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Privacy Policy

Privacy Policy

Privacy Policy

Introduction

This is the Privacy Policy of BuddIn and its various & next versions including BuddIn APP version (hereinafter collectively referred to as "BuddIn", "us", "we", or "our") and is incorporated into and is subject to our Terms of Use. In this Privacy Policy (the “Policy”), we refer to our products and services as the "Service".

BuddIn has always solemnly promised to protect the privacy of users who use our products and service (collectively “user” or “you”). When you use the Service, we may collect and use your personal data. The protection of your personal data is of great importance to us. This Policy therefore intends to inform you about how BuddIn, acting as data controller, collects and processes your personal data (or referred to as “personal information”) that you submit or disclose to us. We may also act as data processor when we process your personal data received or obtained through third parties.

We encourage you to read this Policy carefully (especially the contents highlighted in bold or underlined) before using the Service to make the appropriate choice. If you do not agree to this Policy, please do not register, log in, visit or use the Service, and do not provide us with your personal data. If you do not wish certain kinds of your personal data to be used by us as set out in this Privacy Policy, please note that in such a case, we may not be able to provide you with the corresponding parts of our services, you may not have access to and/or be able to use some features of our services, and your customer experience may be impacted. When you agree to all terms and conditions hereof this Police, you agree that we will deal with your personal information in accordance with this Policy.

After reading this Policy, if you have any questions about this Policy or matters related hereto, you can contact us through the feedback channels listed in Section XI "How to Contact Us" , and we will give you an answer as soon as possible.

I. Personal Data that We May Collect

We encourage you to read this Policy carefully (especially the contents highlighted in bold or underlined) before using the Service to make the appropriate choice. If you do not agree to this Policy, please do not register, log in, visit or use the Service, and do not provide us with your personal data. If you do not wish certain kinds of your personal data to be used by us as set out in this Privacy Policy, please note that in such a case, we may not be able to provide you with the corresponding parts of our services, you may not have access to and/or be able to use some features of our services, and your customer experience may be impacted. When you agree to all terms and conditions hereof this Policy, you agree that we will deal with your personal information in accordance with this Policy.

After reading this Policy, if you have any questions about this Policy or matters related hereto, you can contact us through the feedback channels listed in Section XI "How to Contact Us", and we will give you an answer as soon as possible.

II. How Will We Collect and Use Personal Information

We Will Collect and Obtain Your Information through the Following Ways

1. Information provided by you. For example:

(1) Information provided by you when you register an account for the Service or use BuddIn;

(2) Sharing information provided by you to other users through the Service, and information saved when you use the Service.

Please note that if you upload, post or make your information public in a public area visible to other users or in response to other users, such your information may be collected and used by other users. When you find that other users improperly collect or use information from you or others, please contact us as guided in Section XI “How to Contact Us” below.

Your information shared by other users, also sharing information about you provided by other users when they use the Service.

Your information obtained by us. The information collected, summarized and recorded by us when you use the Service, such as log information, location information and device information.

(3) We Will Collect and Use Your Information for the Following Purposes

Help you to complete the registration and login

In order for us to provide the Services for you, you need to provide basic registration or login information, such as mobile phone number (personally sensitive information), verification code matching results (personally sensitive information), nickname, gender, date of birth, and profile picture etc., used to create an account (username and password).

You can also log in BuddIn using our supported third-party platform accounts, and in such cases we will obtain the relevant information about you (such as your nickname, avatar) under the third- party account according to your authorization.

Your above personal data provided by you or obtained by us from your third-party platform account under your authorization, is therefore processed for these purposes in order to provide you with and perform the Service based on your engagement with us. Without this personal data, we are not able to provide you with our services, and you will not be able to log in or use BuddIn.

You may also fill in your additional information (such as your location, height, occupation, weight, education, annual income, profile, personal label, interests and hobbies) during registration, login or subsequent use, which will help us to provide personalized recommendations and better service experience for you. However, if you do not provide this information, it will not affect your use of the basic functions of our product and the Service. 

2. Implement Real Person Verification

In order for us to verify you are a real person, and to guarantee the security of system, service and users' property, you need to provide your real person verification information, in accordance with relevant laws, regulations and regulatory requirements that are applicable.

For example, when you reply to a private message, use the voice/video calling services, you may need to provide your profile photo (personal sensitive information) and your personal photos of specified actions instructed by us (personal sensitive information). We will make the photo comparison to complete the real person verification (hereinafter referred to as "Real Person Verification").

Please note that your profile photo, real person photo belongs to your sensitive personal information. Please be careful to provide them. If you do not agree to provide such information, you may not be able to obtain relevant services, but it does not affect your normal use of other functions and services of BuddIn. 

3. Provision of Search Services

When utilizing the search function in BuddIn, we collect your search queries, browsing history, duration of browsing, and interaction frequency. This information enables us to provide relevant content and services that align with your interests.

4. Provision of Interaction and Content Sharing Services

When you use BuddIn to upload, post, or share content—including text, comments, audio, video, images, or other materials—or engage in activities such as following users or sending virtual gifts, we collect and display the content you create within BuddIn. Additionally, your nickname and avatar may be displayed. 

(1) Content Upload and Verification

When you upload a profile picture, complete real-person verification, record an audio bio, or post updates—including text, images, audio, video, or other content—we will request access permissions for your microphone, camera, photos, and storage. We collect the audio, video, images, text, and other materials you provide through these functionalities. If you choose not to grant these permissions, certain services may be unavailable; however, this will not impact your access to other core features of BuddIn.

Please note that uploaded audio, photos, and videos may contain sensitive personal information. Exercise caution when sharing such content. Additionally, if your uploaded content includes personal information of others, you must obtain their consent before posting.

 (2) User Interactions and Engagement

When you follow other users or interact with their content—such as liking, commenting, or sharing—we collect data on the accounts you follow and provide you with updates from those accounts. Likewise, we record your interactions, including likes, comments, and shared content, and may display or notify relevant users within BuddIn.

(3) Virtual Gift Transactions

When you send virtual gifts to other users using in-app currency, we collect and display your profile picture, nickname, and gift transaction details to the recipients.

 (4) Location-Based Services

To recommend nearby users and provide personalized content, we may request access to your location data (a category of sensitive personal information). If you grant this permission, we will collect and display your location to other users. You may disable location sharing at any time, after which we will cease collecting or displaying your location data.

 5. Provision of Customer Service and User Response Service

In the circumstance where you make contact with us for the purposes of availing customer service or submitting user responses, which can cover a wide range of aspects such as inquiries, feedback, suggestions, and complaints among others, we are entitled to request that you supply us with indispensable personal information. The primary aim of this request is to conduct the matching and verification of your user identity, thereby guaranteeing the security not only of your individual account but also of the entire system.

 We may retain various types of information, including but not limited to your communication or call records, the content of conversations, and the contact information you have provided. The retention of such information serves multiple legitimate purposes. It enables us to establish effective communication with you, offer assistance in resolving any issues you may encounter, and document the resolutions and results associated with the relevant matters.

Your personal data is processed with these specific intentions in order to deliver and implement the services in strict accordance with the terms of our engagement with you. Additionally, this personal data may also be processed to protect and uphold your legitimate rights and interests in obtaining relevant information and other related data that pertains to the services you receive from BuddIn.

6. Provision of Information Display and Recommendation Service

We may make use of your information, which might encompass your interests and hobbies, personality descriptors, browsing and search histories, device specifications, usage behaviors, location details, order information (when applicable), and various combinations thereof. Through the application of sophisticated recommendation algorithm modeling, programming methodologies, advertising frameworks, user behavior analytics, and user profiling techniques, we will extract in-depth insights regarding your browsing and search inclinations, behavioral patterns, and location-based information. The overarching objective of these endeavors is to present you with more customized page displays that are precisely tailored to meet your specific needs and to recommend personalized content that aligns with your preferences.

7. Notification Push Service

When it is considered essential and appropriate, we may dispatch notifications to you that are directly related to the services we offer. For example, in situations where we are compelled to suspend, modify, or discontinue the provision of a particular service due to system maintenance or other legitimate reasons.

In the event that you no longer desire to receive the messages that we have pushed to you, you have the prerogative to submit a request to us to halt the pushing of such messages. For instance, in accordance with the established SMS unsubscribe protocols, you may formally request us to cease sending promotional SMS messages. Alternatively, you can configure your mobile devices to block messages originating from us. However, it should be noted that this exemption does not apply when we are legally obligated to send messages in strict compliance with the provisions of relevant and applicable laws and regulations. 

