WeCom

Privacy Policy

Last Updated: 28 March 2025

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to WeCom (“Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

This Privacy Policy only applies to users located outside the PRC. For users located in the PRC, this Privacy Policy does not apply to you. Please see the privacy policy located at https://work.weixin.qq.com/nl/privacy.

SUMMARY

Here is a summary of the information contained in this Privacy Policy You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Service?

·       If you register an account to use the Service, then we will need some information from you to set this up. This includes your mobile phone number, email address, user name, display name and profile picture, depending on the method of registration. We will generate a User ID, which is an internal ID for your account.

·       If you choose to set up your profile using a social media account, such as WeChat or Weixin, we also collect the following information, including name, profile picture, mobile phone number, and WeChat or Weixin friends list, from that social media account service provider when you connect.

·       If you choose, you can provide certain other optional information to set up your account and/or enable certain Service features.

·       If you need to get in touch with us, then we will also retain some information so that we can get back in touch with you and address any concerns.

·       We are the data controller for personal information processed in WeCom, except with regard to Company-controlled Data (as defined below), i.e., personal data in information or documents submitted or produced by users of the Service. If you use one of our Interoperable Functions (as defined below), such as WeChat, we automatically collect certain data from you (e.g., you will be able to add your WeChat contacts to the Service, view each other’s profiles and send messages in the messaging function). The provider of the Interoperable Function is your data controller.

More Information.

How will we use your information?

·       We use your information to provide the many functions and services that comprise the Service. We also use your information for account verification, security purposes, to support and improve the Service, and to comply with our legal obligations and enforce our legal rights.

More Information.

Who do we share your information with?

·       We use third parties and work with our affiliates to help us deliver the best possible experience (e.g., use cloud providers to back up your data; use our affiliates around the world to help us to deliver the Service).

·       All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above).

·       In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.

More Information.

Where do we process your information?

 

·       Our servers are located in Singapore and the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong and Macau) (“PRC”). Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the PRC.

More Information.

How long do we keep your information?

·       We generally retain your information we process as a data controller until we receive a data deletion request from you, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. For Company-controlled Data, this information is kept for the duration set out in the Company User’s data retention policy. For data processed by the Interoperable Functions, please refer to the privacy policy of the relevant Third Party Provider.

More Information.

How can I exercise my rights over my information?

·       Depending on where you are, you may have certain rights with respect to your information, such as rights of access, receiving a copy of your data, or deleting your data or restricting or objecting to our processing of your data. To exercise your rights in relation to Company-controlled Data, you can use our deletion, access and download tools, or contact the relevant Company User who is the controller of the Company-controlled Data.

More Information.

How will we notify you of changes?

·       Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.

More Information.


 

Welcome to WeCom!

This Privacy Policy explains the when, how and why when it comes to processing your personal information in connection with WeCom (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully — it is important for you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the Privacy Policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested, and stop using the Service. By using the Service, you are acknowledging our rules regarding your personal information, as described in this Privacy Policy.

This Service has been developed by Tencent International Service Pte. Ltd.

Data controller activities

WeCom-controlled Data

For the purpose of data protection laws, the data controller of WeCom-controlled Data (as defined below), in relation to the Service, except with regards to Company-controlled Data (as defined below), are as follows:

·       If you are a WeCom user located in the European Economic Area (“EEA”), the United Kingdom of Great Britain and Northern Ireland (the UKor Switzerland: Tencent International Service Europe B.V., a Dutch company, located at Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands; and

·       If you are a WeCom user located outside of the EEA, the UK, Switzerland and the Chinese Mainland: Tencent International Service Pte. Ltd., located at 10 Anson Road, #21-07 International Plaza, Singapore 079903.

In this Privacy Policy, we, our or usrefers to either of the above entities, depending on where you are located.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at WeCom_DP@tencent.com. We have representatives for data protection purposes listed here.

Please note that this Privacy Policy describes how we process the personal information you provide to set up your account and use the Service. We are the data controller for such personal information, except with regard to Company-controlled Data (as defined below).

