Privacy Policy
Last updated: August 2023
Welcome to Bubbly (the “Platform”). This Platform is provided and controlled by AZUREPHANTOM TECH LIMITED.
(“
Bubbly
”, “we”
or “us”). We are committed to protect and respect your privacy. 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.
Please read this Privacy Policy carefully to understand how we will treat your
information before you start to use our Service or communicate with us outside the Platform certain features or
functionalities of our Platform may be available via the Platform. This Privacy Policy governs the collection
and use of data about you and your use of the Platform. (Although, we may provide additional notice and choice
options within the Platform itself.)
By accessing or using our Platform, you are accepting and consenting to the
practices described in this Privacy Policy, which may be updated and amended from time to time. If you do not
agree to the terms of this Privacy Policy, you may not access or use the Platform.
1.
What information do we collect?
We collect information when you create an account and use the Platform, such as
your contact details, content you create, and your location. We also collect information you share with us from
third-party social network providers, and technical and behavioral information about your use of the
Platform.
Information you choose to provide
For certain activities, such as when you register, upload content to the
Platform, or contact us directly, you may provide some or all of the following information:
·
Registration information, when you sign up for an account on
Bubbly, you are asked to enter your
phone number
or
Facebook
or Google account
details
, and you are asked to enter your nickname, date of birth, gender, profile image, your current
countrycity. You may
also
fill in
your
information you disclose in your user profile during subsequent
use
, such as your personal introduction
.
·
User Content and Behavioural Information, such as preferences you set (such as
choice of language)
,
photographs, audios, videos you upload or create or send on Bubbly with Album’s permissions ,camera's permissions, microphone permissions.
·
Information from Third Parties, such as a third-party social network account
details (e.g., Facebook, Apple, Google) or login service and the information collected from you, and your
interaction with the Platform and other third-party sites and Apps.
·
·
The microphone permissions to
provide
Real-time voice
call
while you chat
with
y
our friends in the app.
·
Your opt-in choices and communication preferences.
·
Payment information, such as Google or Apple payment information
·
Notification permission in your mobile phone.
·
Information as your communication/call history and contents or the contact
information you send to us when you are contacting us.
·
Location data
,
including location information based on your IP address. With your
permission, we may also collect Global Positioning System (GPS) data to match the apposite playmates for you
based on location information.
Information we collect automatically
We automatically collect certain information from you when you use the Platform
(as described below), including your IP address, location-related data, unique device identifiers, browsing
history (including content you have viewed in the Platform), Cookies (as defined below), your mobile carrier,
time zone setting, and mobile or device information including the model of your device, screen resolution,
operating system, app and file names and types, and platform.
Device information
The device you are using (such as device model, operating system version, device
configuration, device identification, device network information, device environment and other characteristic
information of software & hardware).
Technical Information
IP address, user agent, mobile carrier, time zone settings, identifiers for
advertising purposes.
Browsing and search history
We automatically collect your browsing and search history (including content you
have viewed in the Platform) from you when you use the Platform.
Cookies
We and our vendors and service providers use cookies and other similar
technologies (e.g. web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure
and analyse which web pages you click on and how you use the Platform, enhance your experience using the
Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across
your different devices. Cookies are small files which, when placed on your device, enable the Platform to
provide certain features and functionality. Web beacons are very small images or small pieces of data embedded
in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date 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.
2.
How we use your information
We use your information to fulfill and enforce our Terms of Service, to improve and administer the Platform, and to allow you to use its
functionalities. We may also use your information to, among other things, show you suggestions, promote the
Platform, and customize your ad experience.
We generally use the information we collect:
·
to fulfill requests for products, services, Platform functionality, support and
information for internal operations, including troubleshooting, data analysis, testing, research, statistical,
and survey purposes and to solicit your feedback
·
to customize the content you see when you use the Platform. For example, we may
provide you with services based on the country settings you have chosen or show you content that is similar to
content that you liked or interacted with
·
to improve and develop our Platform and conduct product development
·
to support the social functions of the Platform, including to permit you and
other users to connect with each other through the Platform
·
to help us detect abuse, fraud, and illegal activity on the Platform
·
to communicate with you, including to notify you about changes in our
services
·
to enforce our terms, conditions, and policies
·
for any other purposes disclosed to you at the time we collect your information
or pursuant to your consent.
·
to combine all the information we collect or receive about you for any of the
foregoing purposes
3.
How we share your information
We may share your personal data
in accordance with
the
relevant laws and regulations
of
your country/region, including without limitation:
·
Cloud storage providers to store the information you provide and for disaster
recovery services, as well as for the performance of any contract we have entered into with you;
·
Analytics and search engine providers that assist us in the improvement and
optimization.
·
IT service providers that help develop, maintain, secure and optimize
the Platform;
·
Payment
Provider
s to facilitate the transactions.
·
Our data centre and the servers of our host providers.
