Privacy Policy

Privacy Policy

This Privacy Policy (“this Policy”) explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Policy only applies to personal information that we collect through all Loklok products and services that are offered on our APP.

Your consent to this Policy or continued usage of Loklok services will be deemed as consent and authorization for us to collect, use, store and process your personal information as per this Policy. We will update this Policy from time to time and will notify you of such in one or several manners by push notification, website announcement or pop-ups.

Please read through this Privacy Policy carefully and fully understand the entire content of this Privacy Policy before using our Services. If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Privacy Policy.

 

  1. What personal information about you that we collect and process
  2. Use your personal data
  3. Share your personal information with whom
  4. The use of cookies and similar technologies
  5. Keep your personal information secure
  6. International data transfers
  7. Retain your personal information time
  8. Your data protection rights
  9. Information relating to children
  10. Updates to this Privacy Policy
  11. How to contact us

 

  1. What personal information about you that we collect and process

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, we may ask you to provide your contact details in order to register an account with us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

1) Registration as a user of our Services

We offer multiple choices of how you can register as a user of our Services. Please note that registration is not a prerequisite for using our Services. When you sign up and log in to your Loklok account, you need to complete a series of signup procedures following the guidance. During this process, you need to provide us with the following information: mobile phone number and we will generate your user ID number on Loklok. You may fill in relevant information such as your nickname , birthday, personalized signature or profile photo during registration or in future use. You should ensure the correctness of such information. We collect such information to provide account registration and log-in services and to protect your account and prevent safety risks.

2) Expressing your Viewing Preference

When you start using our Services, you can provide us with your Viewing Preference by clicking the channels, creators or interest tags, etc.

3) Creating your profile on Loklok

You can go to account setting to provide more personal information about yourself such as data of birth,, nickname, profile picture, personalized signature. Please note that this step is completely optional for you to use our Services.

 

Information that we collect automatically

When you use our Services, we may collect certain information automatically from your device. In some instances, our use of your personal information may result in automated decisions being taken (including knowing your preference and prompting the relevant videos to you based on your expressed Viewing Preference). Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review. You can use the settings on Loklok to express your preference over certain videos and the algorithms will record your choice and will accordingly reduce the sharing of such videos of the similar category to you.

1) Security, administration and management of the platform of our Services

When providing our Services to you, we will automatically collect your device information (including hardware model, operating system version number, MAC address, network device hardware address, unique device identifier, IP address, software version number, network access method and type, network quality data, log of operation, usage and service, device name, system language, advertising identifier) and your IP address, your application crash message, your login time and attempts, your behavioral information. We collect such to (i) ensure your safety and security including reviewing UGCs, messages and associated metadata for breach of our Community User Code of Conducts and other inappropriate content; (ii) to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on Loklok; (iii) carry out data analysis and test the Platform to ensure its stability and security; (iv) provide you with user support; (v) enable you use certain practical functions, such as recommending quality videos in your area. We will roughly infer your location based on IP address.

2) Data analytics

When you enter a search word to search for videos, your search words and search logs will be analyzed by us among other users of our Services in order for us to find the trends. Please rest assured that your search words will not be disclosed to anyone in our analytics and you can choose to erase your search words.

3) Video display and playback

You can use video display and playback on Loklok and we will collect your device information including your IP address, equipment type, model, device name, Universally Unique Identifier, operating system, language setting, APP version and your behavioral information to record where you pause on a specific video.

 

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including certain SDK providers where they record the potential IP address or device ID being identified as a potential security concern if such IP address or device ID has launched cyber security attack before). Our professional security team will reinforce the security of personal information (including reporting of sensitive information, encrypted storage of sensitive information, and access control, etc.).

You understand that it is important and a legitimate interest to us to maintain the security and safety of the community of Loklok users and our Services, such as to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

 

  1. Use your personal data

We will use the information we collect about you in the following ways:

1) enforce our terms, conditions and policies;

2) provision, processing, maintenance, R&D and improvement of our Services;

3) personalize the content you receive and provide you with tailored content that will be of interest to you;

4) communication with you, including sending commercial promotion information, operation activity notice and update of agreement;

5) ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Policies and other inappropriate content;

6)provide you with location-based services (where those services are available in your jurisdiction);

7) conduct market survey and trend analysis, and comprehensive statistics, data analysis, processing and investigation related to our Services.

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

 

  1. Share your personal information with whom

You can share your personal information or other information with any third party (including unspecified objects) based on our Services. For example, you can choose social APP (such as Facebook) or other applications to share relevant information when you using the sharing function of our Services. The information you shared to any third-party applications will be controlled and processed by such third party, subject to its service terms and privacy policy. You should solely bear the responsibility for any disclosure, misuse or similar circumstances due to your sharing and we shall bear no responsibilities in this regard.

We may disclose your personal information to the following categories of recipients:

1) Business partners: if you choose to register to use the Platform using your social network account details (including Facebook, Google, Apple), you will provide us or allow your social network to provide us with your username and public profile. Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as WhatsApp or a link to the content will be shared.

2) Payment providers: if you choose to become our Premium and activate the Premium Services, we will share data with the relevant payment provider to facilitate this transaction. We share a transaction ID to enable us to identify you once you have made the payment.

3) Service providers: we provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that Loklok is a safe and enjoyable place.

4) Analytics providers: we use analytics providers (including Appsflyer, Firebase) to help us in the optimization and improvement of our Services. Our third party analytics providers also help us serve targeted advertisements.

5) any competent law enforcement body, regulatory, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.; (iv) detect, prevent or otherwise address security, fraud or technical issues; (v) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction); (vi) enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof. For example, if the UGC that you upload is in breach of applicable laws in one jurisdiction or more, we may be obligated to provide certain information about you at the request of the competent law enforcement body, regulatory, government agency, court.

