This Privacy Policy (“Policy”) applies to Sayyo App and other related sites, apps, communications and services (“Services”,“Sayyo”). EXU(HK) Limited (hereinafter referred to as “we”, “us”, “our”) is the service provider and operator of Sayyo and its Services. We fully respect your privacy and are committed to protecting it through our compliance with this Privacy and applicable laws and regulations. This Policy is meant to help you understand our practices related to the collection, use, storage, and disclosure of information we collect from or about you when you interact with us, your rights regarding the information provided to us, and how we safeguard your rights.
It is important to note that this Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies. We encourage you to read and review the privacy statements of each Third-Party Service that you may choose to use.
If you have any comments or queries about this Policy, or how we use your information, please contact us using the contact details provided below.
Please make sure to read this Policy carefully to understand our practices regarding your Personal Information and access it frequently to understand the updates to this Policy. If we update this Policy, we will notify you by announcements in the App or our website to let you know about the changes we made. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of the Privacy Policy for the latest update time.
If you have any questions, please feel free to contact us at 【support@sayyo.live】.
You can also access this Privacy Policy by the following means:
【Me> Settings>About 【Sayyo】>Privacy Policy】
This Privacy Policy will help you understand the following contents:
i. Important Definitions
ii. Information Collection and Use
iii. How We Store Your Data
iv. How We Share, Transfer and Disclose Your Personal Information and Data
v. How Your Personal Information Is Transferred Across Borders
vi. How We Handle the Personal Information of Children
vii. Your Data Protection Rights
viii. Cookies And Similar Technologies
ix. Third-Party Service Providers and Services
x. Supplement And Update of The Policy
xi. How To Contact Us
I. Important Definitions
· Personal Information: Personal Information means any information that relates to a living individual directly or indirectly and can be used to identify a living individual, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity.
· Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself.
· Cookies: Cookies are small pieces of data stored on a user’s device.
· Data Controller: Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Policy, we are a Data Controller of your data.
· Data Subject: Data Subject is any living individual who is the subject of Personal Data.
II. Information We Collect and Use
For your better experience in our Services, we may require you to provide us with certain Personal Information while using our Services.
We may collect your Personal Information in the following ways: 1) information you provide directly to us (such as your nickname, profile picture and phone number (if applicable) you provide to us when you register or login to your account); 2) information we obtain automatically during your use of our Services (such as Device Information and Usage Data); 3) information we obtain from other sources.
You are not required to provide your Personal Information to us, but in some cases, if you choose not to do so, we may not be able to provide you with related features or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your Personal Information only for the purposes described in this Policy. The following describes your Personal Information that we collect and how we use it:
Information You Provided
· Registration
If you choose to register or log in via third party platform (e.g. Facebook, Google, Apple, collectively “Third Party Accounts”), we may collect your account ID, OpenID, and other certain information that you make available on Third Party Platform (for example, your username, profile picture, gender, date of birth, friend lists). The Personal Information we are ultimately able to obtain will be based on the content authorized by the third-party service providers. You can also choose to fill in or change your information according to your own needs, however, if you refuse to provide information about your third-party account, you will not have the option to register and log in with your third-party account.
· Profile information
You have choices about the information you provide on your Account, such as your profile picture, nickname, relationship status, date of birth, gender, and self-introduction. Your Profile is available to other users of the Service who are connected to you on our service. In addition, unless you opt-out (which you may do so at any time in the settings of our application), your Profile is discoverable by other users.
You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including making others to better know you and chat with you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add Personal Information to your profile that you would not want to be publicly available.
· Payment information
We may collect and process your purchase and transaction record in the Services, including device information (including Open ID, IP address, OS version, type of device, internet connection), transaction details (time and date, cost, product purchased, currency, order ID) and transaction records (including user ID, time of transaction, country, email, purchase history and payment card details), to perform our contract with you to facilitate your payment and provide you with details of your transactions. However, we do not process the payments for in-app purchase nor do we have any access to your credit card information or billing information.
Payment transactions for in-app purchases in our Services are completed via Google or Apple or other app stores/platforms. Any post-purchase processes are controlled by those app stores/platforms and are subject to their specific terms. Please review the Privacy Policy and terms of service of the app stores/platforms you choose.
