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"
4)Follow
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.
VIII.International 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.
IX.State 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.