Privacy Policy

Updated on October 18, 2022

Chengdu Tommi Technology Co., Ltd. (hereinafter referred to as "us") is fully aware of the importance of personal information to you, and will do its utmost to protect the security and reliability of your personal information. We are committed to maintaining your trust in us and strictly abide by the following principles to protect your personal information: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of consent by choice, the principle of minimum sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will take appropriate security measures to protect your personal information according to the mature security standards in the industry. Please carefully read and understand this Privacy Policy before using our products (or services).

1.Definition

PickFun platform services: PickFun provides various services to you based on the Internet in various forms including PickFun platform websites, clients, etc. (including new service forms emerging from future technology development).

Users: hereinafter referred to as "you" or "users" refer to individuals or organizations that register, log in, use, browse, and obtain services under this policy.

Personal information: refers to all kinds of information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

Sensitive information: refers to personal information such as ID card number, personal biometric information, bank account number, property information, whereabouts, transaction information, minors' information, etc.

2.How Do We Collect and Use Your Personal Information

Personal information refers to various information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

We will only collect and use your personal information for the following purposes described in this policy:

2.1. Provide online services for you

2.1.1. Account Registration

To complete the account creation, you need to provide the following information: your name, email address, user name and password created. During the registration process, if you provide the following additional information, it will help us to provide you with better service and experience: mobile number, job title, company, education background. However, if you do not provide such information, the basic functions of using the service will not be affected. The above information provided by you will continue to authorize us to use during your use of this service. If you no longer use PickFun's services, we also provide the cancellation of your registered account if you meet the conditions agreed in the service agreement and relevant national laws and regulations. You can enter the app personal center, click "Settings", click "Account Cancellation", and complete the account cancellation according to the instructions. When your account is cancelled or deleted, All service information and data under PickFun's services related to the account will be deleted or anonymized, unless otherwise specified by laws and regulations. When you cancel your account, we will stop using and delete the above information. The above information will be stored in the People's Republic of China. If cross-border transmission is required, we will obtain your authorization and consent separately.

2.1.2. Video Play and browse

a. In order to ensure the quality of video content and achieve the goal of displaying interesting videos and relevant information, we may collect relevant necessary log information.

b. The above log information includes:

Behavior information you operate and use: click, follow, collect, search, browse, share

Information you actively provide: feedback, publishing, like (like), comments

Geographic location information: including accurate geographic location information obtained through GPS information, WLAN access point, Bluetooth, base station and other sensor information, and approximate geographic location information obtained through network location information (such as base station, IP and WLAN)

c. Precise geographic location information is personal sensitive information. If you refuse to provide it, we will not recommend information to you based on the precise geographic location information, and will not affect the normal use of other functions.

d. We will show and recommend the local relevant information of your region (city, district, county, etc.) based on the city and/or district/county corresponding to the approximate geographic location information.

2.1.3. Content Publishing and Interaction

a. When you publish audio, video, pictures and other content or make comments, we will collect your published information and display your nickname, avatar, published content and information.

b. When you use the function of publishing pictures, audio and video, we will ask you to authorize camera, photo and microphone permissions. When using the download video function, you will be asked to authorize the mobile phone storage permission; If you refuse to provide authorization, you will not be able to use this function, but it will not affect your normal use of other functions.

c. Information collected by us due to users' use of our products or services, for example, information published by other users may contain some of your information (for example, information related to you is involved in comments, messages, pictures and texts, audio and video).

d. We attach great importance to the user experience. In order to improve the upload speed of audio and video, enrich publishing functions and optimize the experience, when you publish audio and video, we will temporarily load the audio and video to the server before clicking "Publish" to confirm the upload. If you cancel or fail to upload for other reasons, we will delete the relevant audio and video immediately. We respect your choice. If you want to turn off the preload function, you can turn it off in [I] - [Settings] - [General Settings] - [Upload works in advance to reduce the waiting time].

2.2. Data Analysis and Research

Third party SDK statistical services to improve our products or services. We collect data based on your interaction with us and your choices, including your privacy settings and the products and functions you use. During your use of our services, in order to identify the abnormal status of your account, understand the product adaptability, provide you with basic services such as browsing and searching, and maintain the normal operation of basic functions, we may automatically collect, store and correlate information about the services you use and how you use them, including:

(1) Log information: When you use our service, we may automatically collect your detailed use of our service and save it as a relevant network log. The log information includes your login account, search query content, IP address, browser type, telecom operator, network environment, language used, access date and time, and web browsing records you visited, push open records, crash records, stay time, refresh records, publishing records, attention, subscription, collection and sharing.

(2) Device information: We may receive and record the information about the device you use (including device identifier (IMEI/MAC/OPEN UDID), serial, SIM card IMSI ID, device model, operating system and version, client version, device resolution, package name, device settings, process and software list, Android ID, IDFA, UUID Software and hardware feature information), information about the location of the device (including IP address, GPS location and WLAN access point, Bluetooth and base station sensor information that can provide relevant personal information).