Company-controlled Data

Your respective employer or organization (as relevant) will be the data controller of Company-controlled Data (as defined below) if you use the Service in the course of your employment or in a non-personal capacity, which includes personal information such as approval records data if this function is used by your employer as part of the Service. If you join another Company User’s WeDrive, they will be the controller of any data submitted or generated as part of that WeDrive. In each case, we will be the data processor in relation to Company-controlled Data.

To the extent your respective Company User processes certain of your Company-controlled Data in connection with the Service, we are the data processor and act on the Company User’s instructions with respect to such Company-controlled Data. We describe this further below. Please also see our Data Processing Agreement, located here, for further information.

Relevant Definitions

·       Company User means the individual or organization registering, logging in to and using the Service and obtaining the administrative permission to operate a company account, including, but not limited to, legal persons, government agencies, other organizations, partners or sole proprietors. A Company User creates its own work platform, which means a virtual workspace that is created and managed by the Company User, and may be available for many people to concurrently use the Service, through the Service, inviting and authorizing an individual user to join such work platform to become its end user.

·       Company-controlled Data” means information that may be submitted, created or generated by the Company User or you during the use of the following functions of the Service and which we process on the Company User’s behalf as a processor. Please refer to the section “The Types of Personal Information We Use” for a list of the Company-controlled Data.

·       Individual User” means the individual user who is invited by the Company User to join the company platform and registers to use the Service, also referred to as “you” or “End User”. When the Company User invites you to access its work platform as an End User, you will receive an invitation and may choose whether or not to join this Company User.

·       WeCom-controlled Data” means information we hold about you as a data controller, such as account registration information (listed below) and information about you generated as part of the Service.

 

Interoperable Functions

WeCom is interoperable with various functions and features (“Interoperable Functions”) provided by other service providers (“Third Party Provider”). This enables you to use certain features and functions operated by these service providers, such as scheduling a video or voice call meeting on VooV Meeting or communicating with WeChat users, in accordance with the function’s applicable terms. When you use an Interoperable Function, certain data may be collected by the relevant Third Party Provider, or made available to the relevant Third Party Provider, either by you or via the Service, in order to enable your use of that function. You will also be subject to the Interoperable Function’s privacy policy. If you have any questions about the processing of your data by the Third Party Provider, please contact them directly.

You may view the list of Interoperable Functions below.

Interoperable Function

Third Party Provider

Account registration: if you register for a WeCom account using WeChat or Weixin.

WeChat

Weixin

Address book: if you add any contact that is a user of WeChat or Weixin.

WeChat

Weixin

Communication by way of text chat, voice call or video call: if you communicate with users of WeChat or Weixin.

WeChat

Weixin

Contact customers: if the customers added for customer management purposes are users of WeChat or Weixin.

WeChat

Weixin

Customer group chat: if you invite users of WeChat or Weixin to join a customer chat group.

WeChat

Weixin

Forms: to enable users of WeChat or Weixin to participate in a form created by an Individual User.

WeChat

Weixin

Invitation to join the company platform: if an Individual User is invited by the Company User to join the company platform as an End User via WeChat or Weixin.

WeChat

Weixin

Meetings: if you use the Meetings function offered by VooV Meeting.

VooV Meeting

Mini program operators: if you or your Company User uses third-party products or services through the WeCom website, the third-party service provider may use our API or SDK to notify us of which third-party products or services you have used.

Mini Program operator

Weixin

Moments: if you or other Individual Users allow your contacts to view WeCom Moments via their WeChat or Weixin.

WeChat

Weixin

Succession upon resignation: if you assign your clients to users of WeChat or Weixin upon resignation.

WeChat

Weixin

Weixin Customer Service plugin: to allow users of WeChat or Weixin communicate with you or other Individual Users acting on behalf of the Company User to obtain customer service support on the services provided by the Company User.

