HeyTap Privacy Notice
Last updated on: March 15, 2021
Thank you for choosing HeyTap.
BRAVO UNICORN PTE. LTD. (hereinafter referred to as "we", "us", or "our"; Contact Address: 9 Raffles Place, #26-01 Republic Plaza, Singapore 048619) is committed to protecting and respecting your privacy. Personal information refers to any information relating to an identified or identifiable natural person. During your use of our accounts, websites, mobile apps, or other products or services (collectively, our "HeyTap Products"), we may collect and use your personal information.
This Privacy Notice explains why and how our HeyTap Products collect your personal information, what personal information they collect from you, your rights to your personal information, and how we protect the security of your personal information.
This Privacy Notice universally applies to all our HeyTap Products. Given the great variety of our products and services, we have also developed separate privacy notices for certain specific HeyTap Products to explain in more detail how we collect and use your personal information during your use of those products or services. If a HeyTap Product has its own privacy notice, the privacy notice specific to that product shall prevail. For matters not covered in the product-specific privacy notice, this Privacy Notice will apply.
Before using our HeyTap Products, please read this Privacy Notice carefully to understand our privacy practices.
This Privacy Notice will help you understand:
- 1. How We Collect and Use Your Personal Information
- 3. How We Retain Your Personal Information
- 4. How We Disclose Your Personal Information
- 5. How We Protect Your Personal Information
- 6. Your Rights to Your Personal Information
- 7. How We Process Children's Personal Information
- 8. Third-Party Service Providers and Their Services
- 9. How Your Personal Information Is Transferred Globally
- 10. How This Privacy Notice Is Updated
1. How We Collect and Use Your Personal Information
- 1.1 Personal Information That We Collect
- (1) Information directly provided by you to us
- a. To use certain HeyTap Products or related services, you need to first sign up for a HeyTap Account or, if you already have one, sign in to your HeyTap Account. During the sign-up or sign-in process, we may need to collect your phone number or email address, password, username, profile picture, gender, sign-up SMS message, date of birth, the country or region where you sign up and other relevant information. The phone number or email address and password are necessary for sign-up or sign-in. If you do not provide such information, we will be unable to provide you with the sign-up or sign-in service
- b. We need to obtain your list of installed apps to ensure that your HeyTap Account can successfully sign in to all the apps and services that are accessible with a HeyTap Account and to determine whether your HeyTap Account has signed in to these apps.
- c. When you sign in to our HeyTap Products with a third-party account, we need to collect the information about your third-party account to determine whether it is linked to your HeyTap Account.
- d. During account verification, we may collect your IMSI number and the information about the contacts you have specified for manual account recovery (their name and phone number).
- e. When you add a delivery address on the relevant HeyTap Product page or in the online store section, you may need to provide us with your Contacts. We collect this information to help you quickly enter the receiver's name and phone number.
- f. If you order a product, apply for a return or refund, or use a paid service from us, we may collect delivery details, the bank account number, payment history, billing address, and other financial information as well as your contact and communication records and other relevant information in order to process your order. If you do not provide this information, you may not be able to order a product, apply for a return or refund, or use a paid service from us.
- g. When providing after-sales services and customer support to you, we need to collect your location information so as to provide you with the addresses of our nearby after-sales service centers. We may request and collect your personal information, such as your device information (e.g., the IMEI number), your name, phone number, email address, and postal address, and we may record the calls between you and our customer service representatives.
- h. We may request and collect your personal information on other occasions, such as when you participate in our lucky draws or competitions, promotional or marketing activities organized by us alone or jointly with our partners, or surveys.
- i. Depending on the characteristics of certain HeyTap Products, we may also request and collect your personal information in other scenarios. If this is the case, we will inform you through the product-specific privacy notices.
- (2) Relevant information obtained during your use of our HeyTap Products
During your use of our HeyTap Products, we may collect information about your device and how you and your device interact with the HeyTap Products or services, including:
- a. Device information, such as the device name, device/phone model, IMEI number, OpenID, MAC address, serial number, IP address, operating system version, carrier information, and Wi-Fi network name.
- b. Log information and behavioral data, including information about the operations performed by you after signing in to your HeyTap Account (such as information about changing your password or the linked phone number or email address and the manual account recovery history), the time and duration of your use of the HeyTap Products, search keywords entered by you via our services, and information about your app events (such as restarts, upgrades, errors, and crashes).
