Tangram – PRIVACY POLICY

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INTRODUCTION

Welcome to Tangram!

We value your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us.

The use of Tangram (through the Tangram mobile app or any third party platforms through which Tangram is provided) may involve the collection and use of your Information. It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using Tangram, you agree that we may collect, use, store and share your Information in accordance with this Privacy Policy, as revised from time to time. If you change your mind in the future, you may withdraw this consent at any time in accordance with this Privacy Policy.

If you do not agree with this Privacy Policy, you must not use Tangram. If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact:

If you wish to make any complaints regarding this Privacy Policy or its implementation by us, please contact us via the above contact details; in addition, subject to applicable laws and regulations in your jurisdiction, you may also have the right to lodge a complaint with your country's data protection authority.

In this Privacy Policy, "we", "our" or "us" refers to: Wuhan Zhenzhun Technology Co.,Ltd..

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to Tangram, including any services related with Tangram that incorporates this Privacy Policy by reference (for example, the Tangram Official Account Admin Platform). Those Tangram services may have further privacy-related terms that you must agree to if you use those services.

This Privacy Policy is incorporated into and forms part of the Tangram Terms of Service that you have agreed to in order to use Tangram. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the Tangram Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise. Please note that this Privacy Policy does not apply to Information collected: (a) through any services other than Tangram; (b) through any third party services (including any third party websites) that you may access through Tangram; or (c) by other companies and organisations who advertise their services on Tangram.

If you are using Tangram on behalf of a company, partnership, association, government or other organisation (your "Organisation"), you agree to notify your Organisation's relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time ("Connected Persons") of the collection of their Personal Information, and you agree to obtain your Connected Persons' consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. Where throughout this Privacy Policy we refer to “you” or “your”, this applies to the Personal Information of Connected Persons.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.

Whenever we make any changes to this Privacy Policy that are important for you to know about, we will notify you via Tangram or other means before the change becomes effective.

THE INFORMATION WE COLLECT

In providing Tangram, we collect, store and use the following Information relating to you:

Information” is Personal Information and Non-Personal Information;

"Personal Information" is any information or combination of information that relates to you or a Connected Person, and can be used to identify you or a Connected Person. We set out examples of Personal Information (and how we collect such Personal Information) in the "How we collect Information via Tangram" section below.

“Location Data” is information that we collect regarding your location (when you use a location-enabled service), including:

"Log Data" is technical information that is automatically collected by us when you use Tangram, whether through the use of cookies, web beacons, log files, scripts and ETags (as explained in more detail in the “Tracking Technologies” section below) or otherwise, including:

Non-Personal Information” is any information that relates to you but from which it is not reasonably practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.

Shared Information” is information about you or relating to you that is voluntarily shared on Tangram. Shared Information may include postings that you make on Tangram (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using Tangram share about you.

HOW WE COLLECT INFORMATION VIA Tangram

We collect Information from you when you use Tangram – for example, when you:

The following sets out how we collect such Information from you as you use Tangram. The remainder of this Privacy Policy sets out further information regarding some of these categories.

Registration and Account Information. You must register for a Tangram account in order to use Tangram. To register, you may need to provide certain Personal Information, such as your name, mobile phone number and password.

Account Verification. If you choose to apply for account verification (in order to unlock additional payment and fund settlement features in Tangram) you may need to provide additional Personal Information, including gender, nationality, date of birth, residential address, copy of residential address proof, copy of personal identification document (for example passport, identification card, home return permit, etc.), personal identification document number, occupation and source of funds

Connected Persons. If you are an Organization you may provide information related to Connected Persons to allow us to administer your Tangram account and comply with laws and regulations applicable to us and our affiliated companies.

Social Connect. When you choose to connect your third party social media account to your Tangram account, we may collect certain Information from your account with that social media platform – for example, to facilitate your login to Tangram with that account.

Using Tangram. We collect Information from and about you through your use of Tangram. For example, we may collect Personal Information from you within Tangram via the following:

Purchases via Tangram. When you make purchases through Tangram, you may need to provide certain Personal Information to complete the purchase, such as your credit card information or bank account information. Where the payment is processed by a third party payment service provider, we do not collect or store such Personal Information, though we may receive summary information about transactions. Where we or our affiliate companies process your payments as a payment service provider, or where we fulfil any purchases you have made on Tangram, we may collect, use and store your Personal Information in order to fulfil such purchases. "Such as"

Working with our third party partners. We may work with third parties to gather additional demographic information about our users on an aggregate and anonymised basis.

Location Data, Log Data and your device. Tangram automatically collects Log Data from your device to enable and assist Tangram's functionalities. In addition, you may also permit Tangram to access other content and data on your device – for example, your contact list and photo storage.

Cookies, Automatic Data Collection, and Related Technologies. We further explain such collection in the "Tracking Technologies" section below.

