Privacy Policy
Welcome and thank you for
choosing VFly. VFly provides an online and mobile chatting and
social networking platform via the https://api-web.vflyapp.com/ website (the “Site”), the VFly client software
(the “Software”, if any) and/or mobile application (the “App” , if any)
and related Internet services (collectively, the “Services”). The Services are
operated by VFly Team.(the “team”, “we” or “us”) for users of the
Services, including you (“you”).
This Privacy Policy explains what information of yours will be
collected by us when you access the Site, Software, App and other
Services (including through the websites and services of our partners), how the
information will be used, and how you can control the collection, correction
and deletion of such information. We will not use or share your information
with anyone except as described in this Privacy Policy. This Privacy Policy
does not apply to information we collect by other means (including offline) or
from other sources. This Privacy Policy is incorporated into, and is subject
to, our Terms of Use and End User License Agreement (the “Terms”). Capitalized
terms that are not defined in this Privacy Policy shall have the meaning given
to them in the Terms.
By accessing and using the Site, Software, App or other
Services, you accept the privacy practices described in this Privacy Policy. If
you do not or no longer agree with this Privacy Policy, please stop your access
and use of the Site, Software, App and other Services.
I. INFORMATION WE COLLECT
1. Information We Collect on Our Own Behalf
A. For our Services: As long as quality of the Services can be
guaranteed, we endeavour to collect your information as minimal as
possible. When you register for an account or during the use of the Services,
we may collect personally identifiable information about you, such as your full
name, ID/passport number, picture, phone number, email address, IP address,
device identifier, geological location, billing information, and so on, as well
as non-personally identifiable information, such as type of network, operating
system and its versions, mobile network operator, manufacturer of device,
messages, images, VoIP data, audio-video streaming data, other content sent and
other activities done by you under the Services, to enable the functions and
features of the Services and comply with applicable laws. If you purchase a
product or service from us, we and/or our third-party payment processors may
also collect your payment information. We may send you service related emails,
as well as promotional emails to the extent permissible under applicable laws.
If you no longer wish to receive these emails, you may opt out of them by
canceling your account.B. Cookies and tracking technologies. Technologies
such as cookies, beacons, tags, scripts and similar technologies are used by
us. These technologies may be used in analyzing trends, administering the
Services, tracking your movements around the Sites, Software and App, and to gather
demographic information about our user base as a whole. Cookies are pieces of
text records being stored in your browser or device that can be read upon
future visits. We use cookies to remember users’ settings as well as for
authentication and analytics, but we may expand our use of cookies to save
additional data as new features are added to the Service. Users can control the
use of cookies at each of their browser application. Please refer to the manual
or help of such browser applications for the method of changing cookies
settings. If you choose to reject cookies, you may still use our Services, but
the functions and features of our Services may not be working correctly. We may
use technologies such as web beacons and single-pixel GIF files to record log
and usage data. We may also use third-party analytic tools such as Google
Analytics, Google Tag Manager, Google AdWords (Conversion Tracking), Yahoo
(Conversion Tracking), Quora (Conversion Tracking), and so on. Some
or all of these tools may be used to track information about your behavior
under our Services depending on your region. For more information or to
opt-out, please visit the respective website(s) of these third-party vendors or
suppliers, or seek for help from our customer service.
C. Information obtained from third parties. You may give us
permission to collect your information from services provided by third parties.
For example, you may connect a social networking service (“SNS”) such as
Facebook or Twitter to your account opened with us. When you do this, it allows
us to obtain information from those accounts (for example, your friends or
contacts).
2. Information We Collect on Behalf of Third Parties Cookies and
tracking technologies. Technologies such as cookies, beacons, tags, scripts and
similar technologies are used by our partners, affiliates, analytics or service
providers for the purpose of analyzing trends, administering the Services,
tracking your movements around the Sites, Software and App, and to gather
demographic information about our user base as a whole to enable us to
customize the application according to your preference We may receive reports
based on the use of these technologies by such companies on an individual as
well as aggregated basis.
3. Information obtained from your device
a) CONTACTS OF PHONE
Used for permissions that are associated with accessing the
contacts in the user's device. This permission allows VFly to
recommend the user's friends in the contacts to the user so that they are able
to share videos and have fun on VFly together.
b) PHONE_STATE
Used for permissions that are associated telephony features.