We may share your information with any member or affiliate of our group, which
includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are
controlled by or under common control, and our service providers and strategic business partners, and their
respective subsidiaries, in each case in or outside your country, for the purposes set out above (“How We Use
Your Personal Data”).
We may share your information with law enforcement agencies, public or tax
authorities or other organizations if legally required to do so, or if we have a good faith belief that such use
is reasonably necessary to:
·
Comply with a legal obligation, process or request (including tax and related
reporting requirements);
·
Enforce our Terms of Service and other agreements, policies, and standards,
including investigation of any potential violation thereof;
·
Detect, prevent or otherwise address security, fraud or technical
issues;
·
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).
We may also disclose your information to third parties:
·
In the event that we sell or buy any business or assets, in which case we may
disclose your data to the prospective seller or buyer of such business or assets; or
·
If we sell, buy, merge 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. In any
such cases, the third party company or business will adhere to the provisions of this Privacy Policy and where
it will result in a change in any of the provisions herein, such changes will be communicated to you and you
will be given the chance to consent or opt out at your discretion.
4.
Third-Party Providers
You acknowledge and agree that we may process
y
our personal information for the purpose of improving the quality of Services,
conducting data and product analysis, planning promotional activities, etc., and may share your personal
information to our affiliates and partners or to independent third-party vendors listed below for that
purpose.
Such third-party providers may be local operating partners or technical support
partners outside your country. After the cooperation terminated, they will be denied access to all of our
information, including the information to which they previously had access. We promise not to provide, sell,
rent, share, or trade your personal information to any unrelated third party, unless we have your prior
consent.
Besides, to provide you with social features, diversify or otherwise improve our
Services, we may also provide third-party features or contents in our Services. Some of third-party
service
s
being linked to or embedded in Service (such as Social Media Platforms,
third-party payment platforms, Fraud-Detection Service Provider, Anti-Crack and Anti-Cheat Service Provider,
Social sharing Tools Provider, Customer Support Partner, etc.) may use cookies, web beacons, and/or other
tracking technologies to collect or receive data about you according to their
own
Pri
vac
y Policy, and we do not control the information that these third parties collect
or how they use that information. We strongly encourage you to check their own Privacy Policies on their
official websites and learn more about their data processing practices. Notwithstanding the foregoing, if you
discover that any third party collects or processes your personal information illegally or in a manner which
worries you, you are encouraged to contact us, and we will make reasonable efforts to help you. Main third-party
vendors linked to our Services which may collect your Personal Information and links to their Privacy Policy are
as follows (the specific list of Third-party vendors linked with each of our Service may vary):
|
Third-Party Services
|
Purpose
/
Function of these Third-Party Services
|
D
ata they collect
|
Links to the
ir
Privacy Policy
|
|
Facebook
|
Login
|
Device information, Technical Information
|
|
|
F
irebase
|
crash reporting tool
|
Device information, Technical Information
|
|
|
Agora
|
voice and video calling
|
Device information, Technical Information
|
https://www.agora.io/en/privacy-policy/
|
|
T
encent
Cloud
|
Cloud Streaming Services
|
Device information, Technical Information
|
https://intl.cloud.tencent.com/zh/document/product/301/17345
|
5.
Your Rights
·
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 login information in a browser and to opt out of login information 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.
·
If you have registered for an account you may access, review, and update certain
personal information that you have provided to us by logging into your account and using available features and
functionalities.
·
If you want to view, modify, or delete your data, please check the
personal page to edit.
·
You also have the right to have your personal data deleted, object how we use or
share your personal data, and restrict how we use or share your personal data. You can always withdraw your
consent
，
for example by turning off notification permission information functionality in
your mobile device settings if you do not wish to accept our information. If you don't want to use the location
function, you can turn it off on the system settings page. After turning off location function we will not be
able to match the apposite playmate for you based on location information.
·
you can deactivate your account so that you will not be able to send or receive
messages, Should you choose to do so, you may delete your entire account in Settings.
You can exercise your rights by contacting us at np.gaohee@gmail.com
or
feedback
service
. We will respond to your request consistent with applicable law and subject to
proper verification.
6.
Data S
t
orage
The information we collect from you is stored and encrypted in our servers
located in Singapore. We maintain major servers around the world to bring you our services globally and
continuously. And you are aware and agree that your personal
data
may be transferred to, stored in, and processed by affiliated companies,
subcontractors and/or partners, located in third countries/outside the country where you live or work. we will
take steps according to applicable laws and regulations in your country to ensure that your personal
d
ata
is adequately protected within the data process location.
7.
Security
We use reasonable measures to help protect information from loss, theft, misuse
and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage
system or transmission of data over the Internet or any other public network can be guaranteed to be
100
%
secure. Although we will protect your personal data, for example, by
encryption, we cannot guarantee the security of your information transmitted via the Platform are no risk
，
this is why we need you to strictly adhere to the agreements and guidelines in
documents such as our privacy policy, and we will work together to keep your personal information as secure as
possible.
We have put in place 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.
Data Retention
We retain your data for necessary to provide you with the service. 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 or defence of legal claims.