- c. Location information, such as the GPS signal of your device or information relating to nearby Wi-Fi access points and cell towers, your device location ID, or the network service provider ID. We will ask you whether to turn on the "Location" permission for location-based apps. You can change the location settings of your device, such as by changing or disabling the methods and servers used for location-based services, or by changing the accuracy of your location information, to change the location information provided to us.
- d. Cloud service data: At your request, we will store your information (such as photos, videos, contacts, SMS messages, notes, browser bookmarks, calendar events, and call logs) securely in our cloud.
- e. Some of our HeyTap Products allow you to communicate and share with others. As required by the technology used in these products, such communications and shared content may be transmitted through our system and be stored in the system.
- f. When you use voice commands for control or other voice services provided by us, we may record your voice and store it on our server.
- g. Depending on the characteristics of certain HeyTap Products, we may separately request you to grant us certain user permissions or we may obtain other types of personal information about you. If this is the case, we will inform you through the product-specific privacy notices.
- (3) Personal information about you obtained from third parties
Depending on the characteristics of certain HeyTap Products and where permissible by law, we may obtain data about you from public or commercial sources and combine that information with other information that we have received or that relates to you. For example, to realize your HeyTap Account benefits such as reward points and membership, we will collect data about your HeyTap Account activity within the products provided by our affiliates or third parties that are accessible with your HeyTap Account (such as the sign-in address and time, the duration, etc.) and other data that you have authorized to be shared.
- 1.2 How We Use Your Personal Information
- (1) To create and maintain your HeyTap Account. We will use the data to create and maintain your HeyTap Account.
- (2) To handle your orders. We will use the data to handle your orders and provide you with after-sales services, including customer support, order delivery, and invoice printing.
- (3) To provide notification and push services. We may use your data to provide you with content pushes or notifications relating to our HeyTap Products or third-party content, including Lock Screen Magazine, quick apps, updates and installations of apps, and sales and promotional messages.
- (4) To provide location-based services. In order to provide you with the best possible user experience, we or third parties will use your location information to provide you with more targeted services, such as local weather information and geographically-targeted push services or notifications relating to our HeyTap Products.
- (5) For you to sign in to your HeyTap Account and use HeyTap Products provided by our platform. After signing in to your HeyTap Account, you may use the products and services provided by our platform, such as HeyTap Cloud, App Market, Theme Store, Browser, Search, and notifications, etc. When you use our HeyTap Products, we may use your data to implement specific features of the HeyTap Products.
- (6) For you to sign in to the products and services provided by our affiliates or third parties that are accessible with a HeyTap Account. You may sign in to your HeyTap Account to use the products and services provided by our affiliates or third parties that are accessible with a HeyTap Account.
- (7) To realize your user rights and interests relating to our HeyTap Products such as reward points and membership. We will collect and sync the behavioral data of your HeyTap Account within our HeyTap Products and the products and services provided by our affiliates or third parties that are accessible with your HeyTap Account to accrue your user benefits such as reward points and membership.
- (8) To improve our products and the user experience. We will use the phone number obtained during your sign-up for a HeyTap Account or your participation in our user activities to conduct user research and surveys.
- (9) To provide customer support. We use the data to diagnose product issues, repair customers' devices, and provide other customer care and support services. We may also collect your email address to respond to the questions raised or comments made by you in the "Contact Us" section of our website.
- (10) To prevent fraud. We may use the data you provide to verify your identity, analyze our business efficiency, review user transactions, and prevent fraud.
- (11) To provide you with personalized services. We may use your personal information for profiling and behavioral analysis so as to show and push more suitable information, products, or services to you or to better implement safeguards, such as prioritizing App Market products or services that may interest you the most. In addition, we may combine your personal information collected via our various services to provide you with an optimal user experience as a whole.
- (12) To conduct commercial promotions. For instance, if you wish to receive information about our HeyTap Products, services, and apps, or if you wish to provide improvement recommendations for them, we will need to request your contact information so that we will be able to contact you. If you do not want to receive such information, you may turn off the Notifications and Feedback feature at any time through "Account - My Info - Notifications and Feedback".
- 1.3 Requesting Device Permissions
- (1) We may request certain device permissions to collect your personal information and provide you with the relevant service functions or services. Specifically, we may request the following device permissions.