10) any other person with your consent to the disclosure.

 

  1. Cookies and similar tracking technology

We and our vendors and service providers may use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyse which web pages you click on and how you use our Services, enhance your experience using Loklok, improve our Services, and provide you with targeted advertising on Loklok across your different devices. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. For example, we use Cookies and similar tracking technologies offered by Google.

 

  1. Keep your personal information secure

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. For example, we use SSL to encrypt and protect data; we have established an access control mechanism to ensure that only authorized personnel can access personal information of our users; we hold security and privacy protection training courses from time to time to increase employees’ awareness of the importance of protecting personal information.

To prevent the occurrence of security accidents, we have established a special data security department and formulated a proper early warning mechanism and emergency response plan. In the event of a personal information security incident, we will promptly inform you in accordance with the requirements of applicable laws and regulations in a manner that is appropriate and sufficient to bring this to your attention, and we will immediately activate the emergency plan to minimize the loss.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

 

  1. International data transfers

Your personal information will be stored and retained in Singapore and may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. For the purpose of security maintenance and business intelligence purpose and other necessary purposes .

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. Internally, we also enter into intra-group data transfer agreements with these affiliates of Loklok group and our services providers or business partners outside Singapore to require them to protect your personal information when processing your personal information to provide Services to you.

 

  1. Retain your personal information time

Generally, we only need to store your personal information in the shortest period of time possible for provision of our services and after such period, we will delete or anonymize your personal information as per the requirements of relevant laws and regulations. If such information is shared by us to any third party, we will also require such third party to do the same. However, in the following circumstances, we may alter the period for storage of information due to relevant legal requirement:

1) to follow relevant provisions of applicable laws and regulations;

2) to follow court decision, ruling or other legal procedures;

3) to follow the requirements of relevant government organs or statutory authorized organizations;

4) we deem necessary to follow relevant provisions of laws and regulations;

5) for proper and necessary purposes to execute relevant service agreement or this Policy, maintain social public interests, and protect the personal and property safety of us, our related companies, our partners, other users or employees, or to protect other lawful rights and interests.

 

  1. Your data protection rights

As a user of our Services, you have the following data protection rights:

1) Right to access

You can inquire or access your relevant personal information in our Services, including:

Account information: You can log in to your personal account at any time through related product page to access the personal information in your account including profile photo, nickname, birthday and gio;

Usage information: You can inquire part of your usage information at any time through the related product page, including collection history, viewing history and downloads;

2) Right to correct

You may rectify/alter part of your personal information by following the operation guide and settings on relevant product pages in Loklok and you can also contact us to directly modify or alter your data.

3) Right to delete

You may request deletion of your personal information by emailing us at johnkenden302@gmail.com. If you want to remove your information of our Services regarding to your Facebook account，you can follow our data deletion instructions URL . For some of your personal information, you can also voluntarily delete the information you provided through the functional pages of related products and services we provide.

You can directly demand of us to delete your personal information or notify the receiving third party to delete such if we collect, use or share your personal information in violation with relevant laws and regulations, except where such data has been anonymized or otherwise stipulated by relevant laws and regulations.

You understand and agree that once you delete your personal information from our Services by yourself or with our help, we may not immediately delete your information from the backup system subject to applicable laws and regulations and relevant security technology, in which case, we will store your personal information in a secure manner and separate such from any further data processing, till such information is deleted or anonymized during the update of our backup system.

4) Right to limit or refuse processing of personal information

You may limit or refuse the processing of part of your personal information if such rights are granted to you according to the law of your judicial jurisdiction area and we will handle your request based on such law while considering your actual conditions.

5) Right to cancel your account

You can also de-register your account. We will then contact you and end you our Account Termination Agreement via the contact channel. Please read it carefully. After we verify your identity and obtain your confirmation, we will delete or anonymize all relevant personal data generated by you in Loklok in accordance with relevant laws and regulations, unless otherwise required by laws and regulations. You can also email us at johnkenden302@gmail.com to exercise the right.

6) Right to withdraw your consent

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. For example, you can withdraw the authorization to use “camera” by clicking “Me-Setting-Permissions”.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

7) Right to obtain the copy of personal information

If you need to obtain the copy of your personal information, you can contact us via the contact information in this Policy and upon verifying your identity, we will provide the copy of such information in our services for you within the period prescribed and in accordance with the law, unless otherwise stipulated by the applicable laws and regulations or as otherwise agreed upon in this Policy.

8) Right to complain

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

To exercise your rights above you may also contact us using the contact details under the “How to contact us” heading below.We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect the security of your account and your personal information, we may ask you to provide certain additional information to verify your identity before we respond to your requests.

 

  1. Information relating to children

Children under the age of 14 are not allowed to register and create their own accounts for the Services. If you are 14 above but are considered a minor in your country (please refer to the following table) , you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to create your Loklok account. Children of all ages may use the Services if such use is allowed by their parent or legal guardian. If you are a parent or legal guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create his/her own account or to use the Services. You agree that you will be subject to this Privacy Policy and be responsible for your children’s activities while using the Services. You agree to supervise your children’s use of the Services and make sure that your children only view the contents that are age appropriate to your children.

Country / Region in which the user is located Minimum age of the user：Indonesia 21/Malaysia 18/Philippines 18/Vietnam 16/Thailand 20

 

  1. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance and materiality of the changes we make. We will obtain your consent to any material changes to this Privacy Policy if and where this is required by applicable data protection laws.

 

  1. How to contact us

If you have any questions or concerns about this Privacy Policy and our use of your personal information, please contact our at johnkenden302@gmail.com.

 

 

 

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