WinkBee - Privacy Policy

WinkBee Video Chat Application (" WinkBee", "we", "Service", or "our") is incorporated into and subject to our Terms of Service, which can be viewed here. In this Privacy Policy, we refer to our products and services as the "Services". Please continue reading to learn more about our data practices. We respect your privacy and want you to understand how we collect, use, and share your data. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or limit our use of your personal data; it is written in plain language, minimizing the use of legal and technical jargon. Your privacy is at the heart of how we design and build the Services and products you know and love, so that you can have complete trust in them and focus on building meaningful connections. Unless we link to another policy or indicate otherwise, this Privacy Policy applies when you visit or use the Services. Your use of the Services constitutes your agreement to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, do not use the Services.

1. Controller

Controller: The controller of the data processing is WinkBee . You can contact us by email at cnyang0818@gmail.com .

2. What data do we collect

This Privacy Policy applies to the websites, applications, and other services we operate. We process personal data that you provide to us as a user of our products (for example, by using our products) and personal data that users provide to us ("Data"). Without some of your Data, such as basic profile details and the types of people you want to meet, we cannot help you make meaningful connections. We also collect information generated when you use our Services, such as access logs, and information from third parties (for example, when you access our Services through a social media account). We also collect some Data automatically, such as information about your device and which parts of our Services you have interacted with or where you spend time.

2.1 Data you provide to us

Account Data: In order to use certain features (such as registering an account), you need to create a user account. When you create or update an account, we collect and store the data you provide, such as your name, gender and date of birth, and assign you a unique identification number ("Account Data").

Profile Data: You may also choose to provide profile information, such as a photo, biographical information, name, or other data. Your profile data will be publicly viewable by others unless you delete your account. To add certain content, such as pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide to us may be considered "special" or "sensitive" in some jurisdictions, such as your racial or ethnic origin, sexual orientation, and religious beliefs. By choosing to provide such information, you consent to our processing of that information.

Usage Data: When you use our services and features, we collect certain data, including messages, audio, photos, videos, gifts and other user data. Of course, as part of the operation of the service, we also process your chat history with other users and the content you post.

Shared Content: Some Services allow you to interact with other users or share content publicly, including gifts you receive, videos you post, and data you provide in your profile. Such shared content may be publicly viewable by others, depending on where it is posted.

 Promotions: When you choose to participate in one of our promotions, events or contests, we collect your registration or entry information. If you win a prize, we collect your financial information as a reward.

 Your account data on other services: If your social media or other online accounts are connected to your accounts on our Services, we may obtain certain information from those accounts. If you log in to our Services through Google , we will ask for your permission to access certain information from that other account. For example, depending on the platform or service, we may collect your name, profile picture, gender, personal information, and birthday.

These platforms and services provide information to us through their APIs. The information we receive depends on what information you (through your privacy settings) or the platform or service decides to provide to us.

If you access or use our services through a third-party platform or service, or click on any third-party links, the collection, use and sharing of your data will also be subject to the privacy policy and other agreements of that third party.

Paid Services Data: All of our paid services are provided through iOS or Android platforms. We only receive transaction receipts provided by these platforms. For security reasons, we do not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

Communication and Support: If you contact us for support or to report a problem or concern (regardless of whether you create an account), we collect and store your contact information, message, and other relevant data, such as your name, email address, operating system, IP address, and any other data you provide or we collect through automated means (described in more detail below). We will use this data in accordance with this Privacy Policy to respond to you and research your question or concern. If you ask us to communicate with another person or otherwise process their information (for example, if you ask us to send an email to one of your friends on your behalf), we collect the information you provide to us about that other person in order to fulfill your request.

Sensitive Information: Please be cautious about posting sensitive information about yourself, such as your religious affiliation and health status, in your profile. While you can voluntarily provide us with this information when creating your profile, it is not mandatory. Please keep in mind that photos or any video clips you post on our services may reveal such sensitive personal information. If you upload and choose to inform us of your sensitive information, you explicitly consent to us processing your information and making it public to other users.

We may need to use the system permissions in your device (excluding permissions for third-party calls) to collect relevant personal information. Although we have already touched upon this in the previous section, this section will summarize all system permissions used by WinkBee to facilitate a more systematic, complete and transparent presentation to you. You can choose whether to authorize us to use the relevant permissions of your device. If you do not authorize us to use the relevant permissions, some services may be unavailable, but it will not affect your use of other functions of WinkBee .