Device Permission Purpose of Permission Request Ask Before Turning On the Permission User Can Turn Off the Permission Camera To allow account sign-in on a webpage through QR code scanning Yes Yes Location To obtain the addresses of our nearby repair/after-sales services centers Yes Yes Phone To obtain the IMEI/IMSI number for user verification to enhance account security Yes Yes SMS To enable sign-up or sign-in via one tap or to provide identity verification for you Yes Yes Storage To edit your profile picture, take photos, or access your photos Yes Yes
- (2) When a permission is turned on, you may go to "Settings" on your mobile phone at any time to turn off the permission. After the permission is turned off, the corresponding product function may not work properly.
- Please note that the required permissions and their management may vary according to the phone brand and model. For the required permissions, please refer to your actual phone. We undertake that we will not use your device permissions without your authorization or consent, or use your personal information collected based on your device permissions in scenarios to which you have not given your authorization or consent.
- 2.1 What Are Cookies
- (3) Many web browsers have a Do Not Track feature which sends a Do Not Track request to a website. If you enable the Do Not Track feature in your browser, we will respect your choice and your browsing experience on all of our websites will not be tracked.
- (4) Like most websites, we automatically collect certain information to analyze cumulative trends and manage our websites. Such information may include the Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, files viewed by you on our websites (such as HTML pages and graphics), operating system, date/time stamp, and/or clickstream data.
- 2.3 Clearing/Disabling Cookies
You can manage cookies and cookie preferences in your browser. Here are guides to show you how to do this in popular browsers:
- 2.4 More Information about Cookies
For more information about cookies and instructions on how to configure your browser to accept, delete, or disable cookies, please go to www.allaboutcookies.org.
3. How We Retain Your Personal Information
4. How We Disclose Your Personal Information
- (1) Sharing with our affiliates: In order for us to provide services to you based on your HeyTap Account, we may share your personal information with our affiliates. We will only share necessary personal information. If we or our affiliates intend to change the purpose for which your personal information is used and processed, we will obtain your authorization or consent again.
- (2) Sharing with our authorized partners: Some of our services will be provided by our authorized partners only for the purposes stated in this Privacy Notice. We may share some of your personal information with our partners in order to provide you with better services and a better user experience. Our authorized partners include but are not limited to logistics companies, cloud service providers, SMS or other technical service providers, payment or financial service providers, and Internet content providers. For example, when we need to award you a prize for an activity, we will inform the logistics company of the contact information provided by you during the activity so as to complete the delivery of the prize to you.
- (3) In the event of a merger, acquisition, bankruptcy, or liquidation, if we need to transfer your personal information, we will request the new company or organization to which your personal information will be transferred to continue to be bound by this Privacy Notice; otherwise, we will request such company or organization to obtain your authorization or consent again. If there is no need to transfer your personal information, we will adequately inform you and delete or anonymize all personal information controlled by us.
- (1) With your express consent; or
- (2) When required by law. When we are required to respond to subpoenas or other legal procedures, litigations, or mandatory requirements of government authorities, we may disclose your personal information if we sincerely believe that the disclosure is necessary to protect our rights, ensure the safety of you or others, investigate fraud, or to respond to government requests.
5. How We Protect Your Personal Information
- (1) We use mainstream security means such as SSL to encrypt a variety of services. We regularly review our practices regarding information collection, storage, and processing (including physical security measures) to protect our systems from unauthorized access or alteration.
- (2) We strictly control access to personal information and only grant the access permission to our employees and those of an authorized service provider who need access to personal information in order to help us process such information. These employees are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held legally liable or be terminated. Personal information access logs will be kept and audited periodically.
- (3) The security of your information is very important to us. Therefore, we will continue our efforts to ensure the security of your personal information and implement safeguards such as encrypting stored data and end-to-end encryption during transmission to protect your information from unauthorized access, use, or disclosure. In addition, certain encrypted data is inaccessible to anyone other than the user.
- (4) When transmitting and storing your personal information of special types, we will use security measures such as encryption. Before storing your personal biometric information, we will take technical measures to process it, such as only storing a summary of your personal biometric information.
- (5) We carefully select business partners and service providers and include our requirements for the protection of personal information in our business contracts, audits, or assessments.
- (6) We conduct security and privacy protection training, tests, and publicity activities to raise our employees' awareness of the importance of personal information protection.
