Heytalk- Privacy Policy

Welcome to use Heytalk App (hereinafter referred to as "Heytalk", "we" or "Service"). Our Privacy Policy is part of the Terms of Service and applies to all situations when you use our Services, unless otherwise specified. The purpose of this Privacy Policy is to explain in an easy-to-understand way how we collect, use, share and protect your personal information, and explain how you can access and control your personal data.

Scope of application: Unless we link to other policies or have special instructions, this Privacy Policy applies to all your activities when you visit or use Heytalk services.

Acceptance of Terms: By using our services, you confirm that you have read, understood and agree to all the terms of this Privacy Policy. If you do not agree to any of the terms in this policy, please do not use our services.

Data Controller and Data Protection Officer:

1. Controller

Controller: Heytalk is responsible for deciding how to process your personal data.

Data Protection Officer: If you have any questions about the processing of your personal data, you can contact our Data Protection Officer at the specified e-mail address.

Respect for Privacy: Your privacy is at the core of our product design and service building. We are committed to protecting your personal information, ensuring that you have full trust in our services, and focus on building meaningful connections.

Transparency: We are committed to being transparent about our data processing practices, so you can clearly understand how your data is collected and used.

Control: We provide ways for you to access, correct or limit our use of your personal data to enhance your control over the management of your personal data.

By using our services, you agree to the above privacy policy. We encourage you to read and understand the content of this policy carefully before using the services. If you have any questions or need further information, please contact us through the specified methods.

2. What data do we collect

In order to provide and optimize your user experience, ensure the effective operation of the Services, and establish meaningful connections for you, we collect and process the following types of data:

Data you provide: When you use our products and services, you may actively provide certain personal data, such as basic personal information (name, email address, contact information, etc.) filled out during registration. Without this basic information, we may not be able to provide you with complete service functions.

Service usage data: We collect information generated when you use the service, such as access logs, pages you visit, links you click, and records of your activities in the application. This information helps us analyze the usage patterns of the service and improve the quality of the service.

Device and Technical Data: We collect certain data automatically, which may include device identifiers, IP addresses, operating system information, browser type, and other technical information about your device. We may also record which parts of our Services you interact with and how much time you spend in those parts.

Third-party data: When you choose to log in or link our services through a social media account, we may receive information from those platforms. This includes, but is not limited to, your social media user name, profile picture, and public information on those platforms.

By collecting and analyzing this data, we aim to provide a more personalized user experience and continuously optimize our service features. We promise to always comply with applicable data protection regulations and best practices when processing your personal data. If you have any questions about how we use your data, please feel free to contact our Data Protection Officer.

2.1 Data you provide to us

Account Data : In order for you to use some of our features, such as registering an account, you need to provide personal information, including but not limited to your name, gender, age. When you create or update your account, we will collect this information and assign you a unique identification number.

Profile Data : You may choose to provide more detailed profile information, such as photos, bios, interests, etc. This information will be publicly viewable by others unless you choose to delete your account. We may need to access your camera or photo album to add specific content, such as pictures or videos. Information you provide, such as race, sexual orientation, or religious beliefs, may be considered sensitive data in some jurisdictions. By providing this information, you consent to our processing of this sensitive data.

Usage Data : When you use our services, we collect your interaction data, including but not limited to messages, audio, photos, videos and other user data. This also includes your chat records with other users and the content you post on the platform.

Shared Content : Our Services allow you to interact with other users or publicly share content, such as your ratings, videos, and information in your profile. The visibility of this shared content depends on where you choose to share it.

Promotional Data : When you participate in one of our promotions, events or competitions, we will collect information about you used to register or participate in the event. If you win a prize, we will collect the necessary financial information to pay the prize.

Third-party account data : If you choose to connect your social media or other online accounts to our services, or log in through a third-party platform such as Google, we may obtain some of your information on those platforms, such as name, profile picture, gender, birthday, etc. The specific content of this information depends on your privacy settings or the platform's policy.

