Arohar Privacy Policy

Update Date: March 18, 2022

Effective Date: March 18, 2022

Version number: Ver 1.4

 

Arohar Privacy Policy (hereinafter referred to as "this Policy" or "this Privacy Policy") applies only to the various products or services provided by ADDOIL BROADCASTS LIMITED (registered address: 15/F PROSPERITY MILLENNIA PLAZA 663 KING'S ROAD QUARRY BAY ; phone number: +852-3700 9004; hereinafter referred to as "the Company" or "We") to you through App Arohar (iOS end), official account, website, etc. (hereinafter referred to as "Arohar "). This Privacy Policy does not apply to other services provided to you by other users or other third parties, while other services are subject to their specific privacy policies or personal information collection and use rules explained to you separately.

We are well aware of the importance of personal information to you and will do our best to protect the security and reliability of your personal information. We are committed to maintaining your trust in us and will abide by the following principles to protect your personal information: the principle of matching rights and responsibilities, the principle of express purpose, the principle of choice and consent, the principle of least sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we undertake to take appropriate security protection measures to protect your personal information in accordance with the mature security standards prevailing in the industry.

Please read and understand this Privacy Policy carefully before using our products (or services), and confirm that you understand our rules for handling your personal information. Once you click to confirm acceptation of this Policy or confirm otherwise, you acknowledge and accept all the contents of this Policy (including the updated version), and agree that we can collect, use, retain, share, transfer or disclose relevant personal information of you in accordance with this Policy.

 

I. Definition and Interpretation

1. Personal information: Personal information refers to various information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information.

2. Sensitive personal information: Sensitive personal information refers to personal data that is regarded as personal sensitive information as per relevant laws and regulations in mainland China. Once such information is leaked or used illegally, it is likely to cause damage to the personal dignity of natural persons or endanger personal and property safety. The personal information or sensitive personal information specifically handled by our products or services is subject to the description of this Privacy Policy and related documents.

3. Subject of personal information: Subject of personal information refers to the natural person identified with personal information.

4. Device: Device refers to a device that can be used for Arohar App, such as a desktop computer, laptop, tablet or smartphone.

5. Unique device identifier: Unique device identifier (Unique ID or UUID) refers to a string of characters programmed into a device by the device manufacturer that can be used to uniquely identify corresponding device (mobile device ID, including IMEI number and MAC address). Unique device identifier can be used for a variety of purposes, including serving advertisements when cookies cannot be used.

6. Audio and video recording permissions: Arohar App will obtain the audio and video recording permissions of mobile phone to generate audio and video images for use in platform up-streaming.

7. IP address: Every device connected to the Internet is assigned a number usually by geographic area, which is called an Internet Protocol (IP) address. An IP address can often be used to identify where a device is connected to the Internet.

8. GPS: Abbreviation for Global Positioning System. The GPS signal receiver on your device can receive signals from GPS satellites and use the incoming information to calculate your location.

9. WIFI: Wi-Fi is a technology that allows electronic devices to connect to a wireless local area network (WLAN), commonly referred to as wireless fidelity.

10. Base station: A base station, that is, a public mobile communication base station, is a form of radio station, which refers to a radio transceiver that transmits information with mobile phone through a mobile communication switching center in a certain radio coverage area.

11. SSL: SSL (Secure Socket Layer) is a security protocol implemented on the Transmission Communication Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which use public key and symmetric key technology to achieve the effect of information confidentiality.

12. De-identification: De-identification is the process in which personal information is processed so that it cannot identify a specific natural person without the aid of additional information.

13. Anonymization: Anonymization refers to the process in which personal information is processed so that it cannot identify a specific natural person and cannot be recovered.

14. HTTPS: HTTPS (Hyper Text Transfer Protocol over Secure Socket Layer or Hypertext Transfer Protocol Secure) is a security-targeted HTTP channel, simply a secure version of HTTP.

15. Personal information collection technology: The "collection" described in this Privacy Policy by Arohar App includes the following technical methods:

1) Cookies

A cookie is a small text file placed by the server on the client (your computer, mobile phone or other smart terminal) when you browse the page, which can be used to improve your experience.