- (7) We use international and industry-recognized standards to protect your personal information and actively acquire certifications of security and privacy protection.
6. Your Rights to Your Personal Information
- (1) Right to be informed: We inform you of how we process your personal information by publishing this Privacy Notice. We are committed to staying transparent about how we use your personal information.
- (2) Right of access: You can directly search for or access your personal information in the user interfaces of our products or services. For example, you can sign in to your HeyTap Account from the relevant product page at any time to access your personal information associated with your account, including your basic information, operation records, and storage and download records. You may also view the information about your uses of relevant products or services at any time; for example, you may access your browsing history in your browser. If you are unable to search for or access your personal information, or if you encounter any problems when accessing your personal information, you can contact our Data Protection Officer at firstname.lastname@example.org to request access to your personal information.
- (3) Right to rectification: If you find that your personal information processed by us is inaccurate or incomplete, you have the right to request us to correct or complete it. You can directly correct and modify parts of your personal information on the relevant product or service page. For any personal information that you are unable to modify, you can contact our Data Protection Officer at email@example.com to have such personal information corrected or completed.
- (4) Right to erasure: You may directly delete certain information submitted in your HeyTap Account, such as your profile picture and username. If you find that we have collected or used your personal information in violation of our agreement with you, you may also contact our Data Protection Officer at firstname.lastname@example.org to request us to delete such information.
- (5) Right to delete your account: We grant you the right to delete your HeyTap Account. After signing in to your account, you may select "Delete account" to submit an account deletion request. After your request is approved, we will delete or anonymize all your personal information, unless otherwise specified by laws or regulations. After your HeyTap Account is deleted, we will no longer be able to provide you with the HeyTap Account sign-up service or the products or services that are only accessible with a HeyTap Account.
- (6) Right to withdraw consent: The performance of each service function requires certain basic personal information (see the "How We Collect and Use Your Personal Information" section of this Privacy Notice). You may change the scope of the personal information you authorize us to continue collecting or withdraw your authorization by deleting information, turning off the device permissions, changing the relevant product or feature settings, or deleting your account.If you withdraw your consent, we will no longer be able to provide you with the related services. Once you withdraw your consent, we will no longer process related personal information, but the withdrawal of consent shall not affect the lawfulness of data processing based on consent before its withdrawal.
- (7) Right to lodge a complaint: You have the right to contact us by email at email@example.com to lodge a complaint. We will respond within 15 workdays from the date we receive your complaint. If you are not satisfied with our reply, particularly if our processing of your personal information damages your legitimate rights and interests, you can also file a complaint or report it to regulatory authorities such as the Cyberspace Administration of China, a relevant public security organ, and the State Administration for Market Regulation, or file a lawsuit with the court with jurisdiction.
7. How We Process Children's Personal Information
8. Third-Party Service Providers and Their Services
9. How Your Personal Information Is Transferred Globally
10. How This Privacy Notice Is Updated
We collect personal information in order to operate more efficiently and provide you with an optimal user experience. The personal information we collect includes: (1) information directly provided by you to us; (2) relevant information obtained during your use of our HeyTap Products; and/or (3) personal information about you obtained from third parties.
The information we collect depends on the HeyTap Products you actually use, the environment in which you interact with us, and the choices you make, including your privacy settings and the products and features you use. When we collect information, you are not obliged to provide your personal information. If you choose not to provide the information, we may be unable to provide you with the related HeyTap Products or respond to or deal with the problems you may encounter.
We will process your personal information with your consent and for the purposes stated in this Privacy Notice when we need to fulfill our obligations to you under the user agreement and/or service contract, or when we are bound by legal obligations, or when, after evaluation, we deem it necessary to protect our legitimate interests or those of a third party. We will use your personal information in strict compliance with this Privacy Notice and its updates.
We will use your personal information for the following purposes:
We will obtain your prior consent if we intend to use your personal information for any purposes other than those specified in this Privacy Notice. We will obtain your prior consent if we intend to use your personal information collected to fulfill a specific purpose for any other purpose. Without your consent, we will not provide your personal information or behavioral data to any third party.
The personal information collected by us will be retained for a minimum period needed to fulfill the purposes described in this Privacy Notice for which it is collected, unless a longer retention period is required by laws. When the minimum or required retention period expires, we will delete or anonymize your personal information.