Album and storage permissions

When you agree to enable this permission, we will use the photo album reading and storage function on your device. This function will be used to upload text, images, videos and other content in your device, and can also cache the text, images, and video content generated during your use of WinkBee services. Please be aware that we will not automatically read the storage content of your local photo album. We will only obtain the image/video data after you agree to enable this permission and actively select the corresponding image in the album. If you refuse this authorization, the aforementioned function will not work properly.

Microphone permissions

Once you agree to enable this permission, we will use the microphone function on your device and recognize the voice information you upload. This permission will be used to implement the voice input function and collect and recognize the voice information input during the implementation of the above function. If you refuse this authorization, the above function will not be available.

Message push permissions

Once you agree to enable this permission, we will push messages to you so that you can receive and understand our notifications in a timely manner. If you refuse this authorization, you will not be able to receive the messages we push to you.

Camera permissions

Once you agree to enable this permission, we will use the camera function on your device. This function will be used to take photos and record videos, and collect and identify the pictures and videos taken or recorded during the implementation of the above functions. If you refuse this authorization, the above functions will not be available.

Floating window permissions

In order to float the content of the "Party Room" on other content, we will apply for your floating window permission. If you refuse such authorization, the above functions will not be available.

Device Information Access Permissions

After you agree to enable this permission, in order to protect your account and login security, we will collect your corresponding device information for optimizing user experience, security checks, identifying whether it is a commonly used device, and device binding status. If you are an Android user, your refusal to grant this authorization will result in your inability to use this product and/or service normally. If you are an iOS user, you may not be able to directly refuse or close the above authorization due to the limitations of the iOS system, but for some device information (for example, IDFA information, which is subject to the actual situation updated from time to time by the iOS system policy), you can choose whether to authorize us to collect it. If you refuse to authorize, we may not be able to provide you with the corresponding functions or services (for example, if you refuse us to collect your IDFA information, we will not be able to provide you with personalized display based on the IDFA tracking identifier).

Access network and obtain network status permissions

Our APP can only connect to the Internet after you agree to enable this permission. At the same time, for the purpose of risk control and service provision, we can also monitor network changes and remind users of the current network environment. If you refuse this authorization, you will not be able to use this product and/or service normally.

2.2. Data from others

In addition to the information you provide directly to us, we may obtain information about you from other people or through automated means, including:

System Data: technical data about your computer or device, such as your IP address, device type, operating system type and version, unique device identifiers, device language, browser, browser language and other system data and platform type ("System Data").

Usage Data: We collect information about your activities on our Services, such as how you use them (e.g., the date and time you logged in, the features you used, search preferences, number of clicks, pages shown to you, referring web page addresses, ads you clicked on) and how you interact with other users (e.g., users you connect and interact with, time and date of communication, number of messages you send and receive, amount of content you post).

oDevice Information: We collect information about the device you use to access our Services, including:

Hardware and software information, such as IP address, device type, device-specific and application settings and characteristics, application crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, which are randomly generated numbers that you can reset by going to your device settings), browser type, version and language, operating system, time zone, identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

oOther information with your consent: If you authorize, we may collect your precise geolocation information (latitude and longitude) in various ways, depending on the service and device you use, including GPS or Wi-Fi connection. If you consent, we may collect your photos and videos (for example, if you want to post photos, videos or streaming media on the service).

Approximate Geographic Data: Approximate geographic location calculated based on your IP address, including information such as country, city, and geographic coordinates.

Other partners: We may receive information about you from our partners, for example when our adverts are published on partners’ websites and platforms (in which case they may pass on details about the success of the campaign).

3. How we obtain your data

We use tools such as analytics services and advertising providers to collect the data listed below. Some of these tools allow you to opt-out of data collection.

3.1 Analysis

The main reason we use your information is to provide and improve our services. We also use your information to keep you safe. Read on for a more detailed explanation of the various reasons we use your information, with real-life examples.