8. Provision of Security Services

In addition to the authentication procedures that are in place, we may utilize your information for a variety of purposes, including customer service support, security safeguarding and control measures, fraud detection and monitoring, data archiving, and backup operations. The ultimate goal of these actions is to ensure the security and integrity of the services that we provide to you.

We may employ or integrate the information that we have collected directly, as well as the information that our partners have obtained either with your explicit authorization or through legal information sharing mechanisms. This comprehensive and holistic approach empowers us to conduct a thorough assessment of your account and transaction risks, carry out identity verification procedures, detect and prevent potential security incidents, and take all necessary actions such as record-keeping, auditing, analysis, and appropriate disposal of relevant data in strict accordance with the law.

 Your personal data is processed with these specific purposes in mind to safeguard and protect your legitimate rights and interests. This ensures the security of your connection to our platform and the protection of your personal data throughout the entire process of your accessing information and availing services from BuddIn.

9. Provision of Customer Service and User Response Service

In the event that you reach out to us for customer service or user response purposes, which may encompass inquiries, feedback, suggestions, complaints, and the like, we reserve the right to request that you furnish us with essential personal information. This is aimed at matching and verifying your user identity, thereby ensuring the security of your account and the system as a whole. We may retain information such as your communication or call history, conversations, or the contact details you have provided. Such retention serves the purposes of enabling us to communicate with you, assist you in resolving issues, or document the resolutions and outcomes of the relevant matters.

Your personal data is processed for these specific objectives to provide and execute the services in accordance with our engagement with you. Moreover, this personal data may also be processed to safeguard your legitimate rights and interests in obtaining relevant information and other associated data pertaining to the services you receive from BuddIn.

10. Provision of Information Display and Recommendation Service

We may utilize your information, which may include your interests and hobbies, personality tags, browsing and search histories, device information, usage habits, location information, order information (if applicable), and combinations thereof. Through the application of recommendation algorithm modeling, programming techniques, advertising models, user behavior analysis, and user profiling, we will extract insights regarding your browsing and search preferences, behavioral patterns, and location information. This is done with the intention of presenting you with more page displays that are tailored to your needs and recommending personalized content.

11. Notification Push Service

When deemed necessary, we may send you notifications related to the services. For instance, in situations where we suspend, modify, or discontinue the provision of a particular service due to system maintenance.

Should you no longer wish to receive the messages that we have pushed, you have the option to request us to cease the push. For example, in accordance with the SMS unsubscribe procedures, you may ask us to stop sending promotional SMS messages or configure your mobile devices to block messages from us. However, this exclusion does not apply when we are required to send messages in compliance with the provisions of relevant applicable laws and regulations.

12. Provision of Security Services

In addition to the authentication process, we may utilize your information for customer service, security prevention and control, fraud monitoring, archiving, and backup purposes. This is to ensure the security of the services we provide to you. We may employ or integrate the information collected by us, as well as the information obtained by our partners with your authorization or through legal sharing mechanisms. This comprehensive approach enables us to assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary actions such as record-keeping, auditing, analysis, and disposal in accordance with the law.

Your personal data is processed for these purposes to safeguard your legitimate rights and interests, ensuring the security of your connection and the protection of your personal data during the process of your obtaining information and services from BuddIn.

13. Enhancement of Our Services

We may invite you to participate in surveys regarding the Service to assist us in enhancing existing features or developing new functionalities. Additionally, we may utilize your information for software updates. The processing of this personal data serves our legitimate interest in improving our services accordingly.

14. Utilization of Anonymized Information

You acknowledge and agree that, in certain instances, upon the collection of your information, we will employ technical measures to de-identify and fully anonymize the data, ensuring that it no longer constitutes personal data directly or indirectly linked to an individual, such as yourself. This de-identified data will not identify or be associated with you. Under such circumstances, we reserve the right to analyze and commercialize the anonymized user database.

Should we intend to use your information for purposes not specified in this Policy, we will seek your prior consent through on-screen prompts, interactive processes, website announcements, or other means. Upon your agreement, such additional usage of your information will be incorporated into and governed by this Policy 

15. Notification Regarding Permissions for Specific Functions

You acknowledge and agree that we may request certain access permissions on your device to collect and utilize information related to specific functions and services, including but not limited to:

(1) With your explicit consent, we may access your device's storage to enable caching, downloading, and saving of content. 

(2) With your explicit consent, we may access your device information for unique identification purposes, allowing us to provide personalized content and recommendations tailored to your preferences, assess product suitability, detect abnormal conditions, and ensure network and service security.

Regarding permissions related to accessing albums/camera, contact lists, microphone, location, and calendar (including reading and writing), most mobile devices allow users to revoke such permissions. Please refer to your device manufacturer or service provider for further details. When you grant any permissions, you authorize us to collect and use the corresponding information to deliver relevant services. If you withdraw a given permission, your authorization will terminate, and we will cease collecting and using the relevant data, thereby discontinuing the provision of associated services. However, the collection and usage of data conducted under your prior authorization will remain unaffected.

16. Exceptions to Authorization Requirements

In accordance with applicable laws and regulations, the collection of your information does not require prior authorization under the following circumstances:

(1) Compliance with obligations under applicable laws and regulations;

(2) Protection of public safety, public health, and significant public interests;

(3) Criminal investigations, prosecutions, trials, and enforcement of judicial decisions;

(4) When obtaining your consent is impractical for safeguarding critical legal rights and interests, including the protection of life and property of the data subject or other individuals;

(5) Information that you have voluntarily disclosed to the public;

(6) Information obtained from publicly available sources, including legitimate news reports and government disclosures;

(7) When necessary for the execution of a contract at your request;

(8) When required to maintain the security and stability of the Service, including identifying and resolving product or service malfunctions;

(9) When necessary for legitimate news reporting;

(10) When necessary for academic research institutions conducting statistical or academic studies in the public interest, provided that any externally published research findings or descriptions contain de-identified data;

(11) Other circumstances as stipulated by applicable laws and regulations. 

17. Special Notice Regarding Personal Sensitive Information

Personal sensitive information refers to any personal data that, if disclosed, illegally provided, or misused, could jeopardize personal and property security, damage personal reputation, impact physical and mental well-being, or lead to discriminatory treatment.

Examples of sensitive personal information include, but are not limited to, identification card numbers, biometric data (such as facial recognition features and voice prints), bank account details, contact lists, communication records and content, property-related information (including virtual assets, virtual currency, and virtual transactions), location data, web browsing history, health and physiological information, and transaction details.

Please exercise caution when handling your sensitive personal information. By using our services, you consent to our processing of your sensitive personal information in accordance with this Policy.

III. Use of Cookies and Similar Technologies

BuddIn, along with our third-party partners, may collect and process your information through Cookies and Web Beacons, storing such information as log data.

Cookies enable us to offer users a streamlined, personalized web experience. A Cookie is a small piece of data sent from a web server to your browser and stored on your computer’s hard drive. We utilize Cookies to enhance user experience. For instance, to expedite the login process within the BuddIn virtual community, you may opt to save your username in a Cookie, allowing for quicker and more convenient access to our services in subsequent sessions. Cookies also help us analyze the web pages and content you interact with, the duration of your engagement with certain services, and the specific services you choose to use.

Cookies enhance our ability to serve you efficiently and personalize your experience within our services. However, you have the ability to control whether and how Cookies are accepted by your browser. Please refer to your browser’s documentation for details on managing Cookie preferences. 

BuddIn and our third-party partners may use Cookies and Web Beacons to collect and store data for the following purposes:

(1) Identity Recognition – Cookies and Web Beacons assist in identifying you as a registered user or in saving your preferences and other information you provide to us.

(2) Usage Analysis – We use Cookies and Web Beacons to understand how users interact with our services, identifying the most popular features and activities. Where required, we will seek your consent before utilizing Cookies and Web Beacons for analytical purposes.

(3) Advertising Optimization – Cookies and Web Beacons enable us to provide you with tailored advertisements based on your interests rather than generic ads. Where necessary, we will seek your consent before using Cookies and Web Beacons for advertising purposes.

While we employ Cookies and Web Beacons for these objectives, we may aggregate the collected data and share it with advertisers and partners to analyze service usage and optimize advertising strategies. 