After you have terminated your use of our Platform, we
will
delete your information or store your information in an anonymised
format.
9.
Minor
The Platform otherwise is not directed at
minors
.
Minors
must not use the Platform for any purpose, except where their parent or guardian has provided
consent. By
minors
, we mean users under the age of 18 years old; or in the case of a region
where the minimum age for processing personal information differs, such different age.
We do not knowingly collect personal information from
minors
under these ages for any purpose. If you believe that we have personal
information of a
minor
under these ages without parental or guardian consent, or if you
are the parent or guardian of the user and wish to withdraw the consent, please submit your request
at np.gaohee@gmail.com and we will delete such information.
10.
Changes
We may update this Privacy Policy from time to time. When we update the Privacy
Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new
Privacy Policy and providing any other notice required by applicable law. We recommend that you review the
Privacy Policy each time you visit the Platform to stay informed of our privacy practices. By accessing or using the Platform, you acknowledge that you have read this
policy and that you understand your rights in relation to your personal data and how we will collect, use and
process it.
If major updates are involved, we will notify you in advance.
11.
Contact
Questions, comments and requests regarding this policy should be addressed
to:
·
Email Address: np.gaohee@gmail.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.
Algeria
By using the
platform
, you give us your consent for the collection, storage, treatment and use of
your personal information, and transfer of your personal information to a third party where it is manually and
electronically treated.
Egypt
This privacy policy is provided in Arabic for users located in Egypt. In case of
dispute, the Arabic version of this privacy policy shall prevail.
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 18 and that you have read and acknowledged Privacy
Policy and Terms of Use and agree to the use by your child of the Platform and registration for an
account.
By clicking the button to proceed or by proceeding with the sign up process, you
acknowledge that you have read, understood, and consented to this privacy policy. If you do not consent to
this privacy policy, you must not use the
P
latform
.
You are acknowledging your consent to the processing, storage, and cross-border
transfer of your personal data. The cross border transfer may be to any country in which we have databases or
affiliates
.
You also acknowledge your consent to receiving marketing messages from us.
As an Egyptian data subject, you have certain rights under the Egyptian Personal Data
Protection Law.
Turkey
If you are using our services in Turkey, the following additional terms apply
along with the contents of the foregoing Policy. 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.
Legal bases for the processing your personal
data.
We
rely on the following legal bases while processing your personal data in
accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:
·
processing is explicitly laid down or dictated by laws
·
processing of your personal data is necessary provided that it is directly
related to the conclusion or fulfilment of the contract between us
·
processing is mandatory for us to be able to comply with our legal
obligations
·
the relevant data is made available to the public by yourself
·
processing is mandatory for the establishment, exercise or protection of a
right
·
processing is mandatory for our legitimate interests, provided that it does not
violate your fundamental rights and freedoms
·
your explicit consent (Please note that we rely on this legal basis only when we
require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the
other legal grounds above)
Your rights. According to Article 11 of the Data Protection Law, you have the following
rights with respect to your personal data:
·
the right to learn whether we process your personal data,
·
the right to request information with regard to such processing, if we process
your personal data,
·
the right to learn the purposes of the processing and whether they are used for
such purpose or not;
·
the right to know the third parties within or outside the country, to whom we
transfer your personal data,
·
the right to request correction of incomplete or inaccurate personal
data,
·
the right to request deletion or destruction of your personal data under the
conditions set forth in Article 7 of the Data Protection Law,
·
the right to request that we notify the third parties, to whom we transferred
your personal data, about the correction, deletion and/or destruction of your personal data per your request
within the scope of the foregoing two items,
·
the right to object to the negative results about you that are due to the
analysis of your personal data processed solely by automated means,
·
the right to claim indemnification for damages incurred due to illegal
processing of your personal data.
You may exercise your rights listed above by contact us at: np.gaohee@gmail.com
The requests found in your application will be resolved as soon as possible
according to the nature of your request and within thirty days at the latest free of charge. However, if your
request incurs additional cost to our company, then you may be charged over the tariff fee determined by the
Turkish Personal Data Protection Board.
Amendments. The following sections of the Policy do not apply to individuals in
Turkey:
If you do not agree with this policy, please do not use this
Platform.
By accessing or using the Platform, you acknowledge that you have read this
policy and that you understand your rights in relation to your personal data and how we will collect and process
it.
Kingdom of Saudi Arabia
You consent to the collection, use, disclosure, transfer, export (to the extent
permitted by applicable laws) and storage of your personal information as described in this privacy policy.
Kuwait
You represent that you are at least 21 years old, or 18 years old and have obtained
parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and
regulations in Kuwait.
By accepting this Privacy Policy, you expressly state that you authorise us to
collect, use, store, and process your personal data and to disclose this data to third parties whether inside
or outside of Kuwait, in line with the provisions of this Privacy Policy.
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
By using our Platform in the UAE, this Privacy Policy will be governed by and
interpreted in accordance with the laws of the UAE.