To see the full Privacy Policy, click here.

In the event that you are somewhere in the range of 13 and 18 years of age, we have likewise arranged a different outline of this strategy and what it implies for you. It is accessible in the application under the ‘Security Policy’ tab.

Synopsis

What data do we gather about you?

We gather and cycle data you give us when you make a record and utilize the Platform. This incorporates specialized and conduct data about your utilization of the Platform. We additionally gather data about you on the off chance that you download the application and utilize the Platform without making a record.

By what means will we utilize the data about you?

We utilize your data to give the Platform to you and to improve and control it. So as to give a viable and dynamic Platform, and where we have decided it is to our greatest advantage, we utilize your data to improve and build up the Platform, forestall wrongdoing and guarantee clients’ security. Where we have your assent, we will likewise utilize your own information to serve you focused on publicizing and advance the Platform

Who do we share your data with?

We share your information with outsider specialist co-ops who help us to convey the Platform including distributed storage suppliers. We additionally share your data with colleagues, different organizations in a similar gathering as Zimpo (counting WayUnique Inc in US which offers specific types of assistance for us regarding the Platform), content control administrations, estimation suppliers, publicists and investigation suppliers. We may impart your data to law implementation organizations, open specialists or with other outsiders just where we are lawfully needed to do as such or if such use is sensibly vital (for example, to guarantee your or another person’s security).

You’re Rights

We offer you settings to control and deal with the individual information we have about you. You additionally have the accompanying rights: you can request that we erase your information; to change or right your information; to give a duplicate of your information and to quit utilizing a few or the entirety of your information. For more data about how to make these solicitations, click here. You can likewise reach us utilizing the contact data beneath, and we will survey your solicitation as per appropriate laws.

We keep hold of your data?

We hold your data however long it is important to give you the administration so we can satisfy our authoritative commitments and exercise our privileges corresponding to the data in question. Where we needn’t bother with your data so as to offer the assistance to you, we hold it just as long as we have a genuine business reason in keeping such information or where we are dependent upon a legitimate commitment to hold the information. We will likewise hold your information if important for lawful cases.

In what capacity will we inform you of any progressions to this Privacy Policy?

We will tell all clients of any material changes to this approach through a notification on our Platform or by different methods. We update the “Last Updated” date at the head of this approach, which mirrors the compelling date of the arrangement. By getting to or utilizing the Platform, you recognize that you have perused this strategy and that you comprehend your privileges corresponding to your own information and how we will gather, use and cycle it.

1. The kinds of individual information we use

We gather and utilize the accompanying data about you:

You’re Profile Information

You give us data when you register on the Platform, including your username, date of birth, email address and additionally phone number, data you reveal in your client profile and your photo or profile video.

Client Content and Behavioral Information

We measure the substance you produce and view on the Platform, including inclinations you set, (for example, decision of language), photos and recordings you transfer, remarks and live-streams you make (“User Content”). We gather data through overviews, difficulties and rivalries in which you partake. We additionally gather data with respect to your utilization of the Platform, for example how you draw in with the Platform, including how frequently you utilize the Platform and how you connect with content we show you, the promotions you see, recordings you watch and issues experienced, the substance you like, the substance you spare to “Top choices”, the words you search and the clients you follow.

We deduce your inclinations, sexual orientation and age to customize content. We additionally construe the interests of our clients to more readily streamline promoting over our Platform. On the off chance that you have agreed, we will utilize this data to serve customized publicizing.

We survey User Content for content control purposes to implement our locale rules, conform to lawful commitments, and forestall and react to mishandle, extortion, criminal behavior and other possibly unsafe substance on the Platform.

We additionally measure data about your supporters, the preferences you get and reactions to content you transfer, for the reasons for customizing your “For You” Feed, elevating your substance to different clients and investigating whether your profile presents open doors for joint effort.

Messages

Where nearby laws permit us to, we gather and cycle your messages, which incorporates examining and investigating the data in those messages through the Platform’s informing usefulness. That data incorporates the substance of the message and data about when the message has been sent, gotten and additionally read, just as the members in the correspondence.

