KOMUTR takes users' information safety and privacy as our lifeline. Based on our basic principle "Users' needs are our first priority", we are committed to enhancing the transparency of information process, honoring your control of data and safeguarding your information and communication security.
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KOMUTR adheres to the following privacy protection principles and is committed to providing you with more secure and reliable service:
1.Security Safeguard and Reliance. We try our best to prevent your information from breach, damage or loss via effective and reasonable information security technology and administrative process;
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2.Choice. We provide you convenient privacy management options so that you may make proper choices to control or manage your privacy;
3.Protection of Communication Secret. We will strictly protect your communication secrets in compliance with the applicable laws and regulations;
4.Reasonableness and Necessity. We will collect necessary data so that we can provide you and other users with better service in order to achieve products' functions.
5.Transparency. We endeavour to introduce our privacy policy in an easy and straightforward way and help you better understand our information process practice;
This Privacy Policy mainly explains: What information we collect. How we use that information. Your Rights.
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We hope that you will read this Privacy Policy (this "Privacy Policy") to understand how we collect and use information in order for you to further understand our services and to make appropriate selections. By using KOMUTR service, you agree to the contents contained in this policy.
â… . Information We Collect Based on the principle of lawfulness, fairness and necessity, we will only collect the following information that is necessary for the purpose of achieving the product's function.
1.1 Information you provide to us
1.1.1 Information you provide to us when registering an account. For example, the nickname and your mobile phone number provided at the time of registration.
1.1.2 Information you upload whilst using our services. For example, your uploaded profile picture and date of birth, etc.
1.1.3 Information provided by you via our customer service or whilst participating in our activities. For example, the questionnaire you completed when participating in our online activities may include your name, contact number, home address or other related information.
Some of our service may need you to provide your selected sensitive personal information to achieve specific functions. If you choose not to provide such information, you may not be able to use specific functions in the service, but it will not affect the usage of other functions. If you provide your sensitive information for us voluntarily, you agree that we process your Personal Sensitive Information in accordance with the purposes and methods provided in this policy.
1.2 Information we may collect when you use our services
1.2.1 Server Logs. We may automatically collect and store relevant information as the service log when you use our services.
1) Device Information. For example, device model, operating system version, unique device identifier ("UDID"), battery, signal strength, and other information.
2) Software Information. For example, software version and browser type. To ensure the security of the operating environment or to provide the necessary services, we will collect information in relation to your usage of mobile applications and other softwares.
3) IP Address.
4) Service Logs. For example, information collected when you use our services to search or view, crash logs information, recommended sites and other information.
5) Communication Logs. For example, the accounts you communicated with, the time and period when you use our communication services.
1.2.2 Location data. We may collect location data of your device when you use the location-related services, in order to provide relevant service for you.
1) We may collect your geographic location data via IP address, GPS, Wi-Fi, or base station when you use the services;
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2) Geographic location data provided by you or by other users when using the services. For example, the location data detailed in your account, or geographical indications contained in photos shared by you or other users;
1.2.3 Other relevant information. For you to better use our product or service, we will collect relevant information, for example, the friends list, group list information, and voice print. Also, if you choose to turn on "import contacts" feature we will encrypt name and phone number of your contacts and collect encrypted information in order to connect you with people you know who also use our service.
1.3 Your information contained in the information shared by other users. For example, photos or videos published by other users may contain your information.
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1.4 Information from third-party partners. We may have cooperation with third-party partners.
â…¡. How We Use the Information We Collect Subject to applicable laws and regulations or agreements with users, we may use the collected information in the following ways. If we use your information for purposes beyond the following purposes, we will explain to you again and ask for consent.
2.1 To provide you with our services.
2.2 To meet your personal needs. For example, language settings, location settings and other personalised services.
2.3 Product development and optimization. For example, when our systems have malfunctions, we will record and analyze the information generated when the system crashes, so as to further optimize our services.
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2.4 To ensure security. For example, we will use your information for identity authentication, safety precautions, anti-fraud monitoring, storage and backup, customer safety service and other applications. For example, the safety software downloaded or installed by you will detect malicious programs or viruses, or identify fraudulent information.
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2.5 To recommend ads, news etc. that you may be interested in to you.
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2.6 To manage software. For example, software certification and software updates, etc.
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2.7 To include your participation in survey activities about our product and services.
â…¢. How We Use Cookies and Relevant Technologies We and our third party partners may collect your information via safely inserted Cookie and relevant technologies, for the purposes for providing you with more personalized user experience and service. We will strictly require such third party partners to observe relevant requirements of this policy.
You may set or mange Cookie via your browser settings. But please be noted that you may not enjoy the best service experience and certain service may not be used if you stop using Cookie. If you hope to learn more information about the security of Cookie, you may refer to the Cookie Policy Statement.
