Effective: 2022/1/12
Your privacy and data security are
extremely important to us. We are committed to the responsible management,
protection, and use of your personal information.
This Privacy Policy (the “Policy”)
serves to explain what information Sino Elite Network Co.,Limited
(collectively, “we”, “us”, or “our”) collect, and how we use and protect your
information when you use any mobile applications that we develop and are
available for download in the Google Play Store.
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We collect your device and network connection information in
order to provide you better experience when you use our app.
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This information depends on the context of your interactions
with us, the choices you make, including your privacy settings, and the
products and features you use, and may include:
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SDK/API/JS code version, IP address, platform, timestamp,
application identifier, application version, application distribution channel,
independent deice identifier, the terminal manufacturer, the terminal device
operating system version, the location of the language, the time zone and the
network state (Wi-Fi and so on), the CPU, and the battery use, Screen
resolution, Memory usage, Storage usage, sim operator, sim card country,
Application release status in google play, Ad loading strategy, Ad platform and
advertising placement id. Phone height and width,sim operator name,os version.
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We store the information collected through the Android ID tied
to the device you are using. In this way, we can retain your advertising
behavior while you are using the app. We will treat this information as
personal information
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Number of clicks, landing pages, pages viewed and order of those
pages, the amount of time spent on particular pages, the date and time of your
request, number of the app opened and some viewed page.
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Permissions status.
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Whether the function is running normally, such as whether a
virus is detected.
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Number of apps installed by users.
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package name
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first open time timestamp
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app brand
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app net status
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firebase_device_id
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app model
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sim country
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system language etc
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Advertisers may store or read cookies
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These data only be passed
to the certified third-party statistical platform: Firebase, Facebook Analytics and our self-built data statistics
system (ECS).
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The above information is only used
to improve the product experience and will not be sold to any third parties. We
will not use this information for purposes other than improving the product
experience and ad performance.
Third-party SDKs integrated in our
app may access your information, including:
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Google Advertising ID
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Demographic data (e.g. determination of your IP address)
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Data to fight against fraud (e.g. click fraud in advertising)
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Data associated with your device (e.g. device type,
technological information, country)
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Data to do advertising, marketing and analysis
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Advertisers may store or read cookies
The information collected by
third-party SDKs is governed by the providers of these SDKs and we have no
control over such third parties. The third-parties include monetization
partners, such as Google Admob, Facebook
Audience Network, MoPub, Smaato,
PubNative, IronSource, ChartBoost, Pixalate etc., and also analytical tools
partners, such as Firebase, Facebook
Analytics and our self-built data statistics system (ECS) . The links to the above-mentioned platforms’ privacy policy
are attached in the section “Third-party Privacy Policy”.
We use your Android advertising
identifier in order to provide you with customized advertisement experience. It
is used exclusively for advertising and analytics. Please note that the
advertising identifier does not contain any user sensitive information that can
be used to identify you as a user or your device. It is not connected to
personally-identifiable information or associated with any persistent device
identifier (for example: SSAID, MAC address, IMEI, etc.).
We may collect information that you
directly and voluntarily provide to us. The information includes but is not
limited to: your email address, the content of feedback, and the content of
questionnaire answered by you.
For all information listed above,
pursuant to the EU General Data Protection Regulation (“GDPR”) or any
equivalent legislation (collectively “Data Protection Laws”), we process the
personal information of users located in the European Economic Area (“EEA”),
United Kingdom and Switzerland (collectively, the “Designated Countries”) based
on our contract with you.
To provide better Services to you,
we have a legitimate interest to collect and process necessary data to:
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Update and develop the Services
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Develop and improve your experience
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Manage the relationship with you
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Customize your service experience
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Respond to your comments and questions and provide support to
you
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Provide offers in the Services as well as in other websites and
services
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Send related information (e.g. updates, security alerts, support
messages) to you
To provider the Services, we process
data necessary to:
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Allow you to use the Apps and the Services
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Operate the Services
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Provide and deliver products and services that you request
To send you personalized advertising
and marketing materials, we may use the information collected from you such as
ad identifiers, age, country, region, gender, language, games played by you,
information related to the interaction of you with the Services and with other
users, and so forth.