We do this to forestall and square spam, forestall and recognize wrongdoing, shield kids (where this is in the generous open intrigue) or to ensure the interests of our clients and others.

If you don’t mind likewise know that messages sent to different clients of the Platform will be available by those clients and that we are not liable for how those clients utilize or uncover them.

Data from Third Parties

You may decide to impart certain information to us from outsiders or, through your utilization of the Platform, we may gather such outsider information consequently.

Colleagues

In the event that you decide to enlist to utilize the Platform utilizing your web-based media account subtleties (for example Facebook, Twitter, Instagram, Google), you will give us or permit your interpersonal organization to give us your username and open profile. We will similarly impart certain data to the significant informal community, for example, your application ID, access token and the alluding URL. For additional data on sharing your Facebook contact list with us, if it’s not too much trouble see Find different clients and welcome your companions.

Publicists and Measurement Partners

Where you have agreed to customized promoting, we will coordinate your data for example your versatile promoting ID, where it is given to us by sponsors and different accomplices, with your zimpo profile to serve you advertisements. We may likewise serve you advertisements dependent on the data we deduce from the information these accomplices give. You can quit this movement whenever through your application settings by going to ‘Security and wellbeing’ and afterward to ‘Personalization and information’ and quitting ‘Promotions dependent on information got from accomplices’.

We use data gave by our estimation accomplices, to see how you’ve collaborated with our advertisement accomplices’ sites and better survey the adequacy of the promoting on our Platform.

For more data about how our estimation and examination suppliers gather information from the Platform, if you don’t mind see our Cookies Policy.

Specialized Information we gather about you

We gather certain data from you when you utilize the Platform including when you are utilizing the application without a record. Such data incorporates your IP address, occurrence IDs (which permit us to figure out which gadgets to convey messages to), versatile transporter, time region settings, identifier for publicizing purposes and the rendition of the application you are utilizing. We will likewise gather data with respect to the gadget you are utilizing to get to the Platform, for example, the model of your gadget, the gadget framework, arrange type, gadget ID, your screen goal and working framework, sound settings and associated sound gadgets. Where you sign in from numerous gadgets, we will have the option to utilize your profile data to recognize your movement across gadgets.

Area

At the point when you utilize the Platform on a cell phone, we will gather data about your area so as to tweak your experience. We gather your inexact area dependent on your IP address. In specific wards, we may likewise gather Global Positioning System information.

Data about your companions

You can pick whether to discover different clients of the Platform utilizing our “Discover Friends” work and to welcome your contacts to go along with you on the Platform. We will utilize the contact data you have for that individual, for example, from inside your phone’s contact rundown or Facebook companions rundown, and give you the choice to send them either a SMS, email or outsider message, (for example, WhatsApp, Facebook Messenger or Twitter) welcoming them to see your Zimpo profile.

We utilize your own information to discover matches dependent on your contact data and your location book. Be that as it may, your contact data and your location book are private and won’t be unveiled. We utilize a specialized

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We use your personal data to find matches based on your contact information and your address book. You’re contact information and your address book is private and will not be disclosed. We use a technical system to find matches without sending your own information or your address book to us in plain text.

If you want to find other users through your Facebook contacts, you can grant us access to your Facebook contact list. We collect your public Facebook information as well as names and profiles of your Facebook contacts. We will match this to registered users and show you any matches so you can follow them.

Information you provide to us

We collect information you provide us in response to a survey. If you respond to a Zimpo survey, your individual responses will be used for the purpose of the survey and will be shared with other organizations, as explained to you when you participate in a survey. We may also use aggregate data from these surveys in the same way.

We also collect information you provide to us in correspondence.

Proof of your identity or age

We sometimes ask you to provide proof of identity or age in order to use certain features, such as Livestream or verified accounts, or when you apply for a “Pro Account”.

2. Cookies

Cookies, pixels and ad tags are small files which, when placed on your device, enable us to collect certain information, including personal data, from you in order to provide certain features and functionality. We and our service providers and business partners use Cookies to collect data and recognize you and your device(s) on the Platform and elsewhere across your different devices. We do this to better understand the effectiveness of the advertising on the Platform and to enhance your user experience.