Paid service data : For paid services provided through iOS or Android platforms, we receive transaction receipt information provided by the platform. For security reasons, we do not collect or store credit card numbers or other sensitive payment information.

Communications and Support : When you contact us to request support or report a problem, whether or not you have created an account, we will collect your contact information and other related information, such as name, email address, geographic location, operating system, IP address, etc. We may also collect other information that you provide or that we obtain automatically. This information will be used to respond to your inquiries and resolve issues.

Sensitive Information : Please be careful about the sensitive information you may share in your profile, such as religious beliefs and health conditions. If you decide to upload and share this type of information, you consent to us processing and making this sensitive data public.

The collection and processing of the above types of data are subject to our privacy policy to ensure that your personal information is properly protected and used legally.

* The data listed above is stored by us and associated with your account in our Services.

2.2 Data from others

In addition to the information you provide to us directly, we also collect data about you through other means, including automatically collected system data and information obtained from third-party partners. The following details the sources of this data and their types:

system data

System data we automatically collect includes but is not limited to:

IP address: Used to identify network connections.

Device information: such as device type, operating system version, hardware settings, unique device identifiers.

Browser information: including type, language and version, to help us optimize display settings.

This information helps us understand users' device configurations and usage habits to improve the overall service experience.

Usage Data

We record your behavior patterns when using our services, including:

Time and date of access.

The features you interact with, your search preferences, and the number of clicks you make.

The pages you visited and the referring source URLs.

Records of your interactions with other users, such as communication time, number of messages exchanged, and content posted.

Collecting this data can help us analyze and optimize service performance and enhance user satisfaction.

Device Information

We collect your device information to provide a more customized user experience, including:

Hardware and software setup.

Advertising identifiers (such as Google’s AAID and Apple’s IDFA).

A unique identifier for your device or browser associated with the cookie.

Other information with your consent

Only with your explicit consent will we collect:

Photos and videos that you wish to share on the Service.

The collection of this data is based on your choices and settings, and you can modify the settings to manage your permissions at any time.

General geographical data

Geographical location information, such as country, city, etc., that we estimate from your IP address.

Third-party partners

We may obtain information about you from advertising partners or other third parties, especially when our ads appear on the platforms of these partners. This information is usually used to measure advertising effectiveness and conduct market analysis. 3. How we obtain your data

We use tools such as analytics services and advertising providers to collect the data listed below. Some of these tools allow you to opt-out of data collection.

3.1 Analysis

The main reason we use your information is to provide and improve our services. In addition, we use your information to help keep you safe. Read on for a more detailed explanation of the various reasons we use your information, as well as real-life examples.

3.2 Specific third-party SDKs include:

SDK:rong cloud

Manufacturer: Rong Cloud

Purpose of use: To provide real-time messaging functions and services

Information collected: device brand, device model, ANDROID_ID, operating system version, CPU information, memory usage, IP address, network access method and type, user ID under App Key, application package name, time zone, language, App version number, App Key of App, user token, RongCloud SDK version number, operator code MNO, interface call error code, link failure error code

SDK:Agora

Manufacturer: Agora

Purpose of use: Voice calls

Information collected: network type, user's local IP address, WLAN and cellular network signal status, operating system, device model, CPU, memory, device power, audio stream data, Bluetooth, network latency, packet loss rate, bit rate, resolution, audio bit rate, sampling rate

SDK: Facebook

Manufacturer: Meta

Purpose: Facebook event manager

Information collected: Please refer to https://www.facebook.com/privacy/policy/?section_id=1-WhatInformationDoWe

SDK: google

Manufacturer: google

Purpose of use: Login

Information collected: OpenID

SDK: adjust

Manufacturer: Adjust

Purpose of use: Installation data attribution analysis

Information collected: app activity, device or other identifiers

We try our best to provide security measures for users' personal information to prevent illegal use, unauthorized access, disclosure, leakage, damage and loss of users' personal information. We will use all possible security measures within a reasonable security level to ensure information security. For example, we will use encryption technology (such as SSL), anonymization, encrypted storage and other means to protect your personal information; we will establish a reliable protection mechanism to prevent personal information from malicious attacks; we will establish an access control mechanism and abide by the principle of minimum access to ensure that only authorized personnel can access personal information; we will conduct training courses on security and personal information protection to enhance employees' understanding of personal information protection.

