HaloHub Privacy Policy

When you use HaloHub services, HaloHub may collect and use your information.

Through this Privacy Policy, HaloHub hopes to explain to you how HaloHub collects, uses, stores and shares this information when you use HaloHub 's services , as well as the ways HaloHub provides you with to access, update, control and protect this information. This Privacy Policy is closely related to the HaloHub services you use . HaloHub also hopes that you can read it carefully and make the choices you think appropriate according to the guidance of this Privacy Policy when necessary. HaloHub will try to explain the relevant technical terms involved in this Privacy Policy to you in a concise and concise manner. By using our products, you understand and agree that we are providing you with a platform to post content, including photos, voice, video, comments and other materials (hereinafter referred to as "User Content") on the products and share User Content publicly.

A. What kinds of information do we collect?

When we provide the HaloHub Services, we obtain information about you in the ways discussed below. Please note that we need certain types of information in order to provide you with the HaloHub Services.

i. User-Provided Information

ii. Information collected for legitimate interests

Registration information and personal profile. HaloHub allows users to create an account in the product using your third-party platform account. When you create an account, we may collect personal information you provide to HaloHub , such as your name, gender, birthday, self-introduction, languages speaking, photos, etc. We will also collect information from third-party accounts that can be used to identify you.

User-generated content (“ UGC ”), such as comments, text, messages, pictures, images, video, sounds, code, or other data or materials that you upload, distribute, or stream on the Application when you use the HaloHub Services;

Payment information, such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number, or other payment information required for payment;

Transaction information such as transaction serial number and transaction history after you purchase paid services;

Information you provide when you participate in in-app surveys and activities.

HaloHub account by connecting to a third-party social media (such as Google) , or if you connect your HaloHub account with a third-party social media account, information you provide from the social media;

When you use our products, we may collect information about your device or information sent by your mobile device, such as the operating system, language and Android ID, your IP location and log files when you use our products.

When you use HaloHub , we may request your mobile phone status permission to ensure the arrival rate of push notifications and avoid repeated push notifications. We promise not to disclose any of your mobile phone information.

Small text files (Cookies). We may use small text files or similar technologies to collect information about how you use our products and their features.

Information you choose to post and/or publicly display. You can post your photos, voice or other materials on our products and share them with others in/through our products. These materials you post will still be under your control, and you can still choose whether to post, display or remove such materials.

Log information (log). When you use the Products, HaloHub servers will automatically record the activities and related information you create. This log information may include: the links you click on to our Products, the video streams you watch, the date and time you access the webpage, product features and other statistics and small text file information. We may also collect information from your interaction with the Products to understand your interests and customize and improve our Products and features.

Your IP address. When you use the product to provide more specific features or services, we may collect your IP address information.

When you subscribe or purchase a Paid Service from us directly (rather than through the iOS or Android Platform), you may provide us or our payment service providers with information such as your charge or credit card number or other financial information.

HaloHub Services for legitimate interests , we may collect some or all of the following personal information about you:

Web activity information, such as your browsing history, search history, videos or pages you visit, the date and time of your visit, other users' accounts to which you subscribe, and information about your interactions with other users;

We may need to use the system permissions in your device (excluding permissions called by third parties) to collect relevant personal information. Although we have already touched upon this in the previous section, this section will summarize and organize all the system permissions used by HaloHub 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 features of HaloHub.

Album and storage permissions

Once 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 HaloHub 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 functions 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 "Voice Party Room" on other content, we will apply for your floating window permission. If you refuse such authorization, the above function 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 .

B.Third-party SDKs we use

SDK: RongCloud

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.

Please note that when you use our services, you voluntarily share or even disclose your information, which may involve your personal information or the personal information of others. Please carefully consider whether to share or even disclose such information when using our services.

You are responsible for maintaining the confidentiality of your password and account information at all times.

In order to enhance the user experience and functionality of HaloHub, we may use third-party SDKs (Software Development Kits). These SDKs may collect, process or store user data. We promise to take all reasonable measures to protect your privacy and ensure the security of your personal information when using these SDKs.