HOW WE USE YOUR INFORMATION

Use of your Information within Tangram

We may use your Information for any of the following purposes:

In addition, we may need to retain, disclose and use your Information for the following purposes (collectively, the "Retained Information Purposes"):

We may also anonymise or aggregate any Personal Information collected through Tangram and use such anonymised and aggregate data for any purpose.

Use of Personal Information on our other services

In order to provide our users across Tangram and our other services with a better experience, to improve Tangram and our other services, or otherwise where you have consented, Personal Information collected through Tangram may, subject to user privacy controls (where available), be used by our other services (whether in an aggregated or individualised manner) in accordance with the relevant privacy policy for those other services.

For example, Personal Information collected during your use of Tangram may be used to suggest particular content that can be made available to you on, or be used to present more relevant advertising to you in, another Tencent service. You may also ask us to migrate or export your Personal Information contained in Tangram to another Tencent service, where such migration option is available.

Personal Information within Your Content

If any of your Personal Information comprises Your Content (as defined in the Tangram Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the “Your Content” section of the Tangram Terms of Service.

DIRECT MARKETING

We may use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties.

Such products and services (of ours or third parties) include the following:

We will honour your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact our Privacy Officer at any time and free of charge.

In addition, you may be able to opt-out of certain direct marketing by following the relevant instructions set out on our marketing communications.

We will not share your Personal Information with advertisers unless we have your permission to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.

When you opt out of direct marketing pursuant to the above, you may continue to see online advertising (that is not direct marketing) within Tangram and/or our advertisements on other websites or applications.

SHARING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES

Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

Sharing for the provision of Tangram

We may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes:

Sharing for marketing purposes

We may allow third party marketing partners (such as Tangram Official Accounts partners, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use Tangram. If you wish to opt-out of such collection of your Personal Information by our third party marketing partners while you are using Tangram, please contact us at policy@wechat .com.

We may also provide your Personal Information to third party marketing partners where you have asked us or consented to us doing so or where it is required in order for us to provide Tangram to you.

Other terms relating to the sharing of your Personal Information Where we or our affiliate companies share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information:

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organise our group structure. In these circumstances, your Information may be transferred within our group and/or to a third party who will continue to operate Tangram or similar services under either this Privacy Policy or a different privacy policy that will be provided to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your home country.

We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the "Period of use of your Personal Information" section below.

A WORD ABOUT SHARED INFORMATION

Tangram enables Shared Information to be shared publicly with your Tangram contacts, all users of Tangram and/or the public, via features provided by either us or third parties, so that Shared Information can be broadly and instantly transmitted. Shared Information will remain public for as long as you do not delete it; and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.

In addition, we may also provide other Tangram-related features that allow you to share Shared Information in public – for example, publicly accessible blogs and forums, or certain social media features within Tangram – for example, “plug-ins” (which create a direct link between two websites) and “widgets” (which are interactive mini-programs that provide third party services within Tangram). You should be aware that any information you provide within such features may be read, collected and used by third parties who access them.

Please consider carefully what you post and communicate through Tangram. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in Tangram.

COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use Tangram, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Tangram for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to Tangram, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Before communicating any Personal Information of a sensitive nature within Tangram, please consider whether it is appropriate to do so.

You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy.

Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

THIRD PARTY SERVICES AND YOUR INFORMATION

Tangram may link you to social media or other features or services (including websites, plug-ins and widgets) provided by, or allow you to share certain Information with, a third party. For example:

These third party social media or other services may be hosted by the relevant third party or us. Please note that third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer or device to enable such features to function properly.

Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party’s own terms of services and privacy policies and not the Tangram Terms of Service or this Privacy Policy, so please review those third party terms carefully. This Privacy Policy only applies to any Information collected by us, and does not apply to any services offered by or information practices of any third parties. We are not responsible for any third party use of any Information provided by you to them.

AGE RESTRICTIONS

Children under the age of 13 are not allowed to use Tangram. We do not knowingly collect Personal Information from any children under the age of 13. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 – we will promptly investigate (and remove) such Personal Information. As set out in the Tangram Terms of Service – if you are between the ages of 13 and 18 (or the relevant age in your jurisdiction where you are considered a minor), your parent or guardian must agree to this Privacy Policy (both for themselves and on your behalf) before you can use Tangram.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. Any of the third parties referenced in the "Sharing of your Personal Information" section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances, your Personal Information may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction.

We will ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us.

Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of Tangram or any information you provide to us through Tangram.

We may communicate with you electronically regarding security, privacy, and administrative issues relating to Tangram. If we learn of a Tangram security breach, we may attempt to notify you electronically by posting a notice within Tangram or by sending direct communication to you.

If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

We will only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the “How We Use Your Information” section above.

