents or guardians, or when necessary for the protection of the child. Huacheng strongly recommends that parents take an active role in supervising the online activities of their children. If you believe we might have any information from or about a child, please contact us at ­­­ privacy@imoulife.com .

 

4. How we store and protect your personal data

4.1 Data Security Measures

We have implemented appropriate technical and organizational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

We also provide training on security and privacy protection for employees to raise their awareness of personal data protection. We are committed to protecting your personal data; however, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal data when transferred from you or to you via the Internet.

We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.

4.2 Retention Policy

Your personal data will be retained for as long as required for the purposes described in this Privacy Policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will retain your personal data for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. We will cease to retain and delete or anonymize personal data once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding service.

 Please pay attention that video recordings and snapshots within Imou App are automatically deleted after the cloud service or the cloud saving period ends. And the retention periods of alarm messages, alarm snapshots and IP addresses in API logs are just 7 days.

An exception to this is personal data that we are processing for public interest, scientific, historical research, or statistical purposes. Huacheng will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

 

5. How we disclose Personal Data

5.1 We might disclose your personal data with certain trusted third parties for the following reasons:

To our subsidiaries and affiliates to provide you the services you have requested us for and for the purposes of our legitimate interests of customer relation management

To forwarders/carriers and other business partners to the extent that we need to deliver your orders

 To IT services providers who offer support during our daily operations, such as the maintenance of digital databases

  To third party hotline service provided for receiving and following up on your request for after-sales

 To marketing services providers in order to provide you the services you have requested us for, such as receiving the news you have opted-in  

 To a buyer or potential possible buyer of our business for evaluation and completion of transactional corporate matter.

All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.

 

5.2 We may also disclose your personal data:

 To comply with any court order, law or legal process, including to respond to any government or regulatory request or for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).

  To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

  If we believe disclosure is necessary or appropriate to protect the legitimate rights, property or our safety, our customers or others.

 

5.3 As regards the personal data collected during your use of the Imou App and Cloud, we use the services of cloud service providers, including: Amazon Web Services. Inc (United States), 阿里云计算有限公司(Alibaba Cloud Computing Co., Ltd(P.R. China), Azure (United States), 北京金山云网络技术有限公司(Beijing Kingsoft Cloud Internet Technology Co., Ltd(P.R.China) Apart from that, we ensure you that we will not share such data unless you have explicitly requested such sharing, when for example you apply to connect your Imou App and device with IFTTT Inc., Google Inc., Amazon.com, Inc., etc. or when you use your Facebook account to log in (Facebook Inc.)

 

 

6. Third Party Suppliers and Their Services

To ensure you have a smooth browsing experience, you may receive content or network links from third party suppliers (hereinafter referred to as the third party) beside us and our partners. Except as otherwise expressly stated in this Imou Privacy Policy, this Imou Privacy Policy does not apply to situations where a third party independently provides services to you through our services, such as websites that may include the services we offer or other third parties’ sites that have a link to our services. Please note that if you use such third parties’ products and/or services (including but not limited to PayPal, Stripe or other credit card payment services) and provide your personal data, your information will be handled in compliance with that third party's privacy statement or similar policies. We cannot control the privacy and data protection policies of the third parties, and the third parties are not bound by this policy. Before submitting personal data to third parties, please see the privacy policy of these third parties. You can choose whether to access links, contents, and services provided by third parties. We take no responsibility when your information was misused or improperly disclosed in such occasions.