We may also use various third party
advertising and marketing partners to assist us on our behalf and may share
information collected from you with such third parties for this purpose.
Hence, we have a legitimate interest
to process necessary data to:
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Track the content you access in connection with the Services and
your online behavior
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Deliver, target and improve our advertising and marketing
materials
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Pass the information collected from you to third party
advertising and marketing partners
By accepting this Privacy Policy and
downloading or continuing to use the Services, you consent to us and our
advertising and marketing partners collecting and using information about you
to personalize advertising and marketing materials and to improve your
experience unless you opt out of receiving this service.
We encourage you to review the
privacy policies of our third party advertising and marketing partners so that
you can understand how these third parties collect, use and share your
information. We are not responsible for the privacy policies of any third party
whether accessed through the Services or otherwise.
Ensuring the security in the course
of performing the Services is a top priority for us. We take appropriate
security and technical measures to protect your information from unauthorized
access, loss and misuse. To achieve this purpose, we also request our suppliers
who process personal information on our behalf to take appropriate security
measures.
In order to keep the Service safe,
to fight fraud and to ensure acceptable use otherwise, we have a legitimate
interest to process necessary data to
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Analyze and monitor use of the Services
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Prevent cheating, crime or fraud
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Take action against fraudulent or misbehaving users
Despite our efforts, we cannot
guarantee the absolute security of your personal data, nor can we ensure the
security of any of the communication facilities provided by us. We recommend
that you exercise caution when disclosing any information through the Services.
In particular, please note that any personally identifiable information or
personally sensitive data that you communicate or disclose to any user in
connection with the Services may be collected and used by others. As such, you
should take care of the information shared online. Please also be reminded that
any questions answers, comments, submissions that you post in the forum will be
publicly available.
For all purposes listed above,
pursuant to the EU General Data Protection Regulation (“GDPR”) or any
equivalent legislation (collectively “Data Protection Laws”), we process the
personal information of users located in the European Economic Area (“EEA”),
United Kingdom and Switzerland (collectively, the “Designated Countries”) based
on our contract with you.
As mentioned above, your personal
information may be shared with our third-party partners. We may disclose your
personal information to our business partners, including advertisers,
publishers, and data tracking companies. These business partners may use your
personal information to show you advertisements, measure your ad/site
interaction, and better understand the site and app traffic usage or user
behavior in order to improve their services. Such partners’ use of the
information that we disclose to them will be governed by their privacy
policies.
Depending on the context of your
interactions with us, we may ask you to provide certain permissions in order to
let our app perform properly. You may choose to opt-out anytime, but please
note that not giving us these permissions can result in malfunctioning of our
app. The permissions we ask are listed below:
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Storage
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read the contents of your USB storage
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modify or delete the contents of your USB storage
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Location
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approximate location (network-based)
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precise location (GPS and network-based)
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Device ID & call information
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read phone status and identity
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Wi-Fi connection information
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view Wi-Fi connections
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Photos/Media/Files
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read the contents of your USB storage
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modify or delete the contents of your USB storage
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Camera
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take pictures and videos
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Phone
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read phone status and identity
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Other
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bind to an accessibility service
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update component usage statistics
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receive data from Internet
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full network access
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close other apps
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control vibration
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measure app storage space
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install shortcuts
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view network connections
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reorder running apps
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draw over other apps
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prevent device from sleeping
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uninstall shortcuts
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run at startup
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connect and disconnect from Wi-Fi
We process Personal Data for the
purposes set out in this Privacy Policy, as described above. Our legal basis to
process personal data includes processing that is: necessary for the
performance of the contract with you (for example, to provide you with the
services you request and to identify and authenticate you); necessary to comply
with legal requirements (for example, to comply with applicable accounting
rules and to make mandatory disclosures to law enforcement); necessary for our
legitimate interests (for example, to manage our relationship with you, to
ensure the security of our services, to communicate with you about our products
and services); and based on consent by our customers (for example, to place
certain cookies and to share your information with third parties for
advertising purposes).