WeChat

Weixin

 

1.            Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience of using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2.            Children

Our Service is intended for business use only and is not intended for children. Children must not use the Service for any purpose, except where WeCom is used in schools / by educational organisations (available in certain jurisdictions only).

By children, 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. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

 

Region in which the user is located

Minimum age of the user

European Economic Area

16

Russia

14

Switzerland

16

United Kingdom

16

United States

16

 

3.            How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

It also identifies the legal basis under which we process your data under applicable data protection laws (where relevant).

We process certain personal information (WeCom-controlled Data) as a data controller, as set out below. Company-controlled Data is processed by us, as a data processor, on the Company User’s and your behalf, as set out below.

A.           WeCom-controlled Data: Information we process as a data controller

Personal Information

Use

Legal Basis (where applicable)

Information you provide to us (either directly or through a third party). 

Account registration information:

·       New account creation (via phone number / email address): User ID, mobile phone number/ email address, user name, gender, display name and profile picture.

·       WeChat or Weixin account login: your WeChat or Weixin ID, WeChat or Weixin friends list, user ID, mobile phone number, user name, gender, display name and profile picture.

We use this information to create your account for the Service, in accordance with your request.

Necessary to perform our contract with you to provide the Service.

IP address

This is processed momentarily by us but is not stored on our servers.

We use this information to identify your location to determine whether the Service is available to you.

Necessary to perform our contract with you to provide the Service.

Date of birth

This is processed momentarily by us but is not stored on our servers.

We use this information to determine if you are a child and whether the Service is available to you.

It is in our legitimate interest to ensure compliance with applicable age-gating rules.

Country or primary location and language selection (manually selected by you).

We use this information to ensure you receive the most appropriate version of the Service.

It is in our legitimate interests to use this information to deliver the most appropriate version of the Service.

WeCom verification on the identity of a company, education and training institution, government entity and public institution, non-profit organization or social organization*: full name of the entity, name in short form of the entity, unified social credit code on the business registration certificate, business registration certificate or, name of administrator, mobile phone number of administrator.

*functionality subject to availability

We use this information to verify the identity of a company, education and training institution, government entity and public institution, non-profit organization or social organization to register it as a Company User and provide the Service, in accordance with request of such entity’s administrator.

Necessary to perform our contract with you to provide the Service.

Individual User’s real-name identity verification*: country, full name, ID card or passport or driver license (photos of the front and back and its information), mobile phone number, credit card statement, bank statement

*functionality subject to availability

We use this information to verify the identity of an Individual User so that the Individual User can communicate or interact with users located in the PRC.

Necessary to perform our contract with you to provide the Service.

Invitation by the Company User to join the company platform as an End User via the following methods:

·       Text message: user name, mobile phone number;

·       Email: user name, email address;

·       WeChat or Weixin: user name, WeChat or Weixin friends list, WeChat or Weixin ID.

We use this information to allow the Company User send invitations to Individual Users to join the company platform as an End User.

Necessary to perform our contract with you to provide the Service.

Customer support information: relevant information that you voluntarily provide to us through our customer service representative or when participating in our services, your company information and a questionnaire completed by you when you participate in our online activity which may contain your contact information (e.g., name, email address, phone number and other contact information).

We use this information to:

·       provide troubleshooting, such as addressing and remediating technical issues and bugs; and

·       for administering product / customer support services to you.

Necessary to perform our contract with you to provide the Service.

Information generated or processed as part of the Service

Device information

Android: Device ID (IMEI), Series ID, Android ID, MAC address, device host, device hardware, RadioVersion.

iOS: IDFV, Model, OS Version, Network, WiFI, MAC, operating system, service software version number and device accelerator (such as gravity sensor device).

MacOS: Serial number, MAC address of the network card device, model identifier.

Windows: MAC address, motherboard UUID, hard drive serial number, domain name and domain computer name, device model.

We use this information:

·       to improve our services, including the functionality of the Service;

·       for security and verification purposes; and

It is in our legitimate interests to improve the Service and ensure the integrity and security of the Service.

·       to allow you to connect to our server.

