1. Introduction
Welcome to use the Sphevolabs products and related services!
1.1 The content, services, ownership and operation of the Sphevolabs products and related services (hereinafter referred to as “the Product”) are owned by Sphevolabs LTD. (“Company” or “we”). We are aware of the importance of your personal information and will do our best to protect the security and reliability of your personal information. We will abide by the principles of consistent authority and responsibility, clear purpose, choice of consent, minimum necessary, security, subject participation, and openness and transparency in accordance with laws and regulations, and commit to take appropriate security measures to protect your personal information in accordance with the mature security standards of the industry.
1.2 Personal information refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. We have established this Personal Information Protection Policy (hereinafter referred to as “this Policy”) and specifically remind you that you should read and understand this Policy carefully before using the Product and related services, and use the Product and related services after confirming that you fully understand and agree to it. By using the Product and related services, you acknowledge that you have fully understood and agreed to this Policy.
1.3 If you do not expressly agree to this Policy and begin using it, we will collect only the information necessary to view it, which will prevent us from providing you with the full range of products and services, but we will also use de-identification, encryption, and other measures to protect this information. If you do not agree to this policy, we will not be able to provide you with the full range of products and services, and you may choose to discontinue your use. When you choose to continue or re-use it, you will be deemed to accept and approve our processing of your relevant information in accordance with this Policy on the basis that it is necessary to provide the products and services.
1.4 This Policy applies to your access to and use of our products and services through our software applications, official websites, and other available services etc..
1.5 If you have any questions, comments or suggestions regarding the contents of this Policy, you may contact us through the various contacts provided in Section 9.1 of this Policy.
1.6 This Policy will help you understand in detail how the Product collects, uses, stores, transmits, shares, transfers (if applicable) and protects your personal information; it will help you understand how to access, access, delete and correct authorized personal information. Among them, the terms and conditions about your personal information rights and interests we have taken bold form to indicate, please pay special attention to and focus on reading.
1.7 This policy includes the following aspects:
1) How we collect and use personal information;
2) How we use cookies and similar technologies;
3) how we share, transfer, and publicly disclose personal information;
4) how we protect the security of personal information;
5) how we manage your personal information;
6) how we store personal information;
7) How this policy is updated;
2. How we collect and use personal information
2.1 We will only collect personal information that you voluntarily provide when using the Product and related services, as well as personal information collected through automated means when you use functions or receive services, in accordance with the appropriate methods specified in this policy.
2.2 Registration, login and identity authentication
2.2.1 To ensure that your account is not lost, you need to provide your mobile phone number and other related informations when registering and logging in to this product and related services. This information is collected to help you complete the registration. You can also choose to fill in your other information to complete your personal information according to your needs. Such information is collected to meet the requirements of relevant laws and regulations in some countries and regions. If you do not provide this information, you may not be able to use our services normally. The above information you provide will continue to be authorized for us to use during your use of this software and will be stored in the Republic of Singapore. When you actively cancel your account, we will anonymize or delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.
2.2.3 The aforementioned log information includes:
1)Information We Collect Directly from You:
The type of information that we collect directly from you varies based on your interaction with our Site and our Service. For example, we collect information directly from you when you register an account with us, liaise with us on a customer service issue, apply for a job, and complete an application or other forms on the Site and/or Service. We also collect information that you send us via any medium, including, but not limited to email address and phone number.
2)Information We Receive from Customers:
We receive information from customers in order to provide our Service. Such information may include a user’s social media handle, username, profile picture, biography, follower counts, website URL, first and last name (if provided by user), and messages or communications with our customers. We collect information from individuals employed by our customers such as their contact information in order to provide our Service.
3)Information Collected Automatically:
When you visit our Site or use our Service, we may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), third party webpages accessed via the Service and other technical information. We may also collect information about how your device has interacted with our Site (including the pages accessed and links clicked) or Service (including content accessed). Collecting this information enables us to better understand the visitors who come to our Site or use our Service, where they come from, and what content and functionality is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site and/or Service to our visitors and users.