Purpose of data use: Data collected by third-party SDKs is only used to provide relevant functions of their services, such as advertising display, personalized recommendations, data analysis, etc. The data will not be used for purposes unrelated to these functions.

Data Sharing: We will not share your personal information with any other third party without authorization. Data will only be shared with relevant third parties when required by law or to achieve application functions (such as payment processing, advertising display, etc.).

Data anonymization and de-identification: For analysis of usage data, HaloHub and third-party SDKs usually perform anonymization or de-identification to ensure that your personal identity cannot be directly identified through the data.

User Control and Choice

We respect your privacy and provide flexible controls to help you manage your privacy settings in HaloHub:

Data permission management: You can control the permissions of HaloHub and third-party SDKs in the privacy settings of your device, and choose whether to allow apps to collect location information, device information, etc.

Disable ad tracking: You can choose to disable the ad tracking function of the advertising SDK and stop the display of personalized ads.

Opt out of data collection: You can opt out of data analysis or turn off data collection at any time in the app's privacy settings.

Compliance and legal compliance

We promise that the use of all third-party SDKs will comply with relevant laws and privacy protection requirements:

Comply with privacy laws and regulations: including but not limited to the EU General Data Protection Regulation (GDPR), the US California Consumer Privacy Act (CCPA) and other relevant data protection laws.

Cross-border data transfer: If cross-border data transfer is involved, we will ensure that such data transfer complies with relevant legal requirements and take appropriate measures to protect your privacy and data security.

We will review and update the Privacy Policy regularly to ensure that its content reflects the latest legal requirements and changes in the third-party SDKs we use. If there are major changes to the Privacy Policy, we will promptly inform you through HaloHub in-app announcements or push notifications.

C. How do we use the information we collect?

We may collect and use the information described above to recommend other user content or features that may be of interest to you.

We use this information to operate, maintain, and provide you with HaloHub features and functionality; to communicate with you directly, such as sending you emails and push notifications; and to allow you to share your creations on HaloHub with your contacts or social media sites. We may also send you service-related emails or messages (such as account verification, order confirmation, changes or updates to HaloHub features, technical and security notices).

HaloHub Services and their content to you , including any interactive features on the HaloHub Services, and providing you with the information, products, or services you allow us to provide; we also collect and use personal information to verify your eligibility and provide prizes associated with promotions and sweepstakes;

Service Improvement: To improve and personalize our Services by providing new services, information, suggestions and feedback;

Customer management: administering Registered Users’ accounts, providing customer support and notifications to Registered Users regarding their accounts or subscriptions, and notifications regarding changes to the HaloHub Services or any other products or services we offer or provide through it;

Communications: To communicate and interact directly with you, for example, we may send notifications about upcoming changes, promotions, or improvements to the HaloHub Services;

Content review: reviewing images, graphics and content posted or generated on the HaloHub Services to ensure that we comply with any applicable content regulations in any relevant jurisdictions;

Content Customization: To conduct research and analysis about your use of or interest in the content, products, or services offered on the HaloHub Services in order to develop and display content on our websites and applications based on your interests;

Performance analysis: determine whether users of the HaloHub Service are unique or whether the same user uses the HaloHub Service multiple times, and monitor aggregate metrics such as total number of visitors, number of videos viewed, and demographic patterns;

Functionality and safety: identifying users who do not meet age restrictions, diagnosing or fixing technical problems, and detecting, preventing, and responding to actual or potential fraud, illegal activity, or intellectual property infringement;

Compliance: to enforce our Terms of Use and comply with our legal obligations;

Aggregate: Aggregate the information we collect about you for one or more of the purposes listed above.

Cookies: We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform and improve our Services. Cookies are small files that, 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 of a page view, a descriptive tag for the page where the pixel is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

In addition, we use your email or other login information or device information to associate your contact or subscriber information with your activity across all devices on our Platform. We are not responsible for the privacy practices of these third parties, and their information practices are not covered by this Privacy Policy.

You can refuse or disable cookies by adjusting your browser settings. Since each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of cookies. In addition, your opt-out choices are specific to the particular browser or device you are using when you opt-out, so you may need to opt-out separately for each browser or device. If you choose to refuse, disable or delete cookies, you may no longer be able to use certain features of the Platform.

