Updated Date: June 5, 2020
Effective Date: June 5, 2020
Introduction
PAPILLON strictly complies with laws and regulations and follows the following privacy protection principles to provide you with safer and more reliable services:
1. Safety and Reliability:
We make every effort to prevent the leakage, damage, and loss of your information through reasonable and effective information security technology and management processes.
2. Choice:
We provide you with convenient information management options so that you can make appropriate choices and manage your personal information.
3. Communication Secrecy Protection:
We strictly adhere to laws and regulations to protect your communication secrecy and provide you with secure communication services.
4. Reasonable and Necessary:
To provide better services to you and other users, we only collect necessary information.
5. Clarity and Transparency:
We strive to use clear and simple language to introduce our privacy policy to you so that you can clearly understand how we process your information.
6. Integrating Privacy Protection into Product Design:
We incorporate the concept of privacy protection into various aspects of product or service development, combining legal, product, design, and other factors.
This "Privacy Policy" mainly explains to you: What information we collect, the purposes of collecting information, and your rights.
We hope you carefully read the "Privacy Policy" (hereinafter referred to as "this policy") to understand in detail how we collect and use information so that you can better understand our services and make appropriate choices. We also protect the collected information, as detailed in the "PAPILLON Privacy Protection Guidelines."
If you use PAPILLON services, it means that you agree to the contents stated in this policy. Unless otherwise specified, the terms used in this policy have the same meaning as those in the "PAPILLON License and Service Agreement." If you have any questions, please contact us.
Information We Collect
In accordance with the principles of legality, legitimacy, and necessity, we only collect information necessary to implement product features.
Information you voluntarily provide when using our services
· Information you fill out when registering an account
For example, the nickname and phone number you fill out when registering an account.
· Information you upload when using the service
For example, avatars and shared photos you upload while using the service.
· Information you submit when contacting our customer service or participating in our activities
For example, surveys you fill out during online activities may contain your name, phone number, home address, and other information.
Some of our services may require you to provide specific personal sensitive information to achieve specific functions. If you choose not to provide such information, you may not be able to use specific functions of the service, but it will not affect your use of other functions of the service. If you voluntarily provide your personal sensitive information, it means that you agree to our processing of your personal sensitive information for the purposes and methods stated in this policy.
Information we obtain when you use the service
· Log Information
When you use our service, we may automatically collect relevant information and store it as service log information.
1) Device Information
For example, device model, operating system version, unique device identifier, OAID, battery, signal strength, and other information.
2) Software Information
For example, software version number, browser type. To ensure the safety of the operating environment or provide necessary services, we collect information about the mobile apps and other software you use.
3) IP Address
4) Service Log Information
For example, information you search for and view while using our service, service failure information, referral URLs, and other information.
5) Communication Log Information
For example, the accounts you have communicated with, communication time, and duration while using our service.
· Location Information
When you use location-related services, we may record your device's location information to provide you with relevant services. When using the service, we may obtain your geographical location information through methods such as IP address, GPS, WLAN (such as Wi-Fi), or base stations;
The information you or other users provide during the use of the service may contain your geographical location information, such as the region information included in your account information or geographic tags in photos shared by you or others.
· Sound Information
When you use voice chat services, we will request your recording permission to provide you with related services. When using the service, we will upload your voice input content to assist you in completing voice chat services. If you do not agree to authorize, it will affect the use of this function.
· Other Relevant Information
To help you better use our products or services, we may collect relevant information, such as friend lists, group lists, and voiceprint feature value information. To ensure that you can contact people you know when using our service, if you choose to enable the contact import function, we may encrypt the names and phone numbers of your contacts and only collect encrypted information.
Information shared by other users may contain your information
For example, photos or videos shared by other users may contain your information.
Information obtained from third-party partners
We may obtain information generated or shared by you when using third-party partner services. For example, when you use your account to log in to a third-party partner service, we will obtain the name and login time of your login to the third-party partner service for your authorization management. Please carefully read the user agreement or privacy policy of third-party partner services.
How We Use the Collected Information
We strictly comply with legal regulations and agreements with users to use the collected information for the following purposes. If we use your information beyond the following purposes, we will explain it to you again and obtain your consent.