2) Log files

Log files retain certain data collected automatically. Such data includes Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.

3) JavaScript

JavaScript is a programming language used to make more interactive and dynamic web pages. JavaScript can set, read and delete cookies.

 

II. How We Collect and Use Your Personal Information

We mainly collect your personal information in the following ways:

(1) When you use our products and/or services, you will need to, according to business needs, provide information such as the mobile phone number for creation of an account.

(2) When you use our products and/or services, we may record, collect and summarize your information through automated means by the system, such as: the corresponding information collected through the device permission system authorized by you, the device information collected by automated tools, and the log information recorded by burying point.

(3) When you use our products and/or services, we may indirectly collect your personal information from third parties, for example, we may obtain your nickname and avatar information from third-party authorized accounts.

Under normal circumstances, we will collect and use your personal information or apply for relevant permissions for the realization of the following features/scenarios:

1. To provide you with Arohar products and services:

1) Information filled in upon creation of Arohar account:

When you sign up for and log in Arohar , you can create an account through your mobile phone number. Your mobile phone number is the necessary information collected to fulfill the requirements of national laws and regulations regarding the Real-name Registration on the Internet (authentication of real identity information). If you refuse to provide your mobile phone number for sign-up and login, we may not be able to serve you.

2) Log onto Arohar through a third-party account:

You can also log onto Arohar through a third-party account (such as WeChat, QQ, Weibo account). In this case, you will authorize us to obtain your public information (avatar, nickname, third-party platform uid) registered on the third-party platform, and to bind your third-party account to your Arohar account after you agree to this Privacy Policy, so that you can log in directly through the third-party account and use the product and related services.

3) Creation of a live-stream room/live or shoot:

When you make shooting or live-streaming in the live-stream room, we will ask you to enable the camera permission, photo album permission/retention permission (Android end), and microphone permission, which are used for audio and video shooting and recording, local video picture reading and preservation of live-stream room. If you refuse to enable these permissions, the live-stream feature may not be used normally.

We will load the video picture you selected in the live-stream room and present it in the live-stream room together with the camera shot and the microphone sound.

4) Using the remote control:

When you use the Bluetooth remote control, we will obtain the Bluetooth permission of the system according to the type of remote control you choose, to ensure the connection with the Bluetooth remote control device; when you use the app remote control, we will use the system floating window permission, so that you can still use the remote control when switching to other apps.

5) Learning center:

When you use the learning center module, we will obtain your cookie information in the APP browser to record your current browsing location, so that you can quickly find the learning content.

6) Entry of text content:

When you enter text content in the APP, we will read the content of the system clipboard so that you can complete the entry faster.

7) Using screencast:

When you use the screencast feature, we will identify Wi-Fi information and peripheral devices through the geographic location permission, and will obtain the screen content of the mobile phone through the screen recording permission in order to cast the screen.

8) Device information during use:

When you log onto Arohar through the APP, to prevent fraud, we will collect browser information (browser type, plug-in, language, font, image rendering hash, cache under the domain name), operating terminal information (operating system, region, communication provider).

11) Service log information:

Your use of our products and/or services, IP address, URL of the service accessed, type of browser and language used, date, time and duration of access to the service.

12) Membership feature:

When you purchase or redeem membership in the APP, we will associate the purchase or redemption time and duration information with your account and save it on the server to ensure that we can provide you with normal services during the membership period.

13) Security guarantee:

We will use your information for authentication, security protection, anti-fraud monitoring, archive backup, and customer security services to improve the security of our products and services.

(a) In order to ensure the operational safety, quality and efficiency of software and services, we will collect your hardware model, operating system version number, unique device identifier (such as IMEI, AndroidID, OAID, IMSI, ICCID, GAID and MEID for Android; IDFV and IDFA for iOS; different identifiers will vary in terms of validity, whether they can be reset by the user, and how to obtain them), network device hardware address (MAC address), IP address, Bluetooth, software version number, network access method, type, status, network quality data, operation, usage, service log.

