Last Updated: August 28, 2017
TABLE OF CONTENTS:
- The Types of Personal Data We Use
- How We Use Your Personal Data
- How We Share Your Personal Data
- Where We Store Your Personal Data
- The Security of Your Personal Data
- Data Retention
- Information Relating to Children
- Supplemental Terms – Jurisdiction-Specific
Welcome to Vigo mobile application (the “Platform”). The Platform is provided or controlled by Bytedance (HK) Limited, a corporation registered in Hong Kong (“Bytedance”, “we” or “us”). We are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you are accepting and consenting to the practices described in this policy.
The Types of Personal Data We Use
We may collect and use the following information about you:
- Information you give us. You may give us information about you by accessing or using our Services or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register for and/or use the Platform, such as your customer profile, information about your device, your browsing records, the comments you make on our Platform (including any Virtual Items (as defined in the Terms of Service) you contribute to any user-generated content), as well as account and billing details, including but not limited to, your Apple, Google or Windows account, PayPal or other third-party payment channel account where required for the purpose of paying or withdrawing cash. The information you give us may include your name, State ID number, address, email address, social media login details, telephone number, credit or debit card information. It also includes information that you give to us, such as user-generated content and video content that you may choose to broadcast on our Platform.
- Information you choose to share from your social networks. If you choose to link the Platform to your social network or public forum account (such as Facebook or WeChat), you may provide us or allow your social network to provide us with information from your social network or public forum accounts. This data may include your use of the Platform on such public forums and/or social networks. For further information as to how and for what purpose the social network provider processes your data, please see their privacy policies.
- Information we collect about you. We automatically collect certain data from you, including IP address or other unique device identifiers, Cookies (as defined below), mobile carrier, time zone and locale setting, operating system and platform and information regarding your use of the Platform. We may also collect information about linking your contact or subscriber information with your activity across our Platform or by linking your activity on our Platform across all your devices using your email or social media log-in details.
- Location data. When you use the Platform on a mobile device, we may process information about your location, including location information based on your SIM card, IP address or mobile device location settings, and if activated on your mobile device, by use of a Global Positioning System (GPS). We may use such information to provide you with location-based services, such as advertising and other personalised content. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device.
- Information from third parties. We may receive information if you use any of the other websites we operate or other Services we provide. We may also receive information from third parties (such as advertising networks and analytics providers) and from other sources, including business directories and other commercially or publicly available sources.
We use the following Cookies:
- Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.
- Analytical/performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality Cookies. These are used to recognise you when you return to the Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Do not track signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to “do not track” signals in your web browser.
How We Use Your Personal Data
We will use the information in the following ways:
- In accordance with our contract with you, we may use your information to:
- personalise the content you receive and provide you with tailored content that may be of interest to you;
- notify you about changes to our Services;
- provide you with user support;
- enforce our terms, conditions and policies;
- receive payments from you and/or make payments to you in accordance with the Diamond and Flame provisions set out in the Supplemental Terms – Virtual Items Policy under the Terms of Service or under a separate Premium Content Creator Agreement, if applicable; or
- communicate with you.
- As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organisation, we may use your information to:
- improve the Platform and to ensure content from the Platform is presented in the most effective manner for you and your device;
- administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- allow you to participate in interactive features of the Platform, when you choose to do so;
- personalise the content you receive;
- keep the Platform safe and secure;
- develop our Platform and conduct product development;
- measure and understand the effectiveness of the advertising we serve to you and others;
- make suggestions and recommendations to you and other users of the Platform about goods or services that may interest you or them; or
- provide you – or permit selected third parties to provide you – with information about goods or services we feel may interest you. Where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
It is in our legitimate interests to promote the Platform, and we may use information that you give to us, such as user-generated content and video content that you may choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform.
How We Share Your Personal Data
We may share your personal data with selected third parties in or outside your country, including:
- our business partners so that we can make you special offers via the Platform;
- with respect to on-screen ads, advertisers and advertising networks that require the data to select and serve advertisements to you and others. We will not share your contact details with our business parties so they will not contact you directly, but we will share other information so that they can make you offers tailored to your requirements;
- our suppliers and subcontractors who help us run the Platform; or
- analytics and search engine providers that assist us in the improvement and optimisation of the Platform.
We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above (“How We Use Your Personal Data”).
We may share your information with law enforcement agencies, public or tax authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request (including tax and related reporting requirements);
- enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We may also disclose your information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets; or
- if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
Where We Store Your Personal Data
The information that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”). It may also be processed by staff operating outside your country or the EEA who work for us, for one of our suppliers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy.
The Security of Your Personal Data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.
We may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.
We will retain your information as required under applicable laws.
After you have terminated your use of our services, we may store your information in an aggregated and anonymised format.
Information Relating to Children
The Platform is not directed at children under the age of 16. Users under the age of 16 are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 16, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a child under the age of 16, please contact us at email@example.com.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.
We will generally notify all users of any material changes to this Policy through a notice on our Platform, however, you should look at this Policy regularly to check for such changes. Your continued access to or use of the Services after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Services.
Questions, comments and requests regarding this policy are welcomed and should be addressed to email@example.com.
Supplemental Terms – Jurisdiction-Specific
- The security of your personal data. The personal data shared by you for the purposes of the Services would be safeguarded in accordance with the policies and systems adopted by us.
- Data retention. We will not retain sensitive personal data or information for longer than is required for the purposes for which such information may be lawfully used or is otherwise required under any law for the time being in force.
- Information relating to children. The Platform is not directed at persons under the age of 18. Users under the age of 18 are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 18, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a person under the age of 18, please contact us at firstname.lastname@example.org.
- Your rights
- Data rights. You have the right to access and review personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at email@example.com.
- Parental and Guardian Consent. If you are under the age of 21, you declare that you had the consent of your parent or legal guardian to use the Services or to register an account on the Services.
- Your Rights
- Data Rights. You have the right to access personal data in our Platform from time to time.
- Notification. In the event of Bytedance fails to maintain the confidentiality of your personal data in our Platform, Bytedance will notify you immediately through the contact information provided by you.
- Language. This policy is written in the English language and Indonesian language. In the event of any inconsistency or different interpretation between the English text and Indonesian text, the relevant Indonesian text shall be deemed to be automatically amended to conform with and to make the relevant Indonesian text consistent with the relevant English text. Each party acknowledges that it has read this policy and understands its content and that this policy has been entered into freely and without duress. The official text of this policy shall be in English. The parties agree that to comply with Law No. 24 of 2009 of the Republic of Indonesia (“Law No.24/2009”) on Flag, Language, State Emblem and National Anthem applies to this policy (as an agreement to which an Indonesian entity is a party), this policy is written in both English and Indonesian language. The parties agree that in the event of any dispute concerning the construction or interpretation of this policy, reference shall be made only to the version as written in English and not to the Indonesian language version or any translation into any other language. You acknowledge that you fully understand the language and the content of this policy and you agree that you will not use the provisions under Law No.24/2009 to invalidate this policy.
- Change to the terms. The following terms shall apply with priority over “Changes” above: “we may amend this Policy from time to time to the extent that is permitted by the applicable laws. In the event we amend this Policy, we will notify you of the effective date of the changes through (i) a notice to be posted on the landing page of our website or the splash screen of our mobile app or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended Policy even though we notified you that your failure to do so within the above advance notification period will be considered as an acceptance of the changes, you will be considered to have agreed to the new Policy.”