PRIVACY POLICY (for users living in EEA and Switzerland) Last updated: October 2020

 

INTRODUCTION
This Privacy Policy describes the information that Playfolly (“we”, “our,” or “us”) (see Contact Information below) collects from visitors to and users of www.playfolly.com(the “Website”) and any mobile application in relation to the Website (the “App”) (the Website and the App are collectively referred to as “Playfolly platform”) and how we use it, how we protect it, your choices regarding it and your rights.
PLEASE READ THIS PRIVACY POLICY AND THE TERMS OF USE CAREFULLY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF USE, DO NOT USE OR VISIT THE WEBSITE OR APP. BY USING OR VISITING THE WEBSITE OR APP, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF USE.
Capitalized terms, if not defined herein, shall have the meaning assigned to them in the Terms of Use.

 

CONTACT INFORMATION
If you have any questions about this privacy policy or our information-handling practices, please contact us at info@playfolly.com.

 

INFORMATION WE COLLECT ABOUT YOU
Personal information, means any information about an individual from which that person can be identified (“Personal Information”). We collect your Personal Information on the following grounds:

  • We need to process such information to deliver contractual services to you.

  • You consent to provide us when you create an account and use Playfolly platform.

  • We collect when we believe it is for our legitimate interests in order to provide you better experiences with Playfolly platform.

Information Needed for Contractual Services
We process the following Personal Information only as necessary to deliver contractual services as illustrated in the Terms of Use to you:

  • Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier; and

  • Payment information, such as bank account number, Paypal or other payment information where required for the purpose of payment.

Information You Consent to Provide
You consent to provide some or all of the following Personal Information when you create an account on the App or use Playfolly platform, such as uploading contents on the App or contact us for technical support:

  • Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;

  • User content (“CONTENT”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Playfolly platform;

  • Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Playfolly platform, but such data will only be processed offline to fulfil the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into deidentified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party;

  • Your social network contacts with your permission, when you activate the “Discover Friends” function and allow us to access your contacts;

  • our Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;

  • Your opt-in choices and correspondence with us, such as information used to verify your account or to resolve your feedbacks or complaints;

  • Information you provide when participating in in-app surveys and activities; and

  • Information you provide from such third-party social media when you create a Playfolly account by connecting with a third-party social media, such as Facebook, Instagram, Google, or if you link a Playfolly account with a third-party social media account.

 

Information We Collect for Improved User experience
We may collect some or all of the following Personal Information about you when you use Playfolly platform for legitimate interests:

  • Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed, and information regarding your interaction with other users;

  • Information about you from third-party service providers, such as advertising partners and data analytics providers;

  • Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address;

  • Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests 

  • Metadata, associating with the CONTENT you provided us, which describes other data and provides information about how, when, and by whom the piece of CONTENT was collected and how that CONTENT was formatted, such as hashtags used to label the keywords to the video and captions; and

  • Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Playfolly platform, enhance your experience using Playfolly platform, and provide you with targeted advertising on Playfolly platform and elsewhere across your different devices.

 

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, or to calculate ad impressions served or clicked on.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data).

 

HOW WE USE YOUR INFORMATION
We will only use your Personal Information when the applicable laws allow us to. In general, we use your Personal Information for following purposes:
Provision of services: to present Playfolly platform and its contents to you, including any interactive features on Playfolly platform, and to provide you with information, products or services that you allow us to; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with promotion activities;

  • Improvement of services: to improve and personalize our services by presenting new services, information, recommendations, and feedbacks;

  • Customer management: to manage a registered user’s account, to provide customer support and notices to the registered user about his account or subscription, and notices about changes to Playfolly platform or any other product or service we offer or provide through it;

  • Communication: to communicate and interact with you directly, such as that we may send notifications to you, notify you about upcoming changes, promotion activities or improvements on Playfolly platform, or contact you regarding any content that you have posted to or shared over Playfolly platform;

  • Content review: to review pictures, images and contents posted or generated on Playfolly platform to ensure that we comply with any applicable content regulations in any relevant jurisdiction;

  • Customization of content: to perform research and analysis about your use of, or interest in contents, products, advertising, or services available on Playfolly platform in order to develop and display content tailored to your interests on our Website and App;

  • Performance Analysis: to determine whether users of Playfolly platform are unique, or whether the same user is using Playfolly platform on multiple occasions, and to monitor aggregate metrics such as total number of visitors, number of videos viewed, demographic patterns;

  • Functionality and security: to identify users not meeting the age limit, to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;

  • Compliance: to enforce our terms of use and to comply with our legal obligations;

  • Aggregation: to aggregate information we collect about you to which one or more purposes described above due; and

  • Others: to provide you information which we may describe when your consent is provided separately from this privacy policy.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.