(3) YouMeng (https://www.umeng.com/) SDK: Our product integrates YouMeng+ SDK. Youmeng+ SDK needs to collect your device Mac address, obtain the device serial number (IMEI/android ID/IDFA/OPENUID/GUID, SIM card IMSI information), obtain the information of the pasteboard to provide statistical analysis services, and calibrate the accuracy of the report data through geographical location to provide basic anti cheating capabilities.

At the same time, our product integrates Youmeng+ SDK. Youmeng+ SDK needs to collect your device Mac address, obtain the device serial number (IMEI/android ID/IDFA/OPENUID/GUID, SIM card IMSI information) to provide statistical analysis services, and calibrate the accuracy of report data through geographical location to provide basic anti cheating capabilities.

At the same time, in order to collect the above basic personal device information, we will apply for permission to access your device information. We collect this information to provide you with our basic services and basic functions. If you refuse to provide the above permission, you may not be able to use our products and services.

Please note that separate equipment information and log information are information that cannot identify a specific natural person. If we combine this kind of non personal information with other information to identify the identity of a specific natural person, or use it with personal information, during the combined use, this kind of non personal information will be considered as personal information, and unless we obtain your authorization or otherwise specified by laws and regulations, we will anonymize and de identify this kind of personal information. During the combined use, these information will be treated and protected as your personal information in accordance with this privacy policy.

When we want to use the information for other purposes not specified in this policy, we will ask for your consent in advance. When we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance.

3.How Do We Use Cookies and Similar Technologies

3.1.Cookie

To ensure the normal operation of the website, we will store a small data file named Cookie on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store data such as your preferences or products in shopping baskets. We will not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. You can clear all Cookie saved on your computer. Most web browsers have the ability to block Cookie. But if you do, you need to change the user settings personally every time you visit our website.

3.2. Website Beacon and Pixel Tags

In addition to cookies, we will also use website beacons, pixel tags and other similar technologies on the website. For example, the email we send you may contain a click URL that links to our website content. If you click this link, we will follow this click to help us understand your product or service preferences and improve customer service. A website beacon is usually a transparent image embedded in a website or email. With the help of the pixel tag in the email, we can know whether the email is opened or not. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

3.3. Do Not Track

Many web browsers have the Do Not Track function, which can publish Do Not Track requests to websites. At present, major Internet standards organizations have not set up relevant policies to specify how websites should respond to such requests. But if your browser has enabled Do Not Track, all our websites will respect your choice.

4.How Do We Share, Transfer and Publicly Disclose Your Personal Information

4.1. Sharing

We will not share your personal information with any other company, organization or individual, except for the following circumstances:

1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

2. We may share your personal information according to laws and regulations or mandatory requirements of competent government departments.

3. Share with our affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information and are bound by the purposes stated in this privacy policy. If an associated company wants to change the purpose of processing personal information, it will ask for your authorization again.

4. Share with authorized partners: Some of our services will be provided by authorized partners only for the purpose stated in this privacy policy. We may share some of your personal information with partners to provide better customer service and user experience. Companies engaged by us to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In this case, these companies must comply with our data privacy and security requirements. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and only share the personal information necessary for providing services. For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our instructions, this privacy policy and any other relevant confidentiality and security measures.

4.2. Transfer

We will not transfer your personal information to any company, organization or individual, except for the following circumstances:

1. Transfer with explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;

2. In case of merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to ask for your authorization consent again.

4.3. Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

1. With your explicit consent;

2. Law based disclosure: We may publicly disclose your personal information under the mandatory requirements of laws, legal procedures, lawsuits or government authorities.

5.How Do We Protect Your Personal Information

(1) We have used security measures that comply with industry standards to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information. For example, when exchanging data (such as credit card information) between your browser and the Service, it is protected by SSL encryption; At the same time, we provide https safe browsing mode for our website; We will use encryption technology to ensure the confidentiality of data; We will use a trusted protection mechanism to prevent data from being attacked maliciously; We will deploy an access control mechanism to ensure that only authorized personnel can access personal information; And we will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

(2) We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period required to achieve the purposes described in this policy, unless the retention period needs to be extended or permitted by law.

(3) The Internet is not an absolutely secure environment, and email, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us ensure the security of your account.

(4) The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.

(5) In the event of an unfortunate personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions that you can independently prevent and reduce risks, and remedial measures for you. We will inform you of the event in a timely manner by mail, letter, telephone, push notification, etc. If it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will actively report the disposition of personal information security incidents according to the requirements of the regulatory authorities.

6.Your Rights

In accordance with the relevant laws, regulations and standards of China, as well as the prevailing practices of other countries and regions, we guarantee that you exercise the following rights on your personal information:

6.1. Access your personal information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you want to exercise the data access right, you can access it by yourself through the following ways: account information - if you want to access or edit the personal information and payment information in your account, change your password, add security information or close your account, etc.

6.2. Correct your personal information

When you find that our personal information about you is incorrect, you have the right to ask us to make corrections. You can apply for correction in the way listed in "(I) Access to your personal information".