This permission is triggered by Google Play Install referrer API, which
allows VFly to collect information of app downloading and usage. With
permission of the user, VFly collects the user's local mobile phone
number for the purpose of account matching and friend recommendation from
address book, so that they are able to interact and play with friends
in VFly. However, we won't collect telephony information such as IMEI and
device ID.
c) LOCATION AND IP
Used for permissions that are associated with accessing user's
location. This permission allows VFly to exhibit the user's location
in the profile and recommend interesting people aside the user's location. When
you post information such as audio and video or watch a video posted nearby, we
will seek the user’s authorization to provide user’s location and collect
location information related to the service. This location information includes
information such as IP address and GPS.
d) CAMERA
Used for permissions that are associated with accessing camera
or capturing images/video from the device. This permission
allows VFly to capture the user's selfies in order for them to be
viewed in the profile, or allows the user to take photos and send to friends
on VFly.
e) MICROPHONE
Used for permissions that are associated with accessing
microphone in the user's device. The permission allows the user to shoot videos
on VFly.
f) STORAGE
Used for permissions that are associated with accessing and
uploading from the storage in the user's device. The permission
allows VFly to upload user’s videos from the gallery in the device
on VFly and to download video resources.
g) LIST OF INSTALLED APPLICATIONS
This permission allows VFly to read the list of
installed applications in users' devices. With user's permission, the
information of third-party apps can be accurately provided,
allowing VFly to use such information for analysis to provide better
services.
h) FACIAL DATA
With your permission, we obtain facial data for the purpose of
providing you with "cartoon image" photos which is a feature
of VFly, When using functions such as "anime computer",
"emoji avatar" and "polaroid animation" in the
"cartoon image" module, we generate cartoon images for you based on
the photos provided by you, which we can only access upon you confirming your
permission. The processed images will not contain personally identifiable
information. Such data is used strictly for such features of VFly and
will be deleted after the process. We do not store or share such facial data or
images with any third party.
II. HOW WE USE AND DISCLOSE YOUR INFORMATION
1. How We Use Your Information
A. We use the information you provide in a manner that is
consistent with this Privacy Policy. Generally, we use the information that we
collect to operate and maintain our Services and to respond to your demands and
concerns. If you provide information for a certain reason, we may use the
information in connection with the reason for which it was provided.
B. The Company and its subsidiaries and affiliates
(the “Related Companies”) may also use your information collected through the
Services to help us improve the content and functionality of the Services, to
better understand our users and to improve the Services. The Company and the
Related Companies may use this information to contact you in the future to
offer you additional services.
C. If you have given your consent, we may use the information
that we collect to send you marketing communications or other types of
newsletter. If at any time you wish not to receive any future marketing
communications or you wish to have your name deleted from our mailing lists,
please contact our customer service
2.How We Disclose and Share Your Information
A. The Company is not in the business of selling your
information. We consider this information to be a vital part of our
relationship with you. There are, however, certain circumstances in which we
may share your information with certain third parties, as described below.
B. Personally Identifiable Information. Your information
collected through the Service may be processed and/or stored in India (for
India users), Singapore or any other country in which the Company or the
Related Companies, agents or service providers maintain facilities which are
necessary for the provision of the Services, but we will not rent or sell your
personally identifiable information to any others. Any personally identifiable
information you elect to make publicly available under our Services, such as
posting comments on public visible interfaces, will be available to others. If
you remove information that you have made public under our Services, copies may
remain viewable in cached and archived pages of our Services, or other users
may have copied, saved or captured that information.
C. Non-Personally Identifiable Information. We may share
non-personally identifiable information (such as anonymous usage of data,
landing/exit pages and URLs, platform types, number of clicks, etc.) with
interested third parties to help them understand the usage patterns for certain
Services and those of our partners. Non-personally identifiable information may
be stored in locations outside our direct control and may be stored indefinitely.
D. Instances where we are required to disclose your information.
We will disclose your information where required to do so by law, if subject to
court orders or other legal proceeding or if we reasonably believe that such
action is necessary to (a) comply with the law and the reasonable requests of
law enforcement; (b) to comply with a legal obligation; (c) to protect the
personal safety of users of the Services or the public; (d) to enforce our
Terms or to protect the security or integrity of our Service; and/or (e) to
protect and defend the legitimate rights or property of the Company, Related
Companies, our users or other persons.
E. Other circumstances that we may have to share your
information. (a) Business Transfer. We and/or our stakeholders may buy or
sell/divest/transfer the Company (including any shares in the Company), or any
combination of its products, services, assets and/or businesses. Your
information may be among the items sold or otherwise transferred in these types
of transactions. We may also undergo corporate divestitures, mergers,
acquisitions, bankruptcies, dissolutions, reorganizations, liquidations,
similar transactions or proceedings where your information may be part of the
assets involved. (b) Agents, professional consultants and alike. We sometimes
engage other companies or individuals to perform certain business-related
functions. Your information may be provided to them for such functions
including without limitation professional analysis, technological maintenance
and payment processing. (c) Development use. Developers using our SDK or API
may be given access to their end users’ information, including message content,
message metadata, and voice and video metadata, only for the purpose of
providing the SDK/API functionality within their applications and/or services
which are necessary for the continued provision of the Services. (d)
Testimonials. We may display personal testimonials of satisfied customers on
our Site, Software and App. With your consent, we may post your testimonial
along with your name.