 

Necessary to perform our contract with you to provide the Service.

Log information: manner, type and status of the network accessed, network quality data, operation log information, such as the website information the individual views at WeCom and service fault information.

We use this information:

·       to improve our Service, including the functionality of the Service; and

·       for security and verification purposes.

It is in our legitimate interests to ensure the integrity and security of the Service.

Service usage data and backend statistics: how often you use the Service, the date and time of logging into the Service, service default / error information, overall usage data and performance data.

Service log information: the operational record generated when you use the Service, including device IP address, fault log and software operational data (in case of failure, users can also voluntarily submit log files to the administrating server).

We use this information to:

·       ensure the security of the service, solve and locate problems, help us better understand how our application is running, optimize our services and improve the quality of the Service; and

·       to determine whether an account has been hacked or whether any improper or illegal act exists.

It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.

Security-related information: device operation system settings, device information including equipment brand, available space on device, Device ID, model, CPU structure, CPU model, kernel version and resolution.

We use this information:

·       to provide a fair environment; and

·       to solve crashes and optimize compatibility.

It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.

 

B.            Company-controlled Data: Information we process as a data processor

Personal Information

Use

Legal Basis (where applicable)

Content shared by the Company User or you, which we process on your behalf as a processor

Company registration data: Your company, job title, department, landline number, fax number and office seat.

We use this information to register your account as being associated with the Company User.

We process this data as a processor on the Company User’s behalf.

Address book:

·       Company internal contact list: display name, department, job title

·       Company member list: details of Company member

·       External contact list: WeChat/Weixin user name and WeChat/Weixin ID if the contact added is a WeChat/Weixin user

We use this information to add company contacts to Individual Users’ accounts.

We process this data as a processor on the Company User’s behalf.

Chat data: Content of communications (by way of text messages, voice messages, images and documents) between you and other WeCom users, display name, profile picture, email address, phone number, gender, company name location information (this involves sharing of your location, which is available to users in certain jurisdictions only), (if the recipient is using WeChat or Weixin) WeChat or Weixin user name and WeChat or Weixin ID. For group chat, also display name of group members, group details and group notice. This information is stored on your device and the devices of the users that you have sent communications to.

Unless the Company User choose to store your chat, we do not permanently store this information on our servers and it only passes through our servers so that it can be distributed to the users you have chosen to send communications to.

If the Company User chooses to store your chat history, this will be stored in accordance with the instructions of the Company User.

If you voluntarily choose to use this function, we facilitate the posting of your communications with other users.

We process this data as a processor on the Company User’s behalf.

Backend management statistics for Company User: data relating to your use of the Service, being the time and date on which you logged

We use this information to display statistics on your use of the Service to the Company User.

We process this data as a processor on the Company User’s behalf.

Company forum function: user ID, display name, communication logs between you and other Individual Users.

The use of the Company Forum function is subject to certain restrictions regarding the acceptable use of the Service set out in the WeCom Acceptable Use Policy.

If you voluntarily choose to use this function, we process this information to enable you to communicate with other Individual Users.

We process this data as a processor on the Company User’s behalf.

Voice and video call functions: content of communications between users, display name, profile picture, email address, phone number, gender, company and object of the chat.

This information is stored on your device and the devices of others to whom you have sent communications. We only process this information momentarily on our servers to facilitate your communications.

You instruct us to use this information solely to facilitate you making a voice or video call while using the Service. We do not access the contents of your communications, which are encrypted.

We process this data as a processor on the Company User’s behalf.

Schedule / Calendar: calendar data and address book.

If you voluntarily choose to add meetings into your calendar and sync calendar data between WeChat users.

We process this data as a processor on the Company User’s behalf.

Favourite: User name, display name, file name of text messages, voice messages, images, videos, documents or any other files marked as favourite.

If you voluntarily choose to mark certain text messages, voice messages, images, videos, documents, location data and email attachments as favourite.

We process this data as a processor on the Company User’s behalf.