Please note that separate device information and log information is information that cannot identify a specific natural person, so separate device information and log information is not “personal information” within the meaning of this policy. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information will be treated as personal information for the duration of the combined use, and we will anonymize and de-identify such personal information unless we obtain your authorization or unless otherwise required by law or regulation.
4) Information from Other Sources:
Data brokers or resellers from which we purchase data to verify and supplement the data we collect.
Social networks when you engage with our content, reference our Site or Service, or grant us permission to access information from the social networks.
Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
Customers that provide us with information which we process as a service provider.
2.3.4 In order to ensure that you receive relevant notification in a timely manner, we may ask you to authorize notification permissions. If you refuse to provide it, you will only be unable to use this feature, but it will not affect your normal use of other features of the Product. Notification permission is a setting on your device, which you can manage through the local notification permission management page. When you cancel this authorization, we will no longer obtain this permission and can no longer provide you with the above-mentioned services corresponding to it.
2.4 Use of Information
We processes information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include the following:
1)Operate and improve the Site and Service;
2)Provide users or customers with the Service and other products and services that a user or customer may request or that a user or customer has expressed interest in;
3)Evaluate user interest and needs in order to improve the Service and make available other offers, products or services;
4)Record calls with customers for quality, training and Service improvement purposes (upon receipt of consent where required by applicable law);
5)Evaluate the types of offers, products or services we make available to users or customers and potential users or customers;
6)Monitor use of the Service, including for troubleshooting and product improvement purposes;
7)Provide customer support;
8)Combine datasets to create aggregated data for internal evaluation and analysis;
9)Send you reminders, technical notices, updates, product announcements, security alerts and support and administrative messages, service bulletins, or marketing;
10)Manage our everyday business needs such as Site and/or Service administration, forum management, fulfillment, analytics, fraud prevention, enforcement of our corporate reporting obligations, legal terms and any other contractual agreement relating to our Service or to comply with the law;
11)Fulfill any other business or commercial purposes at your direction or with your notice and/or consent.
12)Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
2.5 To improve the security of your use of the services provided by us and our affiliates and partners, to protect you or other users or the public from harm to your personal property, to better prevent security risks such as phishing sites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and to more accurately identify violations of laws and regulations or the rules of the relevant agreement with Company, we may use or integrate Your user information, transaction information, device information, relevant web logs, and information that affiliates or partners have obtained your authorization or shared in accordance with the law, in order to make a comprehensive determination of your account and transaction risks, verify your identity, detect and prevent security incidents, and take the necessary recording, auditing, analysis, and disposal measures in accordance with the law.
2.6 Change of purpose of collecting and using personal information
2.6.1 Please understand that as our business develops, there may be adjustments to the features of the Product and the services provided. In principle, when new functions or services are related to the functions or services we currently provide, the personal information collected and used will be directly or reasonably related to the original purpose of processing. In scenarios where there is no direct or reasonable connection to the original processing purpose, we will collect and use your personal information and will again inform you and obtain your consent.
2.7 Exceptions to Obtaining Authorized Consent
2.7.1 When we use information for purposes other than those set out in this policy, or when we use information collected for a specific purpose for other purposes, we will seek your prior authorized consent.
2.7.2 According to the relevant laws and regulations, your authorized consent is not required for the collection of your personal information in the following cases:
1）Related to national security or national defense security
2）Related to public safety, public health, and significant public interests
3) in connection with crime investigation, prosecution, trial and execution of judgments, etc;
4) For the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals but for which it is difficult to obtain your own authorized consent;
5) The personal information collected is disclosed to the public by yourself;
6) Where your personal information is collected from information that is lawfully and publicly disclosed, such as lawful news reports, government information disclosure and other channels;
7) necessary to enter into a contract at your request
8) necessary for the maintenance of the safe and stable operation of the products or services provided, such as the detection and disposal of product or service failures;
9) necessary for legitimate press coverage;
10) necessary for academic research institutions to conduct statistical or academic research in the public interest and to de-identify the personal information contained therein when providing the results of academic research or descriptions to the public;
11) Other cases stipulated by laws and regulations.