SHARING OR DISCLOSURE OF YOUR INFORMATION
We may disclose some of your Personal Information on the public page of your account, which may be accessible by other users, such as your gender, age and self-introduction.

  • We may share your Personal Information outside of Playfolly platform when we have your consent, either express or implied.

  • We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.

  • We may disclose your Personal Information to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, customization of content, analytics, security, map navigation, data storage and cloud services, supporting our functionality, and other features offered through Playfolly platform. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. However, if you connect to a third-party service through Playfolly platform or otherwise link your Playfolly account with a third-party service, you are requesting and authorizing us to share or grant access to information on your behalf with such third party. We may also send information about the content that you watched or your activities on Playfolly platform to such third party in order to upgrade your experience on Playfolly platform.

  • We may share your Personal Information with advertisers and third-party measurement organizations to understand to what extent the advertisement influences your behaviour on Playfolly platform. We may share mobile advertising identifiers that we collect with these advertising partners so that the mobile advertising identifiers will be used to push you ads that may interest you.

  • We may disclose or share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses it in a manner that is consistent with this privacy policy.

  • We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) comply with any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or other third parties; or (e) to maintain and protect the security and integrity of Playfolly platform or infrastructure.

  • We may disclose aggregated information about our users. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.

 

LINKS TO OTHER WEBSITES OR APPLICATIONS
When you click on a link to any other website, mobile application, or third-party content through Playfolly platform, you will go to another website or other mobile application and another entity may collect information from or about you. We have no control over, do not review, and cannot be responsible for, these third-party websites or mobile applications or their content. Please be aware that the terms of this privacy policy do not apply to these third-party websites or mobile applications or content, or to any collection of information after you click on links to these third-party websites, mobile applications or content.

 

SECURITY OF YOUR PERSONAL INFORMATION
We take appropriate administrative, technical, and physical security measures to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your Personal Information. You should use caution whenever submitting information through Playfolly platform and take special care in deciding which information you provide us with.
You are responsible for maintaining the secrecy of your password and account information at all times.

 

CHOICES REGARDING YOUR PERSONAL INFORMATION
You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note that your choice to disable cookies will be specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
You can at any time request to opt out from further allowing us to send you push notifications by adjusting the permissions in your mobile device.
You can switch off GPS location, Microphone, Camera or other similar functions on your mobile device if you do not wish to share them.
You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of Playfolly platform because such information may be required in order for you to register as a user; purchase Paid Services; participate in a promotion, survey, or sweepstakes; or make complaints.
You can change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings. For more information on how to change the advertising identifier privacy settings on your device, please visit http://www.networkadvertising.org/mobile-choice or http://youradchoices.com/appchoices.
You can make changes to your information, including accessing your information, correcting, or updating your information or deleting your information by editing your profile in the App.

 

YOUR RIGHTS
You have the following rights with respect to our collection of the Personal Information we collect about you. We will respond to your request consistent with the applicable laws as soon as practicable, normally within one month, after proper verification procedures. Your exercise of these rights is usually free of charge, unless we deem it is chargeable under the applicable laws. We WILL NOT DISCRIMINATE due to your exercise of any right to privacy.

 

Child Protection
Playfolly platform is not directed to children, and if you are under the age of 16 years old, you may not create a Playfolly account or use Playfolly platform. We have zero tolerance to any form of child abuse or exploitation. At the time of registering you are asked to consent that you are 16 years or older. Playfolly does not take responsibility for any wrong or misleading information provided by the user.
 