Additionally, third-party advertisers and partners may place Cookies, Web Beacons, and similar technologies within the Service. These technologies may collect information about you to analyze user engagement, deliver relevant advertisements, or assess advertising effectiveness. The collection and usage of such data by third parties are governed by their respective privacy policies and not this Policy. BuddIn assumes no responsibility for third-party Cookies, Web Beacons, or similar technologies.

You can manage or reject Cookies and Web Beacons via your browser settings (if accessing the Service through a web browser) or through user preference settings. However, please note that disabling Cookies or Web Beacons may impact your user experience, and certain services may not function as intended. You will still receive advertisements, but their relevance to your interests may be reduced.

IV. Information Sharing, Transfer, and Disclosure

(1) Sharing

Except in the following circumstances, we will not share your information with any third party other than BuddIn without your consent:

a. Provision of Services: We may share your information with our partners and other third parties to facilitate core functions or deliver the services you require, such as payment processing and data services.

b. Service Maintenance and Improvement: We may share your information with our partners and third parties to enhance service quality and provide you with more tailored experiences. For instance, communication service providers may send notifications on our behalf.

c. Purpose Fulfillment: We may share your information to fulfill the objectives outlined in Section II, "Collection and Use of Personal Information."

d. Contractual and Policy Compliance: Sharing may occur to fulfill our obligations under this Policy or other agreements between you and BuddIn and to enforce our rights.

e. Marketing and Promotions: We may share aggregated, non-identifiable data with third-party partners who commission us for promotional activities. Such data includes metrics on promotional reach and effectiveness, but not personally identifiable details such as name, phone number, or email address. For example, we may inform third parties about the number of users who viewed their promotions or purchased products following an interaction with their advertisements. Any shared data will be anonymized to prevent personal identification.

f. Legal Compliance and Security Measures: To the extent permitted by applicable laws and regulations, we may exchange information with other companies and organizations to comply with legal requirements, protect BuddIn, our affiliates, partners, users, or the public from harm, prevent fraud, or mitigate credit risk. This excludes any sale, lease, or unauthorized disclosure of information for profit, which would violate our commitments under this Policy.

g. Dispute Resolution: We may share your information to assist in resolving disputes or controversies upon your lawful request.

h. Guardian or User Requests: Your information may be shared in response to legitimate requests from you and/or your legal guardian.

i. Service Agreements: Sharing may be conducted under individual service agreements signed with you, including electronically signed contracts and corresponding platform regulations.

j. Academic Research: We may provide data for academic research purposes.

k. Public Interest Compliance: We may share information when required for social and public interest reasons, in compliance with applicable laws and regulations.

We only share information for legitimate, justified, necessary, specific, and explicit purposes. Entities receiving shared data must adhere to strict confidentiality agreements and process information in compliance with our instructions, this Policy, and other applicable security and confidentiality standards. 

(2) Transfer

a. Business Transactions: In the event of a merger, acquisition, asset transfer, or similar corporate transaction, your information may be transferred as part of the business transition. The receiving entity must comply with this Policy. Otherwise, we will seek your authorization before proceeding with the transfer.

b. User Consent: We may transfer your information to third parties with your explicit consent. 

(3) Disclosure

 We will only disclose your information under the following conditions while adhering to industry-standard security measures:

a. User-Requested Disclosure: We will disclose specified information in the manner explicitly requested by you.

b. Legal and Regulatory Compliance: If disclosure is required under applicable laws, regulations, administrative enforcement, or judicial directives, we will provide only the necessary information and in the required manner. Upon receiving such requests, we will verify the validity of legal documents such as subpoenas or investigation orders and ensure transparency to the extent permitted by law. Requests will be carefully reviewed to confirm their legality and necessity, ensuring that only the required data is disclosed for legitimate legal purposes.

 V. Exceptions to Authorization Requirements

Under applicable laws and regulations, the following circumstances do not require prior authorization for information collection, sharing, transfer, or disclosure: 

(1) Public Safety and Interest: When directly related to national security, public health, or significant public interests.

(2) Legal Investigations and Proceedings: When related to criminal investigations, prosecutions, trials, or the enforcement of judicial rulings.

(3) Protection of Legal Rights: When necessary to protect critical legal rights and interests such as life and property, where obtaining your consent is impractical.

(4) Publicly Disclosed Information: When information has been voluntarily disclosed by you to the public.

(5) Legally Available Sources: When information is collected from publicly available, legally authorized sources, such as news reports and governmental disclosures.

(6) Legal and Regulatory Obligations: When required to fulfill obligations under applicable laws and regulations.

(7) Other Legally Permissible Circumstances: As permitted under relevant legal provisions.

According to applicable laws and regulations, the sharing, transfer, or public disclosure of de-identified personal information—where the recipient cannot re-identify the natural person—does not constitute personal data processing. We may store and process such de-identified data without prior notice or user consent.

VI.  How We Retain, Store, and Protect Your Information

We retain your information only for the duration necessary to fulfill the purposes outlined in this Policy and within the timeframe mandated by applicable laws and regulations. If we terminate the Service, we will promptly cease collecting your personal information in accordance with relevant legal requirements. Following the termination of the Service, we will delete or anonymize your personal information, except where applicable laws, regulations, or regulatory authorities require otherwise.

 The information we collect and generate within the Service is stored in Singapore. By using this Policy, you authorize us to store and transfer your personal information across borders. We are committed to ensuring that your personal information remains adequately protected in compliance with this Policy and applicable laws and regulations. To safeguard your information, we implement the following measures:

 (1) Data Security Technological Measures

We adopt industry-standard security measures, including the establishment of robust system specifications and security technologies, to prevent unauthorized access or modification of your information, as well as to mitigate the risk of data loss or damage. For instance, in certain services, we employ encryption technologies (such as SSL) to store and protect your information and utilize isolation technologies to enhance security. Additionally, when processing information (e.g., displaying or computing information), we apply various data desensitization techniques and enforce strict data access controls, including multi-factor authentication, to prevent unauthorized use.

 (2) Additional Security Measures to Protect Information

We regulate the storage and utilization of information by establishing a hierarchical data classification system, security management policies, and development security standards. A comprehensive data security control system is enforced through access confidentiality agreements, monitoring, and auditing mechanisms. We also emphasize security awareness by conducting training programs on privacy and security protection to enhance employees’ understanding of the importance of safeguarding information.

 (3) Access Control and Confidentiality Obligations

Access to your information is restricted to employees and partners who require it for operational purposes. Strict access control and monitoring mechanisms are in place to enforce this restriction. Additionally, all personnel with potential access to your information are bound by confidentiality obligations. Any failure to comply may result in legal liability or termination of cooperation with BuddIn V.

 (4) Minimization of Data Collection

We take all reasonable and practical steps to ensure that we do not collect unrelated or excessive information.

 (5) Security of Communications and Online Environment

The internet is not an entirely secure environment, and communication methods such as email, instant messaging, and social media may not be fully encrypted. We advise you to use complex passwords and exercise caution when sharing personal information through these channels.

 Although we strive to protect your data, the online environment is not 100% secure. In the event of unauthorized access, disclosure, alteration, or destruction of information due to a breach of our security infrastructure, we will assume legal responsibilities as required by applicable laws.

 (6) Incident Response and Security Breaches

When interacting with third parties via the Service, your information may be disclosed to the recipient or potential counterparties. Please ensure that you only share your information when necessary. 

To mitigate risks such as data breaches, loss, or compromise, we have implemented systems that define security incident classification standards, vulnerability assessments, and corresponding response procedures. We maintain a dedicated emergency response team to handle security incidents by initiating mitigation plans, conducting forensic analysis, implementing remedial measures, and collaborating with relevant authorities for resolution. 

In the unfortunate event of a security breach, we will promptly notify you in compliance with applicable laws and regulations. This notification will include details of the incident, potential impact, remedial actions taken, and recommendations to minimize risk. If direct notification is not feasible, we will issue a public announcement through appropriate channels. Furthermore, we will report the incident to regulatory authorities as required.

(7) Your Role in Protecting Your Information

While we implement stringent security measures, technical limitations and unforeseen circumstances may impact the security of your information. The communication systems and networks you use to access the Service may also encounter issues beyond our control. We urge you to safeguard your account credentials, passwords, and other identity verification details. Unauthorized disclosure of such information may lead to losses. If you suspect or detect any security vulnerabilities or breaches, please contact us immediately as outlined in Section X, "How to Contact Us," so we can take timely and appropriate measures to mitigate potential damages.