(b) In order to prevent malicious programs and ensure operational quality and efficiency, we will collect the overall operation, usage and frequency of applications, application crashes, overall installation and usage, performance data, and application sources.

(c) We may use your account information, device information, service log information, as well as the information that our affiliates and partners can provide to us according to your authorization or in accordance with the law, for purposes of judging account security and transaction security, identity verification, identifying violations of laws and regulations, detecting and preventing security incidents, and we may accordingly take necessary recording, analysis and disposal measures in accordance with the law.

2. Permission description:

Android end

(1) Camera permission: When you use the live/shoot feature, we need the camera permission in order to obtain the picture captured by the camera.

(2) Microphone permission: When you use the live/shoot feature, we need the microphone permission in order to obtain the sound recorded by the microphone.

(3) Permission to read/write external memory: When you create a live-stream room, upload local materials, or save shot videos, we need this permission to ensure that the content can be read and written normally.

(4) Permission to read phone status: For security and risk control, we will apply to read device information such as device identifier.

(5) Bluetooth permission: When you use the Bluetooth remote control to control the live-stream room, we need this permission to keep the remote control connected normally.

(6) Geographical location permission: When you use the screencast feature, we need this permission in order to obtain the information of the wlan and peripheral devices for screencast pairing.

(7) Screen recording permission: When you use the screencast feature, we need this permission in order to obtain the screencast of the screencast mobile phone.

(8) Local network permission: When you use the screencast feature, we need this permission in order to pair with the device in the local area network for screen transmission.

iOS end:

(1) Camera permission: When you use the live/shoot feature, we need the camera permission in order to obtain the picture captured by the camera.

(2) Album permission: When you create a live-stream room, upload local materials or save shot videos, we need the album permission to ensure that the content can be read and written normally.

(3) Microphone permission: When you use the live/shoot feature, we need this permission in order to obtain the sound recorded by the microphone.

(4) Geographical information permission: When you use the screencast feature, we need this permission in order to obtain the information of wlan and peripheral devices for screencast pairing.

(5) Local network permission: When you use the screencast feature, we need this permission in order to pair with the device in the local area network for screen transmission.

You can enable or disable the above permissions, change the authorization scope or withdraw your authorization in the settings of your device. You can also adjust relevant system permissions in APP Arohar through the path: [My]-[Settings]-[Privacy Management]-[System Permission Management]. Please note that if you enable any permission, it means that you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you disable any permission, it means that you cancel the authorization, and we will no longer collect or use relevant personal information based on the corresponding permission, and cannot provide you with the services corresponding to this permission. However, your decision to disable the permission will not affect the previous collection and use of information based on your authorization.

3. Other rules for the collection and use of personal information:

(1) Please understand that there may be adjustments and changes to the features and services provided by Arohar, with the development of our business. In principle, when a new feature or service is related to the feature or service we currently provide, the personal information collected and used will be directly or reasonably related to the original processing purpose. In scenarios that are not directly or reasonably related to the original processing purpose, we will inform you again and obtain your consent before we collect and use your personal information.

(2) The sensitive personal information we collect has been displayed with prominent signs in this Policy. Once your sensitive personal information is leaked, falsified or used illegally, it will cause damage to your personal or property safety. In order to prevent your sensitive personal information from being leaked or used illegally, we have taken appropriate technical and organizational protection measures to ensure the security of your information.

(3) If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to us. If the personal information of children (Anyone under the age of 13) ,you need to obtain the consent of the corresponding child's guardian before providing the information. In the aforementioned case, the guardian has the right to contact us through the channels specified in this policy to request correction or removal of the content that involves children's personal information.

4. Except for circumstances with prior authorization and consent:

According to relevant laws and regulations and national standards, we will collect and use your personal information in accordance with the law without your consent in the following circumstances:

(1) Necessary for the conclusion and performance of a contract to which you are a party;

(2) Necessary for performance of legal duties or legal obligations;

(3) Necessary for responding to public health emergencies, or protecting the life, health and property safety of you or other natural persons in an emergency;

(4) Collection of personal information within a reasonable range for use in news reports, public opinion supervision and other acts for the public interest;

(5) Collection of the personal information that you have disclosed by yourself or others legally within a reasonable range in accordance with the law;

(6) Other circumstances stipulated by laws and administrative regulations.

