Last Updated: [2021/04/13]
Your privacy is important to us. This privacy statement explains our collection, use, and disclosure of personal data. This privacy statement applies to Tuyoo Online HK Limited and to our controlled affiliates and subsidiaries (“Tuyoo,” “We,” “Us”). References to our “services” in this statement include our websites, apps, devices, and other products and services. This statement applies to our services that display or reference this statement, but it does not apply to any services that display or reference a different privacy statement.
PERSONAL DATA WE COLLECT
The personal data we collect depends on how you interact with us, the services you use, and the choices you make.
We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.
Information you provide directly. We collect personal data you provide to us. For example:
Information we collect automatically. When you use our services, we collect some information automatically. For example:
Information we or others create or generate. We infer new information from other data we collect, including using automated means to generate demographic data about you, such as age and gender, and other information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.
Information we obtain from third-party sources. We also obtain any of the above categories of information from third parties. These third-party sources include, for example:
When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or function correctly.
COOKIES, MOBILE IDs AND SIMILAR TECHNOLOGIES
What are cookies and similar technologies?
Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.
Software tools refer to software integrated with our apps to provide specific functionalities.
We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the pages you visit, the links you click on, similar usage information, the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use our app). We and our partners also use these technologies to collect personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.
The third-party analytics and advertising providers we use in our services include, for example:
|Company/Service||Purpose(s)||Privacy Notices||Manage Settings (opt-out)|
|Fyber||Advertising||Services Privacy Statement - Fyber|
|Ironsource||Analytics / Advertising||https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/|
|Google Analytics||Analytics||How Google uses information from sites or apps that use our services – Privacy & Terms – Google||https://tools.google.com/dlpage/gaoptout|
To learn about their privacy practices and how to opt-out from their use of personal data for targeted advertising purposes, click on the links above.
These companies may also participate in associations that provide simple ways to opt out of analytics and ad targeting, which you can access at:
|Purposes of Use||Categories of Personal Data|
|Product and Service Delivery. To provide and deliver our services, including troubleshooting, improving, and personalizing those services.||Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences|
|Business Operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.||Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, sensor data, inferences|
|Product Improvement, Development, and Research. To develop new services or features, and conduct research.||Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, inferences|
|Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.||Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, inferences|
|Customer Support. To provide customer support and respond to your questions.||Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences|
|Communications. To send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.||Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences|
|Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners (see the Choice and Control section of this privacy statement for how to change your preferences for promotional communications).||Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, inferences|
|Advertising. To display advertising to you (see the Cookies section of this privacy statement for information about personalized advertising and your advertising choices).||Contact information, demographic data, content and files, identifiers and device information geolocation data, usage data, inferences|
To make such requests or contact our Data Protection Officer, please use the contact information at the bottom of this statement. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.
Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by contacting us at email@example.com.
Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, email us at firstname.lastname@example.org or write to us at Floor 3, Building B, Sunny Valley Chaoyang District, Beijing, China.
Right to Opt-Out. You have a right to opt-out from future “sales” of personal information.
Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” under those definitions. In particular, we let advertising and analytics providers collect IP addresses, cookie IDs, and mobile IDs through our sites and apps when you use our online services, but do not “sell” any other types of personal information. For more information, including how to opt-out, please see the Cookies section of this statement. We do not knowingly sell the personal information of minors under 16 years of age.
Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.
Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.
California Customers may request further information about our compliance with this law by e-mailing email@example.com. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated e-mail address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To request that we remove such content or information, please send a detailed description of the specific content or information you wish to have removed to firstname.lastname@example.org. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
RETENTION OF PERSONAL DATA
We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. After a user deletes Tuyoo apps or their Tuyoo account, personal data that is not needed for the reasons described above, will be deleted after three years.
LOCATION OF PERSONAL DATA
The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States, Europe, China, and Asia-Pacific. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this statement is processed and protected according to the provisions of this statement and applicable law wherever the data is located.
Location of Processing European Personal Data. We transfer personal data from the European Economic Area (EEA), UK, and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
SECURITY OF PERSONAL DATA
We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction.
To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
CHANGES TO THIS PRIVACY STATEMENT
We will update this privacy statement when necessary to reflect changes in our services, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.
HOW TO CONTACT US
If you have a privacy concern, complaint, or a question for Tuyoo or our data protection officer, please contact us at email@example.com.
Our address is Floor 3, Building B, Sunny Valley, Chaoyang District, Beijing, China.