ACCESSING, UPDATING, AMENDING OR PORTING YOUR PERSONAL INFORMATION

Subject to applicable laws and regulations, you may have the right to:

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us, including consent for email and targeted marketing communication and data transfers. We will use reasonable efforts to apply your preferences going forward.

If you would like to update or amend your Personal Information within Tangram, you may do so in the first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within Tangram.

If you wish to:

please contact our Privacy Officer. We will use reasonable efforts to respond to all such requests made to our Privacy Officer without undue delay and in accordance with any time limits required by law. Please note that your right to access Personal Information in the above manner may be limited in some circumstances by local law requirements.

In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may be extremely impractical or require disproportionate technical effort (e.g. any requests that relate to our backup systems), or are prohibited by law.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through Tangram, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using Tangram may put your Personal Information in the hands of third parties that we cannot control.

We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of Personal Information about you. Except where required by law, we cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Policy or our privacy practices.

International Data Transfers

We are a global business. We may transfer Personal Information to countries other than the country in which the data was originally collected. For example:

Your Personal Information may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction. When we transfer your Personal Information to other countries, we will protect that Personal Information as described in this Privacy Policy.

In particular, we may need to transfer your Personal Information to countries that are not considered to provide an adequate level of protection under EU data protection laws. However, we ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer.

By agreeing to the Privacy Policy, you consent to the transfer of your Personal Information for the purposes described in the Privacy Policy. You have the right to withdraw your consent at any time, but please note that if you do not consent to the transfer of if you withdraw your consent to transfer, you may not be able to benefit from all or some of our Services.

TRACKING TECHNOLOGIES

We may, from time to time, use cookies, log files, web beacons, scripts, tags and other tracking technologies to collect, use and store Information about you or relating to you. This section describes how we use such tracking technologies.

Why do we use tracking technologies?

To help us better understand and provide Tangram to you and our users

Tracking technologies enable us to better understand and provide Tangram to you – for example, tracking technologies help us collect the following Information:

To help us deliver relevant and safe advertising to you

Advertising helps keep Tangram and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:

What are tracking technologies?

The “tracking technologies” that we use within Tangram include the following:

How do we use tracking technologies?

Tracking technologies used in partnership with third parties

We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:

We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis.

We may use Google Analytics to collect and process certain Tangram-related usage data. Google provides additional privacy options regarding cookie use described at http://www.google.com/policies/privacy/partners/.

Our own tracking technologies

In addition, we also use our own tracking technologies to personalise your experience on Tangram and for various other purposes. For example, we use such tracking technologies to:

Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyse how you and others use our services and to serve advertising.

General terms in relation to tracking technologies

We may from time to time partner with third party partners to display advertising on our website or to manage our advertising on other sites. Our third party partners may use cookies or other tracking technologies in order to provide you with advertising based on your browsing activities and interests.

Please note all such third party tracking technologies are governed by the relevant third party’s own privacy policy, and we are not responsible for such third party tracking technologies (including information collected by the relevant third party using such third party tracking technologies).

While we may have agreements in place with these third parties in relation to the proper handling and protection of your Personal Information, we cannot guarantee their privacy practices as they are third parties.

If you wish to opt out of interest-based advertising, click here: http://preferences-mgr.truste.com/. Please note you will continue to receive generic ads.

If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out by contacting policy@wechat .com. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for Tangram via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered Tangram. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.

How you can control tracking technologies

You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal Tangram experience and some or all of Tangram’s features may not function properly.

You may also control what tracking technologies-collected Information we receive by certain settings within Tangram – for instance, by using the “Clear Location” option within Tangram.

Specific types of cookies

We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.

Category of cookies use Description
Authentication These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region.
Security We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.
Functionality We use such cookies to perform and improve the functions of our services. In particular, we use these cookies to help us collect information about how our users are interacting with Tangram – for example, your most recent searches and the profiles that you most frequently visit on Tangram.
Analysis and Research We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions. For example, these cookies helps us better understand the demographics of the Tangram user base, which in turn helps us consider what new Tangram features may be the most relevant for our users.
Advertising We use cookies to:
  • deliver advertising on Tangram,with the aim of delivering more relevant advertising to all of our users–for example,you may receive advertisements based on your general location derived from your IP address or from your previous Tangram searches;and
  • to help us and advertisers collect statistics regarding the delivered advertisements,such as how many users have viewed,clicked on and/or made purchases through such advertisements.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of Tangram as used on your phone. As part of such process, we may (via Tangram) record information such as how often you use Tangram, the events that occur within Tangram, aggregated usage, performance data, and where and when Tangram was downloaded from on your device. We do not link such mobile analytics information that we collect with any personally identifiable information you submit within Tangram.

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If you have questions or complaints regarding our Privacy Policy or privacy practices, please contact our Privacy Officer. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us info@fastkit.cn. This dispute resolution process is only available in English.

Last modified: 2018-01-01