RETENTION
We will retain your Personal Information for as long as reasonably necessary for the purposes described in this privacy policy, while we have a legitimate business need to do so in connection with your account, or as required by laws (for example, for legal, tax, accounting or other purposes), whichever is the longer.
To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we use your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

NO ERROR FREE PERFORMANCE
We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential, or punitive damages relating to this privacy policy.

 

CHANGES TO OUR PRIVACY POLICY
We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at Playfolly platform so you are aware of any changes, as they are binding on you.
If we change anything in our privacy policy, the date of change will be reflected in the “last updated date”. You agree to note the date of the last revision to our privacy policy. By continuing to use Playfolly platform subsequent to us making available an amended version of our privacy policy in a way that you can easily take notice of it, you thereby consent to such amendment.

PRIVACY POLICY (for users domiciled in the U.S.) Last updated: October 2020

 

INTRODUCTION
This Privacy Policy describes the information that Playfolly (“we”, “our,” or “us”) (see Contact Information below) collects from visitors to and users of www.playfolly.com(the “Website”) and any mobile application in relation to the Website (the “App”) (the Website and the App are collectively referred to as “Playfolly platform”) and how we use it, how we protect it, your choices regarding it and your rights. 
PLEASE READ THIS PRIVACY POLICY AND THE TERMS OF USE CAREFULLY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF USE, DO NOT USE OR VISIT THE WEBSITE OR APP. BY USING OR VISITING THE WEBSITE OR APP, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF USE.
Capitalized terms, if not defined herein, shall have the meaning assigned to them in the Terms of Use.

 

CONTACT INFORMATION
If you have any questions about this privacy policy or our information-handling practices, please contact us at info@playfolly.com.

 

INFORMATION WE COLLECT ABOUT YOU
Personal information, means any information about an individual from which that person can be identified (“Personal Information”). We collect your Personal Information primarily from three sources:

  • You opt to provide us when you create an account and use Playfolly platform;

  • We obtain from third-party sources; and

  • We collect automatically when you use Playfolly platform.

Information You Opt to Provide
You may opt to provide some or all of the following Personal Information when you create an account on the App or use Playfolly platform, such as uploading contents on the App or contact us for technical support:

  • Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier and language;

  • Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;

  • User content (“CONTENT”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Playfolly platform;

  • Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Playfolly platform, but such data will only be processed offline to fulfil the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into deidentified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party;

  • Payment information, such as bank account number, Paypal or other payment information where required for the purpose of payment;

  • Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services;

  • Your social network contacts with your permission, when you activate the “Discover Friends” function and allow us to access your contacts;

  • Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;

  • Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedbacks or complaints; and

  • Information you provide when participating in in-app surveys and activities.

 

Information We Obtain from Third-Party Sources
we may obtain your Personal Information from several third-party sources on the following circumstances:

  • When you create a Playfolly account by connecting with a third-party social media, such as Facebook, Instagram, Google, or if you link a Playfolly account with a third-party social media account, we will use information from such third-party social media you provided us.

  • We may collect information about you from third-party service providers, such as advertising partners and data analytics providers.

 

Information We Collect Automatically
We may collect some or all of the following Personal Information about you automatically when you use Playfolly platform:

  • Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed, and information regarding your interaction with other users;

  • Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address;

  • Information regarding your access to and use of other apps;

  • Other location information, such as the information based on your SIM card;

  • Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests 

  • Metadata, associating with the CONTENT you provided us, which describes other data and provides information about how, when, and by whom the piece of CONTENT was collected and how that CONTENT was formatted, such as hashtags used to label the keywords to the video and captions; and

  • Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Playfolly platform, enhance your experience using Playfolly platform, and provide you with targeted advertising on Playfolly platform and elsewhere across your different devices. For more information about what cookies we use and how cookies help better your experience on the App, see our Cookie Policy.

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, to calculate the percentage of users accessing a specific website feature, or to calculate ad impressions served or clicked on.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data).