6.3. Delete your personal information

·In the following cases, you can request us to delete your personal information:

1. If we handle personal information in violation of laws and regulations;

2. If we collect and use your personal information without your consent;

3. If our handling of personal information violates the agreement with you;

4. If you no longer use our products or services, or you cancel your account;

5. If we no longer provide you with products or services. If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise stipulated by laws and regulations, or these entities have obtained your independent authorization. When you delete information from our service, we may not delete the corresponding information in the backup system immediately, but we will delete the information in the backup update.

6.4. Change the scope of your authorization and consent

Each business function requires some basic personal information to complete (see "Part I" of this strategy). For the collection and use of additional collected personal information, you can give or withdraw your authorization consent at any time. You can operate by yourself in the following ways:...... After you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous personal information processing based on your authorization. If you do not want to accept the commercial advertisement sent to you by us, you can cancel it at any time by contacting customer service.

6.5. Account cancellation of personal information subject

You can cancel your previously registered account at any time. After you cancel your account, we will stop providing you with products or services, and delete your personal information according to your requirements, unless otherwise specified by laws and regulations.

6.6. Personal information subject obtains copy of personal information

You have the right to obtain the copy of your personal information. On the premise of technical feasibility, such as data interface matching, we can also directly transfer the copy of your personal information to the third party designated by you according to your requirements.

6.7. Automatic decision of constraint information system

In some business functions, we may only make decisions based on non manual and automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appropriate remedies.

6.8. Respond to your above request

To ensure security, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will reply within thirty days.

In principle, we do not charge for your reasonable request, but we will charge a certain amount of cost for repeated requests that exceed the reasonable limit as appropriate.

We may reject requests that are gratuitously repeated, require too many technical means (for example, need to develop new systems or fundamentally change existing practices), bring risks to the legitimate rights and interests of others, or are very unrealistic (for example, involving information stored on backup tapes).

In the following cases, we will not be able to respond to your request according to the requirements of laws and regulations:

1. Related to national security and national defense security;

2. Related to public safety, public health and major public interests;

3. Related to criminal investigation, prosecution and trial;

4. There is sufficient evidence to show that you have subjective malice or abuse of rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.

7.Third-party Services

We may access or link to social media or other services (including websites or other service forms) provided by third parties. include:

(1) You can use the "Share" button to share some content to a third-party platform, or you can use third-party services to log in to PickFun's services. These functions may collect your personal information (including your log information), and may install COOKIES in your equipment, so as to operate the above functions normally;

(2) We provide you with links through advertising or other ways of our services, so that you can link to third-party services or websites;

(3) Other access to third-party services. For example, in order to achieve the purpose stated in this policy, we may access SDK or other similar applications (such as embedded code, plug-ins, etc.) provided by third-party service providers to provide you with better customer service and user experience.

Some third-party SDKs (Youmeng SDKs) or similar applications we access may collect your personal information. The product integrates Youmeng+SDKs and push channel SDKs (such as Xiaomi, Huawei, oppo, vivo, Meizu, etc.). The push channel SDKs need to collect collection device identifiers (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI information, etc.) to uniquely identify devices so as to push messages to user devices. Collect geographic location to screen push channels and improve the regional coverage of message push. If you use such services provided by a third party in our services, you agree that they will directly collect and process your information. We will evaluate the legality, legitimacy and necessity of such third-party services to collect personal information, require such third-party services to take protective measures against your personal information, and strictly comply with relevant laws, regulations and regulatory requirements.

8.How Do We Handle Personal Information of Minors

Our products, websites and services are mainly for adults. Children cannot create their own user accounts without the consent of their parents or guardians. In the case of collecting children's personal information with the consent of parents, we will only use or publicly disclose this information when it is permitted by law, explicitly agreed by parents or guardians, or necessary to protect children. Although local laws and customs have different definitions of children, we regard anyone under the age of 14 as a child. If we find that we have collected children's personal information without the prior consent of verifiable parents, we will try to delete relevant data as soon as possible.

9.How Do Your Personal Information Is Transferred Globally

In principle, the personal information we collect and generate in the People's Republic of China will be stored in the People's Republic of China. Since we provide products or services through resources and servers all over the world, it means that your personal information may be transferred to or accessed from foreign jurisdictions in the countries/regions where you use products or services after obtaining your authorization and consent. Such jurisdictions may have different data protection laws, or even no relevant laws. In such cases, we will ensure that your personal information is adequately and equally protected in the People's Republic of China. For example, we will ask for your consent to cross-border transfer of personal information, or implement security measures such as data de identification before cross-border data transfer.

10. Update of This Privacy Policy

We may adjust or change this privacy policy from time to time, and any update of this privacy policy will be published on our website by marking the update time. Unless otherwise required by laws, regulations or regulatory provisions, the adjusted or changed content will take effect as soon as it is notified or published. If you continue to use any of our services or visit our relevant websites after the adjustment or change of the privacy policy, we believe that this represents that you have fully read, understood and accepted the revised privacy policy and are bound by it.

This privacy policy will take effect from the date of update

11.Contact Us

Application information: PickFun

Developer: Chengdu Tommi Technology Co., Ltd

Email: developer@tommi-smart.com

Contact: Service@pick-fun.com