We will also take all reasonable and feasible measures to avoid collecting irrelevant personal information. If you find that your personal information, especially your account or password, has been leaked, please contact us immediately so that we can take appropriate measures based on your application.

Please note that when you use our services, you voluntarily share or even disclose your information, which may involve your personal information or the personal information of others. Please carefully consider whether to share or even disclose such information when using our services.

You are responsible for maintaining the confidentiality of your password and account information at all times.

3.3 Online Advertising

We use third-party advertising services (such as Google's advertising services including DFP, Admob, AdX and Facebook Audience Network) to serve online ads to users in our services (including mobile apps and websites). These ads are personalized based on the following information about you:

Information we collect about you from third parties (see section 2.2 Data from others).

Information collected about you by ad service providers through tracking technologies.

Ads may be personalized based on your recent activity, long-term behavioral patterns, and your activity on other services. When you use other services, you may also see online ads that are personalized to your interests and preferences.

We also promote our services on some third-party platforms, such as Google's Adwords, Apple's search ads, Facebook custom campaigns, and Google Ads. By working with marketing service providers (such as Facebook), we can market and promote on third-party websites and apps and measure the effectiveness of advertising campaigns. We may use data to create a "custom audience", which is a group of users who we believe will be most interested in a specific advertisement.

Tracking technologies and data sharing

In order to provide personalized advertising, we may place cookies on your device or use other tracking technologies to collect data about your use of our services. We may also access these technologies to provide personalized advertising. To do this, we may provide service providers with hashed anonymized versions of some of your personal information and the content you share publicly on the service. This information is processed in a non-human readable form to ensure the security and privacy of the data.

All third-party tools we use, such as Adjust and Admost, are GDPR compliant. These tools are mainly used for analysis and tracking of advertising and user data to measure usage.

If you access or use our services through a third-party platform or service, or click on any third-party links, the collection, use and sharing of your data will be subject to the privacy policy and other agreements of that third party.

All advertising processes, including personalized advertising, use only irreversibly anonymized data, ensuring that the identity of any individual cannot be inferred from it.

If you are located in a region protected by CCPA and GDPR, you have the right to change your personalized advertising preferences in settings to control how you receive and view ads.

4. Purposes for which we use your data

To administer your account and provide you with our services

Create and manage your account

Provide you with customer support and respond to your requests

Complete your transaction

Communicate with you about our services, including order management and billing

Help you connect with other users

Analyze your and other users’ profiles to recommend meaningful connections

Show users’ profiles to each other

Improve our services and develop new ones

Administer focus groups and surveys

Conduct research and analysis on user behavior to improve our services and content (for example, we may decide to change the appearance or even significantly modify a feature based on user behavior)

Develop new features and services (for example, we may decide to build a new interest-based feature based on user requests).

Prevent, detect and combat fraud or other illegal or unauthorized activity

Addressing ongoing or suspected misconduct on and off the platform

Conduct data analysis to better understand and design countermeasures to these activities

Retain data related to fraudulent activity to prevent recurrence

Ensuring compliance with the law

Comply with legal requirements

Assisting law enforcement

To enforce or exercise our rights, such as our terms

To process your information as described above, we rely on the following legal bases:

Providing you our Services: Most often, we process your information to perform the contract between you and us. For example, when you use our Services to build meaningful connections, we use your information to maintain your account and profile, make it viewable to other users, and recommend other users to you.

Legitimate Interests: We may use your information where we have a legitimate interest in doing so. For example, we analyze user behavior on our Services to continually improve our Services, we recommend offers that we think may interest you, and we process information for administrative, fraud detection, and other lawful purposes.

marketing:

Push message marketing: With your explicit consent, we will send you marketing push messages.