· To provide you with fun features and services
(1) We collect personal information from you when you provide, post or upload it to our Services, such as when you post contents in live rooms. We will display your nickname, profile picture and the content of the information you have posted (including but not limited to comments, texts, messages, pictures, images, videos, sounds, code or other data and materials). To ensure that we comply with any applicable content regulations in any relevant jurisdiction, we may review the content you provide, post or upload (including but not limited to pictures, images, comments, texts, messages, videos).
When you use the posting and uploading function, we may ask you permissions to access your device’s camera, photos and microphones. Your refusal to provide the permission will prevent you from using such function, but will not affect your normal use of other features.
(2) To help you find users around you and match up with nearby players, we will collect information about your approximate location, including location information based on your SIM card and/or IP address.
We may also ask your permission to your precise location data (such as GPS) for above functions, your refusal to provide the permission will prevent you from using such function, but will not affect your normal use of other features.
· To provide you with customization of content and marketing communications
We may recommend content tailored to your interests on our website and APP based on your use of, preference, personal behaviors and other characteristics. You can opt-out the notifications through the setting function on your device. We may also send messages related to our services and marketing communications to your email address, mobile phone number, or via third party accounts. You can opt-out the marketing information at any time by using the unsubscribe function within the electronic marketing material or making request to our customer service. Where required by the applicable laws and regulations, we will obtain your consent before sending marketing communications to you. If you have any questions about our marketing communications, you can contact us using the contact details provided in "How to contact us" of this Privacy Policy.
· To provide you with customer service and feedback services
If you encounter any problems while using our Services, you may contact us and seek assistance through our customer service. We may collect the content of your enquiry, your device information, contact details or other contact information you leave with us in order to contact you or help you resolve the problem, or to record the problem and its solution. If you choose not to provide such information, we may not be able to provide you with this service, but your use of other features of will not be affected.
· To improve our products or services
We may also collect other information about you that we reasonably need to improve our products or services, including any feedback you provide when you contact customer service and any questionnaire you send back to us when you participate in a survey. We may combine information from one service with information from others in order to provide you with better service.
· To provide you with security services
To improve the security of your use of our services, to protect you, other users, or public safety and property from harm, to better prevent security risks and to more accurately identify violations of laws and regulations or our relevant agreement rules, we may use or integrate information about your device as well as your usage data to help you conduct security risk detection, prevent security risks, and take the necessary recording, auditing, analysis and disposal measures in accordance with the law.
· Other situations in which your information may be collected
To the extent permitted by law, we may obtain your personal information from other individuals, business entities, public sources or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
Information We Collect When You Use Our Services
During your use of our services, in order to ensure that you can fully use our App and its Services and to provide you with in-app personalized recommendations and displays, we will automatically collect information about your device or your usage of 【Sayyo】, including:
Device information. When you start using Sayyo, based on your specific actions in Sayyo and the specific permissions you have granted to us during the installation and use of Sayyo, we will collect information about the mobile device you are using, such as UUID, IMEI, MAC address, IDFA, your device model, operating system and version, APK name, App version, device display resolution, device setting, CPU information, storage information, battery usage status, time zone settings and device location information (IP address, GPS location and WLAN connection, Bluetooth and cell site information that provides location information).
Network activity information, such as your browsing history, search history, the videos, live rooms or pages you visited, the date and time of your visits, other users’ accounts that you follow, and information regarding your interaction with other users.
Usage Data. When you use our services, we will collect details of your use of our services and keep them as Usage Data, including your login account, IP address, provider information, Internet connection environment, WIFI status information, and other Usage Data.
User content, such as photos, screenshots, comments, and other materials that you create on the service may also be collected. Your photos and videos may be captured by other users on the service, and those content can be stored and used by us or third party services (e.g. Facebook) for content moderation and community safety monitoring purposes. You can change third party sharing options in our product settings or writing to us directly.
Location Information. When you use our services we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
Please note that some of the above-mentioned information alone cannot be used to identify a specific natural person, thus cannot be considered as Personal Information. Only when such Non-Personal Information is used in combination with other information to identify a specific natural person, or when it is used in combination with Personal Information, will this information be regarded as Personal Information during such combination. In this case, we will anonymize and de-identify this type of information, unless with your consent or otherwise according to laws and regulations. The above-mentioned information is essential to the provision of the Service. If you choose not to provide them, we may not be able to provide you with related Services.