2.7.3 If we cease to operate the Product or related services, we will promptly stop the activities of continuing to collect your personal information, notify you of the cessation of operations by delivering or announcing the cessation of operations on a case-by-case basis, and delete or anonymize the personal information held.
3. How we use cookies and similar technologies
3.1 About cookies and similar technologies
Cookies and similar technologies are common and frequently used technologies in the Internet. When you use the Product and related services, we may use such technologies to send one or more cookies or anonymous identifiers to your device in order to collect and store information about your access to, and use of, the Product. We use cookies and similar technologies primarily to perform the following functions or services. We promise not to use cookies for any purpose other than those described in this Personal Information Protection Policy.
3.1.1 To ensure the safe and efficient operation of our products and services: We may set cookies or anonymous identifiers for authentication and security purposes to enable us to confirm that you are securely logged in to our services, or that you have not encountered misuse, fraud or other misuse. These technologies also help us improve the efficiency of our services and increase login and response times.
3.1.2 To help you have an easier access experience: Using such technologies can help you eliminate the need to repeat steps and processes that involve you filling out personal information and entering search content (e.g., recording search history).
3.2 How to set, reject and clear cookies and similar technologies
3.2.1 You can set or refuse to manage cookies through your browser, but please note that if you deactivate them, you may not be able to enjoy the best service experience and some services may not work properly. Also, you will receive the same number of advertisements, but they will be less relevant to you.
3.2.2 Most browsers provide users with the ability to clear browser cache data, and you can perform the appropriate data clearing operations in the browser settings function. If you do so, you may not be able to use the cookie-dependent services or features provided by us.
4. How we share, transfer and publicly disclose personal information
4.1 Principles of sharing personal information
4.1.1 Authorized consent principle: We will not share your personal information without your consent, unless the personal information shared is de-identified processed information and the sharing third party cannot re-identify the natural person subject of such information. If the third party uses the information for purposes beyond the scope of the original authorized consent, they will need to re-obtain your consent.
4.1.2 Legitimate and Minimal Necessity Principle: Data must be shared for a legitimate and lawful purpose and shared to the extent necessary to achieve the purpose.
4.1.3 Security and Prudence Principle: Only to achieve the purposes stated in this personal information protection policy, some of our products or services will be provided jointly by us and authorized partners. We may share some of your personal information with authorized partners to provide you with better products or services and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and we will only share personal information necessary to provide products or services. Our authorized partners have no right to use the shared personal information for other purposes unrelated to products or services. Company will also sign strict agreements with partners, requiring them to process your personal information in accordance with Company’s instructions, this policy and any other relevant confidentiality and security measures.
4.2 Information shared to implement features or services
4.2.1 When you use the functions provided by our affiliates or third parties in the product,we will share the information necessary to achieve our business with these affiliates or third parties for comprehensive statistics and algorithmic feature and preference analysis to form an indirect crowd profile
4.2.2 When you choose to participate in relevant marketing activities organized by us and our affiliates or third parties, you may be required to provide your name, mailing address, contact information .etc. This information is personally sensitive and refusal to provide it may affect your participation in the relevant activity, but will not affect other functions. We will only share this information with affiliates or third parties with your consent in order to ensure that you receive a consistent experience in joint activities.
4.3 Shared information to achieve security and analytics statistics
4.3.1 Securing Use: We take account, service and content security very seriously. To protect your account and property and the legitimate and legal rights of you and other users from unlawful infringement, we and our affiliates or service providers may share necessary device, account and log information.
4.3.2 Analysis of product usage: In order to analyze the usage of our services and improve the user experience, we may share statistical data on product usage with affiliates or third parties that are difficult to combine with other information to identify you personally.
4.3.3 Academic research and scientific research: In order to improve scientific research capabilities in related fields and promote the level of scientific and technological development, we may share de-identified or anonymized data with scientific research institutes, universities and other institutions under the premise of ensuring data security and proper purposes.