Third-party usage analytics tools:

SDK:Rongyun

Manufacturer: RongCloud

Purpose of use: To provide real-time messaging functions and services

Information collected: device brand, device model, ANDROID_ID, operating system version, CPU information, memory usage, IP address, network access method and type, user ID under App Key, application package name, time zone, language, App version number, App Key of App, user token, RongCloud SDK version number, operator code MNO, interface call error code, link failure error code

SDK:Agora

Manufacturer: Agora

Purpose of use: Voice calls

Information collected: network type, user's local IP address, WLAN and cellular network signal status, operating system, device model, CPU, memory, device power, audio stream data, Bluetooth, network latency, packet loss rate, bit rate, resolution, audio bit rate, sampling rate

SDK: Facebook

Manufacturer: Meta

Purpose: Facebook event manager

Information collected: Please refer to https://www.facebook.com/privacy/policy/?section_id=1-WhatInformationDoWe

SDK: google

Manufacturer: google

Purpose of use: Login

Information collected: OpenID

SDK: adjust

Manufacturer: Adjust

Purpose of use: Installation data attribution analysis

Information collected: app activity, device or other identifiers

We try our best to provide security measures for users' personal information to prevent illegal use, unauthorized access, disclosure, leakage, damage and loss of users' personal information. We will use all possible security measures within a reasonable security level to ensure information security. For example, we will use encryption technology (such as SSL), anonymization, encrypted storage and other means to protect your personal information; we will establish a reliable protection mechanism to prevent personal information from malicious attacks; we will establish an access control mechanism and abide by the principle of minimum access to ensure that only authorized personnel can access personal information; we will conduct training courses on security and personal information protection to enhance employees' understanding of personal information protection.

If you find that your personal information, especially your account or password, has been leaked, please contact us immediately so that we can take appropriate measures based on your application.

3.2 Online Advertising

We use third-party advertising services, such as Google’s advertising services (DFP, Admob, AdX) and Facebook Audience Network, to serve online advertisements to our end users in our Services, including mobile applications and websites. Ads may be based on information we know about you (as detailed in Section 2.2 “Data from Others”) and information these advertising service providers know about you based on their tracking data. Ads may be based on your recent activity or activity over time and across other services, and may be personalized based on your preferences and interests. You may also receive personalized online advertisements when using other services. We work with marketing service providers, such as Facebook (hereinafter referred to as “Marketing Service Providers”), to help us promote and advertise our Applications and Services on third-party websites and applications and to measure the effectiveness of our advertising campaigns. We may use data to include you in a “custom audience” that receives WinkBee advertising content (a custom audience is essentially a list of people we think are most likely to be interested in a particular advertisement).

Depending on the type of advertising services we use, we may place cookies or other tracking technologies on your device to collect data about your use of our services and may access these tracking technologies to provide you with personalized ads. To help provide personalized ads, we may provide these service providers with a hashed, anonymized version of your personal information in a non-human-readable form, along with content you share publicly on the services.

If you access or use our services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policy and other agreements of that third party.

All third-party tools are GDPR compliant.

If you are located in a region protected by CCPA and GDPR, you can change your personalized ads preferences from settings.

4. Purposes for which we use your data

To administer your account and provide you with our services

Create and manage your account

Provide you with customer support and respond to your requests

Complete your transaction

Communicate with you about our services, including order management and billing

Help you connect with other users

Analyze your and other users’ profiles to recommend meaningful connections

Show users’ profiles to each other

Improve our services and develop new ones

Administer focus groups and surveys

 Conduct research and analysis of user behavior to improve our services and content (for example, we may decide to change the appearance or even significantly modify a feature based on user behavior)

Develop new features and services (for example, we may build new interest-based features based on user requests).

Prevent, detect and combat fraud or other illegal or unauthorized activity

 Addressing ongoing or suspected misconduct on or off the platform

 Conduct data analysis to better understand and design countermeasures to these activities

Retain data related to fraudulent activity to prevent recurrence

Ensuring compliance with the law

 Comply with legal requirements

Assisting law enforcement

 To enforce or exercise our rights, such as our terms

To process your information as described above, we rely on the following legal bases:

Providing you our Services: Most often, we process your information to perform the contract between you and us. For example, when you use our Services to build meaningful connections, we use your information to maintain your account and profile, to make it visible to other users, and to recommend other users to you.

Legitimate Interests: We may use your information where we have a legitimate interest in doing so. For example, we analyze user behavior on our Services to continually improve them; we recommend offers that we think may interest you; and we process your information for administrative, fraud detection, and other legal purposes.

marketing:

Push message marketing: With your explicit consent, we will send you marketing push messages.