VII. How to Manage Your Information

(1) Access, Rectification, Update, Objection, and Deletion

We encourage you to rectify, update, and modify your information to ensure its accuracy and effectiveness. You may access and manage your information independently through the Service or request that we make modifications, supplements, or deletions on your behalf. We employ appropriate technical measures to facilitate your ability to access, update, correct, and delete your personal information or any other data provided or generated during your use of the Service to the greatest extent possible. 

To safeguard your information, we may require identity verification before allowing access, updates, corrections, or deletions. Upon receiving a request to access, update, correct, or delete your personal data, we will assess whether any applicable laws or exceptions permit us to deny the request and will inform you of our decision accordingly.

Regarding information collected via COOKIES, we provide details on available user controls in Section III, "How We Use COOKIES and Similar Technologies." To search, modify, or delete specific information, please log into your BuddIn. account to perform the necessary actions. If you have any inquiries or requests related to accessing, rectifying, updating, modifying, or deleting your data, you may contact us as described in Section X, "How to Contact Us."

Unless otherwise mandated by applicable laws and regulations, when you correct or delete personal information or request account cancellation, relevant information may not be immediately removed from backup systems. However, we will ensure the deletion or correction of such information upon the next backup update. 

(2) Publishing and Sharing

The Service enables you to share information not only within your social network but also with all users. This includes content you upload or post, responses to others' posts, personal information shared in publicly accessible areas, location data, and log information associated with such data. Unless deleted by you, shared content may remain publicly available. Even if deleted, such content may be cached, copied, or saved by other users or third parties beyond our control, or otherwise retained in public domains.

If your publication or sharing of information results in its disclosure, we disclaim liability. Therefore, we strongly advise you to carefully consider whether to publish or share information through the Service.

(3) Account Cancellation

Subject to the conditions set forth in the service agreement and applicable laws and regulations, your account for the Service may be canceled or deleted. Once an account is canceled or deleted, all related service data and information will be either deleted or processed in accordance with the BuddIn V. service agreement. You may complete the cancellation process by following the guidance provided in the relevant operational section of BuddIn.

(4) Modifying the Scope of Your Consent

While some information is essential for using the Service, most data collection depends on your consent. Where personal data processing is consent-based, you may decide whether to disclose such information. You can modify the scope of your consent or withdraw it by deleting information, disabling device functions, or using other available methods. You may also withdraw consent by contacting us as outlined in Section X, "How to Contact Us."

 Upon withdrawing consent, we will cease to provide the corresponding service and will not process the related information. However, your withdrawal does not affect prior data processing activities conducted based on your consent.

 (5) Guidelines for Sensitive Information

Certain information is considered sensitive due to its nature, including but not limited to race, religion, health records, medical data, identification documents, biometric data, financial details, location history, and information about minors.

Please be aware that content you provide, upload, or post on the Service (such as images or details about your social activities) may inadvertently reveal sensitive information. Carefully consider whether to disclose such information. By doing so, you explicitly consent to our processing of this sensitive data in accordance with this Policy. 

(6) Restrictions on Automated Decision-Making

In certain business functions, we may rely on automated decision-making mechanisms, such as algorithms and information systems. If such decisions significantly affect your rights and interests, you may request an explanation, and we will provide appropriate remedies.

For security purposes and to process such requests, we may require a written application and identity verification. Reasonable requests will not incur charges; however, repetitive or excessive requests may be subject to a fee. We may deny requests that are unduly repetitive, require disproportionate technical effort (such as developing a new system or significantly altering existing processes), risk others’legitimate interests, or are highly impractical (e.g., involving backup data stored on tapes). 

Circumstances Under Which We Cannot Fulfill Your Request

a. We may be unable to comply with your request under the following conditions:

b. When fulfilling the request would violate applicable laws and regulations.

c. When the request is directly related to national security, public health, or significant public interests.

d. When the request is linked to criminal investigations, prosecutions, trials, or enforcement of judgments.

e. When there is sufficient evidence to suggest that the request is made with malicious intent or constitutes an abuse of rights.

f. When fulfilling the request would compromise the life, property, or other significant legal rights of you or others, and obtaining your consent is impractical 

g. When fulfilling the request would cause serious harm to your own or others’ legitimate rights and interests.

h. When the request pertains to trade secrets. 

i. When other applicable legal and regulatory exceptions apply.

 VIII. Services Provided by Third Parties

The BuddIn service may include links to social media platforms or other services provided by third parties (including websites and other forms of services), such as:

(1) You may use the "share" button to share certain content from the BuddIn service with a third-party service, or utilize a third-party service to log into BuddIn. These features may collect your information (including log data) and may place cookies on your device to ensure proper functionality 

(2) BuddIn may provide you with links through advertisements or other service features to facilitate access to third-party services or websites. 

(3) Additional scenarios involving third-party services. For instance, to fulfill the purposes outlined in this Policy, BuddIn may integrate SDKs or similar applications provided by third parties (such as embedded code, plug-ins, etc.) to enhance customer service and user experience.

Types of Third-Party Service Providers BuddIn May Access:

(1) Advertising services, including advertisement display, data analytics, and monitoring. 

(2) Message push services, including mobile manufacturer notifications, event reminders, and personalized recommendations.

(3) Payment-related services, such as order transactions, payment verification, revenue settlement, and statistical aggregation of payment data. 

(4) Facial recognition functionality.

(5) Access to device location permissions, device information collection, and log data processing with user consent.

(6) Third-party authentication services, including third-party account login and content sharing with third-party platforms.

(7) Support for product functionalities such as voice playback, video playback, and content storage 

(8) Product performance optimization, including network capacity enhancements, server cost reductions, and functional hotfixes. 

(9) Security and product integrity services, including network monitoring, domain name resolution (HTTDNS), anti-hijacking, anti-spam, anti-fraud, and encryption/decryption solutions.

(10) Content moderation services for audio, video, and text-based materials.

(11) Compliance with regulatory requirements, including integration with blacklist-sharing systems.

Certain third-party SDKs or similar applications integrated within BuddIn may collect user data. By utilizing such third-party services within BuddIn, you acknowledge and agree that your information may be directly collected and processed by these third parties. BuddIn will assess the legality, legitimacy, and necessity of such data collection, require third parties to implement protective measures, and ensure compliance with applicable laws and regulations.

These third-party social media platforms and other services are operated independently by their respective providers. Your use of these services (including providing your information to such third parties) is governed by their terms of service and privacy policies, not this Policy. It is your responsibility to review their terms carefully. This Policy applies solely to information collected by BuddIn and does not extend to third-party services or their data usage practices. BuddIn assumes no liability for any information you provide to third-party entities.

IX. Age Limit

BuddIn services are intended for adults only. Minors (defined as natural persons who have not yet reached the age specified by applicable laws) are not permitted to create a user account or use our services. We are committed to protecting the personal information of minors in accordance with relevant laws and regulations. 

We do not knowingly process the personal data of minors without the explicit consent of their guardians. If you believe that we may have collected personal data from a minor under your guardianship, please contact us using the details provided in Section X, "How to Contact Us." We will promptly investigate the matter and, if necessary, delete such personal information. The personal information of minors will only be used or disclosed as permitted by applicable laws and regulations, with the explicit consent of guardians, or when necessary to protect the well-being of minors.

X. Notice and Amendment

We may update this Policy as needed, and any modifications will be incorporated into this Policy. For significant changes (including but not limited to major modifications in our service model, ownership structure, primary purposes of personal information sharing, transfer, or public disclosure, your rights regarding personal data processing and how to exercise them, the department responsible for personal information security, and relevant contact information and complaint channels), we will provide prominent notifications. If you do not agree with the revised Policy, you may choose to discontinue using our services. Continued use of the services constitutes acceptance of the updated Policy. 

Any amendments will prioritize user satisfaction. We encourage you to review this Policy periodically when using our services.

When necessary, we may issue service-related announcements (e.g., notifications regarding service suspension due to system maintenance). These service-related announcements are not promotional in nature and may not be subject to cancellation.

Lastly, you are responsible for maintaining the confidentiality of your account credentials. Please ensure that your account information is securely stored at all times.

XI. How to Contact Us

If you have any complaints or concerns regarding the security of online information, or if you have any questions, comments, or suggestions about this policy, your personal information, or BuddIn's privacy practices, please contact us at buddin_support@refpte.com

Additionally, if you have any concerns about the processing of your personal data by BuddIn, you have the right to file a complaint with the appropriate data protection authority.

