Privacy Notice
Effective date: Jan. 1, 2022
This Privacy Notice for California Residents ("CA Notice") applies to "consumers" as defined by the California Consumer Privacy Act ("CCPA") and supplements other privacy policies or notices issued by Xender (HK) Limited ("Xender", "we", "our", or "us"). In the event of a conflict between any other Xender statement or notice and this CA Notice, this CA Notice will prevail with respect to California consumers and their rights under the California law.
HOW WE COLLECT, USE, AND SHARE PERSONAL INFORMATION
We collect personal information from a variety of sources, including information we collect from you directly (e.g., when you contact us); information we generate about you in the course of our relationship with you; and information we collect about you from other sources, including third party services (such as third-party social media companies, advertising partners, and analytics providers). We may also collect certain personal information about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfillment of these obligations.
We may collect the following categories of personal information from and about you:
- Identifiers such as a nickname, telephone number, email address, profile ID, unique personal identifier, online identifier, account name, IP address, or other similar identifiers;
- Demographic information, including characteristics that may be protected by law such as gender or age range;
- Internet or other electronic network activity information, such as the data we receive when you interact with our services (e.g., your search history, log data, or actions you take within the App), information about your network, carrier, or device (e.g., your operating system, system language and region, device version, and device identification number), the information about other apps you have installed;
- Coarse geolocation data, such as location information we receive about you, e.g. based on your IP address or WiFi SSID;
- Audio, electronic, visual, thermal, olfactory, or similar information, such as your profile photograph;
- Commercial information, such as a record of purchases you make through the Apple iTunes or Google Play stores; and
- Any information you include in your publicly-visible profile or which you or others make available to us or the public (e.g., your social media profile information if you use your social media account to log into our services or your comments on the videos publicly circulated on the App or feedback you leave).
We may use your personal information for the following purposes:
- Identification and authentication: We use your identification information to verify your identity when you register for or access and use our services, or otherwise engage with us, and to ensure the security of your personal information, such as to detect and prevent fraud, abuse, or illegal actions.
- Service operations: We process your personal information to provide our services, such as to recommend content and connect you with other users. We use the information about the other apps you have installed to provide you with peer to peer transmission service.
- Service improvements: We analyze usage information, including site analytics, to continually improve the user experience.
- Communications: Communications may include providing information about changes to the terms and conditions, updates regarding our services, information regarding new services or features, or responses to questions you pose.
- Advertising and Marketing: We may use your personal information to build a profile about you, to understand your preferences, and to help determine which marketing materials would be of interest to you.
- Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
- Complying with our obligations: We may process your personal information to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
- Customizing your experience: We may use your personal information to improve your experience with our services, such as by providing interactive or personalized elements and providing you with content based on your interests.
We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other company, and may use this anonymized information for any other purpose.
| Categories of personal information disclosed for our business purposes | Categories of third parties to whom this information was disclosed |
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Note that California law characterizes some sharing and transfer of personal information as a "sale," even when the sharing or transfer is not done in exchange for monetary consideration. We do not believe that any of the sharing or transfers described in this CA Notice constitute sales under California law.
YOUR RIGHTS
California law grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the following rights:
- Right to know. You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information.
- Right to delete. You have the right to request the deletion of your personal information, subject to certain exceptions.
- Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.
If you are a California resident and would like to exercise any of the above rights, please submit your request via email to legalsupport@xender.com or via postal mail to:
Xender (HK) Limited
ROOM 1702 17/F HONG KONG TRADE CENTRE NOS. 161-167 DES VOEUX ROAD CENTRAL HK
Please note that we may require additional information from you in order to honor your request, and there may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request. If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.
Finally, California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below and put "Shine the Light" in the subject line of your request.
CONTACT US
If you have questions or concerns regarding the way in which your personal information has been used, please contact us at legalsupport@xender.com.