Live broadcast data: user name, profile picture, broadcast subject, audio and video data, audio and video quality data such as volume, packet loss rate and other relevant data, and chat data.

We use this information to optimize compatibility and to ensure this meets your personalized requirements.

We process this data as a processor on the Company User’s behalf.

Emails: communications between Individual Users, including pictures, attachments, email addresses, user ID, profile picture, display name, title, department phone number and device information.

If you voluntarily choose to use this function, we process this information to enable you to send emails to other Individual Users and to the Company User.

We process this data as a processor on the Company User’s behalf.

Meeting data (supported by VooV Meeting):

 

·       Audio and video data (including any screen sharing which is encrypted and can only be viewed in real time), any shared files (documents that can be viewed and edited before, during or after the meeting);

 

·       Audio and video quality data (including volume, packet loss rate and other relevant data) and meeting log records on participants, time and duration of the meeting;

 

·       Communication log: meeting ID, meeting subject, meeting start and end time, user ID of participants, user ID of participant recording meeting;

 

·       Network status data, being the status of the user’s WiFi/Internet connection and whether the user has authorisation to connect to the Service and its network (this will not be collected by us);

 

·       Network status data, being the status of connection between the user's connecting server and WeCom’s server (this will be collected and stored by the Service);

 

·       Blocked meeting participants (user ID of the blocked participants)

If you voluntarily choose to use this function, we process this information to enable you to communicate with other Individual Users and the Company User in a meeting.

We process this data as a processor on the Company User’s behalf.

Documents: Documents and files, user ID, profile picture, display name

If you voluntarily choose to use this function, we process this information to enable you to view and/or edit documents with other Individual Users and the Company User.

We process this data as a processor on the Company User’s behalf.

WeDrive: User name, display name, department, title, uploaded files

If you voluntarily choose to use this function, we process this information to enable you to upload files on WeDrive.

We process this data as a processor on the Company User’s behalf.

Mini Programs: User ID, profile picture, display name, WeChat/Weixin open ID (if you opened the Mini Program on WeChat/Weixin), information shared with us or provided to us by a third party operating Mini Program.

If you voluntarily choose to use this function, we process this information to enable you to access Mini Programs.

We process this data as a processor on the Company User’s behalf.

Contact customers: User name, user ID, profile picture, WeChat/Weixin user name and WeChat/Weixin ID, WeChat/Weixin profile picture

If you voluntarily choose to use this function, we process this information to enable you or other Individual Users and the Company User to view, contact and manage customers.

We process this data as a processor on the Company User’s behalf.

Moments: Information / media that you share, which may include geo-tagging your location* (only available in certain jurisdictions).

*functionality subject to availability

If you voluntarily choose to use this function, we facilitate the posting of information / media on Moments and allow your contacts to view via their WeChat or Weixin.

We process this data as a processor on the Company User’s behalf.

Customer Group Chat: User name, user ID, profile picture, WeChat/Weixin user name, ID and profile picture

If you voluntarily choose to use this function, we use this information to enable you to join group chats with customers within the Service.

We process this data as a processor on the Company User’s behalf.

Forms: User ID, display name, content of forms, location, WeChat or Weixin ID

If you voluntarily choose to use this function, we process this information to enable you or other Individual Users to create a form or participate in a form created by an Individual User.

We process this data as a processor on the Company User’s behalf.

Body temperature data (to the extent legally permitted in your jurisdiction)*: Body temperature, user ID, display name, phone number, address, gender, location information

*functionality subject to availability

Where the Company User requires the collection of this information, we process this information to enable the Company User to comply with its legal obligations relating to health and safety.

We process this data as a processor on the Company User’s behalf.

Approval records: User ID, user name, location and approval records produced / submitted by you or other Individual Users (no timekeeping data is collected)

If you voluntarily choose to use this function, we process this information to enable you or other Individual Users to submit approval requests to a Company User.

We process this data as a processor on the Company User’s behalf.

Inspection report: Inspection incident information, user ID, display name, ID information, address, location data and phone number.