Email marketing: With your explicit consent, we may send you marketing emails.

Text messages: With your explicit consent, we may send you text messages (SMS).

Consent: We may ask for your consent from time to time to use your information for certain specific reasons. You can withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. How We Share Information

5.1 With other users:

When you voluntarily disclose information on the Services, including your public profile, you are sharing information with other users. Please be careful with your information and make sure that what you share is what you would like to see publicly, because once you share your information, neither you nor we can control what others do with it.

5.2 With our service providers and partners:

We use third parties to help us operate and improve our Services. These third parties assist us with a variety of tasks, including data hosting and maintenance, analytics, customer service, marketing, advertising, payment processing, and security operations. These service providers may have access to your personal data and are required to use it only in accordance with our instructions and to provide our requested services.

We may also share information with partners who distribute and assist us in promoting our Services. For example, we may share limited information about you in a hashed, non-human-readable form with advertising partners.

We follow a rigorous vetting process before engaging with any service provider or partner. All service providers and partners must agree to abide by strict confidentiality obligations.

5.3 Where required by law:

We may disclose your information when reasonably necessary to: (i) comply with legal process, such as a court order, subpoena or search warrant, a government/law enforcement investigation, or other legal requirement; (ii) assist in the prevention or detection of crime (in each case, subject to applicable law); or (iii) protect the safety of any person.

5.4 Exercising legal rights:

We may also share information: (i) if disclosure may mitigate our liability in actual or threatened litigation; (ii) when necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; or (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

5.5 Monitoring:

Moderators are responsible for monitoring activity on the Site/App and approving content. Anti-fraud and anti-spam providers are responsible for protecting the Service from criminal activity.

5.6 Change of Control:

We may need to disclose your personal data if our Service or any of its affiliates goes through a business transition or change in ownership, such as a merger, acquisition by another company, reorganization or sale of all or a portion of its assets, or in the event of bankruptcy or administration.

6. Your rights

You have certain rights regarding the use of your data, including opting out of cookies and preventing certain analytics providers from collecting your data. You can update or terminate your account on our services or contact us to make a request regarding your personal data. We want you to be in control of your information, so we provide you with the following tools:

Access/Update Tools in the Services: Tools and account settings that help you directly access, correct, or delete the information you have provided to us and that is associated with your account in the Services.

Device permissions: Mobile platforms have a permissions system for certain types of device data and notifications, such as phonebook, location services, and push notifications. You can change your device settings to agree or object to the collection of that information or the display of that notification. Of course, if you do this, some services may lose full functionality.

Deletion: You can delete your account directly using the corresponding function on the Service.

We want you to understand your privacy rights. Here are some key points to keep in mind:

 Review your information: Applicable privacy laws may give you the right to review the personal information we hold about you (depending on the jurisdiction, this may be referred to as the right of access, the right of portability, or a variation of these terms). You can request a copy of your personal information by sending us an email at cnyang0818@gmail.com .

Updating your information: If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and wish to request correction, deletion or object to processing of it, please contact us at cnyang0818@gmail.com .

To protect your safety and the safety of all of our users, we may ask you to provide proof of identity before we can respond to the above requests.

Please note that we may deny your request for certain reasons, including if the request is unlawful or may infringe upon trade secrets, intellectual property rights, or the privacy of other users. If you wish to receive information about another user, such as a copy of any messages you receive from that user through our Services, that user must contact our Privacy Officer to obtain written consent before the information is released.

Additionally, we may not be able to honor certain requests to object to the processing of your personal information, particularly if such a request would result in us being unable to continue to provide you with our services. For example, if we do not have your date of birth, we will not be able to provide you with our services.

Uninstall: You can stop all information collected by uninstalling the App through your device’s standard uninstall process. If you uninstall the App from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the App on the same mobile device, we will be able to re-associate this identifier with your previous transactions and activity.

Accountability: In some countries, including the EU, you have the right to lodge a complaint with the appropriate data protection authority if you have any concerns about how we process your personal information. The data protection authority to which you can lodge a complaint is usually the authority in your habitual residence, place of work or where we are established.

If you would like to exercise any of the rights listed above, please visit our feedback form or send an email to cnyang0818@gmail.com .