III. How We Store and Protect Your Information
Your information collected by us will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected Personal Information in countries or regions outside the country where our business is located.
Currently, the personal data we collect from you may be stored on a server located in 【Japan】. According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
We generally retain your personal information to the extent as necessary to the proper business needs of our company (e.g., for the purposes of providing our services to you or complying with the requirements of laws, tax and finance), except as provided otherwise by the applicable laws or regulations. When there is no such business need to use your Personal Information, or the time limit for the retention expires according to the applicable laws or regulations, we will delete or anonymize your Personal Information, or if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion or anonymization is possible.
While you can close your account by yourself, we may also close your account if you fail to comply with this Policy, Sayyo Terms of Service, other Sayyo related rules or applicable laws and regulations. In case of such account closure, we will delete or anonymize your relevant information.
The security of your Personal Information is important to us and we implement security safeguards designed to protect your Personal Information and regularly monitor our systems for possible vulnerabilities and attacks We are constantly working to improve on these safeguards to keep your personal data secure.
However, we need to remind you that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
IV. How We Share, Transfer and Disclose Your Personal Information
When sharing, transferring, and disclosing your Personal Information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your Personal Information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your Personal Information in the following situations:
1. How we share your Personal Information
WE DO NOT SELL ANY PERSONAL INFORMATION TO THIRD PARTIES. We will share your personal data with our affiliates to provide and develop our Services.
We may share the necessary Personal Information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, in order to enable you to share information with third-party platforms, and use location service and other kinds of services and features, we may embed third-party SDK or other similar applications of authorized partners in our Services. Please refer to the “Third-Party Service Providers and Services” section for more details.
In order to provide evaluation, analysis or other business services, we may also share your Non-Personal Information with third parties.
2. How we transfer your Personal Information
We will not transfer your information to any other parties, except in the following circumstances:
(1) Obtain your explicit consent.
(2) If we are involved in a merger, acquisition or sale of all or part of its assets, which may affect your Personal Information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and the rights of your Personal Information, and any choices you may have about your Personal Information.
(3) It is proposed by yourself.
3. How we disclose your Personal Information
We may need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of our Services, our users, personnel or others. We attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
V. How Your Personal Information is Transferred Across Borders
For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your Personal Information to our servers stipulated in section III of this Policy for storage or processing, we may also transfer your Personal Information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions.
In the circumstance that we transfer Personal Information outside of your jurisdiction, whether it is transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
VI. How We Handle the Personal Information of Children
Our Services are not directed to children under 【18】 (or other age as required by local law), and we do not knowingly collect Personal Information from children.
If you are a parent or guardian and wish to review information collected from your child or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with Personal Information in violation of applicable law, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it and terminate the child’s account.
VII. Your data protection rights
We would like to make sure that you are fully aware of all of your data protection rights. As a data subject, you have a variety of rights regarding the use and control of your user information.
In certain circumstances, you have the following data protection rights:
· Right to access. You have the right to access the Personal Information that we hold about you. If you request a copy of your Personal Information, we will provide you a copy in an electronic format after passing our verification process. However, if you choose to delete the data, some features that require such data may no longer be available.
· Right to rectification. If you consider that the Personal Information we hold about you is inaccurate or incomplete, you have the right to obtain rectification of your Personal Information without undue delay.
· Right to erasure. You have the right to obtain deletion of Personal Information concerning you if the reason why we could collect it, does not exist anymore or if there is another legal ground for its deletion.
· Right to object and restrict. You have the right to object to our processing of your Personal Information or request that we restrict the processing of your Personal Information. You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
· Right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. You may ask us to transfer some of your Personal Information, by (a) using the Help Center function on our Services or (b) by sending your request to us via email at 【support@sayyo.live】.
· Right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information. You can withdraw your consent previously granted to us for a specific purpose by deleting information, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your Personal Information that we manage or control. If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of our product and Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
According to the applicable laws of some jurisdictions, you may have other data subject’s rights.