3. How we use your personal data

We will use the information we collect about you based on the legal grounds described below.

To perform our contract with you, we will use your information to:

provide the Platform and associated services;
notify you about changes to our service;
provide you with user support;
enforce our terms, conditions and policies;
administer the Platform including troubleshooting;
the content you receive and personalize you with tailored content that will be of interest to you;
enable you to share User Content and interact with other users;
enable our messenger service to function if you choose to use it and are 16 or above;
participate in the virtual items program; and
Communicate with you.

In order to comply with our legal obligations and as necessary to perform tasks in the public interest or to protect the vital interests of our users and other people, we use your data to help us prevent and respond to abuse, fraud, illegal activity and other potentially harmful content on the Platform.

In accordance with our legitimate interests to provide an effective and dynamic Platform, we may use your information to:

ensure content is presented in the most effective manner for you and your device.
understand how people use the Platform so that we can improve, promote and develop it;
promote popular topics, hashtags and campaigns on the Platform;
data analysis is carried out to test the Platform to ensure its stability and security;
verify your identity, for example, to enable you to have a ‘verified account’, and your age, for example, to ensure you are old enough to use certain features;

provide non-personalized advertising, which keeps many of our services free;
infer your interests for optimizing our advertising offerings, which, where you’ve consented to personalized advertising, may be based on the information our advertising partners provide to us;
measure the effectiveness of the advertising you see on our Platform;
inform our algorithms so we can deliver the most relevant content to you and to prevent crime and misuse of the Platform;
carry out surveys regarding our services, products and features;

allow you to participate in interactive features of the Platform; and
Enable you to socialize on the Platform. For example, we may allow other users to identify you via the “Find Friends” function or through their phone contacts or connect you with other users by tracking who you share links with.

Where we process your information to fulfill our legitimate interests, we conduct a balancing test to check that using personal data is really necessary for us to achieve our business purpose. When we carry out this balancing test we also take into account the privacy rights of our users and put in place appropriate safeguards to protect their personal data.

4. How we share your personal data

We share your data with the following selected third parties:

Business Partners

To register to use the Platform using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you provide us or allow your social network to provide us with your username and public profile. Share certain information with the relevant social network such as your app ID, access token and the referring URL.
Where you opt to share content on social media platforms, the video, username and any text associated with the post will be shared on that platform or, in the case of sharing via instant messaging platforms such as WhatsApp, a link to the content will be shared.
To provide the “Find Friends” functionality with your Facebook contact list, we share data with Facebook to allow this function to work.

Service Providers

Information is provided to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.

Analytics and measurement providers

We use analytics and measurement providers to help us improve the Platform including by assisting us with content measurement and following your activity on our Platform across your devices.
Third party analytics providers also help us measure advertising on our Platform and help our advertisers determine whether their advert has been shown on our Platform and how it performed. We share your mobile advertising ID with measurement companies so that they can link your activity on the Platform with your activity on our advertisers’ websites.

Advertisers

We only share aggregated user information with advertisers. Aggregated information is information that is grouped together and is not specific to an individual user. This is done to help measure the effectiveness of an advertising campaign by showing advertisers how many users of the Platform have viewed or clicked on an advertisement.

Our Corporate Group

We share information to improve and optimize the Platform, including to prevent illegal use and to support users.

Legal Obligation

We may share your information with law enforcement agencies, public authorities or other third parties if we consider that we are legally required to do so or if such use is reasonably necessary to:
comply with a legal process or request;
prevent abuse, fraud, illegal activity or security or technical issues; or
Protect property of 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).

Public Profiles

You’re public profile is visible to anyone on the Platform and may be accessed by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. You can also change your profile to private by changing your settings to ‘Private account’ in ‘Privacy and safety’ settings. If your profile is public, other users can use your content to produce and upload further content, for example, by creating a duet with your video.

Sale or Merger

We disclose your information to third parties:
In the event that we sell or buy any business or assets (for example, as a result of liquidation, bankruptcy or otherwise). In such transactions, we will disclose your data to the prospective seller or buyer of such business or assets; or
If we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. User information may be among the transferred assets.