 

HOW WE USE YOUR INFORMATION
We will only use your Personal Information when the applicable laws allow us to. In general, we use your Personal Information for following purposes:

  • Provision of services: to present Playfolly platform and its contents to you, including any interactive features on Playfolly platform, and to provide you with information, products or services that you allow us to; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with promotion activities and sweepstakes;

  • Improvement of services: to improve and personalize our services by presenting new services, information, recommendations, and feedback;

  • Customer management: to manage a registered user’s account, to provide customer support and notices to the registered user about his account or subscription, and notices about changes to Playfolly platform or any other product or service we offer or provide through it;

  • Communication: to communicate and interact with you directly, such as that we may send notifications to you, notify you about upcoming changes, promotion activities or improvements on Playfolly platform, or contact you regarding any content that you have posted to or shared over Playfolly platform;

  • Content review: to review pictures, images and contents posted or generated on Playfolly platform to ensure that we comply with any applicable content regulations in any relevant jurisdiction;

  • Customization of content: to perform research and analysis about your use of, or interest in contents, products, advertising, or services available on Playfolly platform in order to develop and display content tailored to your interests on our Website and App;

  • Performance Analysis: to determine whether users of Playfolly platform are unique, or whether the same user is using Playfolly platform on multiple occasions, and to monitor aggregate metrics such as total number of visitors, number of videos viewed, demographic patterns;

  • Functionality and security: to identify users not meeting the age limit, to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;

  • Compliance: to enforce our terms of use and to comply with our legal obligations;

  • Aggregation: to aggregate information we collect about you to which one or more purposes described above due; and

  • Others: to provide you information which we may describe when your consent is provided separately from this privacy policy.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.

 

SHARING OR DISCLOSURE OF YOUR INFORMATION
Please note that though we will share or disclose your Personal Information in the limited circumstances described below, we WILL NOT SELL your Personal Information to any third party.

  • We may disclose some of your Personal Information on the public page of your account, which may be accessible by other users, such as your gender, age and self-introduction.

  • We may share your Personal Information outside of Playfolly platform when we have your consent, either express or implied.

  • We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.

  • We may disclose your Personal Information to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, customization of content, analytics, security, map navigation, data storage and cloud services, supporting our functionality, and other features offered through Playfolly platform. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. However, if you connect to a third-party service through Playfolly platform or otherwise links your Playfolly account with a third-party service, you are requesting and authorizing us to share or grant access to information on your behalf with such third party. We may also send information about the content that you watched or your activities on Playfolly platform to such third party in order to upgrade your experience on Playfolly platform.

  • We may share your Personal Information with advertisers and third-party measurement organizations to understand to what extent the advertisement influences your behaviour on Playfolly platform. We may share mobile advertising identifiers that we collect with these advertising partners so that the mobile advertising identifiers will be used to push you ads that may interest you.

  • We may disclose or share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses it in a manner that is consistent with this privacy policy.

  • We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) comply with any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or other third parties; or (e) to maintain and protect the security and integrity of Playfolly platform or infrastructure.

  • We may disclose aggregated information about our users. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.

 

TRANSFERS OF YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
By using Playfolly platform you consent to the transfer of information that we collect about you, including Personal Information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.

 

LINKS TO OTHER WEBSITES OR APPLICATIONS
When you click on a link to any other website, mobile application, or third-party content through Playfolly platform, you will go to another website or other mobile application and another entity may collect information from or about you. We have no control over, do not review, and cannot be responsible for, these third-party websites or mobile applications or their content. Please be aware that the terms of this privacy policy do not apply to these third-party websites or mobile applications or content, or to any collection of information after you click on links to these third-party websites, mobile applications, or content.

 

SECURITY OF YOUR PERSONAL INFORMATION
We take appropriate administrative, technical, and physical security measures to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your Personal Information. You should use caution whenever submitting information through Playfolly platform and take special care in deciding which information you provide us with.
You are responsible for maintaining the secrecy of your password and account information at all times.

 

CHOICES REGARDING YOUR PERSONAL INFORMATION
You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note that your choice to disable cookies will be specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
You can at any time request to opt out from further allowing us to send you push notifications by adjusting the permissions in your mobile device.
You can switch off GPS location, Microphone, Camera or other similar functions on your mobile device if you do not wish to share them.
You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of Playfolly platform because such information may be required in order for you to register as a user; purchase Paid Services; participate in a promotion, survey, or sweepstakes; or make complaints.
You can change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings. For more information on how to change the advertising identifier privacy settings on your device, please visit http://www.networkadvertising.org/mobile-choice or http://youradchoices.com/appchoices.
You can make changes to your information, including accessing your information, correcting or updating your information or deleting your information by editing your profile in the App.