Note that we may process your personal information for more than one lawful ground, depending on the specific purpose for which we are using it.

D. How Your Information May Be Disclosed

We will not disclose your information to any other third party, which means any other third party that is not controlling HaloHub , controlled by HaloHub , or under common control with HaloHub . We will not sell any of your information to any third party.

E. Third-party websites

Apps, Services and Websites obtain third-party information (such as information from your Facebook account), typically through an application programming interface. We may provide links to third-party websites such as Facebook as a service to our customers. When you click on a third-party link on an App, Service or Website, you may leave the App, Service or Website. Some of these third-party websites may be co-branded with our name/logo or the names/logos of our affiliates, even if the third-party websites are not operated or maintained by us. This Policy does not address websites operated by third parties, and we are not responsible for websites operated by third parties, whether linked to by an App, Service or Website or otherwise accessible from an App, Service or Website. The inclusion of a link to or access to a third-party website does not imply our endorsement of the third-party website.

HaloHub will not disclose your email and mobile number to anyone. When you pay with Google Pay, Apple Pay, or log in with third-party methods such as Facebook, Twitter, Instagram, etc., they may ask you to enter your email or mobile number. You need to read their privacy policy for details.

We will delete all open platform data as quickly as possible under the following circumstances:

a. When it is no longer necessary to retain the Open Platform Data for legitimate business purposes consistent with these Terms and all other applicable terms and policies;

b. When we stop operating the products or services previously used to obtain these open platform data;

c. When a third party asks us to delete open platform data for the purpose of protecting users;

d. When you request to delete your open platform data or cancel an account created in our products or services (unless the open platform data has been aggregated, obfuscated or de-identified and cannot be associated with a specific user, browser or device), or for technology providers, when you or a customer requests to delete their open platform data or a customer cancels an account created in your products or services;

e. When required by applicable laws or regulations;

i. If applicable laws or regulations require us to retain Open Platform Data, we will retain proof of applicable legal or regulatory requirements or requests and provide it to third parties upon request.

ii. If we receive Open Platform Data in error, we will provide feedback to the third party, delete the Open Platform Data, and provide proof of deletion upon request.

F. Users with whom your information is shared

You share information with other users, and we cannot control the actions of those other users. You share information with other users who use an application, service or website (including through Forums), and we cannot and do not control your information, and we cannot and do not control how those other users will use or share that information. We are not responsible for third parties circumventing our security measures.

G. Sensitive Information

We ask that you not send us any sensitive personal information or disclose any sensitive personal information to us on or through an App, Service or Website (for example, information about race or ethnicity, political opinions or other beliefs, health, sexual orientation, criminal background or past organizational affiliations, including trade union membership).

H. International Users

Some of our systems and equipment are located in the United States and may use applications, services or websites to store and process your information. With your consent to transfer your information to American systems and equipment, the data protection rules provided to you in foreign countries may be different from those in your country and may be less strict. If you object to the transfer of your information or the use described in this policy, please do not use any application, service or website and immediately delete all applications on your user device.

I. Links to other websites or applications

When you click on a link to any other website, mobile application, or third-party content through the HaloHub Services, you will be transferred to another website or other mobile application, and another entity may collect information from or about you. We do not control, do not review, and are not responsible for these third-party websites or mobile applications or their content. Please note that the terms of this Privacy Policy do not apply to these third-party websites or mobile applications or content, or to any information collected after you click on a link to these third-party websites, mobile applications, or content.

J. Data Security

We take appropriate administrative, technical, and physical security measures to protect your personal information from unauthorized access and disclosure. For example, only authorized employees have access to personal information, and they may do so only for permitted business functions. In addition, we use encryption when transmitting certain of your personal information between your systems and ours, and we use firewalls to help prevent unauthorized persons from accessing your personal information. Please be aware, however, that we cannot completely eliminate security risks associated with the storage and transmission of your personal information. You should exercise caution when submitting information through the HaloHub Services, and take particular care in deciding what information you provide to us.