In some instances, you may be
required to provide us with Personal Data for processing as described above, in
order for us to be able to provide you all of our services, and for you to use
all the features of our apps. of our app.
We provide you with the rights
described below when you use our Services. Please contact us at SinoElite.feedback@hotmail.com if you would like to exercise your
rights under applicable law. When we receive an individual rights request from
you, please make sure you are ready to verify your identity. Please be advised
that there are limitations to your individual rights. We may limit your
individual rights in the following ways:
Where denial of access is required
or authorized by law;
When granting access would have a
negative impact on other's privacy;
To protect our rights and
properties; and Where the request is frivolous or burdensome.
If we rely on consent to process
your personal information, you have the right to withdraw your consent at any
time. A withdrawal of consent will not affect the lawfulness of our processing
or the processing of any third parties based on consent before your withdrawal.
If you request a copy of your
personal information that we hold, we will provide you with a copy without
undue delay and free of charge, except where we are permitted by law to charge
a fee. We may limit your access if such access would adversely affect the rights
and freedoms of other individuals. You may also request to correct or update
any of your personal information held by us, unless you can already do so
directly via the Services.
You may request us to erase any of
your personal information held by us that: is no longer necessary in relation
to the purposes for which it was collected or otherwise processed; was
collected in relation to processing that you previously consented to, but later
withdrew such consent; or was collected in relation to processing activities to
which you object, and there are no overriding legitimate grounds for our
processing.
You have the right to restrict our
processing your personal information where one of the following applies:
You contest the accuracy of your
personal information that we processed. We will restrict the processing of your
personal information, which may result in an interruption of some or all of the
Services, during the period necessary for us to verify the accuracy of your
personal information;
The processing is unlawful and you
oppose the erasure of your personal information and request the restriction of
its use instead;
We no longer need your personal
information for the purposes of the processing, but it is required by you to
establish, exercise or defense of legal claims; or
You have objected to processing,
pending the verification whether the legitimate grounds of our processing
override your rights.
We will only process your restricted
personal information shall with your consent or for the establishment, exercise
or defense of legal claims or for the protection of the rights of another
natural or legal person or for reasons of important public interest. We will
inform you if or when the restriction is lifted.
You may object to our processing at
any time and as permitted by applicable law if we process your personal
information on the legal basis of consent, contract or legitimate interests. We
can continue to process your personal information if it is necessary for the
defense of legal claims, or for any other exceptions permitted by applicable
law.
If we process your personal
information based on a contract with you or based on your consent, or the
processing is carried out by automated means, you may request to receive your
personal information in a structured, commonly used and machine-readable
format, and to have us transfer your personal information directly to another
“controller”, where technically feasible, unless exercise of this right
adversely affects the rights and freedoms of others.
If we share your personal
information with third parties, we will notify them of any requests for
rectification, erasure or restriction of your personal information, unless this
proves impossible or involves disproportionate effort. Upon your request, we will
identify such third parties.
You have the right not to be subject
to a decision based solely on automated processing of your personal
information, including profiling, which produces legal or similarly significant
effects on you, unless an exception applies under applicable law.
If you believe we have infringed or
violated your privacy rights, please contact us at SinoElite.feedback@hotmail.com so that we can work to resolve your
concerns. You also have a right to lodge a complaint with a competent
supervisory authority situated in a Member State of your habitual residence,
place of work, or place of alleged infringement.
Here we list the links to the
third-party partners’ privacy policy. Please note that these policies are
governed by the third parties and we have no control over them. Check the
following links to get details about how user data is collected, used and shared.
1.
Google Admob & Firebase
https://policies.google.com/privacy?hl=en
2.