 

YOUR RIGHTS
You may submit a request to access, modify or delete the Personal Information we collect about you by (a) using Help or Feedback function on Playfolly platform or (b) by sending your request to us via email at info@playfolly.com. We will respond to your request consistent with the applicable laws as soon as practicable after proper verification procedures. We WILL NOT DISCRIMINATE due to your exercise of any right to privacy.
If you are a California resident, you may request us to disclose the categories and specific pieces of Personal Information about you that we collect or share to any third party for commercial uses. You will need to send an email to info@playfolly.com if you wish to make such request, and format the subject line as Identification of Personal Information+Californian+Your Playfolly ID. We may ask you to go through a verification process, such as using your phone number and an instant pin, before we respond to your request. Please note that we will not be able to handle this kind of request if submitted through postal mail, telephone, or facsimile.
If you are a California resident, you may also request us to delete Personal Information that we have collected about you. You will need to send an email to info@playfolly.com if you wish to make such request, and format the subject line as Deletion of Personal Information+Californian+Your Playfolly ID. You will need to describe in your email what Personal Information you wish us to delete, and provide any supplementary information that helps us to locate such piece of Personal Information, such as the date you provided us with such piece of Personal Information and the specific content of such piece of Personal Information. We may ask you to go through a verification process, such as using your phone number and an instant pin, before we respond to your request. Please note that we will not be able to handle this kind of request if submitted through postal mail, telephone, or facsimile or if you fail to provide information in sufficient details to permit us to locate the Personal Information concerned. Further, we do not guarantee complete deletion of the Personal Information concerned given that it may already be shared or reposted by other users or third parties.
Users domiciled in California are encouraged to designate an authorized agent to exercise their rights of privacy on their half.

 

CHILDREN
Playfolly platform is not directed to children, and if you are under the age of 16 years old, you may not create a Playfolly account or use Playfolly platform. We have zero tolerance to any form of child abuse or exploitation. At the time of registering you are asked to consent that you are 16 years or older. Playfolly does not take responsibility for any wrong or misleading information provided by the user.

 

RETENTION
We will retain your Personal Information for as long as reasonably necessary for the purposes described in this privacy policy, while we have a legitimate business need to do so in connection with your account, or as required by laws (for example, for legal, tax, accounting or other purposes), whichever is the longer.
To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we use your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

NO ERROR FREE PERFORMANCE
We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential, or punitive damages relating to this privacy policy.

CHANGES TO OUR PRIVACY POLICY
We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at Playfolly platform so you are aware of any changes, as they are binding on you.
If we change anything in our privacy policy, the date of change will be reflected in the “last updated date”. You agree to note the date of the last revision to our privacy policy. By continuing to use Playfolly platform subsequent to us making available an amended version of our privacy policy in a way that you can easily take notice of it, you thereby consent to such amendment.

Privacy Policy (excluding the U.S., the EEA & Switzerland) Last updated: October 2020

 

INTRODUCTION
This Privacy Policy describes the information that Playfolly (“we”, “our,” or “us”) (see Contact Information below) collects from visitors to and users of www.Playfolly.com (the “Website”) and any mobile application in relation to the Website (the “App” or “Playfolly”)) (the Website and the App are collectively referred to as “Playfolly platform”) and how we use it, how we protect it, and your rights.
Playfolly does not intend to create account for users who are under the age of 16 years old or other age of majority as required by the laws of the country of your domicile. So please do not use Playfolly and Playfolly platform if you are under such age requirement.
BY ACCESSING OR USING PLAYFOLLY PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND THAT YOU UNDERSTAND YOUR RIGHTS IN RELATION TO YOUR INFORMATION AND HOW WE WILL COLLECT, USE AND PROCESS IT. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD NOT USE PLAYFOLLY PLATFORM.
Capitalized terms, if not defined herein, shall have the meaning assigned to them in the Terms of Use.
HOW WE COLLECT YOUR INFORMATION
In order to provide Playfolly platform, and improve the user experience and security of Playfolly platform, we will collect, record, store, adapt, use, share or otherwise process your personal information, when you register a Playfolly account and use Playfolly platform.
We collect your personal information on the following grounds:
1.    We need to process such information to deliver contractual services to you.
2.    You consent to provide us when you create an account and use Playfolly platform.
3.    We collect when we believe it is for our legitimate interests in order to provide you better experiences with Playfolly platform.
Information Needed for Contractual Services
We process the following personal information only as necessary to deliver contractual services as illustrated in the Terms of Use to you:

  • Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier; and

  • Information You Consent to Provide

You consent to provide some or all of the following personal information when you create an account on the App or use Playfolly platform, such as uploading contents on the App or contact us for technical support:

  • Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;

  • User content (“CONTENT”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Playfolly platform;

  • Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Playfolly platform, but such data will only be processed offline to fulfil the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into deidentified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party;

  • Your social network contacts with your permission, when you activate the “Discover Friends” function and allow us to access your contacts;

  • Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;

  • Your opt-in choices and correspondence with us, such as information used to verify your account or to resolve your feedbacks or complaints;

  • Information you provide when participating in in-app surveys and activities; and

  • Information you provide from such third-party social media when you create a Playfolly account by connecting with a third-party social media, such as Facebook, Instagram, Google, or if you link a Playfolly account with a third-party social media account.

Information We Collect for Legitimate Interests
We may collect some or all of the following Personal Information about you when you use Playfolly platform for legitimate interests:

  • Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed, and information regarding your interaction with other users;

  • Information about you from third-party service providers, such as advertising partners and data analytics providers;

  • Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services;

  • Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address;

  • Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests

  • Metadata, associating with the CONTENT you provided us, which describes other data and provides information about how, when, and by whom the piece of CONTENT was collected and how that CONTENT was formatted, such as hashtags used to label the keywords to the video and captions; and

  • Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Playfolly platform, enhance your experience using Playfolly platform, and provide you with targeted advertising on Playfolly platform and elsewhere across your different devices. For more information about what cookies we use and how cookies help better your experience on the App

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, or to calculate ad impressions served or clicked on.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data).

 

HOW WE USE YOUR INFORMATION
We use the information we collect about you for the following purposes:

  • to administer Playfolly platform (i.e. to provide Playfolly platform to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to guarantee Playfolly platform’ stability and security) and to solicit your feedback;

  • to allow you to participate in interactive features of Playfolly platform, when you choose to do so;

  • to personalize the contents that you receive and provide you with tailored content that will be of interest to you;

  • to provide you with user support and to improve, develop Playfolly platform and facilitate product development;

  • to use information that you provided us, such as pictures and video contents that you choose to upload or broadcast on Playfolly platform, as part of our advertising and marketing campaigns to promote Playfolly platform;

  • to measure and understand the effectiveness of the advertising we serve to you and others;

  • to provide you with services based on the country settings you have chosen, such as content pushing and other content that is related to the country settings;

  • to enable us and our advertising partners to provide ads that may be more relevant to your interests;

  • to make suggestions and recommendations to you and other users of Playfolly platform about goods or services that will interest you or them;

  • to allow other users to identify you via the "Discover Friends" function as a user of Playfolly platform, to allow you to find other users and to connect with them on Playfolly platform, and to support the socializing function of Playfolly platform;

  • to enable our messenger service to function and to communicated with you;

  • to help us detect abuse, fraud, and illegal activity on Playfolly platform;

  • to review pictures, images and contents posted or generated on Playfolly platform to ensure that we comply with any applicable content regulations in any relevant jurisdiction;

  • to enforce our terms, conditions, and policies; and

  • to comply with other applicable laws and regulations.

 

HOW WE SHARE YOUR INFORMATION
We may share your information with certain authorized third parties to assist in the improvement and optimization of Playfolly platform, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes, including but not limited to:

  • to our business partners so that we can improve Playfolly platform;

  • to third-party advertising partners so that they can deliver ads they believe are relevant to you in other third party apps 

  • to cloud storage providers to store the information you provide;

  • to analytics and search engine providers that assist us in the optimization and improvement of the user experience on Playfolly platform;

  • to IT service providers; and

  • to any member, subsidiary, parent, or affiliate of our corporate group.