3. Aggregated Information
In a continuing effort to better understand and serve the users
of the Services, we may conduct research on our customer demographics,
interests and behavior based on the information collected. This research may be
compiled and analyzed on an aggregate basis, and we may share this aggregate
data with the Related Companies, agents and business partners. We may also
disclose aggregated user statistics in order to describe our Services to
current and prospective business partners, and to other third parties for
business and other lawful purposes.
III. STORAGE AND PROCESSING OF YOUR INFORMATION
1. Your information collected through the Service may be
processed and/or stored in, Singapore or any other country in which the Company
or the Related Companies, agents or service providers maintain facilities. We
may transfer information that we collect about you, including personal
information, from your country or jurisdiction to other countries or
jurisdictions around the world. The laws of the place where information is
collected, processed or used may not be as comprehensive or protective as the
laws of the country where you live. If you are located in India, please note
that we will only transfer information, including personal data, in accordance
with the Indian laws i.e. Information Technology Act 2000 and the applicable
rules made thereunder. If you are located in the European Union, please note
that we will only transfer information, including personal data, in accordance
with the General Data Protection Regulation (the “GDPR”).
2. Retention of Your Information
A. If you have an account with us, we will retain your
information for as long as your account is active or as needed to be ready to
provide you services. We will retain and use your information as necessary to
comply with our legal obligations, resolve disputes and enforce our agreements.
B. If you are a visitor to our Services, we will retain your
information for as long as necessary but no longer than as required by
applicable laws after your last visit to our Services.
C. To dispose of personal information, we may anonymize it,
delete it or take other appropriate steps. Information may persist in copies
made for backup and business continuity purposes for additional time and will
not be retained for longer than is required for the above mentioned purpose or
as otherwise required under the applicable laws .
IV. HOW WE PROTECT YOUR INFORMATION
1. Protecting your privacy and data is our priority. We always
take reasonable physical, technical or managerial measures to protect the
information collected via the Services from loss, misuse, and unauthorized
access, disclosure, alteration, or destruction. However, no method of
transmission over the Internet or method of electronic storage, is one hundred
percent secure. In particular, email sent to or from the Services may not be
secure. Therefore, you should take special care in deciding what information
you send to us via email. Please keep this in mind when disclosing any
information on the Internet.
2. Compromise of Personal Information
In the event that personal information is compromised as a
breach of security, we will promptly notify our customers in compliance with
applicable law. If such breach of security is caused by any of the following
reasons, you hereby agree that we shall in no circumstance be held liable:
A. Government or judicial authorities seize data from us in
compliance with applicable laws, regulatory policies, administrative or judicial
orders, or on the basis of other lawful grounds.
B. Disclosure or exposure of any personal information resulting
from the user's own action of sharing or leaking his/her account or
password.
C. Any information disclosure caused by hacking, computer virus, trojans or
other cybercrimes, or system failure or telecommunication malfunction, where it
is commercially impractical for current technology to prevent or withstand such
incidents.
D. In the event of an emergency, which endangers public safety
or other person’s life, health or property, your information may be disclosed
to mitigate the situation. If your rights have been jeopardized as a result,
you may claim compensation from the beneficiary of such event under applicable
laws.
E. Any disclosure of your information under an event of force
majeure, or for any other cause that is not attributable to the Company.
V. YOUR CHOICES ABOUT YOUR INFORMATION
1. If being a current user of our Services, you can update
certain information by accessing your profile via “Settings” or other
interfaces alike. You can also unsubscribe from certain emails and
notifications by clicking the “unsubscribe” button or link or switching off
relevant features. You can opt out from certain cookie-related processing by
following the instructions given by the manual or help screen of your browsers.
2. You have the right to request to review, correct, update or
delete inaccuracies to certain information about you that we keep on file by
logging into your account to update your relevant information. Alternately, you
can contact our customer service to make such requests and inquiries. So long
as applicable laws mandatorily require, you have the right to request that we
provide, rectify or delete the personal data or restrict the processing of your
personal data. Additionally, you also have the right to data portability if it
should become relevant and required by applicable laws.