You are responsible for maintaining the confidentiality of your password and account information at all times.

K. Your Choice

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note that your choice to disable cookies will be specific to the particular browser or device you are using when you disable cookies, so you may need to disable cookies separately for each type of browser or device. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

You may opt-out of allowing us to send you push notifications at any time by adjusting the permissions in your mobile device.

If you don't want to share, you can turn off the microphone, camera or other similar features on your mobile device. You can also hide your location, uploaded videos, recent activity time and other information by adjusting the "Privacy" settings.

You can choose not to provide us with personal information, but this may result in you being unable to use certain features of the HaloHub Services, as such information may be required to register as a user, purchase paid services, participate in promotions, surveys, sweepstakes or file complaints.

You can limit ad tracking through your mobile device’s privacy settings.

You can change your information by editing your profile in the App, including accessing your information, correcting or updating your information, or deleting your information.

L. Your rights

The laws of certain jurisdictions grant HaloHub users specific rights, which are detailed in this section. Under applicable law, you may have all or some of the following rights. We will respond to your request as soon as practicable, consistent with applicable law, and usually within one month, after appropriate verification procedures. You will generally exercise these rights free of charge, unless we determine that there is a charge under applicable law.

submit a request to access the personal information we have collected about you by (a) using the help or feedback features on the C Service or (b) sending us your request by emailing us at hw87204@gmail.com .

submit a request to correct the personal information we have collected about you by (a) using the help or feedback features on the HaloHub Service or (b) sending us your request by emailing us at hw87204@gmail.com .

Right to Deletion - You may submit a request to delete the personal information we have collected about you by (a) using the help or feedback features on the HaloHub Service or (b) sending us your request via email. Although we cannot guarantee complete deletion of your data stored in our backup servers, we promise not to use the data in the backup servers for any other purpose.

Right to data portability - If technically feasible, you may ask us to transfer some of your personal information to you or another environment specified by you in a structured, commonly used and machine-readable format by (a) using the help or feedback features on the HaloHub Service, or (b) sending your request by email to hw87204@gmail.com .

Right to withdraw consent - If your personal information was collected based on your consent, you may withdraw your consent at any time and ask us not to continue to collect or process your personal information by (a) using the help or feedback features on the HaloHub Services, or (b) emailing us with your request. Your exercise of this right will not affect processing activities that occurred before your withdrawal.

Right to restrict processing - If you believe that such information has been collected unlawfully or you have other reasons, you may ask us to stop processing your personal information by (a) using the help or feedback features on the HaloHub Service or (b) sending us your request by emailing feedback @hw87204@gmail.com . We will review your request and respond accordingly.

Right to object - You may object at any time by (a) using the help or feedback features on the HaloHub Service or (b) emailing us your request at hw87204@gmail.com . Please note that we may deny your request if we demonstrate compelling legitimate grounds for the processing which override your interests and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.

Rights regarding automated decision making and profiling - If you believe that such automated decision making and profiling has a legal or similarly significant impact on you, you can ask us to stop automated decision making or profiling (a) by using the help or feedback features on the HaloHub Service, or (b) by emailing us your request at hw87204@gmail.com . We will review your request and let you know whether your request is applicable under the relevant laws and regulations.

In addition to the rights set out above, you also have the right to lodge a complaint with the competent data protection authority (“DPA”), which will typically be the DPA in your country.

M. Children's Privacy Policy

We are committed to protecting the privacy and safety of children. We have taken the following measures to protect children's safety:

Minor testing:

In all scenarios, we have enabled AI technology to identify whether there are underage users involved. If suspected minors are found, our system will automatically block their activities and conduct further review and processing of the relevant accounts.

Report of illegal behavior:

If a user reports possible child exploitation or abuse, we will review it as a priority and, if confirmed, submit the relevant information to appropriate law enforcement agencies or relevant organizations (such as NCMEC) as required by law.

Please note that AI detection is only used for identification of minors in private scenarios and will not analyze other content to ensure user privacy.

N. Retention of your information

We will retain your Personal Information and Other Information as long as you maintain your HaloHub account.

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