7. Data Retention

We retain your personal information only for as long as it is necessary for legitimate business purposes and as permitted by applicable law. To protect the safety of users within and outside our Services, we maintain a security retention period of six months after account deletion, unless there are technical issues. During this period, some of your account information will be retained, but the account will of course no longer be displayed in the Services. In practice, we delete or anonymize your information after deleting your account (after the security retention period) or after 5 consecutive years of inactivity. An account is considered inactive when the member's application has not established contact with WinkBee 's servers (including due to deactivation of the geolocation process) and the member has not used the application. In any case, the accounts of premium members are not considered inactive.

unless:

 We must retain it to comply with applicable laws (for example, certain “traffic data” is retained for one year to comply with statutory data retention obligations) and to prevent abuse of the system by robotic systems;

 We must retain it to demonstrate our compliance with applicable law (for example, records of consent to our Terms, Privacy Policy, and other similar consents will be retained for five years);

 there is an unresolved issue, claim or dispute which requires us to retain the information until it is resolved; or

 The information must be retained for our legitimate business interests, such as fraud prevention and enhancing the safety and security of our users. For example, it may be necessary to retain information to prevent users who have been banned for unsafe behavior or security incidents from opening new accounts.

Correspondence with our customer support team will be retained for longer to allow us to deal with any follow-up queries you may have, but will generally be deleted after 6 years if no queries have been made.

Anonymous information about activity on our services will be retained for longer periods of time for statistical and product research purposes but will no longer be attributed to an individual once the personal data is deleted.

Please keep in mind that while our systems are designed to perform the data deletion process in accordance with the above guidelines, due to technical limitations we cannot guarantee that all data will be deleted within a specific time frame.

8. Data Protection and Security

We work hard to protect your personal information from unauthorized access, alteration, disclosure or destruction. Like all technology companies, while we take steps to protect your information, we do not promise, and you should not expect, that your personal information will always be secure. Your password is an important part of our security system and you are responsible for protecting it. You should not share your password with any third party. If you believe your password or account has been compromised, please change it immediately and contact cnyang0818@gmail.com with any questions.

We regularly monitor our systems for possible vulnerabilities and attacks and periodically review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

If we suspect or discover any security breach, we may suspend your use of all or part of the Service without notice. If you believe that your account or information is no longer secure, please notify us immediately. We are not responsible for virus protection outside the Service network. We are also not responsible for damage or destruction of user data. We will pursue all detected hacking and other attacks under civil law, even to the courts if necessary.

In the event of a data breach, we will notify EU representatives, our Data Protection Officer (DPO), and potentially affected users within 72 hours of the attack. We will publish a notice on our webpage.

9. Children’s Privacy

Our Services are intended for use by users who are 18 years of age or older. We do not allow users under 18 to access our Platform, and we do not knowingly collect personal information from anyone under 18. If you suspect that a user is under 18, please use the reporting mechanism provided by the Service. If we discover that a child, minor, or anyone under 18 has registered with us and provided us with personal data, we will take steps to terminate the user's registration and remove their profile information from our Services. If we delete your profile for violating our "No Child Registration" policy, we may retain your basic account and profile information to ensure that you do not attempt to circumvent our policy by creating a new profile.

10. International Transfer Policy

In order to provide you with the Services, we must transfer your data to our servers and process it there. By accessing or using our Services, you consent to the storage of your data on our servers. If you use the Services, you consent to the transfer, storage and processing of your data. Specifically, personal data collected in Switzerland and the European Economic Area ("EEA") will be transferred and stored outside of those regions.

WinkBee or our service providers process data outside Switzerland and the European Economic Area, including processing transactions, facilitating payments and providing support services as described in Sections 4 and 5. We have entered into data processing agreements with our service providers to limit and regulate their processing of your data on our behalf. By submitting your data or using our services, you consent to such transfer, storage and processing by WinkBee and its processors. We operate a global network of servers, including in Germany, the Netherlands, Turkey and Canada. We ensure adequate protection of data through effective legal mechanisms. If you would like more information about the security measures we have in place, please send an email to cnyang0818@gmail.com .

11. Changes to the Privacy Policy

We are always looking for innovative ways to help you build meaningful connections, so this policy may change over time. We will notify you of any significant changes before they take effect so you have time to review them.

12. Contact Us

If you have any questions about this privacy statement or the processing of your personal data, please contact us directly. We are also happy to help you if you require information, make a request or make a complaint:

Email: cnyang0818@gmail.com