 

III. How We Use Cookies and Similar Technologies

1. Cookies

To ensure the proper functioning of the APP, we will retain small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, the APP can retain your preference data.

We will not use cookies for any purpose other than those described in this Policy. You can manage or delete cookies according to your preferences. See AboutCookies.org for details.

2. Beacons and pixel tags

In addition to cookies, we may also use beacons, pixel tags and other similar technologies. Emails we send you may contain click URLs that link to our content. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. A beacon is usually a transparent image embedded in an email. With the help of pixel tags in emails, we can tell if an email has been opened. If you do not want your activities to be tracked in this way, please enable Do Not Track in your browser to unsubscribe from our mailing list at any time.

3. Do Not Track

Many web browsers have a Do Not Track feature that issues Do Not Track requests. Currently, no major Internet standardization organizations have established policies governing how such requests should be handled. But if your browser has Do Not Track enabled, then all of ours will respect your choice.

4. SDK technology

Some of the features in this application are provided by our cooperative third-party organizations (hereinafter referred to as "SDK technology providers") in the form of SDK plug-ins, and the SDK technology providers will obtain corresponding permissions and information based on the provision of features or services to you. Please read ["Third-party SDK List"], and review the specific SDK cooperation information in APP-[My]-[Settings]-[Third-party SDK List]. We have conducted security testing on the SDKs integrated in this application to ensure that these SDKs only use basic permissions to the extent of implementation of their features or services. If you have any objection, you can feedback to us by email.

 

IV. How We Share, Transfer and Disclose Your Personal Information

1. Sharing of information

We will not share your personal information with any companies, organizations or individuals other than the Arohar provider, except in the following circumstances:

1) Your express consent or authorization is obtained in advance;

2) The personal information is shared in accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative or judicial requirements;

3) The personal information may be shared with our affiliates, jointly with which or in assistance of which, we provide products or services to you. Your personal Information may be shared with affiliated companies of ADDOIL BROADCASTS LIMITED. We will only share necessary personal information and be bound by the purposes stated in this Privacy Policy. If any of our affiliates wants to change the purpose of use and processing of personal information, it will ask for your consent again;

4) Sharing with authorized partners: Only for the purpose stated in this Policy, some of our services will be jointly provided by us and authorized partners. We may share some of your personal information with our partners, so that we can provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share the personal information that is necessary for provision of services. Our partners are not authorized to use the shared personal information for any other purpose. Currently, our authorized partners include the following types:

(1) Authorized partners of advertising and analysis services. Unless we have your consent, we will not share your personal identity information (referring to the information that can identify you, such as name or email address, through which you can be contacted or identified) with our partners that provide advertising and analytics services. We may provide these partners with information about the reach and effectiveness of their advertising, without providing your personal identity information, or we may aggregate such information so that it does not personally identify you.

(2) Suppliers, service providers and other partners. We may send information to suppliers, service providers and other partners that support our business. Such support includes provision of technical infrastructure services, analysis of how our services are used, measurement of the effectiveness of advertising and services, provision of customer services, or academic research and investigation.

We will sign strict confidentiality agreements with the companies, organizations and individuals with which we share personal information, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

2. Transfer of information

We will not transfer your personal information to any companies, organizations or individuals, except in the following circumstances:

1) Transfer with explicit consent: After obtaining your explicit consent, we may transfer your personal information to other parties;

2) Transfer in accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative or judicial requirements;

3) In case of a merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will request the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise we will request the company or organization to seek authorization from you again.

3. Disclosure of information

We will only disclose your personal information in the following circumstances:

1) After your explicit consent is obtained;

2) Disclosure based on law: We may disclose your personal information when required by law, legal process, litigation or government authorities.

4. Except for the circumstances where prior authorization and consent is required before sharing, transferring and disclosing personal information.

