Privacy Policy
Update date:2023.8.24
Effective Date: 2023.8.24
Preface
[littlebear] Network Limited ( “we”, “us”, “our”) is the provider of this Application. We attach great importance to your privacy and personal information. Please carefully read this privacy policy (“Privacy Policy”) when you use our services(“Service”). This Privacy Policy will come into effect for all existing users on 24 [8 ], 2023 Your use of the Service from that day will be subject to this Privacy Policy.
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the Service, and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are accepting our rules regarding your personal information as described in this Privacy Policy.
If any dispute or controversy arises between you and us, it shall first be resolved through friendly negotiation; if negotiation fails, you agree to submit the dispute or controversy to the jurisdiction of the people's court in the place where this Agreement is entered into (i.e., Tianhe District, Guangzhou, China), and the laws of the People's Republic of China (excluding conflict of laws) shall apply.
Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact our data protection officer anytime at [ chenyingwork716@gmail.com ] .
1. How We Collect Your Personal Information
2. How We Use Your Personal Information
3. Your Rights
4. How We Store and Share Your Personal Information
5. The Security of Your Personal Information
6. Services provided by Third Parties
7. Children
8. Notification and Modification
9. California
10. European Economic Area (EEA)
When we provide services, we may collect, store and use your certain personal information based on specific product features. If you do not provide relevant information, you may not be able to enjoy the specific services we provide, or you may not be able to achieve desired effect.
The following is a high level summary of the types of personal information we use:
2. Information we automatically collect from you when you use the Service
· Scope of collection: Device or software information, such as device model, mac address, IMEI, OAID, andriod ID, battery, signal strength, configuration information, your IP address, and the version used by your mobile device or other programs used to access our Services;
· Information you search for or browse when using our Services, such as the web search terms you use, the URL addresses of social media pages you visit, the length of stay, refresh records, posting history, follows, subscriptions, favorites, shares, and other information and content details that you browse or request when using our Services;
· Information about mobile applications (apps) and other software that you have used, and information about the mobile applications and software you have used in the past;
· Information (metadata) contained in content you share through our Services, such as the date, time, or location of shared photos or videos taken or uploaded.
· Purpose of collection:We collect such information to identify the status of your account, understand product adaptability, ensure the network and operational security of our services, and provide you with page display, browsing, and search services that are more suitable for your needs.
· Scope of collection:When you use our services through a mobile device with a location function we will collect your location information through GPS or WiFi, etc.;
· Real-time information provided by you or other users that includes your geographic location, such as information about your location contained in the account information you provide, shared information uploaded by you or others that shows your current or past geographic location, and the geographic tag information contained in photos shared by you or others;
· Purpose of collection: We collect such information to provide you with WiFi connection, WiFi acceleration, optimized services, and more accurate weather reports and personalized targeted push services.
· Scope of collection:We will collect information that you search for or browse when using our Services, such as the web search terms you use, the URL addresses of social media pages you visit, the length of stay, preferences, search frequency, refresh history, posting history, followers, subscriptions, favorites, sharing, and other information and content details that you browse or request when using our Services.
· We use the information for feature analysis and user profiling, which may help present content that better meets your needs on tool creatives and ad content recommendations to reduce your time filtering through massive amounts of Internet content.
· Scope of collection: We may use the IOS system's APIs to collect information about your subscription order, such as purchases, subscription times, order status, payment times. We do not collect specific information about payments, and we are not responsible for the collection and security of such information. Payment information is processed and stored by third-party companies, such as Apple, who can be contacted through their websites: https://www.apple.com. Before you enter your personal payment information, we recommend that you read and familiarize yourself with the privacy policies of these third-party companies.
· Service data and log information: open ID, IP address, device model and information regarding your use of the Service.
3. Information we collect through a third party
We obtain information that you authorize to share from our affiliates, third-party partners. For example, we may obtain your account information (including user name, avatar, nickname, subject to your authorized content) from a third party and bind your third-party account to your service account registered with our products after you agree to this policy, so that you can directly log in and use our services through the third-party account. We will collect and use your information in accordance with relevant laws, regulations, and the agreement with affiliates or third-party partners, and under the premise that the source of the information provided by them is legitimate.
4. Exemption
According to applicable laws and regulations, under the circumstance below, we may collect your information without your prior consent.
2. How We Use Your Personal Information
1. To display and recommend goods or services for you
We may use the information you provide to us, the information we collect about you directly or indirectly (such as your browsing and search history, device information, location information, etc.) to model recommendation algorithms, model programmatic advertising recommendation algorithms, analyze user behavior, and user portraits by combining one or more of the above information, to extract your browsing history, search preferences, behavior habits, location information and related characteristics. In order to provide you with page display and recommend personalized content that is more tailored to your needs.
