XiaoTeng Folove APP PRIVACY NOTICE
Effective May 25, 2020
At XiaoTeng Inc. we know privacy and security is important to you.
The
privacy of your personal data is also important to us. We will provide
you with an experience on our app that is safe and secure.
This
Privacy Notice describes our privacy and data practices on the FoLove
mobile phone application (the “App”), and is meant to help you
understand what information we collect, why we collect it, and how you
can update, manage, export, and delete your information.
1.This App is for People Over the Age of 18
YOU
MUST BE AT LEAST 18 YEARS OF AGE TO USE THIS APP. We do not knowingly
collect personal data from persons under 18. Accordingly, all users will
be required to acknowledge in the App that they are 18 or older prior
to initial use. Additionally, if we learn we have collected or received
personal data from a person under 18, we will delete that information.
If you believe we might have any information from or about a person
under 18, please contact us (For more information about us, please see
Section 14).
2.This Privacy Notice DOES NOT Apply to the Following Information
This
Privacy Notice does not apply to information that we collect offline or
on any other of our apps or websites, including websites you may access
through the App.
Our websites, our other apps and third parties
may have different privacy policies, which we encourage you to read
before providing information on or through them. Please read this
Privacy Notice carefully to understand our policies and practices
regarding your information and how we will treat it. If you do not agree
with our policies and practices, do not download, register with or use
the App.
3.All Folove Devices Can be Used without this App
After
downloading the App, you have the option of using the App to control a Folove device locally, through Bluetooth, or via the internet. We do not
ask you to provide your name, address or other personally identifying
information as part of the App installation process or otherwise.
However, to use the App to connect remotely to a Folove device via the
internet, you must create an anonymous account (by providing a nick
name).
4.Who We are and What We Need
Our
Privacy Notice governs the use and storage of your personal data which
relates to a living individual who can be identified from that data.
“Personal data” means any information relating to an identified or
identifiable natural person; an identifiable natural person is one who
can be identified, directly or indirectly, in particular by reference to
an identifier such as a name, an identification number, location data,
an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity
of that natural person. Identification can be by the information alone
or in conjunction with any other information in our possession or likely
to come into such possession. We will collect your personal data either
directly from you when you provide them to us or automatically when you
use the App. Our processing of personal data of individuals in the
European Union is governed by the General Data Protection Regulation
2016/679 (the “GDPR”).
We, XiaoTeng Inc. are a controller of the
personal data you (data subject) provide us. This means we decide how
your personal data is processed and for what purposes. We collect the
following types of personal data from you:
An anonymous id
Remote chatting content, including Text, Pictures and Audio.
Device information, device identifier, device type.
When using “XiaoTeng”, you will need the following permissions,
Location
permission, Starting from Android 6.0 and later, Bluetooth require you
must turn on the location permission. so when you use the “Folove”
application to request a device connection, we will ask you to give us
the Android application location permission. These location permissions
are used only for Bluetooth connection and we do not collect your
personal location information.
Network permissions, Network
permission is used save your anonymous ID, avatar, device information,
synchronize your chat content, etc.
Recording permissions, for your voice while chatting.
SD card permissions, used to access your SD card when you set your avatar.
Vibration permission, used to provide vibration alerts when you receive a message.
Camera permission, used to access the camera when you set the avatar.
Purpose and Legal Basis for Processing Your Personal Data
We
comply with our obligations under GDPR by keeping personal data up to
date; by storing and destroying it securely; by not collecting or
retaining excessive amounts of data; by protecting personal data from
loss, misuse, unauthorized access and disclosure and by ensuring that
appropriate technical measures are in place to protect personal data.
5.We need your personal data for the following purposes:
To provide and improve our services;
To provide the necessary functionalities for the app.
The
first time you launch the App, we will require you to provide a nick
name, which will be stored on our servers, and we will provide you with a
unique anonymous identifier at the same time. The App will use this
anonymous identifier to create connections with your chatting partners
when you use the App’s remote chatting feature, enable your chatting
partner to identify you, and share control of your Folo products with
your chatting partner.
We provide remote chatting service in the
App. Your chatting records will be encrypted in the communication
process and stored on the server for three days. To the extent you share
any personal data in using the remote chatting feature (including any
sensitive personal data), they will be collected and stored as part of
your chatting records. We store your chatting records for three days for
the purpose of the communication process. We may also process your
personal data for:
6.compliance with a legal obligation to which we are subject;
protecting your vital interests or that of another natural person;
the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
the
purpose of the legitimate interests pursued by us or by a third party,
except where such interests are overridden by the interests or
fundamental rights and freedoms of you which require protection of
personal data.