3. You have a right to ask us to stop using or limit our use of
your personal information in certain circumstances. For example, if we have no
lawful basis to keep using your information, or if you think your personal
information is inaccurate and wish to correct it. The rights and options
described above are subject to limitations and exceptions under applicable law.
In addition to those rights, you have the right to lodge a complaint with
relevant supervisory authorities. However, we encourage you to contact us
first, as we will do our very best to resolve your concern.
V. YOUR CHOICES ABOUT YOUR INFORMATION
1. The GDPR
We make every endeavor to comply with the GDPR framework as set
forth by the European Union regarding the collection, use, and retention of
personal data in relation to European Union member countries.
2. Children’s Privacy
Our Services are not for users below age 18 and we do not
knowingly collect personal information from children under the age of 18. If
you are a parent or guardian of a child under the age of 18 and believe he or
she has disclosed personal information to us, please immediately contact our
customer service. In the event that we learn that we have collected personal
information from a child under age 18, we will halt the processing of such
information and will take reasonable measures to promptly remove applicable
information from our records.
3. “Do Not Track” Policy
California law requires that operators of websites and online
services disclose how they respond to a “Do Not Track” signal. Because there is
not yet a common understanding of how to interpret “Do Not Track” signals, we
do not currently respond to “Do Not Track” signals. We are willing to continue
to work with the industry to define a common understanding of how to treat “Do
Not Track” signals.
VII. OUR LEGAL BASES FOR COLLECTING AND HANDLING OF YOUR
INFORMATION
The laws in some jurisdictions require companies to tell you
about the legal basis they rely on to collect, use or disclose your personal
information. To the extent those laws apply, our legal grounds include but are
not limited to:
A. To perform the contractual obligations. Much of our
processing of personal data is to meet our contractual obligations to our
users, or to take steps at users’ request in anticipation of entering into a
contract with them.
B. Legitimate interests. In many cases, we handle personal information
on the ground that it protects or furthers the legitimate interests of us, our
users and other persons in ways that are not overridden by the interests or
fundamental rights and freedoms of the affected individuals.
C. Legal compliance. We need to use and disclose personal
information in certain ways to comply with our legal obligations.
D. Consent. Where required by applicable laws, and in some other
cases, we handle personal information on the basis of your implied or express
consent.
E. Where the GDPR is applicable, Clause 6(1)(a) through (f) of
the GDPR.
VIII. ADDITIONAL POLICIES
1. Unsolicited information
You may provide us with ideas for new products, services or
improvements to existing ones, and other voluntary and unsolicited submissions (collectively,
“Unsolicited Information”). All Unsolicited Information shall be deemed to be
non-confidential and we shall be free to reproduce, use, disclose, and
distribute such Unsolicited Information to others without limitation or
attribution.
2. Links to Other Websites or Services
We are not responsible for the practices employed by websites or
services linked to or from our Service or Sites, including the information or
content contained therein. When you use a link to go from our Services to
another website or service, this Privacy Policy does not apply to such
third-party websites or services. Your browsing and interaction on any
third-party website or service, including those that have a link or
advertisement on our website, are subject to that third party’s own rules and
policies.
3. Notification Procedures
It is our policy to provide notifications, whether such
notifications are required by law or are for marketing or other business
related purposes, to you via email, written or hard copy notice, or through
conspicuous posting of such notice on the Services, as determined by us in our
sole discretion. We reserve the right to determine the form and means of
providing notifications to you, provided that you may opt out of certain means
of notification as described in this Privacy Policy.
4. Changes to this Privacy Policy
All changes to this Privacy Policy may be made any time and from
time to time where we deem necessary and appropriate, and will be effective
when they are posted on this page. When we change the policy in a material
manner, we will give you a notification via email and/or a prominent notice on
our Site, Software and/or App, prior to the change becoming effective. If you
do not or no longer agree with such changes, please stop your access and use of
the Site, Software, App and other Services.
5. This document is written in the English language and shall be
the only authentic text. We may provide translations in other languages in
different regions we operate for your convenience, but in case of any
discrepancies between such translations and this English text, this English
text shall always prevail.
6. NON-REFUND POLICY: Unless otherwise required by the
applicable law, no refund will be entertained after the virtual items have been
purchased.
7. Contacting us. If you have any questions about this Privacy
Policy or your rights under applicable data protection law including any
complaints or questions in relation to the content of our product, you may
contact our Grievance Officer at: 9 Raffles Place, #26-01 Republic Plaza,
Singapore (048619), attention to: Grievance Officer, VFly Team. The
Grievance Officer shall endeavor to address the any complaints or questions
within one month from receipt of the same.