Introduction

This is the Privacy Policy of BuddIn and its various & next versions including BuddIn APP version (hereinafter collectively referred to as "BuddIn", "us", "we", or "our") and is incorporated into and is subject to our Terms of Use. In this Privacy Policy (the “Policy”), we refer to our products and services as the "Service".

BuddIn has always solemnly promised to protect the privacy of users who use our products and service (collectively “user” or “you”). When you use the Service, we may collect and use your personal data. The protection of your personal data is of great importance to us. This Policy therefore intends to inform you about how BuddIn, acting as data controller, collects and processes your personal data (or referred to as “personal information”) that you submit or disclose to us. We may also act as data processor when we process your personal data received or obtained through third parties.

We encourage you to read this Policy carefully (especially the contents highlighted in bold or underlined) before using the Service to make the appropriate choice. If you do not agree to this Policy, please do not register, log in, visit or use the Service, and do not provide us with your personal data. If you do not wish certain kinds of your personal data to be used by us as set out in this Privacy Policy, please note that in such a case, we may not be able to provide you with the corresponding parts of our services, you may not have access to and/or be able to use some features of our services, and your customer experience may be impacted. When you agree to all terms and conditions hereof this Police, you agree that we will deal with your personal information in accordance with this Policy.

After reading this Policy, if you have any questions about this Policy or matters related hereto, you can contact us through the feedback channels listed in Section XI "How to Contact Us" , and we will give you an answer as soon as possible.

I. Personal Data that We May Collect

We encourage you to read this Policy carefully (especially the contents highlighted in bold or underlined) before using the Service to make the appropriate choice. If you do not agree to this Policy, please do not register, log in, visit or use the Service, and do not provide us with your personal data. If you do not wish certain kinds of your personal data to be used by us as set out in this Privacy Policy, please note that in such a case, we may not be able to provide you with the corresponding parts of our services, you may not have access to and/or be able to use some features of our services, and your customer experience may be impacted. When you agree to all terms and conditions hereof this Policy, you agree that we will deal with your personal information in accordance with this Policy.

After reading this Policy, if you have any questions about this Policy or matters related hereto, you can contact us through the feedback channels listed in Section XI "How to Contact Us", and we will give you an answer as soon as possible.

II. How Will We Collect and Use Personal Information

We Will Collect and Obtain Your Information through the Following Ways

1. Information provided by you. For example:

(1) Information provided by you when you register an account for the Service or use BuddIn;

(2) Sharing information provided by you to other users through the Service, and information saved when you use the Service.

Please note that if you upload, post or make your information public in a public area visible to other users or in response to other users, such your information may be collected and used by other users. When you find that other users improperly collect or use information from you or others, please contact us as guided in Section XI “How to Contact Us” below.

Your information shared by other users, also sharing information about you provided by other users when they use the Service.

Your information obtained by us. The information collected, summarized and recorded by us when you use the Service, such as log information, location information and device information.

(3) We Will Collect and Use Your Information for the Following Purposes

Help you to complete the registration and login

In order for us to provide the Services for you, you need to provide basic registration or login information, such as mobile phone number (personally sensitive information), verification code matching results (personally sensitive information), nickname, gender, date of birth, and profile picture etc., used to create an account (username and password).

You can also log in BuddIn using our supported third-party platform accounts, and in such cases we will obtain the relevant information about you (such as your nickname, avatar) under the third- party account according to your authorization.

Your above personal data provided by you or obtained by us from your third-party platform account under your authorization, is therefore processed for these purposes in order to provide you with and perform the Service based on your engagement with us. Without this personal data, we are not able to provide you with our services, and you will not be able to log in or use BuddIn.

You may also fill in your additional information (such as your location, height, occupation, weight, education, annual income, profile, personal label, interests and hobbies) during registration, login or subsequent use, which will help us to provide personalized recommendations and better service experience for you. However, if you do not provide this information, it will not affect your use of the basic functions of our product and the Service. 

2. Implement Real Person Verification

In order for us to verify you are a real person, and to guarantee the security of system, service and users' property, you need to provide your real person verification information, in accordance with relevant laws, regulations and regulatory requirements that are applicable.

For example, when you reply to a private message, use the voice/video calling services, you may need to provide your profile photo (personal sensitive information) and your personal photos of specified actions instructed by us (personal sensitive information). We will make the photo comparison to complete the real person verification (hereinafter referred to as "Real Person Verification").

Please note that your profile photo, real person photo belongs to your sensitive personal information. Please be careful to provide them. If you do not agree to provide such information, you may not be able to obtain relevant services, but it does not affect your normal use of other functions and services of BuddIn. 

3. Provision of Search Services

When utilizing the search function in BuddIn, we collect your search queries, browsing history, duration of browsing, and interaction frequency. This information enables us to provide relevant content and services that align with your interests.

4. Provision of Interaction and Content Sharing Services

When you use BuddIn to upload, post, or share content—including text, comments, audio, video, images, or other materials—or engage in activities such as following users or sending virtual gifts, we collect and display the content you create within BuddIn. Additionally, your nickname and avatar may be displayed. 

(1) Content Upload and Verification

When you upload a profile picture, complete real-person verification, record an audio bio, or post updates—including text, images, audio, video, or other content—we will request access permissions for your microphone, camera, photos, and storage. We collect the audio, video, images, text, and other materials you provide through these functionalities. If you choose not to grant these permissions, certain services may be unavailable; however, this will not impact your access to other core features of BuddIn.

Please note that uploaded audio, photos, and videos may contain sensitive personal information. Exercise caution when sharing such content. Additionally, if your uploaded content includes personal information of others, you must obtain their consent before posting.

 (2) User Interactions and Engagement

When you follow other users or interact with their content—such as liking, commenting, or sharing—we collect data on the accounts you follow and provide you with updates from those accounts. Likewise, we record your interactions, including likes, comments, and shared content, and may display or notify relevant users within BuddIn.

(3) Virtual Gift Transactions

When you send virtual gifts to other users using in-app currency, we collect and display your profile picture, nickname, and gift transaction details to the recipients.

 (4) Location-Based Services

To recommend nearby users and provide personalized content, we may request access to your location data (a category of sensitive personal information). If you grant this permission, we will collect and display your location to other users. You may disable location sharing at any time, after which we will cease collecting or displaying your location data.

 5. Provision of Customer Service and User Response Service

In the circumstance where you make contact with us for the purposes of availing customer service or submitting user responses, which can cover a wide range of aspects such as inquiries, feedback, suggestions, and complaints among others, we are entitled to request that you supply us with indispensable personal information. The primary aim of this request is to conduct the matching and verification of your user identity, thereby guaranteeing the security not only of your individual account but also of the entire system.

 We may retain various types of information, including but not limited to your communication or call records, the content of conversations, and the contact information you have provided. The retention of such information serves multiple legitimate purposes. It enables us to establish effective communication with you, offer assistance in resolving any issues you may encounter, and document the resolutions and results associated with the relevant matters.

Your personal data is processed with these specific intentions in order to deliver and implement the services in strict accordance with the terms of our engagement with you. Additionally, this personal data may also be processed to protect and uphold your legitimate rights and interests in obtaining relevant information and other related data that pertains to the services you receive from BuddIn.

6. Provision of Information Display and Recommendation Service

We may make use of your information, which might encompass your interests and hobbies, personality descriptors, browsing and search histories, device specifications, usage behaviors, location details, order information (when applicable), and various combinations thereof. Through the application of sophisticated recommendation algorithm modeling, programming methodologies, advertising frameworks, user behavior analytics, and user profiling techniques, we will extract in-depth insights regarding your browsing and search inclinations, behavioral patterns, and location-based information. The overarching objective of these endeavors is to present you with more customized page displays that are precisely tailored to meet your specific needs and to recommend personalized content that aligns with your preferences.

7. Notification Push Service

When it is considered essential and appropriate, we may dispatch notifications to you that are directly related to the services we offer. For example, in situations where we are compelled to suspend, modify, or discontinue the provision of a particular service due to system maintenance or other legitimate reasons.

In the event that you no longer desire to receive the messages that we have pushed to you, you have the prerogative to submit a request to us to halt the pushing of such messages. For instance, in accordance with the established SMS unsubscribe protocols, you may formally request us to cease sending promotional SMS messages. Alternatively, you can configure your mobile devices to block messages originating from us. However, it should be noted that this exemption does not apply when we are legally obligated to send messages in strict compliance with the provisions of relevant and applicable laws and regulations. 