Pixalate
https://www.pixalate.com/privacypolicy/
3. Facebook Audience Network &
Facebook Analytics
https://www.facebook.com/about/privacy
4. Mopub
https://www.mopub.com/en/legal/privacy
5. Trustlook
https://www.trustlook.com/privacy.html
6. smatto
https://www.smaato.com/privacy/
7. PubNative
https://pubnative.net/privacy-policy/
8. InMobi
https://www.inmobi.com/privacy-policy/
9. Pangle
https://ad.oceanengine.com/union/media/privacy
10. Pubmatic
https://pubmatic.com/legal/privacy-policy/
11. Fyber
https://www.fyber.com/services-privacy-statement/
12. Criteo
https://www.criteo.com/privacy/
13. adview
https://www.adview.com/web/policy/privacy
14. admixer
15.AdMob
https://policies.google.com/privacy?hl=en
16.Adjust
https://www.adjust.com/terms/privacy-policy/
17.AppLovin
https://www.applovin.com/privacy/
18.Unity
https://unity3d.com/legal/privacy-policy
We prepare this separate Privacy
Notice for California Consumers to comply with the California Consumer Privacy
Act of 2018 (“CCPA”) and other California privacy laws.This notice is designed
to supplement the information described in our <Privacy Policy> and
applies solely to users who reside in the State of California (“consumers” or
“you”).
IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS POLICY DOES NOT APPLY
TO YOU. PLEASE REFER TO OUR MAIN PRIVACY NOTICE HERE INSTEAD.
As required by CCPA, you( or your
authorized agent) have the right to request us to disclose information to you
about how we collect, use and share your personal information over the past 12
months.These information include: the categories of personal information we
collected; the categories of sources for personal information we collected; our
business purpose for collecting that personal information; the categories of
third parties with whom we share that personal information.
Under the CCPA, You( or your
authorized agent) have the right to opt out of having your information sold or
shared.You (or your agent)have the right to request that we delete your
specific personal information that we collected from you and retained, except
in the following cases Such cases include:
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We need your information to detect security incidents, protect
against malicious, or illegal activity;
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We need your information to identify and repair application
errors that impair existing intended functionality;We need your information to
exercise free speech, ensure the right of another consumer to exercise their
free speech rights, or exercise another right provided for by law.
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We need your information to conduct internal uses that are
reasonably aligned with your expectations based on your relationship with
us;and other cases provided by CCPA and other California laws.
To exercise your rights described
above, please submit a verifiable consumer request to us by SinoElite.feedback@hotmail.com
Only you or your authorized agent
may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for request for information
twice within a 12-month period. A verifiable consumer request must:Provide
sufficient information that allows us to reasonably verify you identity and
make us confirm we collected personal information about you.Describe your
request with sufficient details that allows us to understand and respond to it.
We cannot respond to your request
accurately if we cannot verify your identity.
We endeavor to respond to a
verifiable consumer request within 45 days of receipt. If we require more time
(up to 90 days), we will inform you of the reason and extension period by email
,telephone or other electronic means.
We do not charge a fee to process or
respond to your verifiable consumer request unless it is excessive, repetitive,
or manifestly unfounded. If we determine that the request warrants a fee, we
will tell you why we made that decision and provide you with a cost estimate
before completing your request.
These Services do not address anyone
under the age of 13. We do not knowingly collect personally identifiable
information from children under 13. In the case we discover that a child under
13 has provided us with personal information, we immediately delete this from
our servers. If you are a parent or guardian and you are aware that your child
has provided us with personal information, please contact us so that we will be
able to do necessary actions. For users aged 13~16, they have the right to opt
in, and if you are the parent or guardian of users who are aged 13~16, you can
also contact us.
These Services do not address anyone
under the age of 13. We do not knowingly collect personally identifiable
information from children under 13. In the case we discover that a child under
13 has provided us with personal information, we immediately delete this from
our servers. If you are a parent or guardian and you are aware that your child
has provided us with personal information, please contact us so that we will be
able to do necessary actions.
Any information that is collected is
subject to the Policy in effect at the time such information is collected. We
may, however, modify the Policy from time to time. If such change has been
made, we will provide you additional forms of notice of modifications or
updates as appropriate under the circumstances. Your continued use of our app
or services following the change of the Policy will mean you accept those
changes.
If you have any questions or
concerns about the Policy, you may contact us at email: SinoElite.feedback@hotmail.com