Provide services to you
Product development and service optimization
For example, when our system malfunctions, we will record and analyze the information generated during system malfunctions to optimize our services.
Security protection
For example, we use your information for identity verification, security prevention, anti-fraud monitoring, archive backup, and customer security services.
Software Management
For example, software authentication and software updates.
Invite you to participate in surveys related to our services
In order to provide you with a better experience, improve our services, or for other purposes with your consent, within the scope of relevant laws and regulations, we may use the information collected through certain services for other services. For example, we may use the information you provide when using a certain service for user research analysis and statistical services in another service.
To ensure the security of the service and help us better understand the operation of our application, we may record relevant information, such as the frequency of your use of the application, fault information, overall usage, performance data, and the source of the application. We will not combine the information stored in the analytics software with your personal identity information provided in the application.
How We Use Cookies and Related Technologies
We or our third-party partners may collect your information by placing secure cookies and related technologies for the purpose of providing you with a better user experience and services. We strictly require third-party partners to comply with the relevant provisions of this policy.
You can also manage cookies through browser settings. However, please note that if you disable cookies, you may not be able to enjoy the best service experience, and some services may not function properly. If you want to learn more about the security of cookies, you can refer to the "Cookie Policy Explanation."
Information You Share
You can share your relevant information with friends, family, and other users through our services.
Please note that this may include sensitive information such as personal identity information and personal property information. Please carefully consider disclosing your relevant personal sensitive information.
You can control the scope of information sharing through the privacy settings in our service and delete information you have publicly shared through the settings or guidance provided by us. However, please be aware that this information may still be independently stored by other users or unrelated third parties beyond our control.
How to Manage Your Information
During your use of our services, you can access, modify, and delete the registration information and other personal information you provide, and contact us according to the notification instructions. The scope and methods of accessing, modifying, and deleting personal information will depend on the specific service you use.
For example, if you want to stop sharing your location information when using location-related services, you can stop sharing by turning off location functions on your mobile device, software and hardware service providers, and communication service providers. We recommend carefully reading the relevant instructions.
We will only collect and use your information for the purpose of realizing the functions of our products or services, as stated in this policy.
If you find that we have collected and used your personal information in violation of laws, regulations, or agreements, you can request us to delete it.
If you find that there are errors in the personal information we have collected and stored, you can request us to correct it.
Please contact us through the contact information listed in this policy.
When you access, modify, and delete related information, we may request you to verify your identity to ensure the security of your account.
Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your requests, and we will respond to your requests within a reasonable period.
Information We Share
We strictly limit the sharing of information in accordance with the requirements of laws and regulations, such as:
With your prior consent, we may share your personal information with third parties.
For the purpose of external processing only, we may cooperate with third-party partners (third-party service providers, contractors, agents, advertising partners, application developers, etc., such as communication service providers that send emails or push notifications on our behalf, map service providers that provide location services for us) (they may not be located in your jurisdiction) to share your personal information with them for processing in accordance with our instructions, privacy policy, and other relevant confidentiality and security measures for the following purposes:
· Provide our services to you;
· Achieve the purposes described in the "How We Use Collected Information" section;
· Fulfill our obligations in the "PAPILLON License and Service Agreement" or this policy and exercise our rights;
· Understand, maintain, and improve our services.
If we share your information with the third parties mentioned above, we will use encryption and anonymization methods to ensure the security of your information.
As our business continues to grow, when mergers, acquisitions, asset transfers, and other transactions result in the sharing of your personal information with third parties, we will inform you of the relevant circumstances through push notifications, announcements, and other forms, and continue to protect your personal information in accordance with legal requirements and standards no lower than those required in this policy by law.
We will use the information collected for big data analysis.
For example, we will use the collected information to analyze and generate city heat maps or industry insight reports that do not contain any personal information.
We may disclose your personal information for the following purposes:
· Comply with applicable laws and regulations and other relevant requirements;
· Comply with the provisions of court judgments, rulings, or other legal procedures;
· Comply with the requirements of relevant government agencies or other legally authorized organizations;
· We have reason to believe that it is necessary to comply with applicable laws and regulations and other relevant requirements;
· For the purposes of executing relevant service agreements or this policy, maintaining the public interest, and protecting the personal and property safety or other legitimate rights and interests of our customers, us or our affiliated companies, other users, or employees, for reasonable and necessary purposes.