2. To send you marketing messages which is based on your characteristics via email, SMS or other means, to provide or promote the our or third parties’ goods and services
Our goods and services, including but not limited to: instant 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, online advertising services, Internet finance and other social media, entertainment, online games, e-commerce, information and communication-related software and services; and
Third-party goods and services, including but not limited to: Internet services, food and catering, sports, music, movies, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewelry, cosmetics, personal health and hygiene, electronics, collectibles, household utensils, appliances, home decoration and furnishings, pets, cars, hotels, transportation and travel, banking, insurance and financial services, points and rewards programs, and other goods and services that we believe may be relevant to you.
3. To give you notice
We give you notices in connection with a service when necessary (e.g., when we suspend a single service, change, or terminate the provision of a single service due to system maintenance).
If you do not wish to continue to receive messages from us, you may ask us to stop pushing, for example, to ask us to stop sending promotional text messages in accordance with the SMS unsubscribe guidelines, or to set up a mobile device to no longer receive messages from us; However, we do not apply the circumstances where we send messages in accordance with the provisions of the law or the service agreement of the individual service.
4. Help us design new services and improve our existing services;
5. Evaluate and improve the effect of advertising and other promotion activities;
6. Software certification or management software upgrades;
7. To involve you in surveys about our products and services;
8. Other Uses
You understand and agree that after collecting your personal information, we will de-identify or anonymize the data through technical means. The anonymized information will not be able to identify you, and in this case we may use the anonymized information for user database analysis or commercialize it without your consent.
Please note that if we want to use your personal information for other purposes not specified in this policy or collect additional personal information that is not mentioned, we will obtain your consent separately through page prompts, interactive processes, website announcements or by other means. Once you give us consent, such additional use will be deemed to be part of this Policy and such additional information will apply to this Policy.
Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.
This section entitled “Your Rights” applies to users that are located in a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.
The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina and Russia.
You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at [ chenyingwork716@gmail.com ] .
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at [chenyingwork716@gmail.com ] .
Correction
You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at [ chenyingwork716@gmail.com ].
Erasure
You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please contact us at [ chenyingwork716@gmail.com ].
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restrict automated decision-making and targeted push
You have the right to restrict automated decision-making and targeted push at any time, and we will provide you with options that are not specific to your personal characteristics.
For example, if we use your data and algorithms to push marketing information, commercial advertisements, etc. (hereinafter referred to as "targeted push"), we will clearly mark “targeted push” and provide you with the option to stop receiving it; When you choose to stop receiving targeted push messages, we will stop. If you do not want to receive commercial advertisements from us, you can cancel at any time by selecting [Settings - Privacy Management - Personalized Advertising], after which we will block personalized push content for you. However, you shall be aware that the push information you receive will no longer be accurate, and it will affect our ability to provide you with more optimized product experience.
You can constrain automated decision-making made by information systems at any time, and in some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legitimate interests, you have the right to ask us for an explanation and we will provide appropriate remedies.
To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at [ chenyingwork716@gmail.com ]. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., service statistics). You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions.
Complaints and Reports
We have set up a complaint channel, and you can feedback through the contact information listed in this policy. Your comments will be dealt timely.
Protection of personal information of deceased users
After the death of a user (natural person only), his/her close relatives may, for their own legitimate interests, exercise the right to access, copy, correct, delete, etc. personal information of the deceased user through the contact information published in this policy, unless otherwise arranged before the deceased user's death.
Please understand and confirm that in order to fully protect the personal information rights and interests of deceased users, the close relatives of deceased users who apply to exercise this right need to submit the identity documents, death certificate documents, and identity certificates of the deceased users in accordance with the procedures or customer service prompts specified by us
We may from time to time send you announcements when we consider it is necessary to do so (for example, when we temporarily suspend the Service’s access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
Response
For security purposes, you may be required to provide a written request or prove your identity by other methods. We may ask you to verify your identity before processing your request. We will respond you within 15 working days. If you are not satisfied with our response, you may also contact our customer service staff to make a complaint.
In principle, we will not charge you a fee for reasonable request, but for same or similar repetitive requests that exceed reasonable limits, we will charge you certain fee as appropriate. We may reject requests that are unreasonably repetitive, requiring excessive efforts (e.g., need to develop new systems or fundamentally change existing rules), posing a risk to the legitimate rights and interests of others, or impractical (e.g., involving information stored on backup tapes).
In the following cases, we may not respond to your request in accordance with laws and regulations:
1. Related to Personal Data Controllers' performance of obligations required by laws and regulations;
2. Related to national security or national defense security;
3. Related to public safety, public health, or major public interests;
4. Related to criminal investigation, prosecution, trial, etc.;
5. It is proved that you have subjective malice or abuse of rights;
6. For the purpose of safeguarding the major lawful rights and interests of other individuals, such as their life and property, and it is difficult to obtain the consent of the person;
7. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
8. Involving trade secrets.
We will try our best to take any appropriate technical measures to ensure that you can access, update and correct your registration information or other personal information provided when using our services. At the same time, we will require you to authenticate your identity to protect your account security.
Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy.
Marketing data about you that is collected or shared with third party ad partners (e.g., Facebook and Google) may also be stored and processed on our third party SDK’s (Appsflyer and AppLovin) servers in the United States. Customer support information may also be stored in our third party partner’s servers in the United States.
In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
· Regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
o detect, prevent or otherwise address security, fraud or technical issues; or
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission of your information which you do at your own risk.
Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
6. Services Provided by Third Parties
A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any new owner or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any new owner or other third party involved in such sale or transfer.
7. Children
7.1 By children, we mean users under the age of 13 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries, we have listed the relevant minimum age in the table below.
|
Country in which the user is located |
Minimum age of the user |
|
Algeria |
19 |
|
Argentina |
13 |
|
Australia |
18 |
|
Brazil |
18 |
|
Bangladesh |
18 |
|
Colombia |
18 |
|
Cambodia |
18 |
|
Canada |
13 |
|
Egypt |
18 |
|
European Economic Area/Switzerland |
16 |
|
Kingdom of Saudi Arabia |
15 |
|
Kuwait |
21 |
|
Mexico |
18 |
|
Morocco |
18 |
|
Myanmar |
18 |
|
New Zealand |
16 |
|
Nigeria |
13 |
|
Qatar |
18 |
|
Russia |
14 |
|
Serbia |
15 |
|
South Africa |
18 |
|
Sri Lanka |
18 |
|
Tunisia |
18 |
|
Turkey |
18 |
|
United Arab Emirates |
21 |
|
United Kingdom |
13 |
|
United States |
13 |
7.2 If you are children, you shall read this Agreement and use the Service under the supervision and guidance of a guardian, and we will collect your personal information from children only after obtaining your parental/guardian consent.
7.3 We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at [ chenyingwork716@gmail.com ] and we will delete such information.
7.3 If you are the parent or guardian of the user, you may contact us at chenyingwork716@gmail.com to provide us with your consent of dealing with your child’s personal Information.
7.4. Before we collect, use, transfer, or disclose children's personal information, we will notify the child's guardian in advance through the contact information of the guardian provided when the child's guardian registers an account for the child, and only after obtaining their consent will the child's information be collected, used, transferred, and disclosed.
7.5 The child's guardian may refuse us to collect, use, transfer and disclose the child's personal information in accordance with this Privacy Policy after receiving above notice, and we may not collect, use, transfer and disclose any of the child's information. However, If we are not authenticated (as well as withdrawal of consent) with child’s necessary personal information, the child may not be able to use some of our services or may be subject to restrictions in the process of using our services. If the child's personal information is necessary to operate our products, the child will not be able to use our products at all.
7.6 Our staff's access to children's personal information shall be subject to the approval of head in charge of children's personal information protection or his authorized management personnel, and the access shall be recorded, technical measures shall be taken to avoid illegally copy or download of children's personal information.
7.7 The parent or guardian of child may withdraw consent of collect, use, transfer and disclose their child's personal information by contacting us, and we will delete such information.
7.8 If we transfer children's personal information to a third party, we shall conduct a security assessment by ourselves or by entrusting a third-party agency.
7.9 If we stop operating products or services, we will immediately stop collecting children's personal information, delete the children's personal information we hold, and promptly notify the child's guardian of the suspension or termination of products and services.
8. Notification and Modification
In order to provider you with better service, we reserve the right to modify the terms of this Agreement as necessary, and such modifications will become part of the Privacy Policy. You may review the most recent version of these Terms and Conditions on the relevant Services page. If you do not accept the modified Agreement, you should stop using the Services provided by us. Otherwise if you continue to use the Software or Services provided by us after the terms of this Agreement have been changed, you will be deemed to have accepted the modified Agreement. Please check the Services page frequently to see if there are any updates or changes to the Privacy Policy.
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
We collect your personal information for the following purposes:
We disclose personal information to the following types of entities:
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.
Rights under the CCPA
If you are a California resident, you have the right to:
We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at [chenyingwork716@gmail.com ].
When you are located in the EEA, you will have following additional rights:
When you are located in the EEA, your personal data will be transferred to recipients in countries located outside the EEA, which do not provide a similar or adequate level of protection to that provided by countries in the EEA.
You hereby expressly consent to the transfer of your personal data to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.
You can use your accounts of the App to update and correct your personal data. You can also contact us and ask us to update or correct your data.
We do not knowingly collect personal data about children under the age of 13 (in EEA is under the age of 16). If a parent or guardian becomes aware that his or her child has provided us with data without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such data is deleted from our files.