Last modified: [1 November], 2018
The provision of your Personal Information to us is generally voluntary, including your social media account information, which you can link for easy login. However, the provision of certain Personal Information, including information you make available to us when you open an account, such as your name, telephone number, email address (and, if you are obtaining a paid subscription, your credit card or other payment method details) is mandatory. Without such information, we will not be able to provide the Platform services to you.
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
In providing our services, we collect, store and use the following Information relating to you:
“Information” is Personal Information and Non-Personal Information;
"Personal Information" is any information or combination of information that relates to you, and can be used, directly or indirectly, to identify you. Personal Information may include the following:
“Location Data” is information that we collect regarding your location (when you use a location-enabled service), including:
“Non-Personal Information” is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.
“Shared Information” is information about you or relating to you that is voluntarily shared on our services, including postings that you make on our services (including your public profile, the lists you create), any postings from others that you re-post and including Location Data and Log Data associated with these postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.
HOW WE USE YOUR INFORMATION
We may use your Information for any of the following purposes:
Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through one of our services may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).
For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available.
Our service-specific privacy guidance may more particularly describe how we use Personal Information within the relevant services.
COOKIES, WEB BEACONS AND SIMILAR TECHNOLOGIES
We may use your Information (namely name, email address, WeChat ID, phone number) to try to offer advertising that is more relevant to you.
We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties with your consent (if required by applicable laws). Such products and services (of ours or third parties) include the following:
Once we commence using your Personal Information for marketing purposes in accordance with applicable laws, we will honor your request for us to not use your Personal Information for the marketing purposes noted above. If you wish to make such a request, please: (i) notify our Privacy Officer; (ii) follow the relevant instructions on our marketing communications; or (iii) follow the instructions as set out in certain service-specific guidance (in relation to the relevant service).
Please note that we will not share your Personal Information with advertisers unless you have given us your consent to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.
We will not share your Personal Information with third parties for gain.
SHARING OF YOUR PERSONAL INFORMATION
You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this "Sharing of your Personal Information" section.
A WORD ABOUT SHARED INFORMATION
A number of our services enable Shared Information to be shared publicly with all users of that service and not just your contacts. Our social media services in particular are primarily designed to help you share Shared Information with the world, so Shared Information can be broadly and instantly transmitted and will remain public for as long as you do not delete it (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us).
Please consider carefully what you post and communicate through our services.
COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use our services, we may use your Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
A WORD ABOUT SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.
We urge you to consider whether it is appropriate to communicate sensitive Personal Information within our services.
Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.
THIRD PARTY SERVICES ON OUR SERVICES
Our services may include, or they may link you to, social media or other services (including websites) provided by a third party. For example:
Children under the age of 13 are not allowed to use our services. We do not knowingly collect Personal Information from any children under the age of 13. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 and we will promptly investigate (and remove, if we have any) such Personal Information.
TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.
We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.
In some of our services, we will use encryption technology (such as SSL) to protect certain sensitive Information provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.
RETENTION OF YOUR PERSONAL INFORMATION
Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal Information” section above), we will only retain your Personal Information for so long as is necessary to fulfill the purposes as set out under the “How We Use Your Information” section above.
Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, or to request that we delete any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer. We will respond to all requests made to our Privacy Officer under this “Retention of your Personal Information” section within 60 days.
In addition, within some of our services, we may offer you options to amend or delete, and/or change how we and the public can view and/or access, your Personal Information and/or Shared Information within those services – in which case, please log into your account with us within the relevant service and make the appropriate changes.
Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through our services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using our services may put your Personal Information in the hands of third parties that we cannot control – for example, if you have previously made your Personal Information public via our services. In some instances, we may not be able to delete your Personal Information and/or Shared Information from our services or systems – in which case we will (where reasonably practicable) let you know why we are unable to do so.
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
Your consent (to use) and written consent (to transfer) of your Personal Information is required before we can use your Personal Information for direct marketing purposes. You can withdraw your consent to direct marketing at any time.