5. Where we store your personal data

The personal data that we collect from you will be transferred to and stored at, a destination outside of the European Economic Area (“EEA”).

6. Your Rights

Settings are offered to control the personal data we have about you.

You have the following rights:

The access you’re Data: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.
Delete Your Data: You can ask us to delete all or some of your personal data.
Change or Correct Data: You can ask us to change or fix your data. You can also make changes using the in-app controls and settings.
Portability: You can ask for a copy of personal data you provided in a machine readable form.
Restrict Use of Data: You can ask us to stop using some or all of your data, e.g. if we have no legal right to keep using it. You can ask us to stop processing your personal data for direct marketing purposes; withdraw your consent or ask us to stop making any automatic individual decisions, including profiling. If you object to such processing, we ask you to share the reason for your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

7. The security of your personal data

Steps are taken to ensure that your information is treated securely and in accordance with this policy. The transmission of information via the internet is not secure, although we do our best to protect your personal data: by encryption. We cannot guarantee the security of your information, which means any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk that may be poised to you and other users. We maintain these technical measures and will amend them from time to time to improve the overall security of our systems.

From time to time we include links to the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service so that we can fulfill our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data.

If you ask us to delete your account it will first be placed into a deactivated state for 30 days (to allow you to request it to be reinstated), followed by the deletion of the account. We will also delete personal data that relates to the in-app messaging function within 30 days of you cancelling your user account. Please note that messages sent to other users of our service are stored on their devices and cannot be deleted by us.

In each case, there are also occasions where we may need to keep your data for longer in accordance with our legal obligations or where it is necessary for legal claims.

9. Information relating to children

Zimpo is not directed at children under the age of 13. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: info@wayunique.com

10. Changes

We will notify you of any material changes to this policy through a notice provided via the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.

If you have questions or complaints regarding this policy, or if you wish to reach the zimpo Data Protection Officer, You can also contact us at the following postal address.

If contacting us does not resolve your complaint you have the right to complain to your local data protection supervisory authority.

Privacy Policy

(If you are not in the US, EEA or Switzerland)

This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.

If you have any questions about how we use your personal data, contact us at: info@wayunique.com

SUMMARY

What information do we collect about you?

We collect information you give us when you create an account and upload content to the Platform. This includes technical and behavioral information about your use of the Platform. We collect information if you download the app without creating an account.

How will we use the information about you?

We use your information to, among other things, show you suggestions in the ‘For You’ feed and ensure your safety. Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Platform.

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as zimpo, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

How long we hold your information?

We retain your information in order to provide the service to you; we retain it only as long as we have a legitimate business purpose in keeping such data subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise legal claims.

How will we notify changes to this Privacy Policy?

You should look at this policy regularly to check for any changes. We will update the “Last Updated” date, which reflects the effective date of such policy. By accessing the Platform, you acknowledge your rights in relation to your personal data and how we will collect, and process it.

1. The types of personal data we use

We collect and use the following information about you:

You’re Profile Information. You give us information when you register on the Platform, including your username, date of birth, email address, telephone number, information you disclose in your user profile, and your photograph or profile video.

User Content and Behavioral Information. The content you generate, including choice of language, photographs and videos improve the upload speed of User Content. We will provide a preload service to upload audio and video in advance. If you fail to upload the content for other reasons, including how you interact with content the ads you view, videos and the content you like save to ‘My Favorite’s. We infer your preferences, including your interests, gender and age for the purpose of personalizing content. We process the likes you receive for the purposes of promoting your content.

Information from Third Parties. You may choose to share third party data automatically.

Business Partners

If you choose to register using your social network account details (e.g., Facebook, , Instagram, Google), or allow us with your username. We will likewise share certain information with your social network such as your app ID, and the referring URL.

Advertisers and Advertising Networks

We use the information collected from you, and your interaction with the Platform and other third party sites, to infer your likely interests to provide you with more relevant advertising. This information tells us about apps you’ve downloaded and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and from similar information received from third parties whose sites you visit.