If you voluntarily choose to use this function, we process this information to facilitate the reporting of any incidents by an Individual User or a Company User.

We process this data as a processor on the Company User’s behalf.

Company forum: User ID, display name, and communication logs between you and other Individual Users.

If you voluntarily choose to use this function, we process this information to enable you to communicate with other Individual Users.

We process this data as a processor on the Company User’s behalf.

Weixin customer service plugin: content of communications with customer service teams of different companies (via WeChat/Weixin), display name, profile picture

If you voluntarily choose to use this function, we use this information to allow users of WeChat or Weixin communicate with you or other Individual Users acting on behalf of the Company User to obtain customer service support on the services provided by the Company User

We process this data as a processor on the Company User’s behalf.

Succession upon resignation: user name, company name, WeChat or Weixin user name and WeChat or Weixin ID if you assign your clients to a WeChat or Weixin user.

If you voluntarily choose to use this function, we use this information to allow you to assign your clients to users of WeCom, WeChat or Weixin upon resignation.

We process this data as a processor on the Company User’s behalf.

Customer acquisition assistant: User name, contact channel (e.g. Weixin, WeChat)

If you voluntarily choose to use this function, we use this information to allow you to acquire customers.

We process this data as a processor on the Company User’s behalf.

Group chat assistant: User name, group name, group contact list

If you voluntarily choose to use this function, we use this information to allow you to send mass messages and notifications to multiple customers in batches to enhance efficiency.

We process this data as a processor on the Company User’s behalf.

Classwork*: classwork information, marking information, user ID and display information.

*functionality subject to availability

We use this information to facilitate teachers to monitor the completion and grading of your classwork and remind your parents of your submission of classwork.

We process this data as a processor on the Company User’s behalf.

Extra-curricular activities*: extra-curricular activities information, check-in records and user name.

*functionality subject to availability

If you voluntarily choose to participate in an extra-curricular activity, we use this information to facilitate your participation.

We process this data as a processor on the Company User’s behalf.

School Dashboard*: the number of teachers using the Service, the number of parents using the Service and the number of class groups within a school using WeCom.

*functionality subject to availability

We use this information to facilitate the management of schools and the usage of WeCom by teachers and parents by educational bureau of a municipality and district.

We process this data as a processor on the Company User’s behalf.

Announcement: User ID and display name.

We use this information to allow Company Users to publish announcements and allow Individual Users to issue reports.

We process this data as a processor on the Company User’s behalf.

Human resources assistant: User name, display name

We use this information to allow Company User (and Individual Users acting on its behalf) to manage the onboarding, formal employment, offboarding, and contract renewal of employees.

We process this data as a processor on the Company User’s behalf.

Dining reservation: User name, display name

We use this information to collect dining reservations from members on WeCom.

We process this data as a processor on the Company User’s behalf.

Conference room: conference room information, booking information including time, participants and meeting content, user ID, profile picture and display name.

We use this information to book a conference room based on your request.

We process this data as a processor on the Company User’s behalf.

Industry news: User ID, display name

We use this information to push top-searched industry-related articles to you or other Individual Users for you to understand more about industry trends.

We process this data as a processor on the Company User’s behalf.

Device inspection: User ID, display name

We use this information to conduct device inspection to help the Company User to learn more about device status and inspection results.

We process this data as a processor on the Company User’s behalf.

Wireless projection (screencast): projection device information, user ID, username and device information.

We use this information to allow you to cast the screen of your computer or mobile phone onto a TV or projector wirelessly.

We process this data as a processor on the Company User’s behalf.

Printer: Printer device information, user ID and device information.

We use this information to allow you to print files remotely from WeCom.

We process this data as a processor on the Company User’s behalf.

Wireless connection: Enterprise network data, network terminal data, user ID, user name and device information.

We use this information to allow you to connect with the workplace Wi-Fi and allow the administrator to inspect the workplace network.

We process this data as a processor on the Company User’s behalf.