Information We May Send to You
Information Push
When you use our services, we may send you emails, SMS messages, information, or push notifications.
You can follow our prompts to unsubscribe on your device.
Service-Related Notices
We may send you service-related notices when necessary (for example, when a certain service is temporarily suspended for system maintenance). You may not be able to unsubscribe from these service-related notices, which are not considered advertisements.
Location and Retention of Information
Location of Information Storage
We comply with the requirements of laws and regulations and store personal information collected within the territory.
Information Storage Period
In general, we only retain your personal information for the shortest time necessary to achieve the purpose. However, in the following situations, we may change the storage time of personal information to comply with legal requirements:
· To comply with applicable laws and regulations and other relevant requirements;
· To comply with the provisions of court judgments, rulings, or other legal procedures;
· To comply with the requirements of relevant government agencies or legally authorized organizations;
· We have reason to believe that it is necessary to comply with applicable laws and regulations and other relevant requirements;
· For the purposes of executing relevant service agreements or this policy, maintaining the public interest, and protecting the personal and property safety of our customers, us, our affiliated companies, other users, or employees, or other legitimate rights and interests, for reasonable and necessary purposes.
When our products or services cease operation, we will notify you of such circumstances through push notifications, announcements, and other forms and delete or anonymize your personal information within a reasonable period after verifying your user identity.
Information Security
We provide appropriate security measures for your information to prevent data loss, unauthorized access, or disclosure.
We strictly comply with laws and regulations to protect the confidentiality of user communications.
We use various security protection measures within a reasonable security level to safeguard information.
For example, we use encryption technology (such as TLS, SSL), anonymization, and other means to protect your personal information.
We establish dedicated management systems, processes, and organizations to ensure information security.
For example, we strictly limit the scope of personnel who can access information, require them to observe confidentiality obligations, and conduct reviews.
In case of security incidents, such as personal information leaks, we will initiate an emergency response plan, prevent the expansion of security incidents, and notify you through push notifications, announcements, and other forms.
Protection of Minors
We attach great importance to the protection of personal information of minors.
According to the relevant laws and regulations, if you are under 18 years of age, you should obtain the consent of your parents or legal guardians before using PAPILLON's services.
We have products or services specifically designed for children under 14 years of age, products or services that include features specifically designed for children, or products or services that require users to enter their date of birth, age, and other information that can identify their age.
If you register or use such products or services and you are a child under 14 years of age, according to the relevant laws and regulations, you should obtain the prior consent of your parents or legal guardians and have them assist you in completing the product or service registration process so that you can use the products or services we provide.
If you are a guardian of a child, before helping a child complete the product or service registration and usage, you should carefully read this policy, the specific privacy protection guidelines for the product (if any), and the "PAPILLON Children's Privacy Protection Guidelines", decide whether to agree to this policy, the specific privacy protection guidelines for the product (if any), and the "PAPILLON Children's Privacy Protection Guidelines", and help the child complete the registration and usage of the product or service so that the child can use the products or services we provide.
If you have any questions or requests related to the protection of personal information of the children you care for, please contact us through the contact information disclosed in the eleventh part of the "PAPILLON Children's Privacy Protection Guidelines". We will process and respond to your request within a reasonable time.
Scope of Application
This policy applies to all of our services.
Some services have specific privacy guidelines/declarations that specifically describe how we handle your information in those services.
In the event of any inconsistency between this policy and the specific service's privacy guidelines/declarations, the specific service's privacy guidelines/declarations shall prevail.
Please note that this policy does not apply to services provided by other companies or individuals.
When you use such third-party services, you are bound by their privacy policies (rather than this policy), and you need to carefully read their policy content.
Contact Us
If you have any questions about this policy or other related matters, please send your questions to outlook@papillonx.com.
We will review the issues as soon as possible and respond within fifteen days after verifying your user identity.
Changes
We may revise the content of this policy from time to time.