â…£. How to Manage Your Own Information
4.1 You may access, amend and delete information provided by you during the registration of your account or other personal information when using our services, or contact us via the notice guidelines. The scope and the way in which you access, amend or delete your personal information depend on the service you use. For example, when using geographical related service, to stop sharing your geographical information, you can stop it by turning off cellphone positioning function, or according to methods provided by software and hardware service providers and communication service providers. Please read relevant guidance carefully.
4.2 We will collect and use your information only for achieving the functions of our products or services in accordance with this policy. If you find that our collection or use of your personal information is not in accordance with the laws, administrative regulations or the agreement of both parties, you can require us to delete such information. If you find that we have collected or stored your wrong personal information, you can also require us to correct it. Please contact us via the contact details listed in this Privacy Policy.
4.3 For account security purposes, we may ask you to verify your identity before we allow you to access, amend and delete relevant information.
4.4 Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your requests. We endeavor to respond to your requests within a reasonable period of time.
â…¤. Information We Share We will strictly limit the sharing of information in accordance with the laws and regulations, for example:
5.1 We may share your personal information with a third party other than our data processors with your prior consent;
5.2 For the purpose of external processing, we may share your personal information with third-party business partners (third-party service providers, contractors, agents, advertising partners, application developers etc., for example, the telecommunication service providers who send out emails and push notifications on our behalf, or the map service providers who provide us with location service) (they may not be located in your jurisdiction), and require them to follow our instructions, the Privacy Policy and any other relevant confidentiality and security measures to process the above information for us and for the purposes of:
5.2.1 Providing you with our services;
5.2.2 Implementing the purpose of the section "How We Use the Information We Collect";
5.2.3 Performing our obligations and excising our rights as provided in the KOMUTR Service Agreement and this Privacy Policy;
5.2.4 Understanding, maintaining and improving our services. Should we share your personal information with third parties mentioned above, we will use encryption, anonymization or other means to protect your information security.
5.3 With the development of our business, when mergers, acquisitions, asset transfer or other transactions happens, we will inform you of such circumstances by pushing notifications or notices, and continue to protect or require new controllers to continue to protect your personal information in accordance with the applicable laws and regulations and the standard of protection which will not be lower than that under this Privacy Policy.
5.4 We may use the collected information for big data analysis. For example, We may use collected information for analysis to generate urban heat map or industry insight report which contains no personal identifiable information. We may make it public and share it with our partners the post-processed information that does not contain personal identifiable information, to understand how users utilize our services or to enable the public to better understand the overall use of our services and other purposes.
5.5 We may disclose your personal information due to the following purposes:
5.5.1 To comply with the applicable laws and regulations;
5.5.2 To comply with court decisions, rulings or requirements of other legal procedures;
5.5.3 To comply with the requirements of relevant government agencies or other relevant legally authoritative entities; 5.5.4 We have reasons to believe that we need to comply with applicable laws and regulations;
5.5.5 Reasonable and necessary purposes to implement relevant service agreements or this Privacy Policy, or to protect public interest, personal safety and property and other legitimate rights of our clients, ourselves, our affiliates, our users or employees.
â…¥.Information We May Send to You
6.1 Push notifications When you use our services, we may send emails, text messages, news or push notifications to you. You may follow the relevant notice to unsubscribe on the device.
6.2 Service announcements We may send you announcements related to service if necessary (for example, the suspension of certain service due to system maintenance). You may not be able to cancel these non-promotional service-related announcements.
â…¦. Information Security We take security measures to protect your information against loss, improper use, unauthorized access or disclosure.
7.1 We will strictly protect users communication in accordance with the applicable laws and regulations.
7.2 We will work within the reasonable security standards and use a variety of security measures to protect the security of information. For example, we will use encryption technologies (such as TLS, SSL), anonymization and other means to protect your personal information.
7.3 We have established a specialised management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information, and require them to comply with their confidentiality obligations and conduct audits.
7.4 In the event of a breach of security incident of personal information, we will activate emergency response plan to prevent the expansion of such security incident and inform you in the form of push notifications, public announcements and etc.
â…§. Application Scope All of our services are subject to this Privacy Policy. However, some services have their own specific privacy guidance/statement, such specific privacy guidance/statement describe how we process your information in the service more specifically. If this Privacy Policy is inconsistent with the privacy guidance/statement of a particular service, the privacy policy of that particular service shall prevail.Please note this Privacy Policy is not applicable to services provided by other companies or individuals.
â…¨. Contact Us Should you have any enquiries in relation to this Privacy Policy or other related matters, please contact us via https:com. In accordance with the provided guidelines, you may also complete the relevant details and send your queries to XX@KOMUTR.com
â…©. Changes to Privacy Policy We may update and revise this Privacy Policy from time to time, and if such changes result in a substantial impairment of your rights under this Privacy policy, we will notify you by sending you an e-mail and by reminding you at prominent place on the webpage before the changes take effect. Under such circumstances, if you continue to use our services, you will be deemed to have agreed to be bound by the updated policy.