Door access: door access device information, door access records, user ID and location data.

We use this information to facilitate the administrator to monitor your access to different parts of the workplace, based on the access controls granted by the Company User.

We process this data as a processor on the Company User’s behalf.

Data security: Member data, app data, contact data, client data.

We use this information to protect the critical data of the Company User and its employees, allow the Company User to back up WeCom data such that data can be recovered from the backup if it is accidentally deleted or corrupted, helping companies prevent losses.

We process this data as a processor on the Company User’s behalf.

WeChat/Weixin Workspace: Display name, profile picture, department, company contact list.

We use this information to allow you and other Individual Users to access WeCom functions and receive notifications from WeCom on WeChat or Weixin.

We process this data as a processor on the Company User’s behalf.

 

C.            Information processed in Interoperable Functions

If you choose to use the Interoperable Functions, other than the purposes and legal bases specified this Privacy Policy, your personal information will be processed for the purposes and legal bases specified in the privacy policy for that service. Please refer to the section titled “Interoperable Functions for more information.

 

4.            How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Service in Singapore and in the PRC. The servers applicable to your use of the Service will depend upon your location. We also have support, engineering and other teams who may support the Service, including from the PRC.

If you choose to use the Interoperable Functions, your personal information will be stored by the relevant Third Party Provider in the locations specified in the privacy policy for that function. Please refer to the section “Interoperable Functions” for more information.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

·               Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, for the purpose of processing support ticket ID and support communication and Third Party Providers if you choose to use an Interoperable Function. All Third Party Providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

·               Companies within our corporate group who process your personal information in order to operate the Service and provide interrelated functions such as Shenzhen Tencent Computer Systems Company Limited (i.e., the service provider for users located in the PRC), WeChat, Weixin, VooV Meeting or Tencent Maps. All related group companies may only use your personal information in accordance with this Privacy Policy.

·               Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.

·               Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

o   enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o   detect, prevent or otherwise address security, fraud or technical issues; or

o   protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

·               A third party that acquires all or substantially all of us or our business. We may also disclose your information to the third parties if we either: (a) sell, transfer, merge, consolidate or re‑organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5.            The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

6.            Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

A.           WeCom-controlled Data: Information we process as a data controller

Personal Information*

Retention Policy

Country or primary location and language selection

WeCom verification information on the identity of a company, education and training institution, government entity and public institution, non-profit organization or social organization

Customer support information

Device information

Security-related information

Stored for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request, after which it will be deleted automatically within 15 days).

Account registration information

WeChat/Weixin friends list: Stored in accordance with the WeChat and Weixin Privacy Policies.

All other data: Stored for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request, after which it will be deleted automatically within 15 days).

Individual User's real-name identity verification information

 

Stored for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request, after which it will be deleted automatically within 15 days).

However, the originals of materials submitted for identity verification will be stored for 180 days from date of collection. 

Information related to invitation by the Company User to join the company platform as an End User

 

WeChat/Weixin friends list: Stored in accordance with the WeChat and Weixin Privacy Policies.

All other data: Stored for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request, after which it will be deleted automatically within 15 days).

Log information

Service usage data and backend statistics

Service log information

 

Stored for a maximum of 180 days.

IP address

Date of birth

Processed momentarily by us but is not stored on our servers.

 

*Please see the section above titled “How We Use Your Personal Information” for a full description of each category of data.

B.            Company-controlled Data: Information we process as a data processor

For Company-controlled Data, where we process information as a processor on behalf of a Company User, this is retained in accordance with the Company User’s instructions on the retention periods of your personal information. In general, information is stored until we receive a data deletion instruction from the Company User.

If we are required to retain your information beyond the retention period determined by the Company User, for example to comply with applicable laws, we will store it separately from other types of personal information.

C.            Information processed in Interoperable Functions

If you use an Interoperable Function, your personal information will be stored by the relevant Third Party Provider for the duration specified in the privacy policy for that service. Please refer to the section “Interoperable Functions” for more information.