Email marketing: With your explicit consent, we may send you marketing emails.

Text messages: With your explicit consent, we may send you text messages (SMS).

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You can withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. How We Share Information

5.1 With other users:

When you voluntarily disclose information on the Services, including your public profile, you are sharing that information with other users. Please be careful with your information and make sure that what you share is what you would like to see publicly, because once you share your information, neither you nor we can control what others do with it.

5.2 With our service providers and partners:

We use third parties to help us operate and improve our Services. These third parties assist us with a variety of tasks, including data hosting and maintenance, analytics, customer service, marketing, advertising, payment processing, and security operations. These service providers may have access to your personal data and are required to use it only in accordance with our instructions to provide the services we request.

We may also share information with partners who distribute and assist us in advertising our Services. For example, we may share limited information about you in a hashed, non-human-readable form with advertising partners.

We follow a rigorous vetting process before engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

5.3 Where required by law:

We may disclose your information when reasonably necessary to: (i) comply with legal process, such as a court order, subpoena or search warrant, a government/law enforcement investigation, or other legal requirement; (ii) assist in the prevention or detection of crime (in each case, subject to applicable law); or (iii) protect the safety of any person.

5.4 Exercising legal rights:

We may also share information: (i) if disclosure may mitigate our liability in actual or threatened litigation; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

5.5 Monitoring:

Moderators monitor activity on the Site/App and approve content. Anti-fraud and anti-spam providers protect the Service from criminal activity.

5.6 Change of Control:

We may need to disclose your personal data if our Service or any of its affiliates goes through a business transition or change in ownership, such as a merger, acquisition by another company, reorganization or sale of all or a portion of its assets, or in the event of bankruptcy or administration.

6. Your rights

You have specific rights regarding the use of your data, including the ability to opt out of cookies and certain analytics providers collecting your data. You can update or terminate your account within our services or contact us to make a request for individual rights regarding your personal data. We want you to be able to control your information, so we provide you with the following tools:

Access/Update Tools in the Services: Tools and account settings that help you directly access, correct, or delete the information you have provided to us and that is associated with your account in the Services.

Deletion: You can delete your account directly using the corresponding function on the Service.

We want you to understand your privacy rights. Here are a few key points to remember:

Review your information: Applicable privacy laws may give you the right to review the personal information we hold about you (depending on the jurisdiction, this may be called the right of access, the right of portability, or a variation of these terms). You can request a copy of your personal information by sending us an email at miaoyuchangwei@gmail.com .

Updating your information: If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it, and wish to request correction, deletion or object to its processing, please contact us at miaoyuchangwei@gmail.com .

For your protection and the protection of all of our users, we may ask you to provide proof of your identity before we can respond to the above requests.

Please keep in mind that we may deny requests for certain reasons, including if the request is unlawful or may infringe on trade secrets or intellectual property rights or violate the privacy of other users. If you wish to receive information about another user, such as a copy of any messages you receive from him or her through our Services, the other user must contact our Privacy Officer to provide written consent before the information is released.

Additionally, we may not be able to honor certain requests to object to the processing of your personal information, particularly if such a request would no longer allow us to provide you with the service. For example, if we do not have your date of birth, we cannot provide the service.

Uninstall: You may uninstall the App using your device’s standard uninstall process, thereby stopping all information collected by the App. If you uninstall the App from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the App on the same mobile device, we will be able to re-associate this identifier to your prior transactions and activity.

Accountability: In some countries, including the EU, you have the right to lodge a complaint with the appropriate data protection authority if you have concerns about the way we process your personal information. The data protection authority to which you can lodge a complaint may be the data protection authority of your habitual residence, your place of work or where we are based.

If you would like to exercise any of the rights listed above, please visit our feedback form or send an email to miaoyuchangwei@gmail.com .