If we stop some or all of our products or services for any special reason, we will promptly inform you and stop the collection and processing of your personal information in connection with such products or services, and delete or anonymize your personal information we hold that relates to the products or services, unless otherwise specified by laws and regulations.
In certain circumstances, we will appoint a third party to process your personal information on our behalf. For example, companies that send SMS messages or emails or that provide technical support on our behalf are allowed to use your personal information only to provide you with the relevant services.
We may, from time to time, share certain personal information with our affiliates and strategic partners that work with us to provide products or services for the purpose of providing the products or services you request.
We will require abovementioned third parties to take considerable confidentiality and security measures during their processing of your personal information by means of agreements or other appropriate measures.
We will only publicly disclose your personal information:
We adopt technical and organizational measures that are reasonable and actionable to protect the security of the information collected in connection with our services. Please note that although we take reasonable measures to protect your information, no websites, Internet transfers, computer systems, or Wi-Fi connections are absolutely secure.
We have introduced safeguards up to industry standards to protect the personal information provided by you from unauthorized access, disclosure, use, or alteration, or from damage or loss. We take all reasonable and actionable measures to protect your personal information. For example:
In the event of any security breach of your personal information, we will, pursuant to applicable laws and regulations, promptly notify you of the particulars and possible impact of such breach, the measures taken or to be taken by us, suggestions on how you can prevent and reduce risks, and remedies for you. We will promptly inform you of the information about such breach by email, letter, phone, or push notification. When it is difficult to inform the personal information subjects concerned one by one, we will issue an announcement in a reasonable and effective manner. We will also report the handling of the event in accordance with the requirements of regulatory authorities.
We respect your rights to your personal information. The following lists your rights under the law and explains how we will protect your rights.
Please note that for security reasons, we may verify your identity before handling your request. In general, we will not charge a fee for handling your reasonable requests. However, we will charge the cost of handling unreasonably repeated requests. We may reject unreasonably repeated requests, requests that require excessive technical means (such as developing a new system or fundamentally changing existing practices), requests that present a risk to the legitimate rights and interests of others, or very unrealistic requests. In addition, we may not respond to your request if it directly involves any issues that directly concern public interests such as national security, national defense, public health, and criminal investigations, or if it may result in serious damage to the legitimate rights and interests of you or any other individual or organization.
Our products, websites, and services are mainly intended for adults. Children (we regard people under the age of 14 as children) may not use our products without the consent of their parent or guardian. Children's personal information, collected with the consent of their parent or guardian, will be used or disclosed only when permitted by law and with the express consent of their parent or guardian, or when it is necessary to protect the children.
If we find that we have collected children's personal information without having obtained express and verifiable parental consent, we will try to delete the relevant data at the earliest possible time.
Our websites, products, apps, and services may contain links to third-party websites, products, or services. You can choose whether to access or use any website, product, or service provided by a third party.
We have no control over third-party privacy and data protection policies, as such third parties are not bound by this Privacy Notice. Before you submit personal information to third parties, please refer to their privacy policies.
As a company operating globally, we provide products and services through our resources and servers distributed around the world. We have built data centers in countries such as France, Singapore, India, and Indonesia. This means that pursuant to local laws and regulations and with your prior consent, your personal information may be transferred to or accessed from a jurisdiction outside the country or region where you use the relevant product or service.
You understand that there are different risks under different data protection laws. We will take measures to ensure that the data collected by us is processed in accordance with this Privacy Notice and applicable laws, and that your personal information is as equally protected as in the country or region where you use the relevant product or service. For example, we will obtain your consent to the cross-border transfer of your personal information or take security measures such as encryption, de-identification, or entering into a necessary data transfer/sharing agreement with the recipient of your data when transferring such data across borders.
We reserve the right to update or modify this Privacy Notice from time to time. We will send you update notices through different channels. If you have provided us with your email address, we will notify you of any material changes to this Privacy Notice by email prior to the entry into force of such changes; otherwise, we will post a notice on our website or push a notification to you through your device.
This Privacy Notice is subject to change, but without your express consent, we will not diminish your rights under this Privacy Notice.
If you do not agree to this Privacy Notice, we will be unable to collect and use the information necessary to provide a service, which means we will not be able to provide you with the service.
This Privacy Notice shall enter into force as of the date it is updated.
If you have any questions or concerns about this Privacy Notice or our practices, please contact our Data Protection Officer using the email address below: