Privacy policy

Updated date: December 1, 2023

Effective date: December 1, 2023

Developer:RHINOX MOBILE

This Privacy Policy is designed to inform users about the practices of RhinoX Mobile Inc., Pte. Ltd. (the “Company”) regarding the collection, use, and protection of personal information. The following key points summarize the policy:

1. To ensure the normal operation of both the core and additional functions of the application, the Company collects certain necessary information from users.

2.The Company will not share, provide, transfer, or obtain users’ personal information from third parties without the users’ consent.

3.The Company commits to taking reasonable security measures to protect users’ personal information by employing the industry-standard methods and exerting utmost commercial efforts to safeguard the security of users’ sensitive personal information.

4.The policy also outlines the procedures for users to access, correct, and delete their personal information, withdraw consent and authorization, and file feedback and reports.

If users disagree with this Privacy Policy but commence using the product, the Company will only collect the information essential for maintaining the basic functionality of this application. This limitation may prevent the Company from offering users the full scope of this application’s services. Nonetheless, the Company will still apply de-identification techniques, such as encryption, to protect this information. By using this application again, under the terms required for fulfilling the contract and service, users will be deemed to have accepted and consented to the Company’s processing of their relevant information in accordance with this policy.

The Company places high importance on the protection of users’ personal information and handles such information with the utmost care and caution. When users download, install, open, browse, or use (hereinafter collectively referred to as “iuse”) the application’s software and related services, the Company will collect, store, use, share, disclose, and protect their personal information in accordance with this Privacy Policy. This Policy aims to explain how the Company handles users’ personal information, encouraging careful and complete review of all terms. Important information regarding users’ information rights is highlighted for emphasis.

Key sections include:

Ⅰ. Collection and Use of Personal Information

Ⅱ. Use of Cookies and Similar Technologies

Ⅲ. Storage of Personal Information

Ⅳ. Sharing, Transferring, and Public Disclosure of Personal Information

Ⅴ. Protection of Personal Information

Ⅵ. Users’ Rights

Ⅶ. Cross-Border Transfer of Personal Information

Ⅷ. Policy on Minors

Ⅸ. Amendments and Notifications of Privacy Policy Changes

Ⅹ. Exclusions from This Privacy Policy

Ⅺ. Contact and Resolution Procedures

Ⅻ. Miscellaneous


I. Collection and Use of Personal Information

When users engage with the application’s software and services, the Company collects information in alignment with the principles of lawfulness, fairness, and necessity. The information collected or requested from users serves the following purposes:

a. To guarantee the normal operation of the product’s foundation.

b. To enable various functions and services.

c. To optimize and improve the products and services offered.

d. To ensure the safety of the products, services, and users.

e. To deliver advertisements and information to users.

f. To comply with applicable laws, regulations, and national standards.

The Company collects information that users actively provide and information generated during the use of the application and its services, through the following methods:/p>

We will collect the information that you actively provide when you use the service, and the information generated during the use of the function or the process of receiving the service in the following ways:

1. Collection of Essential Operational Information

To ensure the normal operation of the application and its services, the Company will collect information including but not limited to the user’s hardware model, operating system version number, network device address (MAC), IP address, software version number, software installation list, network access method and type, and operation log. This information is essential for identifying genuine users as opposed to automated software or machines during login and registration processes. Additionally, it facilitates the advertisements to users. It is also utilized in the collection of bug information generated by statistical applications, enabling the Company to enhance product quality. Users are informed that such information is fundamental for the provision of services and to guarantee the seamless functioning of the Company’s products.

2. Registration and Login Processes

To enhance membership status records and provide superior services through account management, the Company requires users to register and log in. By logging into their accounts, users can synchronize their relevant information, facilitating a more personalized and efficient service experience.

3. Description of Permissions

The Company seeks to obtain specific permissions to ensure the effective functionality of its services. Below is a description of such permissions, including how they are obtained and their purposes:

a. Access Camera and Storage Permissions (Read/Write SDCard Data)

Method of Obtaining: Dynamic acquisition, with active user authorization.

Purpose: Facilitates the operation of basic service functions, enhancing the user’s interaction with the app by allowing for the processing of relevant media and data.

Audio

Method of Obtaining: Dynamic acquisition, with active user authorization.

Purpose: Supports the operation of basic service functions, enabling the app to interact with audio content for an improved user experience.

4. Sharing Information with Third-Party Statistical Services

The Company may share user information with third-party statistical services to enhance the functionality of its products and improve user experience. Below are the details regarding this process:

a. Google Statistics SDK

Provider: Google

Scenario Description: Utilizes statistical functions across various dimensions of the application to analyze and improve performance.

Collection Method: Automatic collection through the calling of system-related interfaces.

Types of Personal Information Collected:

-Device Information: Device identifiers (IMEI, IDFA, Android ID, MAC, OAID, etc.), application information (application crash logs, notification settings, software list, etc.), and device parameters and system information (device type, model, operating system, and hardware-related information).

-Network information: IP address, Wi-Fi details, base station information, and other relevant data.

Purpose: To statistically analyze detailed crash logs and user behavior.

Necessity: This information is crucial for the stated purpose.

Information Processing Method: Personal information is de-identified to ensure privacy and security.

Privacy Policy: https://support.google.com/googleplay/android-developer/answer/10144311

b. Google Login

The Company offers users the option to register or log in to the platform using Google as a third-party social network account detail or login service. Here are the details regarding this feature:

Scenario Description: Logging in to application account.

Information Shared with Social network: The Company shares specific information with the social network, including the app ID, access token, and the referring URL, to facilitate this login method.

Purpose: The primary aims are to fulfill requests for products, services, and platform functionality; provide support and information for internal operations such as troubleshooting, data analysis, testing, research, statistical and survey purposes; and to solicit feedback from users.

c. Apple Login

The Company offers users the option to register or log in to the platform using Apple as a third-party social network account detail or login service. Here are the details regarding this feature:

Scenario Description: Logging in to application account.

Information Provided by Users: When opting to use Apple login, users consent to provide or allow the provision of their username, public profile, and other information associated with their Apple account.

Purpose: The primary aims are to fulfill requests for products, services, and platform functionality; provide support and information for internal operations such as troubleshooting, data analysis, testing, research, statistical and survey purposes; and to solicit feedback from users.

d. Facebook Login

The Company offers users the option to register or log in to the platform using FacebookS as a third-party social network account detail or login service. Here are the details regarding this feature:

Scenario Description: Logging in to application account.

Information Provided by Users: When opting to use Apple login, users consent to provide or allow the provision of their username, public profile, and other information associated with their Apple account.

Purpose: The primary aims are to fulfill requests for products, services, and platform functionality; provide support and information for internal operations such as troubleshooting, data analysis, testing, research, statistical and survey purposes; and to solicit feedback from users.

5. Ensuring the Safety of Products, Services, and Users

To enhance the operational safety and service provision of the application, the Company employs third-party statistical tools. These tools are utilized to record network log information, frequency of use, software crashes, and collect overall installation, usage, performance data, and other relevant information. It is important to note that all collected data undergoes de-identification/anonymization processing. Data analysis is conducted using specific codes that cannot be directly linked to user identities, ensuring user privacy and security.

a. Adjustments to the Collection and Use of Personalinformation

With the evolution of the Company’s business and potential adjustments to the applications functionalities and services, the scope of collected and used personal information may change.Any new collection and use of personal information will either be directly or reasonably related to the original processing purpose. In cases where the new purposes are not directly or reasonably related, the Company will notify users and seek their consent anew.

b. Situations Exempt from Consent for Collecting and Using Personal information

Under specific conditions outlined by laws, regulations, and/or national standards, the Company may collect and use personal information without user consent. These conditions include, but are not limited to:

-Matters directly related to national security and defense.

-Issues directly related to public safety, health, and significant public interests.

-Activities directly related to criminal investigations and proceedings.

-Situations where obtaining consent is impracticable yet necessary to protect the legal rights of the individual or others.

-Instances where the user has publicly disclosed their personal information.

-Collection from legally public sources.

-Necessities for contract execution as requested by the user.

-Other legally stipulated scenarios.

c.Guidelines for Account Cancellation

Users wishing to delete their accounts can do so via the account deletion feature in the user account of the app. The deletion process will be completed within 7 days, during which the app remains usable. Success in account deletion leads to erasure of all associated data within the app. Deleted accounts cannot be used for future registrations/logins and cannot be restored. During the deletion process, prompt communication with customer service is advised to ensure the request’s success.

Special Note: Information that cannot identify a user either alone or in combination with other data is not considered personal information under legal terms. However, if such information becomes identifiable through combination with other user data, it will be treated and protected as personal information in accordance with this Policy during such combined use.

Ⅱ. Use of Cookies and Similar Technologies

Cookies and similar technologies are integral to the internet. When interacting with this application software and related services, the Company employs these technologies to send cookies or anonymous identifiers to the user’s device, collecting and storing information about product usage and visits.

The Company sets cookies or anonymous identifiers primarily for authentication and security purposes, ensuring the safe and efficient operation of its products and services. Additionally, these technologies aid in enhancing service efficiency and increasing login response speeds.

Ⅲ.Storage of Personal Information

a. Storage Location

In compliance with applicable laws and regulations, the company stores the personal information collected and generated during domestic operations within locations that are in full legal compliance.

b. Storage Duration

The Company retains personal information, including face data, for a period of one year. Any personal information that exceeds this one-year retention period will be deleted. Additionally upon the deletion of a user’s account, the Company will also proceed to delete or anonymize the user’s personal information.

Ⅳ. Sharing, Transferring, and Public Disclosure of Personal information

1. General Principle

The Company upholds the utmost respect for our user privacy as a fundamental principle. Except in the circumstances outlined below, the Company will not share users’ personal information with any third parties:

a. With Explicit Consent: The Company shares personal information with other entities only after obtaining explicit consent from the user/

b. Legal Requirements: Personal information may be shared externally to comply with judicial or administrative orders.

c. Affiliates: Personal information may be shared with the Company’s affiliated companies. Such sharing is limited to what is necessary and is governed by the objectives outlined in this privacy policy. Should an affiliate wish to change the processing purpose of personal information, it will see consent anew.

d. Authorized Partners: For the purpose of delivering better customer service and user experience, the Company may share personal information with authorized partners. This sharing is strictly for providing services and is carried out under legal, legitimate, necessary, and specific conditions. For instance, purchasing products online necessitates sharing personal information with logistics providers. Partners are prohibited from using the shared information for any purposes beyond those agreed upon. The Company enters into strict confidentiality agreements with all third parties receiving personal information, mandating that they process such information according to the Company’s directives, this privacy policy, and any applicable confidentiality and security measures.

Ⅴ. Protection of Personal information

1. Commitment to Security

The Company places high importance on the security of users' personal information and endeavors to implement reasonable security measures (covering both technical and managerial aspects) to protect such information. These measures are designed to prevent unauthorized access, use, modification, damage, loss, or disclosure of the provided personal information.

2. Use of Advanced Security Tech2. Transfer Conditions

The Company commits to not transferring users’ personal information to any company, organization or individual, with the sole exception being:

-Transfer with Explicit Consent: Personal information may be transferred to other parties only after the Company has obtained explicit consent from the user.

3. Public Disclosure of Personal Information

The Company will publicly disclose users’ personal information only under the following specific circumstances:

a. User-Agreed Disclosure: Personal Information will be disclosed in a manner explicitly agreed upon by the user, adhering strictly to the parameters specified by them.

b. Legal Obligations: In instances where it is mandatory to provide personal information in compliance with laws, regulations, administrative law enforcement, or judicial requirements, the Company may publicly disclose your personal information as necessary. Such disclosures are conducted in accordance with the type of personal information required and the method of disclosure stipulated by law. The Company will demand proper legal documentation, such as subpoenas or investigation orders, to verify the legitimacy of the request.

c. Exemptions Requiring No User Authorization: Under certain conditions defined by laws, regulations, and/or national standards, the Company is not required to obtain user authorization before sharing, transferring, or publicly disclosing personal information. These conditions include but are not limited to: Matters directly related to national security and defense. Situations directly pertaining to public safety, public health, and significant public interests. Cases directly linked to criminal investigations, prosecutions, trials, and the execution of judgments. Circumstances where it is necessary to protect the life, property, and other significant legal rights and interests of individuals, but obtaining consent is impractical. Instances where the user has publicly disclosed their personal information. Collection of personal information from legally public sources, such as legal news reports and government disclosures.

nologies

The Company employs encryption technologies and anonymization methods comparable to or exceeding industry standards, alongside security protection mechanisms, to shield personal information from malicious attacks.

3. Security Management

A dedicated security department, management system, and data security processes are established to safeguard users' personal information. Access to this information is strictly controlled, ensuring only authorized personnel have access, and regular security audits are conducted on data and technology.

4. Acknowledgement of Limitations

Despite adopting reasonable and effective security measures, the Company acknowledges the inherent limitations of internet security due to technical constraints and potential malicious methods. The company commits to doing its utmost to secure the personal information provided by users but cannot guarantee 100% security. Users are encouraged to take proactive steps to secure their personal information.

5. Incident Response and Notification

In the event of a security incident affecting user information,the Company will immediately activate emergency response plans to mitigate impact and consequences. Users will be informed promptly about the incident, including its nature, potential impact, measures taken, and recommendations for risk reduction, via email, letter, or SMS. In situations where individual notifications are impractical, announcements will be made through reasonable and effective means.

6. Scope of Privacy Policy

It is highlighted that the personal information protection measures outlined in this privacy policy apply solely to this application’s software and related services. Once users navigate away from these services to other websites or platforms, the Company cannot protect personal information submitted elsewhere, regardless of the method of access.

Ⅵ. Users’ Rights

The Company highly prioritizes the management of users' personal information and is committed to ensuring users' rights to access, modify, delete, and withdraw authorization and consent regarding their personal information. This commitment empowers users to effectively safeguard their privacy and security.

1. Withdrawal of Authorization

Users have the option to withdraw their consent to the collection and use of their personal information. This can be achieved by disabling specific functions or changing application permissions in the device's settings to modify the scope of authorization. It is important for users to understand that certain services and functionalities require personal information. Should a user withdraw their consent or authorization, the Company will cease to provide the services and functionalities related to this withdrawal and will no longer process the relevant personal information. However, the withdrawal of consent or authorization will not affect any processing of personal information conducted prior to the withdrawal.

2. Accessibility of the Privacy Policy

The complete privacy policy is readily accessible within the app, located under "Settings" > "About" > "Privacy Policy." This ensures users can easily review the policy at any time to stay informed about the management of their personal information.

3. Notification of Operation Cessation:

Should the Company discontinue operations, it will immediately halt the collection of personal information. Notices regarding the discontinuation of operations will be issued to users either individually or through a public announcement, keeping users informed about the cessation of data collection activities.

Ⅶ. Cross-Border Transfer of Personal Information

The personal information collected from end users by the Company is stored in Singapore. In instances involving cross-border data transfer, the Company adheres strictly to the applicable laws and regulations. The company conducts data export security assessments to ensure the security of end users' personal information during such transfers.

Ⅷ. Policy on Minors

If an individual under the age of 13 wishes to use the "App" software and related services, it is required that they read and agree to this Privacy Policy under the supervision and guidance of their parents or legal guardians.

The Company is committed to protecting the personal information of minors in compliance with relevant national laws and regulations. The collection, use, sharing, or disclosure of minors' personal information will only occur if it is permitted by law, with the express consent of parents or legal guardians, or when it is necessary to protect the personal information of the minor. In the event that the Company discovers that personal information from minors has been collected without verifiable parental consent, the company will take immediate action to delete such information.

Guardians of minors are encouraged to contact the Company through the contact information provided in this Privacy Policy if they have any questions or concerns regarding the personal information of the minor under their care. This approach ensures that the Company not only complies with legal requirements but also upholds a high standard of care in protecting the privacy and security of minors' personal information.

Ⅸ. Amendments and Notifications of Privacy Policy Changes

1. Updates to Services and Policy

To enhance the services provided through this application’s software and related services, updates and changes are periodically made. Correspondingly, the Privacy Policy will be revised to reflect these updates, with such revisions forming an integral part of the Privacy Policy and holding the same legal effect. The Company commits to not diminishing the rights granted under the current Privacy Policy without obtaining explicit consent from the users.

2. Notification of Policy Updates

Prior to the enactment of updated terms, the Company will inform users of the changes in a suitable manner through this application’s client, ensuring users are aware of the latest version of the Privacy Policy. Continued use of the services post-update implies acceptance of the revised policy terms. However, should the updates involve the collection of sensitive personal information (e.g., audio and video files, contact details, geographical location), explicit consent will be sought in a conspicuous manner.

3. Notice of Significant Changes

For substantial modifications to the Privacy Policy, the Company will provide more noticeable notifications, including but not limited to emails, text messages, private messages, or special reminders on the browsing page, urging users to review the changes carefully. Significant changes include, but are not limited to:

-Major alterations in the service model, such as changes in the purposes for processing personal information, the types of personal information processed, and the methods of using personal information.

-Significant changes in ownership structure or organizational structure, such as changes resulting from business adjustments, bankruptcies, or mergers.

-Changes in the primary recipients of personal information sharing, transfer, or public disclosure.

-Significant modifications affecting users' rights regarding their personal information and how those rights are exercised.

-Updates to the department responsible for personal information security, along with changes in contact details and complaint channels.

X. Exclusions from This Privacy Policy

This Privacy Policy does not cover the following areas:

a. Third-party Products or Services: This includes third-party products or websites and the advertising content displayed within this application’s service, as well as other products or websites that may be linked from this application’s service.

b. Third-party Advertisers: This refers to third parties that advertise within this application’s service.

The use of any third-party services, including the provision of personal information to such entities, falls under the jurisdiction of the terms of service and privacy policies of those third parties, not under this Privacy Policy. Users are advised to exercise caution in protecting their personal information and to only provide it to third parties when absolutely necessary.

Furthermore, it is noted that this specific application and related services mentioned in this Privacy Policy may differ based on factors such as the mobile phone model, system version, and software application version utilized by the user. Therefore, the actual products and services provided are subject to the version of this application’s software and related services being used.

Ⅺ. Contact and Resolution Procedures

1. Inquiries and Feedback

Users with questions, comments, or suggestions regarding this Privacy Policy are encouraged to contact the Company via email at support@airy365.com. The Company values user feedback and is dedicated to the continuous improvement of its privacy practices.

2. Complaints and Deletion Requests

If a user believes that the Company has collected or used their personal information in violation of applicable laws, regulations, or the agreement between the user and the Company, the user has the right to request the deletion of their personal information by sending an email to support@airy365.com. Upon receipt of such a request, the Company commits to acknowledging the issue within 15 working days, verifying the user's identity, and responding and addressing the concern in a timely manner.

Ⅻ. Miscellaneous

1. Headings and Interpretation

The headings utilized within this Privacy Policy serve solely for the ease of reading and navigation and do not influence the interpretation or meaning of any provisions contained herein.

2. Definitions

For the purposes of this Privacy Policy, the following terms are defined as follows:

Application Software and Related Services: This term refers to client applications branded with this application’s name that are legally owned and operated by the Company and its affiliates.

Affiliate: An affiliate encompasses any company, institution, or the legal representative of said entities, that is controlled by, controls, or is under common control with RhinoX Mobile Inc., Pte. Ltd. both currently and in the future. "Control" denotes the capacity, either directly or indirectly, to direct the management or policies of an entity, whether through ownership, voting rights, contractual agreements, or other means recognized by law.

De-identification: This process involves the technical treatment of personal information to ensure that the subject of the personal information cannot be identified without the use of additional information.

Anonymization: Refers to a process by which personal information is technically processed such that the subject of the information cannot be identified, and the processed information cannot be restored to its original state.

For further assistance or inquiries regarding this Privacy Policy, please contact RhinoX Mobile at:

Email: support@airy365.com

Customer Service Hours: 9:30 – 18:00 (GMT+8)