8. Provision of Security Services

In addition to the authentication procedures that are in place, we may utilize your information for a variety of purposes, including customer service support, security safeguarding and control measures, fraud detection and monitoring, data archiving, and backup operations. The ultimate goal of these actions is to ensure the security and integrity of the services that we provide to you.

We may employ or integrate the information that we have collected directly, as well as the information that our partners have obtained either with your explicit authorization or through legal information sharing mechanisms. This comprehensive and holistic approach empowers us to conduct a thorough assessment of your account and transaction risks, carry out identity verification procedures, detect and prevent potential security incidents, and take all necessary actions such as record-keeping, auditing, analysis, and appropriate disposal of relevant data in strict accordance with the law.

 Your personal data is processed with these specific purposes in mind to safeguard and protect your legitimate rights and interests. This ensures the security of your connection to our platform and the protection of your personal data throughout the entire process of your accessing information and availing services from BuddIn.

9. Provision of Customer Service and User Response Service

In the event that you reach out to us for customer service or user response purposes, which may encompass inquiries, feedback, suggestions, complaints, and the like, we reserve the right to request that you furnish us with essential personal information. This is aimed at matching and verifying your user identity, thereby ensuring the security of your account and the system as a whole. We may retain information such as your communication or call history, conversations, or the contact details you have provided. Such retention serves the purposes of enabling us to communicate with you, assist you in resolving issues, or document the resolutions and outcomes of the relevant matters.

Your personal data is processed for these specific objectives to provide and execute the services in accordance with our engagement with you. Moreover, this personal data may also be processed to safeguard your legitimate rights and interests in obtaining relevant information and other associated data pertaining to the services you receive from BuddIn.

10. Provision of Information Display and Recommendation Service

We may utilize your information, which may include your interests and hobbies, personality tags, browsing and search histories, device information, usage habits, location information, order information (if applicable), and combinations thereof. Through the application of recommendation algorithm modeling, programming techniques, advertising models, user behavior analysis, and user profiling, we will extract insights regarding your browsing and search preferences, behavioral patterns, and location information. This is done with the intention of presenting you with more page displays that are tailored to your needs and recommending personalized content.

11. Notification Push Service

When deemed necessary, we may send you notifications related to the services. For instance, in situations where we suspend, modify, or discontinue the provision of a particular service due to system maintenance.

Should you no longer wish to receive the messages that we have pushed, you have the option to request us to cease the push. For example, in accordance with the SMS unsubscribe procedures, you may ask us to stop sending promotional SMS messages or configure your mobile devices to block messages from us. However, this exclusion does not apply when we are required to send messages in compliance with the provisions of relevant applicable laws and regulations.

12. Provision of Security Services

In addition to the authentication process, we may utilize your information for customer service, security prevention and control, fraud monitoring, archiving, and backup purposes. This is to ensure the security of the services we provide to you. We may employ or integrate the information collected by us, as well as the information obtained by our partners with your authorization or through legal sharing mechanisms. This comprehensive approach enables us to assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary actions such as record-keeping, auditing, analysis, and disposal in accordance with the law.

Your personal data is processed for these purposes to safeguard your legitimate rights and interests, ensuring the security of your connection and the protection of your personal data during the process of your obtaining information and services from BuddIn.

13. Enhancement of Our Services

We may invite you to participate in surveys regarding the Service to assist us in enhancing existing features or developing new functionalities. Additionally, we may utilize your information for software updates. The processing of this personal data serves our legitimate interest in improving our services accordingly.

14. Utilization of Anonymized Information

You acknowledge and agree that, in certain instances, upon the collection of your information, we will employ technical measures to de-identify and fully anonymize the data, ensuring that it no longer constitutes personal data directly or indirectly linked to an individual, such as yourself. This de-identified data will not identify or be associated with you. Under such circumstances, we reserve the right to analyze and commercialize the anonymized user database.

Should we intend to use your information for purposes not specified in this Policy, we will seek your prior consent through on-screen prompts, interactive processes, website announcements, or other means. Upon your agreement, such additional usage of your information will be incorporated into and governed by this Policy 

15. Notification Regarding Permissions for Specific Functions

You acknowledge and agree that we may request certain access permissions on your device to collect and utilize information related to specific functions and services, including but not limited to:

(1) With your explicit consent, we may access your device's storage to enable caching, downloading, and saving of content. 

(2) With your explicit consent, we may access your device information for unique identification purposes, allowing us to provide personalized content and recommendations tailored to your preferences, assess product suitability, detect abnormal conditions, and ensure network and service security.

Regarding permissions related to accessing albums/camera, contact lists, microphone, location, and calendar (including reading and writing), most mobile devices allow users to revoke such permissions. Please refer to your device manufacturer or service provider for further details. When you grant any permissions, you authorize us to collect and use the corresponding information to deliver relevant services. If you withdraw a given permission, your authorization will terminate, and we will cease collecting and using the relevant data, thereby discontinuing the provision of associated services. However, the collection and usage of data conducted under your prior authorization will remain unaffected.

16. Exceptions to Authorization Requirements

In accordance with applicable laws and regulations, the collection of your information does not require prior authorization under the following circumstances:

(1) Compliance with obligations under applicable laws and regulations;

(2) Protection of public safety, public health, and significant public interests;

(3) Criminal investigations, prosecutions, trials, and enforcement of judicial decisions;

(4) When obtaining your consent is impractical for safeguarding critical legal rights and interests, including the protection of life and property of the data subject or other individuals;

(5) Information that you have voluntarily disclosed to the public;

(6) Information obtained from publicly available sources, including legitimate news reports and government disclosures;

(7) When necessary for the execution of a contract at your request;

(8) When required to maintain the security and stability of the Service, including identifying and resolving product or service malfunctions;

(9) When necessary for legitimate news reporting;

(10) When necessary for academic research institutions conducting statistical or academic studies in the public interest, provided that any externally published research findings or descriptions contain de-identified data;

(11) Other circumstances as stipulated by applicable laws and regulations. 

17. Special Notice Regarding Personal Sensitive Information

Personal sensitive information refers to any personal data that, if disclosed, illegally provided, or misused, could jeopardize personal and property security, damage personal reputation, impact physical and mental well-being, or lead to discriminatory treatment.

Examples of sensitive personal information include, but are not limited to, identification card numbers, biometric data (such as facial recognition features and voice prints), bank account details, contact lists, communication records and content, property-related information (including virtual assets, virtual currency, and virtual transactions), location data, web browsing history, health and physiological information, and transaction details.

Please exercise caution when handling your sensitive personal information. By using our services, you consent to our processing of your sensitive personal information in accordance with this Policy.

III. Use of Cookies and Similar Technologies

BuddIn, along with our third-party partners, may collect and process your information through Cookies and Web Beacons, storing such information as log data.

Cookies enable us to offer users a streamlined, personalized web experience. A Cookie is a small piece of data sent from a web server to your browser and stored on your computer’s hard drive. We utilize Cookies to enhance user experience. For instance, to expedite the login process within the BuddIn virtual community, you may opt to save your username in a Cookie, allowing for quicker and more convenient access to our services in subsequent sessions. Cookies also help us analyze the web pages and content you interact with, the duration of your engagement with certain services, and the specific services you choose to use.

Cookies enhance our ability to serve you efficiently and personalize your experience within our services. However, you have the ability to control whether and how Cookies are accepted by your browser. Please refer to your browser’s documentation for details on managing Cookie preferences. 

BuddIn and our third-party partners may use Cookies and Web Beacons to collect and store data for the following purposes:

(1) Identity Recognition – Cookies and Web Beacons assist in identifying you as a registered user or in saving your preferences and other information you provide to us.

(2) Usage Analysis – We use Cookies and Web Beacons to understand how users interact with our services, identifying the most popular features and activities. Where required, we will seek your consent before utilizing Cookies and Web Beacons for analytical purposes.

(3) Advertising Optimization – Cookies and Web Beacons enable us to provide you with tailored advertisements based on your interests rather than generic ads. Where necessary, we will seek your consent before using Cookies and Web Beacons for advertising purposes.

While we employ Cookies and Web Beacons for these objectives, we may aggregate the collected data and share it with advertisers and partners to analyze service usage and optimize advertising strategies. 