Technical Information we collect about you. We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes the content you have viewed on mobile carrier, time zone settings, for advertising purposes. We also collect information regarding the device such as the model of your device, the device system. This includes network type, device ID, and OS.

Location. We use the ‘Region’ you select in Settings to customize your Zimpo experience except where we provide location-based services, in which case we collect GPS.

Find other users and invite your friends. You can choose whether to find other users of the Platform using our ‘Find Friends’ function. This functionality allows you to see which of your friends from either your telephone’s contact list or Facebook friends list is using the Platform and offers you the option to follow them. You can also use this function to invite your contacts to join you on the Platform. We will use the contact information you have for that person, either from within your telephone’s contact list or Facebook friends list and give you the option to send them either an SMS, email or third party message (such as WhatsApp, Facebook (including Facebook Messenger) or Twitter) inviting them to view your zimpo profile.

Buy coins. If you reside in certain jurisdictions that offer in-app coin purchases made via your Apple iTunes. We do not collect any billing information from you in relation to such a transaction. Please review the relevant app store’s terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in coins, we keep a record of the purchases you make, the time at which you make those purchases and the amount spent.

2. Cookies

We use cookies e.g., web beacons, flash cookies, to collect information, and analyze which web pages you click on. And how you enhance your experience using our services across your different devices, which, when placed on your device, enable to provide certain features and functionality. Web beacons are very small images, also known as “pixel tags” 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. By using the Platform, you consent to our use of Cookies.

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because 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. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

3. How we use your personal data

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

notify you about changes to our service;
provide you with user support;
personalize the content you receive and provide you with tailored content that will be of interest to you;
enable you to share User Content and interact with other users;
enable our messenger service to function if you choose to use this function;
enable you to participate in the virtual items program;
communicate with you;
to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform;
ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
ensure content is presented in the most effective manner for you and your device;
improve, promote and develop the Platform and promote popular topics, hash tags and campaigns on the Platform;
carry out data analysis and test the Platform to ensure its stability and security;
allow you to participate in interactive features of the Platform;
to enable you to socialize on the Platform, for example, by allowing other users to identify you via the “Find other friends” function or through their phone contacts;
To ensure that you are old enough to use our Platform (as required by law).
provide you with personalized advertising;
provide you with location-based services (where those services are available in your jurisdiction);
enforce our terms, conditions and policies; and
Administer the Platform including troubleshooting.

4. How we share your personal data

We share your data with the following selected third parties:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

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, a link to the content will be shared.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

comply with legal obligation, process or request;
detect, prevent or otherwise address security, fraud or technical issues; or
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).

Sale or Merger

We will also disclose your information to third parties:

In the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
If we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Where we store your personal data

The personal data we collect from you may be stored on a server located in Singapore or the United States, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

6. Your Choices

You can access and edit most of your profile information by signing into zimpo. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your videos, send you messages, or post comments to your videos. Should you choose to do so, you may delete your entire account in Settings. If you have any questions on how to use those tools, or want to know about any rights you may have in the country where you live, please contact us at: info@wayunique.com

7. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. 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.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymized format.

9. Information relating to children

Zimpo is not directed at children under the age of 13. In certain cases this age may be higher due to local regulatory requirements, please see your local privacy policy for more information. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: info@wayunique.com

10. Complaints

In the event that you wish to make a complaint about how we process your personal data, contact us immediately at: info@wayunique.com We will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

11. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

12. Contact

If you have questions, comments, or requests regarding this policy, contact us at: info@wayunique.com

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

India. If you are using our services in India, the Platform is provided and controlled by Byte dance (India) Technology Private Limited. Zimpo is our brand for providing and promoting the services. When using these services from India, please accordingly read “Zimpo”, “we” or “us” in this policy to refer to Byte dance (India) Technology India Private Limited.

Indonesia. If you are using our services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall apply.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:

you must obtain approval from your parent(s) or legal guardian(s); and
your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iv) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

You’re Choices. You may withdraw your consent to Zimpo disclosure of personal data to third parties. Upon your request, we will ease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of Zimpo features and functionality.