 

7. International Transfers of your personal data

We are headquartered in the P.R. China and we operate globally. We have established subsidiaries in different regions around the world and we offer our services through the use of servers located in different countries. Currently, Huacheng has data centers in the United States, Germany and Singapore. For the purposes described in the Privacy Policy, your information may be transferred to these data centers in accordance with applicable law. We may also transfer your personal data to third-party service providers and business partners and your personal data may be transferred, stored and processed outside of the country or region where it was initially collected. The applicable law in the countries and regions where we operate may differ from the laws applicable to your country of residence. There are different risks under different data protection laws and that we may transfer and store your personal data to overseas facilities. However, we will take necessary measures to ensure that your information is processed as required by this Policy and in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy. If Huacheng shares personal data originating by you in the European Economic Area (“EEA”) to its affiliates or a third party service provider outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR 

 

8. Your Rights to your personal data

You can review and change your personal data by logging into your account on our website and visiting your account profile page.  You may also send us an e-mail at privacy@imoulife.com  to request access to, or require us to correct or delete any personal data that you have provided to us. You may also object to or request us to restrict your processing. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us (see below). A summary of your legal rights is set out below:

 

 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you want to access your head portrait, user name, email address and other basic information, or video, image, order, device and other service information on your Imou account, you can enter Imou and tap on corresponding function button to access relevant information.

 

 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you want to change your nickname, email address, etc. on your Imou account, enter Imou, tap on related function button.

 

 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you want to delete the basic information such as email address, and password, or service information such as video, image, cloud record and alarm on your Imou account, you can delete your information by tapping on related data clear function button through “Me->Settings->Account and Security->Delete Account”.

 

 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

We have the right to refuse to process requests that are frivolous, requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected. 

 

 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you want to disable user experience program and alarm information on your Imou account, you can enter Imou and tap on corresponding close button to turn it off.

For security reasons, we will take steps to authenticate your identity before providing access to your personal data.

 

If you think that the way we process your personal data does not comply with applicable data protection laws, you can contact the relevant competent data protection authority. For EU, you can obtain the information for contacting EU data protection authoritiesat http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

 

9. Updates to Our Privacy Policy

We keep this Privacy Policy under review and modify this Privacy Policy from time to time. We will release the latest Privacy Policy on this page for any changes. If major changes are made to the Privacy Policy, we may notify you through different channels, for example, posting a notice on our website or sending you direct notification. The date the Privacy Policy was last revised is identified at the top of the page.

We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the services on the website, mobile and/or any other device will be deemed acknowledgement of the updated Privacy Policy.

 

10. How to contact us

If you have any questions or comment about this Privacy Policy and our privacy practices, please contact our Data Protection Officer through email at privacy@imoulife.com , or by mail at:

Huacheng Network (HK) Technology Limited

13/F Gloucester Tower, the Landmark,
15 Queen's Road Central Central,
Hong Kong

C/O: Data Protection Officer

 

11. Special Section for Certain Jurisdictions

Hong Kong SAR

If you are using the Services in Hong Kong SAR, the following additional terms apply. If any conflict arises between the main Privacy Policy, the following terms shall prevail: 

As a Hong Kong SAR data subject you have legal rights in relation to the personal data we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request (to receive a copy of the data we process about you). You can also exercise your right to data correction as well as your right to stop to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

 

United States

If you are using the Services in United States, the following additional terms apply. If any conflict arises between the main Privacy Policy, the following terms shall prevail: 

California Consumer Privacy Act. For Users who are California residents, you have the following extra rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

  1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
  2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
  3. We did not sell personal information and therefore did not process requests for opt-out of sale.

California “Shine The Light” Law. For users located in California, we do not share your personal information with third parties for those third parties’ direct marketing purposes. 

 In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using our applications.

 

Russia

If you are using the Services in Russia, the following additional terms apply. If any conflict arises between the main Privacy Policy, the following terms shall prevail: 

Legal Basis. When we process your personal data, we rely on your consent, performance of a contract, our legitimate interest and obligations to process personal data, when we so required by law.

Cross-border Transfer. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates or where our service providers are located

 

Singapore

By clicking "accept", you consent to the collection, use and disclosure of your personal data, for the purposes set out in the section "How we collect and use your personal data" in the Privacy Policy.

Right to Access. You have the right to access your personal data, how we use it, and who we share it with. You can access the personal data you have made available as part of your account by logging into your account.

Right to Correct. You have the right to correct any of your personal data that is inaccurate. You can access the personal data we hold about you by logging into your account.