In the following circumstances, sharing, transferring or disclosing your personal information does not require your prior authorization and consent:

1) Relating to national security or national defense security;

2) Relating to public safety, public health, or major public interests;

3) Relating to criminal investigation, prosecution, trial or execution of judgments;

4) For protection of life, property and other major legitimate rights and interests of you or others, but it is difficult to obtain the consent of you or others;

5) Your disclosure of your personal information to the public;

6) Collection of personal information from legally disclosed information, such as legal news reports, disclosed government information and so on. The sharing and transfer of de-identified personal information according to the law is not deemed the sharing, transfer or disclosure of personal information, provided that the recipient of the data cannot recover and re-identify the subject of the personal information. The retention and processing of such data will be carried out without further notice to and consent from you.

 

V. Third Party Content and Integration

Our services may contain third party content and integration. For example, you may provide information to third parties as well as Arohar through the integration of editing and streaming of live images, beauty treatment of anchors and background deduction. We are not responsible for how these third parties collect or use your information. As always, we encourage you to review the privacy policies of each third-party service you access or use, including those with which you interact through our services. You can learn more about third-party services in Arohar here.

 

VI. How We Retain and Protect Your Personal Information

1. How we retain information

1) Where the information is retained

The information and materials collected about you will be retained on the server in Arohar in Hongkong of China, in accordance with the provisions of laws and regulations, except in the following circumstances:

1) Laws and regulations clearly stipulate otherwise;

2) Your express authorization is obtained;

3) Your personal initiative actions such as cross-border transactions through the Internet.

2) Duration of retention of information

In general, we only retain your personal information for the shortest time necessary for fulfillment of the purpose. Personal information used to identify you and reflect related activities will be retained until the user logs out of the account, unless required or permitted by law to retain such information for a longer period. However, in the following circumstances, we need to modify the retention time of personal information to meet legal requirements:

1) To comply with applicable laws and regulations and other relevant regulations;

2) To comply with court judgments, rulings or other legal procedures;

3) To comply with the requirements of relevant government authorities or legally authorized organizations;

4) We have reason to believe that we need to comply with relevant provisions of laws and regulations;

5) Reasonable and necessary purposes for the implementation of relevant service agreement or this Policy, the maintenance of social and public interests, and the protection of the personal and property safety or other legitimate rights and interests of Arohar's customers, Arohar App, other users or employees;

6) After you terminate the use of Arohar, we will stop the collection and use of your information, unless otherwise stipulated by laws, regulations or regulatory authorities;

7) If you decide to stop using Arohar, you can follow the steps to delete your account by clicking on Settings in [My] and selecting [Data & Security]" and clicking on [Logout]. We'll also delete most of the information We've collected about you after you've been inactive for a while.

8) When relevant services of Arohar cease, we will notify you by means of text messages or phone calls, and delete or anonymize your personal information retained in the server within a reasonable period of time.

2. Data security measures

1) We will adopt the security protection measures prevailing in the industry, including establishing reasonable regimes and specifications and security technologies to prevent your personal information from being accessed, used or modified without authorization, and to avoid data damage or loss. For example, Arohar uses encryption technologies such as https and transport layer security protocol to ensure the security of user data during transmission; we adopt encryption technology, anonymization processing and protection mechanism to encrypt and save user personal information, and isolate it through isolation technology. We manage and regulate the retention and use of personal information by establishing a data classification and grading system, data security management specifications, and data security development specifications. We only allow those personnel of Arohar and Arohar who have the necessity to know the information, to access personal information, and we set up a strict access control and monitoring mechanism, and request all personnel who have exposure to your personal information to fulfill corresponding confidentiality obligations. If they fail to fulfill these obligations, they will be held legally responsible or suspended from the partnership with Arohar. We will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

2) We will take all reasonably practicable measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for a period as long as is necessary to achieve the purposes described in this Policy, unless an extended retention period is required or permitted by law.

3) The Internet is not an absolutely secure environment, and emails, instant messaging, and communications with other users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us keep your account secure.

4) The internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information you send to Arohar. If Arohar 's physical, technical or management protection facilities are damaged, resulting in unauthorized access, disclosure, falsification or destruction of information, which cause damage to your legitimate rights and interests, we will assume corresponding legal responsibilities.