If we collect any special category personal data
(i.e., sensitive personal data about an individual that reveals his or
her racial or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership, genetic data or biometric
data for the purpose of uniquely identifying such individual, data
concerning health or his or her sex life or sexual orientation), we will
explain to you the relevant purposes and processing conditions and seek
your explicit consent prior to processing your such personal data. We
currently do not collect any special category personal data from you
unless you choose to share any such data when using the App’s remote
chatting function.
If you request that we stop processing some or
all of your personal data or if you withdraw your explicit consent for
our use or disclosure of your personal data for purposes set out in this
privacy notice, we may not be able to provide you all of the services
and customer support offered to our users and authorized under this
privacy notice.
Upon your request, we will close your account and
remove your personal data from view as soon as reasonably possible,
based on your account activity and in accordance with applicable
national laws.
7.Where We Do with It
Your
personal data will be processed in our office. Hosting and storage of
your data takes place at the facilities of Alibaba Cloud, which is
located in shanghai..
Safeguarding and Retention of Personal Data
We
have implemented administrative, technical and physical measures
designed to safeguard your personal data in our custody and control
against theft, loss and unauthorized access, use, modification and
disclosure.
We restrict access to personal data on a need-to-know
basis to employees and authorized third party service providers who
require access to fulfill their job requirements.
We keep your
personal data for no longer than reasonably necessary in order to
provide personalized experience toyou In the case of any personal data
you share when using the App’s remote chatting feature, such data will
be collected as part of your chatting records and stored for only three
days.
After the relevant retention period, your personal data
will be irreversibly destroyed. Any personal data held by us for
marketing and service update notifications will be kept by us until such
time that you notify us that you no longer wish to receive this
information.
8.Sharing Your Personal Data
Your
personal data will be strictly confidential. We will only share your
data with third parties outside of us after you grant explicitly
consent.
We may disclose your non-personal information to other
members of the Folove corporate family or to third parties. This
disclosure will improve the user experience of our products and build
some statistic data.
Non-personal Identified Information We Collected
All Other User Data will be Stored Locally
All
data other than the personal data referred to in Sections 4 and 5 above
will be stored on your phone locally. These data are required for the
App’s functionalities; for example, we will record the connection time
of device and show the history chart for you. We will not collect such
data unless you choose to share such data when using the remote chatting
feature of the App, in which case any shared data will be collected as
part of your chatting records. The locally stored data may be removed by
deleting the App and the related local data from your phone.
9.We Collect Anonymous App Analytical Data
We
use third party service providers to collect certain analytical
information to help us improve our products and the quality of the App.
These third parties have stated to us that they will collect such data
in an aggregate, anonymous form that does not personally identify any
individual user. Such anonymous analytical data include the App features
used and time spent on the App. As part of our commitment to privacy,
we will add an option to enable users to turn on/off the anonymous
collection in the recent release.
10.What are Your Rights
Unless there is an exception under the GDPR, you have the following rights with respect to your personal data:
to request a copy of your personal data that we hold about you;
to request that we correct any personal data if it is found to be inaccurate or out of date;
to request your personal data be erased where it is no longer necessary for we to retain such data;
to withdraw your consent to the processing at any time in case where consent is relied upon as the condition for processing;
to
request that we provide you with your personal data and where possible,
to transmit such data directly to another data controller (where
applicable), in cases where we process your data by automated means and
the processing is either (a) based on consent or (b) necessary for the
performance of a contract with you;
where there is a dispute in
relation to the accuracy or processing of your personal data, to request
a restriction is placed on further processing;
to object to the
processing of personal data (where applicable), in case where processing
is based on legitimate interests (or the performance of a task in the
public interest/exercise of official authority), and in case where the
personal data are processed for direct marketing, scientific/historical
research and statistics purposes;
to lodge a complaint with the relevant supervising authority.
Transfer of Your Personal Data Abroad
Your
personal data will be transferred to mainland China where we are
situated. Such transfer of your personal data will be protected by our
undertaking made in accordance with the Standard Contractual Clauses
adopted by the European Commission as appropriate safeguards.
11.Further Processing
If
we wish to use your personal data for a new purpose not covered by this
Privacy Notice, we will provide you with a new notice explaining this
new use prior to commencing the processing and setting out the relevant
purposes and processing conditions. Where and whenever necessary, we
will seek your prior consent to the new processing.
12.Changes to the Privacy Notice
We
may update this Privacy Notice to reflect changes to our privacy and
data practices. We encourage you to periodically review this notice. We
may notify you the changes to this Privacy Notice by email (if possible)
or by posting a notice at
http://support.doiting.com/index/getOneArticle?id=124
13.Contact Details
In
the event that you wish to complain about how we have handled your
personal data, please contact us at [email protected] or in writing atRoom
1025, sangtai building, Shenzhen University Town Pioneer Park, Lishan
Road, Nanshan District, Shenzhen. We will look into your complaint and
work with you to resolve the matter.
XiaoTeng Inc.