Additionally, third-party advertisers and partners may place Cookies, Web Beacons, and similar technologies within the Service. These technologies may collect information about you to analyze user engagement, deliver relevant advertisements, or assess advertising effectiveness. The collection and usage of such data by third parties are governed by their respective privacy policies and not this Policy. BuddIn assumes no responsibility for third-party Cookies, Web Beacons, or similar technologies.

You can manage or reject Cookies and Web Beacons via your browser settings (if accessing the Service through a web browser) or through user preference settings. However, please note that disabling Cookies or Web Beacons may impact your user experience, and certain services may not function as intended. You will still receive advertisements, but their relevance to your interests may be reduced.

IV. Information Sharing, Transfer, and Disclosure

(1) Sharing

Except in the following circumstances, we will not share your information with any third party other than BuddIn without your consent:

a. Provision of Services: We may share your information with our partners and other third parties to facilitate core functions or deliver the services you require, such as payment processing and data services.

b. Service Maintenance and Improvement: We may share your information with our partners and third parties to enhance service quality and provide you with more tailored experiences. For instance, communication service providers may send notifications on our behalf.

c. Purpose Fulfillment: We may share your information to fulfill the objectives outlined in Section II, "Collection and Use of Personal Information."

d. Contractual and Policy Compliance: Sharing may occur to fulfill our obligations under this Policy or other agreements between you and BuddIn and to enforce our rights.

e. Marketing and Promotions: We may share aggregated, non-identifiable data with third-party partners who commission us for promotional activities. Such data includes metrics on promotional reach and effectiveness, but not personally identifiable details such as name, phone number, or email address. For example, we may inform third parties about the number of users who viewed their promotions or purchased products following an interaction with their advertisements. Any shared data will be anonymized to prevent personal identification.

f. Legal Compliance and Security Measures: To the extent permitted by applicable laws and regulations, we may exchange information with other companies and organizations to comply with legal requirements, protect BuddIn, our affiliates, partners, users, or the public from harm, prevent fraud, or mitigate credit risk. This excludes any sale, lease, or unauthorized disclosure of information for profit, which would violate our commitments under this Policy.

g. Dispute Resolution: We may share your information to assist in resolving disputes or controversies upon your lawful request.

h. Guardian or User Requests: Your information may be shared in response to legitimate requests from you and/or your legal guardian.

i. Service Agreements: Sharing may be conducted under individual service agreements signed with you, including electronically signed contracts and corresponding platform regulations.

j. Academic Research: We may provide data for academic research purposes.

k. Public Interest Compliance: We may share information when required for social and public interest reasons, in compliance with applicable laws and regulations.

We only share information for legitimate, justified, necessary, specific, and explicit purposes. Entities receiving shared data must adhere to strict confidentiality agreements and process information in compliance with our instructions, this Policy, and other applicable security and confidentiality standards. 

(2) Transfer

a. Business Transactions: In the event of a merger, acquisition, asset transfer, or similar corporate transaction, your information may be transferred as part of the business transition. The receiving entity must comply with this Policy. Otherwise, we will seek your authorization before proceeding with the transfer.

b. User Consent: We may transfer your information to third parties with your explicit consent. 

(3) Disclosure

 We will only disclose your information under the following conditions while adhering to industry-standard security measures:

a. User-Requested Disclosure: We will disclose specified information in the manner explicitly requested by you.

b. Legal and Regulatory Compliance: If disclosure is required under applicable laws, regulations, administrative enforcement, or judicial directives, we will provide only the necessary information and in the required manner. Upon receiving such requests, we will verify the validity of legal documents such as subpoenas or investigation orders and ensure transparency to the extent permitted by law. Requests will be carefully reviewed to confirm their legality and necessity, ensuring that only the required data is disclosed for legitimate legal purposes.

 V. Exceptions to Authorization Requirements

Under applicable laws and regulations, the following circumstances do not require prior authorization for information collection, sharing, transfer, or disclosure: 

(1) Public Safety and Interest: When directly related to national security, public health, or significant public interests.

(2) Legal Investigations and Proceedings: When related to criminal investigations, prosecutions, trials, or the enforcement of judicial rulings.

(3) Protection of Legal Rights: When necessary to protect critical legal rights and interests such as life and property, where obtaining your consent is impractical.

(4) Publicly Disclosed Information: When information has been voluntarily disclosed by you to the public.

(5) Legally Available Sources: When information is collected from publicly available, legally authorized sources, such as news reports and governmental disclosures.

(6) Legal and Regulatory Obligations: When required to fulfill obligations under applicable laws and regulations.

(7) Other Legally Permissible Circumstances: As permitted under relevant legal provisions.

According to applicable laws and regulations, the sharing, transfer, or public disclosure of de-identified personal information—where the recipient cannot re-identify the natural person—does not constitute personal data processing. We may store and process such de-identified data without prior notice or user consent.

VI.  How We Retain, Store, and Protect Your Information

We retain your information only for the duration necessary to fulfill the purposes outlined in this Policy and within the timeframe mandated by applicable laws and regulations. If we terminate the Service, we will promptly cease collecting your personal information in accordance with relevant legal requirements. Following the termination of the Service, we will delete or anonymize your personal information, except where applicable laws, regulations, or regulatory authorities require otherwise.

 The information we collect and generate within the Service is stored in Singapore. By using this Policy, you authorize us to store and transfer your personal information across borders. We are committed to ensuring that your personal information remains adequately protected in compliance with this Policy and applicable laws and regulations. To safeguard your information, we implement the following measures:

 (1) Data Security Technological Measures

We adopt industry-standard security measures, including the establishment of robust system specifications and security technologies, to prevent unauthorized access or modification of your information, as well as to mitigate the risk of data loss or damage. For instance, in certain services, we employ encryption technologies (such as SSL) to store and protect your information and utilize isolation technologies to enhance security. Additionally, when processing information (e.g., displaying or computing information), we apply various data desensitization techniques and enforce strict data access controls, including multi-factor authentication, to prevent unauthorized use.

 (2) Additional Security Measures to Protect Information

We regulate the storage and utilization of information by establishing a hierarchical data classification system, security management policies, and development security standards. A comprehensive data security control system is enforced through access confidentiality agreements, monitoring, and auditing mechanisms. We also emphasize security awareness by conducting training programs on privacy and security protection to enhance employees’ understanding of the importance of safeguarding information.

 (3) Access Control and Confidentiality Obligations

Access to your information is restricted to employees and partners who require it for operational purposes. Strict access control and monitoring mechanisms are in place to enforce this restriction. Additionally, all personnel with potential access to your information are bound by confidentiality obligations. Any failure to comply may result in legal liability or termination of cooperation with BuddIn V.

 (4) Minimization of Data Collection

We take all reasonable and practical steps to ensure that we do not collect unrelated or excessive information.

 (5) Security of Communications and Online Environment

The internet is not an entirely secure environment, and communication methods such as email, instant messaging, and social media may not be fully encrypted. We advise you to use complex passwords and exercise caution when sharing personal information through these channels.

 Although we strive to protect your data, the online environment is not 100% secure. In the event of unauthorized access, disclosure, alteration, or destruction of information due to a breach of our security infrastructure, we will assume legal responsibilities as required by applicable laws.

 (6) Incident Response and Security Breaches

When interacting with third parties via the Service, your information may be disclosed to the recipient or potential counterparties. Please ensure that you only share your information when necessary. 

To mitigate risks such as data breaches, loss, or compromise, we have implemented systems that define security incident classification standards, vulnerability assessments, and corresponding response procedures. We maintain a dedicated emergency response team to handle security incidents by initiating mitigation plans, conducting forensic analysis, implementing remedial measures, and collaborating with relevant authorities for resolution. 

In the unfortunate event of a security breach, we will promptly notify you in compliance with applicable laws and regulations. This notification will include details of the incident, potential impact, remedial actions taken, and recommendations to minimize risk. If direct notification is not feasible, we will issue a public announcement through appropriate channels. Furthermore, we will report the incident to regulatory authorities as required.

(7) Your Role in Protecting Your Information

While we implement stringent security measures, technical limitations and unforeseen circumstances may impact the security of your information. The communication systems and networks you use to access the Service may also encounter issues beyond our control. We urge you to safeguard your account credentials, passwords, and other identity verification details. Unauthorized disclosure of such information may lead to losses. If you suspect or detect any security vulnerabilities or breaches, please contact us immediately as outlined in Section X, "How to Contact Us," so we can take timely and appropriate measures to mitigate potential damages.

VII. How to Manage Your Information

(1) Access, Rectification, Update, Objection, and Deletion

We encourage you to rectify, update, and modify your information to ensure its accuracy and effectiveness. You may access and manage your information independently through the Service or request that we make modifications, supplements, or deletions on your behalf. We employ appropriate technical measures to facilitate your ability to access, update, correct, and delete your personal information or any other data provided or generated during your use of the Service to the greatest extent possible. 

To safeguard your information, we may require identity verification before allowing access, updates, corrections, or deletions. Upon receiving a request to access, update, correct, or delete your personal data, we will assess whether any applicable laws or exceptions permit us to deny the request and will inform you of our decision accordingly.

Regarding information collected via COOKIES, we provide details on available user controls in Section III, "How We Use COOKIES and Similar Technologies." To search, modify, or delete specific information, please log into your BuddIn. account to perform the necessary actions. If you have any inquiries or requests related to accessing, rectifying, updating, modifying, or deleting your data, you may contact us as described in Section X, "How to Contact Us."

Unless otherwise mandated by applicable laws and regulations, when you correct or delete personal information or request account cancellation, relevant information may not be immediately removed from backup systems. However, we will ensure the deletion or correction of such information upon the next backup update. 

(2) Publishing and Sharing

The Service enables you to share information not only within your social network but also with all users. This includes content you upload or post, responses to others' posts, personal information shared in publicly accessible areas, location data, and log information associated with such data. Unless deleted by you, shared content may remain publicly available. Even if deleted, such content may be cached, copied, or saved by other users or third parties beyond our control, or otherwise retained in public domains.

If your publication or sharing of information results in its disclosure, we disclaim liability. Therefore, we strongly advise you to carefully consider whether to publish or share information through the Service.

(3) Account Cancellation

Subject to the conditions set forth in the service agreement and applicable laws and regulations, your account for the Service may be canceled or deleted. Once an account is canceled or deleted, all related service data and information will be either deleted or processed in accordance with the BuddIn V. service agreement. You may complete the cancellation process by following the guidance provided in the relevant operational section of BuddIn.

(4) Modifying the Scope of Your Consent

While some information is essential for using the Service, most data collection depends on your consent. Where personal data processing is consent-based, you may decide whether to disclose such information. You can modify the scope of your consent or withdraw it by deleting information, disabling device functions, or using other available methods. You may also withdraw consent by contacting us as outlined in Section X, "How to Contact Us."

 Upon withdrawing consent, we will cease to provide the corresponding service and will not process the related information. However, your withdrawal does not affect prior data processing activities conducted based on your consent.

 (5) Guidelines for Sensitive Information

Certain information is considered sensitive due to its nature, including but not limited to race, religion, health records, medical data, identification documents, biometric data, financial details, location history, and information about minors.

Please be aware that content you provide, upload, or post on the Service (such as images or details about your social activities) may inadvertently reveal sensitive information. Carefully consider whether to disclose such information. By doing so, you explicitly consent to our processing of this sensitive data in accordance with this Policy. 

(6) Restrictions on Automated Decision-Making

In certain business functions, we may rely on automated decision-making mechanisms, such as algorithms and information systems. If such decisions significantly affect your rights and interests, you may request an explanation, and we will provide appropriate remedies.

For security purposes and to process such requests, we may require a written application and identity verification. Reasonable requests will not incur charges; however, repetitive or excessive requests may be subject to a fee. We may deny requests that are unduly repetitive, require disproportionate technical effort (such as developing a new system or significantly altering existing processes), risk others’legitimate interests, or are highly impractical (e.g., involving backup data stored on tapes). 

Circumstances Under Which We Cannot Fulfill Your Request

a. We may be unable to comply with your request under the following conditions:

b. When fulfilling the request would violate applicable laws and regulations.

c. When the request is directly related to national security, public health, or significant public interests.

d. When the request is linked to criminal investigations, prosecutions, trials, or enforcement of judgments.

e. When there is sufficient evidence to suggest that the request is made with malicious intent or constitutes an abuse of rights.

f. When fulfilling the request would compromise the life, property, or other significant legal rights of you or others, and obtaining your consent is impractical 

g. When fulfilling the request would cause serious harm to your own or others’ legitimate rights and interests.

h. When the request pertains to trade secrets. 

i. When other applicable legal and regulatory exceptions apply.

 VIII. Services Provided by Third Parties

The BuddIn service may include links to social media platforms or other services provided by third parties (including websites and other forms of services), such as:

(1) You may use the "share" button to share certain content from the BuddIn service with a third-party service, or utilize a third-party service to log into BuddIn. These features may collect your information (including log data) and may place cookies on your device to ensure proper functionality 

(2) BuddIn may provide you with links through advertisements or other service features to facilitate access to third-party services or websites. 

(3) Additional scenarios involving third-party services. For instance, to fulfill the purposes outlined in this Policy, BuddIn may integrate SDKs or similar applications provided by third parties (such as embedded code, plug-ins, etc.) to enhance customer service and user experience.

Types of Third-Party Service Providers BuddIn May Access:

(1) Advertising services, including advertisement display, data analytics, and monitoring. 

(2) Message push services, including mobile manufacturer notifications, event reminders, and personalized recommendations.

(3) Payment-related services, such as order transactions, payment verification, revenue settlement, and statistical aggregation of payment data. 

(4) Facial recognition functionality.

(5) Access to device location permissions, device information collection, and log data processing with user consent.

(6) Third-party authentication services, including third-party account login and content sharing with third-party platforms.

(7) Support for product functionalities such as voice playback, video playback, and content storage 

(8) Product performance optimization, including network capacity enhancements, server cost reductions, and functional hotfixes. 

(9) Security and product integrity services, including network monitoring, domain name resolution (HTTDNS), anti-hijacking, anti-spam, anti-fraud, and encryption/decryption solutions.

(10) Content moderation services for audio, video, and text-based materials.

(11) Compliance with regulatory requirements, including integration with blacklist-sharing systems.

Certain third-party SDKs or similar applications integrated within BuddIn may collect user data. By utilizing such third-party services within BuddIn, you acknowledge and agree that your information may be directly collected and processed by these third parties. BuddIn will assess the legality, legitimacy, and necessity of such data collection, require third parties to implement protective measures, and ensure compliance with applicable laws and regulations.

These third-party social media platforms and other services are operated independently by their respective providers. Your use of these services (including providing your information to such third parties) is governed by their terms of service and privacy policies, not this Policy. It is your responsibility to review their terms carefully. This Policy applies solely to information collected by BuddIn and does not extend to third-party services or their data usage practices. BuddIn assumes no liability for any information you provide to third-party entities.

IX. Age Limit

BuddIn services are intended for adults only. Minors (defined as natural persons who have not yet reached the age specified by applicable laws) are not permitted to create a user account or use our services. We are committed to protecting the personal information of minors in accordance with relevant laws and regulations. 

We do not knowingly process the personal data of minors without the explicit consent of their guardians. If you believe that we may have collected personal data from a minor under your guardianship, please contact us using the details provided in Section X, "How to Contact Us." We will promptly investigate the matter and, if necessary, delete such personal information. The personal information of minors will only be used or disclosed as permitted by applicable laws and regulations, with the explicit consent of guardians, or when necessary to protect the well-being of minors.

X. Notice and Amendment

We may update this Policy as needed, and any modifications will be incorporated into this Policy. For significant changes (including but not limited to major modifications in our service model, ownership structure, primary purposes of personal information sharing, transfer, or public disclosure, your rights regarding personal data processing and how to exercise them, the department responsible for personal information security, and relevant contact information and complaint channels), we will provide prominent notifications. If you do not agree with the revised Policy, you may choose to discontinue using our services. Continued use of the services constitutes acceptance of the updated Policy. 

Any amendments will prioritize user satisfaction. We encourage you to review this Policy periodically when using our services.

When necessary, we may issue service-related announcements (e.g., notifications regarding service suspension due to system maintenance). These service-related announcements are not promotional in nature and may not be subject to cancellation.

Lastly, you are responsible for maintaining the confidentiality of your account credentials. Please ensure that your account information is securely stored at all times.

XI. How to Contact Us

If you have any complaints or concerns regarding the security of online information, or if you have any questions, comments, or suggestions about this policy, your personal information, or BuddIn's privacy practices, please contact us at buddin_support@refpte.com

Additionally, if you have any concerns about the processing of your personal data by BuddIn, you have the right to file a complaint with the appropriate data protection authority.