Except for the above, we will not disclose or share with any third party your personal information, unless under the following circumstances:

  • if we obtained your consent, either implied or express;

  • if we are required to do so in order to comply with the applicable laws and regulations and government requests;

  • If we believe in our good faith that this is necessary to protect the public interest;

  • If it is necessary to do so to protect the safety and fundamental rights of another person;

  • If it is necessary to address fraud, security, or technical issues; and

  • If it is necessary to ensure the enforcement of our terms and conditions and the daily operation of Playfolly platform.

 

YOUR RIGHTS
Pursuant to the applicable laws and regulations of the jurisdiction where you reside, you may have some or all of the following rights:

  • access and update certain personal information that you have provided with us by logging into your Playfolly account and using the features and functionalities available there;

  • You can change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings; and

  • rectify and delete your personal data retained on Playfolly platform

 

HOW WE TRANSFER YOUR INFORMATION
We maintain servers around the world and your information collected by us are firstly stored and processed in servers nearest to your region, but in several cases your information may be stored and processed in any other country where we maintain data collection facilities. We have complied with relevant applicable data localization rules with respect to our data transfer practices. We take appropriate steps to ensure that the information we collected is processed in accordance with the privacy policy and the relevant applicable laws and regulations. If we provide any information about you to any legal agency, we will take appropriate measures to ensure such receiving institutes protect your information adequately in accordance with this privacy policy and the applicable laws.

 

HOW LONG WE KEEP YOUR INFORMATION
We use the following criteria to determine the period for which we will keep your information:

  • our contractual obligations and rights in relation to the information involved;

  • obligation(s) under the applicable laws and regulations to retain data for a certain period of time;

  • statute of limitations under the applicable laws;

  • our reasonable business purposes; and

  • disputes or potential disputes.

We retain your information for as long as it is necessary to provide you with Playfolly platform so that we can fulfil our contractual obligations and rights in relation to the information involved, or for other legitimate purpose such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs vary for different type of information, the context of our interactions with you or your use of Playfolly platform result in different retention periods for different type of information. Where we do not need your information in order to provide Playfolly platform to you, we retain it only for so long as we have a reasonable business purpose in keeping such data.

 

HOW TO MANAGE YOUR INFORMATION
The privacy settings allow you to control whether or not to share certain information and whether you wish to entertain certain functions.
You may download and save the short videos or sound tracks you have shared through Playfolly platform. If you need to download the short videos or sound tracks you uploaded on a massive basis (more than 100 files), you may email us for help.
You may also delete your account. To delete your account, you may use the “Delete Account” function available at Setting or email us indicating in English that you would like to delete your account, after which you will receive instructions from us. You will need to follow our instructions in order to delete your account. Once your account is deleted, you will not be able to restore your account and all your historical data on Playfolly platform will be deleted after certain period of time (usually within 24 months), expect for certain behavioural data which will be anonymized for statistical research.
Note that certain third parties may retain copies of your information even after your Playfolly account has been deleted.

 

SECURITY OF YOUR INFORMATION
We take appropriate administrative, technical and physical security measures to safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your personal information. You should use caution whenever submitting information through Playfolly platform and take special care in deciding which information you provide us with.
You are responsible for maintaining the secrecy of your password and account information at all times.

 

CHILDREN PROTECTION
Playfolly platform is not directed to children, and if you are under the age of 16 years old, you may not create a Playfolly account or use Playfolly platform. We have zero tolerance to any form of child abuse or exploitation. At the time of registering you are asked to consent that you are 16 years or older. Playfolly does not take responsibility for any wrong or misleading information provided by the user.

 

MODIFICATIONS
We may amend any of the terms of the privacy policy by posting the terms. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of Playfolly platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using Playfolly platform.

 

CONTACT INFORMATION
If you have any questions about this privacy policy or our information-handling practices, please contact us at info@playfolly.com.