4.4 Transfer of personal information
4.4.1 We will not transfer your personal information to any company, organization or individual, except for the following:
1) Transfer with express consent: we will transfer your personal information to other parties after obtaining your express consent;
2) As our business continues to grow, we will likely conduct mergers, acquisitions, and asset transfers, and your personal information may be transferred as a result. In the event of the foregoing, we will require the successor party to protect your personal information in accordance with laws and regulations and security standards no less stringent than those set forth in this policy, or we will require the successor party to obtain your authorized consent again.
4.5 Public Disclosure of Personal Information
4.5.1 We will not publicly disclose your personal information except
1) we may disclose your personal information publicly with your express consent or based on your active choice;
2) If we determine that you have violated laws or regulations or seriously violated the rules of the relevant agreement with Company, or to protect the company and its affiliates, users or the public from infringement of personal or property safety, we may disclose information about the relevant account in accordance with laws and regulations or the rules of the relevant agreement with the company;
3) Your publicly released information
4.6 Exceptions to prior authorized consent for sharing, transfer, and public disclosure of personal information
4.6.1 Please understand that in the following cases, in accordance with laws and regulations and national standards, we do not need to obtain your authorized consent in advance for sharing, transferring, or publicly disclosing your personal information:
1) Related to national security, national defense security
2)Related to public safety, public health, and significant public interest
3) related to crime investigation, prosecution, trial and sentence enforcement, etc;
4) For the purpose of safeguarding your or other individuals’ life, property and other significant legitimate rights and interests but for which it is difficult to obtain my authorized consent;
5)Personal information that you disclose to the public on your own;
6) your personal information collected from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels.
4.6.2 According to the law, sharing, transferring or publicly disclosing personal information that has been de-identified and ensuring that the recipient of the data cannot recover and re-identify the subject of the personal information is not an act of sharing, transferring or publicly disclosing personal information to the public, and the preservation and processing of such data will not require separate notification to you and your authorized consent.
5. How we protect the security of personal information
5.1 We attach great importance to the security of your personal information and will endeavor to protect your personal information with reasonable security measures (both technical and managerial) and encryption technologies no less advanced than those used in the industry (e.g. SSL encryption for data exchange between your device and the Services, https secure browsing of the Website, etc.), anonymization and related reasonable and feasible means to protect your personal information from from improper use or unauthorized access, public disclosure, use, modification, damage, malicious attack, loss or leakage of the personal information provided.
5.2 We will establish a special security department, security management system, and data security process to safeguard your personal information. We adopt a strict data use and access system to ensure that only authorized personnel have access to your personal information, and conduct security audits of data and technology when appropriate. We also hold training courses on security and personal information protection to enhance employees’ awareness of the importance of protecting personal information.
5.3 Although we have taken reasonable and effective measures as described above and have complied with the standards required by the relevant legal provisions, please understand that due to technical limitations and the possibility of various malicious means, it is not always possible to guarantee 100% security of information in the Internet industry, even with all efforts to strengthen security measures, and we will do our best to ensure the security of the personal information you provide to us.
5.4 You are aware and understand that the systems and communication networks you use to access our services may experience problems due to factors outside our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to using complex passwords, changing your password regularly, and not disclosing your account password and related personal information to others.
5.5 We will develop emergency handling plans and activate them immediately in the event of user information security incidents in an effort to prevent the expansion of the impact and consequences of these security incidents. Once a user information security event (leakage, loss) occurs, we will promptly inform you, in accordance with the requirements of laws and regulations, of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, and the remedial measures for you. We will promptly inform you of the incident in the form of push notifications, emails, letters, SMS and related forms, and when it is difficult to inform you one by one, we will take reasonable and effective ways to issue announcements. At the same time, we will also take the initiative to report the situation of personal information security incidents in accordance with the requirements of regulatory authorities.
5.6 If you find that your personal information, especially your account number or password, has been leaked, please contact us immediately so that we can take appropriate measures according to your application.
6. How we manage your personal information
6.1 We attach great importance to the management of your personal information, and make every effort to protect your rights related to the inquiry, access, modification, deletion, withdrawal of consent authorization, account cancellation of your personal information, and actively respond to your requests so that you have the ability to safeguard the protection and security of your personal information.
6.2 Inquiries, access and management of your personal information
6.2.1 You have the right to inquire about, access and manage your personal information, except in cases prescribed by laws and regulations.