7. System permissions called

In order to provide you with complete product services, we may need to use the system permissions in your device (excluding permissions called by third parties) to collect relevant personal information. Although we have already touched upon this in the previous section, this section will summarize all the system permissions used to facilitate a more systematic, complete and transparent presentation to you. You can choose whether to authorize us to use the relevant permissions of your device . If you do not authorize us to use the relevant permissions, some services may be unavailable, but it will not affect your use of other functions.

Photo album and storage permissions: When you agree to enable this permission, we will use the photo album reading and storage function on your device. This function will be used to upload text, images, videos and other content in your device, and can also cache text, images, and video content generated during your use of products or services. Please be aware that we will not automatically read the storage content of your local photo album. We will only obtain image/video data after you agree to enable this permission and actively select the corresponding image in the photo album. If you refuse this authorization, the aforementioned functions will not work properly.

Microphone permission: When you agree to enable this permission, we will use the microphone function on your device and recognize the voice information you upload. This permission will be used to implement the voice input function and collect and recognize the voice information input during the implementation of the above function. If you refuse this authorization, the above functions will not be available.

Message push permission: When you agree to enable this permission, we will push messages to you so that you can receive and understand the notifications we send you in a timely manner. If you refuse this authorization, you will not be able to receive the messages we push to you.

Camera permission: When you agree to enable this permission, we will use the camera function on your device. This function will be used to realize the photo shooting and video recording functions, and collect and identify the pictures and video information taken or recorded during the implementation of the above functions. If you refuse this authorization, the above functions will not be available.

Floating window permission: In order to float the minimized content of the "Group Voice Chat Room" on other content, we will apply for your floating window permission. If you refuse such authorization, the above functions will not be available.

Device information access permission: When you agree to enable this permission, in order to protect your account and login security, we will collect your corresponding device information for optimizing user experience, security checks, identifying whether it is a commonly used device, and device binding status. If you are an Android user, your refusal to grant this authorization will result in your inability to use this product and/or service normally. If you are an iOS user, you may not be able to directly refuse or close the above authorization due to the restrictions of the iOS system, but for some device information (for example, IDFA information, which is subject to the actual situation updated from time to time by the iOS system policy), you can choose whether to authorize us to collect it. If you refuse to authorize, we may not be able to provide you with the corresponding functions or services (for example, if you refuse us to collect your IDFA information, we will not be able to provide you with personalized display based on the IDFA tracking identifier).

Access the network and obtain network status permissions: Our APP can only connect to the Internet after you agree to enable this permission. At the same time, for the purpose of risk control and providing services, we can also monitor network changes and remind users of the current network environment. If you refuse this authorization, you will not be able to use this product and/or service normally.

8. Data Retention

We retain your personal information only for as long as necessary for legitimate business purposes and as permitted by applicable law. To ensure the security of users when using and not using our services, in addition to technical issues, we will implement a six-month security retention period after account deletion. During this period, we will retain some of your account information, but the account will no longer be displayed in the service. Generally, we will delete or anonymize your information after the security retention period after account deletion ends or after five consecutive years of inactivity. An account is considered inactive if it has not established contact with the Heytalk server or used the application during this period. However, please note that premium members' accounts will not be considered inactive even if they are inactive.

Data retention in special cases:

Comply with laws: We retain certain information where necessary to comply with statutory data retention obligations, such as retaining “traffic data” for one year.

Demonstrating compliance: To demonstrate our compliance with the law, we may need to retain records related to our Terms, Privacy Policy and other consents, which are typically retained for five years.

Resolving Disputes: If there are pending issues, claims, or disputes, we may need to retain relevant information until those issues are resolved.

Maintaining Business Interests: To prevent fraud and enhance user safety, we may need to retain information necessary to prevent users who have been banned due to inappropriate behavior or security incidents from attempting to create new accounts.

Correspondence with our customer support team may be retained for longer to allow us to deal with any follow-up queries you may have. Generally, this information will be deleted after 6 years if there are no follow-up queries.

Retention of Anonymous Information:

We may retain anonymous information relating to service activity for longer periods of time for statistical and product research purposes. Once a personal profile is deleted, this informa