You may request Zimpo to (i) disclose history of personal data that we have collected; and/or (ii) erase and dispose your personal data that we have collected on our server. Please note that by requesting us to erase and dispose your personal data, you may not be able to use some of Zimpo features and functionality.

To exercise any of your rights, contact us at: info@wayunique.com

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise of legal claims.

After you have terminated your use of our Platform and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymized format. Non-personally identifiable information may be retained indefinitely for analytics.

Philippines. If you are using our services in Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

You’re Rights. To the extent that the relevant laws, rules, and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages, and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Turkey. If you are using our services in Turkey, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Purposes for the processing your personal data. Our purposes for processing your personal data categories as mentioned under “1. The types of information we collect” are; (i) complying with our legal obligations, (ii) fulfilling our obligations stemming from the Terms and Conditions, (iii) processing for all legitimate purposes including providing you the services set forth in the Terms and Conditions, (iv) complying with the retaining, reporting and notifying obligations set forth in the legislation and determined by the relevant regulatory authorities and other authorities; and all other obligations provided in the laws, (v) retaining your personal data based on the statute of limitations set out in the relevant laws and (vi) processing of your personal data which are already made public.

You’re rights. According to Article 11 of the Data Protection Law, you are entitled to request the following with respect to your personal data by submitting a written request:

to learn whether the personal data relating to you are being processed,
if it is processed, to request information with regard to processing,
to learn purposes of the processing and whether they are used for such purpose or not;
to know the third persons within or outside the country to whom the personal data are transferred,
to request correction of the personal data if the data is processed incompletely or inaccurately,
to request deletion or destruction of the personal data under the conditions set forth in Article 7 of the Data Protection Law,
to request notifying third persons to whom the personal data are transferred, about the processes completed within the scope of the foregoing two items,
to object to negative consequences about you that are concluded as a result of analysis of the processed personal data exclusively by automatic means,
to claim indemnification if the you suffered damage due to illegal processing of your personal data.

You may exercise your rights listed above by contacting us at: info@wayunique.com

Language. This policy is written in the English language and Turkish language. In the event of any inconsistency or different interpretation between the English text and Turkish text, the relevant Turkish text shall prevail.

Vietnam. If you are using our services in Vietnam, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:

you must obtain approval from your parent(s) or legal guardian(s); and
your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

Thailand. If you are using our services in Thailand, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 20 years of age and/or legally competent under the applicable laws. If you are below 20 years old and/or not legally competent under the applicable laws:

you must obtain approval from your parent(s) or legal guardian(s); and
your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must immediately cease accessing the Platform.

United Arab Emirates. If you are using the Platform in the United Arab Emirates (“UAE”), the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

1. How we share your personal data

In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.

2. Governing law and dispute resolution

By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:

Where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and
For all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

Israel. If you are using our services in Israel, the following additional terms apply.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged Zimpo Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

South Korea. If you are using our services in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Entrustment and/or Overseas Transfer of Personal Data. We entrust your data to our affiliates, cloud storage providers, IT service providers, and data centers, some of whom are located abroad (See the Korean language Privacy Policy), subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Service, by contacting us here.

Brazil. If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

Parental and Guardian Consent. If required by Brazilian data protection laws, (i) if you are over the age of 16 but under the age of 18, you can only use and register for an account with the assistance of your parent or legal guardian and you declare and represent that you had such assistance to use the Services and to agree to the Policy; (ii) if you are over the age of 13 but under the age of 16, you can only use and register for an account with the representation of your parent or legal guardian, and you must obtain the consent from your parent or legal guardian to the use of the Services and acceptance of this Privacy Policy.

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law – LGPD, once it comes into force:

I. confirmation of whether your data are being processed;

II. Access to your data;

III. Correction of incomplete, inaccurate or outdated data;

IV. anonymization, blocking or erasure of data;

V. portability of personal data to a third party;

VI. Object to the processing of personal data;

VII. Information of public and private entities with which we shared data;

VIII. Information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. Withdrawal of your consent.

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form “Contact”. If you have any questions about the processing of your personal data, we would like to clarify them.

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 6 months, in order to comply with legal obligations.

Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.