If such changes result in a substantial reduction in your rights under this policy, we will notify you before the changes take effect through prominent notices on the page, emails to you, and other means.
In this case, if you continue to use our services, it means that you agree to be bound by the revised policy.
Other
TrueDepth will not record FaceID and other information without consent.
When using video shooting features in daily photo editing and applying AR face effects, we use TrueDepth APIs for better visual effects.
During this process, only TrueDepth APIs are used for scene rendering.
The use of TrueDepth APIs will not collect user Face information.
The use of TrueDepth APIs will not perform any operations that cache files or upload to the cloud or any other operations that record user Face information.
During this process, there will be no operations that cache files or upload to the cloud or any other operations that record user Face information.
How to Manage Cookies
Most browsers provide users with the ability to manage cookies.
When users configure their browser's cookie settings, they can allow trusted websites to enable cookie functionality while blocking other websites from using cookie functionality.
For example, you can manage cookies in your browser settings.
At the same time, you can enable "Do Not Track (DNT)" functionality.
However, please note that if you disable cookies, you may not be able to enjoy the best service experience, and some services may not function properly.
Personal Information
Personal information refers to various pieces of information recorded electronically or in other ways that can be used to identify the personal identity of a natural person individually or in combination with other information, including but not limited to a person's name, date of birth, identity card number, personal biometric information, address, telephone number, etc.
Personal Sensitive Information
Personal sensitive information refers to personal information that, once disclosed, provided unlawfully, or misused, may harm personal and property security, cause damage to personal reputation, physical and mental health, or discriminatory treatment, etc. For example, personal sensitive information includes identity card numbers, personal biometric information, bank account numbers, communication content, health and physiological information, etc.
Device
A device refers to a device that can be used to access PAPILLON services, such as desktop computers, laptops, tablets, or smartphones.
Unique Device Identifier
A unique device identifier (Exclusive ID or UUID) refers to a string of characters incorporated into a device by the device manufacturer, which can be used to uniquely identify the corresponding device (e.g., device MAC address/IMEI/MEID/Android ID/IDFA/OPENUDID/SIM card IMSI information, etc.).
IP Address
Every device connected to the internet is assigned a number, known as an Internet Protocol (IP) address. These numbers are usually assigned based on geographical regions. IP addresses are often used to identify the location where a device connects to the internet.
GPS
Global Positioning System (GPS). The GPS signal receiver on your device can receive signals from GPS satellites and use the information received to calculate your location.
Wi-Fi
Wi-Fi is a technology that allows electronic devices to connect to a wireless local area network (WLAN), typically referred to as a wireless network.
Base Station
A base station, also known as a public mobile communication base station, is a form of radio station that communicates information between mobile phone terminals within a certain radio coverage area and the mobile communication exchange center.
SSL
SSL (Secure Socket Layer), also known as Secure Socket Layer, is a security protocol implemented on the transport communication protocol (TCP/IP). SSL supports various types of networks and provides three basic security services that use public and symmetric key technology to achieve data confidentiality.
Children
Children refer to minors under 14 years of age.
Information Collection Technology
The "automatic collection" described in our "Privacy Policy" includes the following methods:
1. Cookie (Cookie File)
A Cookie is a small text file placed by a website server on the client-side (your computer, mobile phone, or other smart devices) when you browse web pages. It is used to enhance your user experience. For more details, please refer to the "Cookie Policy Explanation."
2. Web beacon (Web Beacon)
A Web beacon is an electronic image file or other technology embedded in a website or email. It is used to count visitors, record whether and when you read emails or visit websites, or to facilitate the use of certain Cookies.
3. Log files (Log Files)
Log files store automatically collected data, including Internet Protocol (IP) addresses, browser types, Internet Service Providers (ISPs), referral/exit pages, operating systems, date/time stamps, and clickstream data, among others.
4. ET Tag (Entity Tag)
An ET Tag is an HTTP protocol header transmitted between internet browsers and servers. It can replace Cookies and is used to track individual users, allowing us to gain deeper insights and improve our services.
5. JavaScript
JavaScript is a programming language used to create more interactive and dynamic web pages. JavaScript can set, read, and delete Cookies.
PAPILLON ENTERTAINMENT LIMITED