6.3 Correction, addition or deletion of your personal information
6.3.1 If you discover an error in the personal information we have processed about you, you have the right to request that we make corrections or additions. You may contact us and make a request for correction or supplementation.
6.4 Changing, withdrawing the scope of your authorized consent
6.4.1 Certain business functions and services will require your information to be completed. After you withdraw your consent or authorization, we cannot continue to provide you with the functions and services for which you have withdrawn your consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of your personal information previously carried out by us based on your authorization.
6.5 Binding information systems for automated decision-making
6.5.1 In some business functions, we may make decisions based solely on non-manual automated decision making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate interests, you have the right to request an explanation from us and we will provide appropriate remedies.
6.6 Responding to your request above
6.6.1 Any request for your personal information may be made by contacting us in the manner set out in clause 9.1 of this Policy. For security purposes, you may need to provide a written request or otherwise prove your identity.
6.6.2 In principle, we do not charge a fee for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. We may refuse requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of a new system or a fundamental change in current practice), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tape).
6.6.3 We will not be able to respond to your request in the following cases:
1) In connection with the performance of the obligations of the controller of personal information under laws and regulations
2) directly related to national security or national defense security
3) directly related to public safety, public health, and significant public interests
4) directly related to criminal investigation, prosecution, trial and execution of judgments, etc;
5) where the controller of personal information has sufficient evidence of subjective malice or abuse of rights by the subject of personal information
6) for the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals but where it is difficult to obtain his or her consent
7) Responding to the request of the subject of personal information will lead to serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations
8) Where commercial secrets are involved
7. How we store personal information
7.1 We will store your personal information collected and generated during our operations in the Republic of Singapore in accordance with laws and regulations. Currently, we will not transfer the above information to other places. If we transfer it overseas, we will comply with relevant national regulations or seek your consent.
7.2 We will retain your personal information only for as long as is necessary to provide the Product and Services: the text and other related information you post will be retained for as long as you do not withdraw, delete or cancel your account. After the necessary period has elapsed, we will delete or anonymize your personal information, except as otherwise provided by law or regulation.
8. How this policy is updated
8.1 In order to provide you with better services, the Product and related services may be updated and changed from time to time, and we may revise this Personal Information Protection Policy from time to time, and such revisions shall form part of this Personal Information Protection Policy and shall have the same effect as this Personal Information Protection Policy.
8.2 We will not reduce your rights under this Personal Information Protection Policy without your express consent.
8.3 When this Personal Information Protection Policy is updated, we will issue the updated version in the Product by indicating the update time and alert you to the latest version of this Personal Information Protection Policy through announcements, notifications, internal letters, pop-up windows or other appropriate means. For major changes, we will also provide more prominent notice of the specific changes to the Personal Information Protection Policy. Material changes within the meaning of this policy include, but are not limited to:
1) Significant changes in our service model. such as the purpose of handling personal information, the type of personal information handled, and the manner in which personal information is used;
2) Significant changes in our ownership structure, organizational structure, etc. Such as change of ownership caused by business restructuring, bankruptcy and merger, etc;
3) Changes in the primary recipients of personal information sharing, transfer or public disclosure;
4) Significant changes in your rights to participate in the handling of personal information and the manner in which they are exercised;
5) When there is a change in the department responsible for handling personal information security, our contact method and complaint channels;
6) When the personal information security impact assessment report indicates the existence of high risk.
8.4 Unless otherwise mandatorily provided by laws, regulations or regulatory provisions, the contents of the adjusted or changed shall be effective immediately upon notification or announcement. If you continue to use the Product after the adjustment or change of the Personal Information Protection Policy, the Company believes that this means that you have fully read, understood and accepted the revised Personal Information Protection Policy and are bound by it.
9. How to contact us
9.1 If you have complaints, suggestions, or questions about this personal information protection policy, you may contact us through our custom services or your sales
9.2 If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you may also seek a solution through the following external means: file a lawsuit with the court where Sphevolabs is located.
9.3 This personal information protection policy is valid for a long time.