You may exercise the above rights by (a) using the Help Center function on Sayyo Services or (b) by sending your request to us via email at 【support@sayyo.live】. Please understand that for security reasons, we may ask you for additional information to confirm your identity and that we are providing access to information about the correct person before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or they require the disclosure of information of third parties.
VIII. Cookies and similar technologies
Cookies are small text files that are stored on your mobile device by us to ensure that this software’s normal operation and your convenient access to it. Cookies usually contain identifiers, site names, and some numbers and characters. Our website, our product, or other information services may use Cookies and other similar technologies such as Pixel Tags and Web Beacons. We generally treat information collected by Cookies and similar technologies as Non-Personal Information as they do not contain any of your personally identifiable information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by the laws of the countries concerned, we will also follow the laws of the countries concerned.
We and our partners may use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. You can manage or delete Cookies according to your preferences.
IX. Third-Party Service Providers and Services
You may receive links to third-party websites or content and services provided by third parties other than us during your use of our Services, and some third parties’ products or services can be accessed in the form of SDKs and others in order to provide you with some functions and features in our Services, such as to provide you with third party logins, notifications and user analysis.
You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your Personal Information.
X. Supplement and Update of the Policy
We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology, and applicable law and practice. In case of any modification of this Policy, we will notify you by announcements in the App or our website to let you know about the changes we made. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy.
XI. How to Contact Us
For the purpose of establishing the personal data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer (in short, “DPO”) who is responsible for the oversight and implementation of the personal data protection strategy and ensures our processing of personal data in compliance with necessary legal requirements stipulated in the applicable laws. If you have any comments, questions or concerns with respect to our Privacy Policy or practices of Personal Information protection, please contact our DPO at 【support@sayyo.live】(All requests must be labeled “Privacy Policy request” on the email subject line for us to better assist you).
We will review your privacy or Personal Information requests as soon as possible and respond to you within 15 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
XII. Jurisdiction Specific Supplemental Terms
According to the applicable laws of some jurisdictions from which you access or use our Services, we may supplement this Policy with jurisdiction specific terms. Such supplemental terms constitute an integral part of this Policy. In the event of a conflict between the provisions of the Supplemental Terms and the rest of this Policy, this Supplemental Terms shall prevail.
(1) For California Residents:
If you are a California resident, you are entitled to request notice of certain information about the user information that we may share with third parties for marketing purposes (e.g., the categories of user information shared, and contact information of applicable third parties), as well as request that we disclose to you what Personal Data about you we collect, use, disclose and sell, the right to opt out of the sale of your information, and the right to request deletion of your Personal Data we collect or maintain. If you would like to exercise any of these rights, please email your request to us as provided above in the section “How to Contact Us”.
You also have the right to not be treated in a discriminatory manner for having exercised your rights regarding your privacy rights under the California Consumer Privacy Act (CCPA).
(2) For Users in the European Economic Area (EEA), UK, and Switzerland:
A. Additional Data Subject Rights
If you are a resident of the above countries, you may also have the right to complain to a data protection authority about our collection and use of your user information. For example, you can lodge a complaint with your local supervisory authority (EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC)).
B. Legal Basis for Processing
If you are a resident in the above countries, we collect and process personal data about you when we have legal bases for doing so under applicable laws. The legal bases that we rely on are the following:
|
Purposes |
Lawful basis (as applicable) |
|
Collect your Personal Information to complete the registration and login process. Collect your Personal Information to maintain the normal operation of Apps and account security. Collect your Personal Information to provide customer service and to answer your inquiries. Collect your Personal Information to provide customization of content and marketing communications. |
“Your consent”, “The necessity of entering into and/or performing a contract” or “the legitimate interests” to provide the products and/or services as the lawful basis for processing Personal Information. |
|
Collect your Personal Data to complete top-up and payment process. |
“Performing a contract” as the lawful basis for processing Personal Information. |
|
Collect Personal Data of children to provide access to the use of our Services. |
“Parental or guardian consent” as the lawful basis for processing Personal Information of children. |
|
Collect your Personal Data to comply with regulatory, compliance, or legal obligations and/or requirements, or to assist law enforcement and government authorities as permitted or required by applicable laws and regulations. |
“The necessity for the performance of legal obligations” as the lawful basis for processing Personal Information. |