5) In the event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic circumstance and impact of the security incident, the measures we have taken or will take, recommendations for you to prevent and reduce risks yourself, and remedies for you, etc. We will promptly notify you of the relevant information of the incident by email, letter, telephone, short messaging, etc. When it is difficult to inform the subjects of personal information one by one, we will take a reasonable and effective way to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

 

VII. Your Rights

In accordance with relevant applicable laws, regulations and standards, as well as common practices in other countries and regions, we guarantee your exercise of the following rights over your personal information. You can refer to the following steps to perform related operations:

1. Query, copy and transfer your personal information

You can query your basic account information by following the steps below:

1) Enter Arohar, and click "My";

2) View the required information.

If you cannot access the personal information through the above operations and pages, you can contact us by email (email address: Alohar@i-click.com).

If you want to obtain a copy of your personal information, you can obtain it through the path: [APP Arohar]-[My]-[Settings]-[Personal Information]-[Personal Information Export]-[Enter Receiving Email Address].

If you need to transfer part or all of your personal information to the personal information processor you designate, you can contact us through the contact information set out in this Policy. For a reasonable transfer request that meets the personal information transfer prerequisites required by law, we will respond to your personal information transfer request.

2. Supplement and modify your personal information

You can supplement or modify your personal information through the product or by contacting us. For example, you can modify your mobile phone number through the following steps:

1) Enter Arohar, and click "My"

2) Click Settings and select "Mobile Number Binding"

3) Modify the required information.

3. Deletion of your personal information

You can delete your personal information in the following ways:

1) Enter Arohar, and click "My"

2) Click Settings and select "Data and Security"

3) Click "Account cancellation"

4Follow the steps to delete your account

You may request us to delete personal information in the following circumstances:

(1) The processing purpose stated in this Policy has been achieved, cannot be achieved or is no longer necessary;

(2) You withdraw your consent to the processing of your personal information;

(3) The retention period of personal information has expired;

(4) We process your personal information in violation of laws, administrative regulations or the agreements with you;

(5) You no longer use our products or services, or you cancel your account;

(6) We stop providing products or services;

(7) Other circumstances stipulated by laws and regulations.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and request them to delete it in a timely manner, unless otherwise required by laws and regulations, or these entities have obtained your independent authorization.

When you delete information from our service, we may not immediately delete the corresponding information in the backup system, but will delete the information when the backup is updated.

4. Change the scope of your authorization or withdraw your authorization

You can change the scope of your authorization or withdraw your authorization online through [App Arohar-My-Settings-Privacy Management-System Permission Management]. You can also change the scope of your authorization to Arohar of continued collection of personal information or withdraw your authorization by contacting customer service online or offline.

Each business feature requires some basic personal information to be completed. For the collection and use of additional personal information, you may give or withdraw your authorization or consent at any time. After you withdraw your consent or authorization, Arohar cannot continue to provide you with the services corresponding to the withdrawn consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your authorization.

5. The right to access the Privacy Policy and request explanation

You can view and download the entire content and historical versions of this Privacy Policy on the registration page through the path: [My]-[Settings]-[Privacy Management]-[Privacy Policy]. If you think it is necessary to explain the Privacy Policy, please contact us through the contact information set out in this Policy, and we promise to handle your request in accordance with relevant applicable laws.

6. Other personal information rights

In order to protect the personal information security of a deceased user, you, as a close relative, can contact us through the contact information of this Privacy Policy for your own legitimate and legitimate interests, and can access, copy, correct and delete the personal information generated by the deceased user in the APP.

7. Responding to your above request

Arohar will take appropriate technical means to ensure that you can query, supplement, correct or delete your personal information, or apply for the supplementation or correction of relevant information by Arohar through the feedback or complaint channels released by relevant products or services of Arohar. After receiving your application, Arohar will conduct processing according to the process. For security, you may need to provide a written request according to the process or prove your identity in other ways. Arohar  may request verifying your identity before processing your request. Arohar will reply within 15 days or the time limit stipulated by law. For your reasonable request, Arohar will not charge any fees in principle, but for repeated requests that exceed reasonable limits, Arohar will charge a certain cost as appropriate. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, the need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical.

If you cannot access or modify your personal information, or you need to access or modify other personal information generated when you use Arohar, or you believe that Arohar has violated laws and regulations or any agreement with you regarding the collection or use of your personal information, you can contact Arohar through the official feedback channel of related products or services announced by Arohar.

We will not be able to respond to your request in the following circumstances:

1) Relating to our performance of obligations stipulated by laws and regulations;

2) Directly relating to national security or national defense security;

3) Directly relating to public safety, public health or major public interests;

4) Directly relating to criminal investigation, prosecution, trial or execution of sentences;

5) We have sufficient evidence to show that you have subjective malicious use or abuse of your rights;

6) For personal life and property safety and other major legitimate rights and interests of you or others, but it is difficult to obtain the consent of you or others;

7) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

8) Involving commercial secrets.

 

VIIIInternational Data Transfers

We may collect your personal information from, transfer it to, and store and process it in the United States and other countries outside of where you live. Whenever we share information outside of where you live, when we are legally required to do so, we make sure an adequate transfer mechanism is in place. We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well. You can find more information on the categories of third parties we share information with here.

 

IXState and Region Specific Information

You may have specific privacy rights in your state or region. For example, in the United States, residents of California and other states have specific privacy rights. Snapchatters in the European Economic Area (EEA), the UK, Brazil, the Republic of Korea, and other jurisdictions also have specific rights. We keep an up-to-date overview of state and region specific disclosures here.

 

X. How We Handle the Personal Information of Minors

Our products or services are mainly targeted at adults, and we will not take the initiative to collect personal information of minors. If you are a minor under the age of 18, you may use our products or services only with the consent of your parents or guardians. Minors may not create their own user accounts without the consent of their parents or legal guardians. For the personal information of minors collected with the consent of parents or legal guardians, we will only use or disclose such information when permitted by law, with the express consent of parents or legal guardians, or when it is necessary for protection of minors.

If we discover that personal information of minors has been collected without prior parental consent, we will try to delete relevant data as soon as possible.

 

XI. How We Update this Privacy Policy

Arohar's Privacy Policy may change:

1) Without your express consent, Arohar will not reduce your rights under this Privacy Policy. Arohar will post any changes to the Privacy Policy on a dedicated page. At the same time, Arohar will archive the old version of this Policy for your review;

2) For material changes, Arohar will also provide more prominent notices, including that Arohar will notify you through publicity or even provide you with pop-up prompts.

Material changes referred to in this Policy include, but are not limited to:

(1) Material changes to the service model of Arohar, such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

(2) Material changes to the control rights of Arohar, such as changes in owners caused by mergers and acquisitions, etc.;

(3) Changes to the main subjects of shared, transferred or disclosed personal information;

(4) Material changes in your rights to participate in the processing of personal information and the manner in which it is exercised;

(5) Changes to the department of Arohar responsible for handling personal information security, the contact information and complaint channels;

(6) When the assessment report on personal information security impact indicates that there is a high risk;

(7) Changes made with the release and implementation of policies or laws, in response to national policies or legal norms.

3) We will also archive the historical version of this Privacy Policy for your review, which can be viewed at the bottom of this Privacy Policy page.

 

X. How to Contact Us

If you have any questions or suggestions about this Privacy Policy in the process of using Arohar, please contact us through the following contact information - E-mail of the person in charge of personal information protection:Alohar@i-click.com.

In order to ensure that we handle your questions efficiently and give you feedback in a timely manner, you are required to submit identification, valid contact information, written requests and relevant evidence. We will process your request after verifying your identity. In general, we will reply within 15 days or a period stipulated by law.

If you are not satisfied with our response, especially if you think that our personal information processing has harmed your legitimate rights and interests, you can also lodge a complaint against the Company through your local data protection authority or ADDOIL BROADCASTS LIMITED is domiciled in a court of competent jurisdiction.