 

7.            Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Where we act as a data controller for your personal information, to exercise any of your rights, please contact us at WeCom_DP@tencent.com. Where we act as a data processor, you should contact the Company User to exercise any of your rights.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account. 

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Service account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at WeCom_DP@tencent.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at WeCom_DP@tencent.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

8.            Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: WeCom_DP@tencent.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #18-01

Singapore

048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9.            Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

10.         Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version;pca; r and local language version of this Privacy Policy, the English version shall prevail.


 

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Service, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

We take reasonable steps to ensure that third-party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third-party recipients. You have the right to access personal information we hold about you, how we use it and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-Service purchases.

 

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

 

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

 

Colombia

Your authorization to process personal information for the Service may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

 

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights, using the information specified in Section 8 (Contact)

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

 

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this privacy policy, as revised from time to time. If you do not agree to this privacy policy, you must not access or use our services and we have the right not to provide you with access to our services.

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

 

Japan

If you are under the age of 18, you must not use the Service for any purpose.

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

 

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 8 (Contact).

 

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may submit a request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Service to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

  • Our data protection officer, responsible for the management and safety of your personal information

 

Mexico

Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising.

In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the Service and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only”, which includes the limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 8 (Contact).

 

Philippines

You are entitled to the following rights:

·       Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

·       Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

·       Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

·       Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

·       Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

·       collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);

·       sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

·       transferring or storing your personal information in destinations outside the Philippines as described in Section 4 (How We Store and Share Your Personal Information)

Russia

If you are using the Service in Russia, this section “Russia” applies to you. By using the Service you consent to:

·               for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this privacy policy; if legitimate interests, optimisation of the Service or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);

·               the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore and the PRC; and

·               for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this privacy policy.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Service after the notification.

As regards the representative for Russia, you can contact us at WeCom_DP@tencent.com. Please include the word “Russia” in the subject line of your email.

Separate consent for using certain data

For the purposes of the operation of the Service, as part of its activities, we do not distribute (publicly disclose) personal data without the appropriate consent of the data subject and in compliance with the requirements of Article 10.1 of Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended).

By using the Service you also consent to the sharing of your personal information with certain third parties for the purposes set out under section “How We Store and Share Your Personal Information“.

You determine, in your discretion, the terms of disclosure to the general public of your personal data, by choosing to use certain features of the Service and by choosing the appropriate privacy settings in respect of your personal information in the Service.

We process your personal information subject to the terms of this privacy policy and your chosen features and settings.

This consent is granted for as long as you use the Services. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us (WeCom_DP@tencent.com): please include the word “Russia” in the subject line of your email.

 

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact).

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register with WeCom. If you are under 7 years of age, please do not attempt to use or register for our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Service. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Service.

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

 

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Service.

 

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

·       withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

·       request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

·       request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

·       lodge a complaint to a relevant authority.

 

Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

 

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is WeCom_DP@tencent.com and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

 

United States

 

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device.

·               Identifiers, such as your name as it appears on your social media profile, device ID, phone number and email address.

·               Internet or other electronic network activity information, such as your information regarding your use of the Service, including the account, time and duration of the communications made while using the Service; Device Information; Communication Log; and Service usage data, all as described in the main privacy policy.

·               Geolocation data such as your region location when you set up your profile and choose to provide this information for the Service.

·               Audio and visual information such as your social media profile picture.

·               Other information described in subdivision (e) of Section 1798.80, including information about your gender, or age. This information is collected directly from you in the context of being our consumer.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

·               To provide you with the Service, including maintaining your account, providing customer service, and facilitating the posting of your communications with other users.

·               To improve our services, including the functionality of the Service.

·               For security and verification purposes, including to prevent and detect fraudulent activity.

·               To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 3 (How We Use Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share Your Personal Information).

 

·               Other companies within our corporate group who process your personal information in order to operate the Service.

·               Other companies that provide services on our behalf in support of the Service and who are prohibited by contract from retaining, using or disclosing personal information for any purpose other than for providing their services to us.

·               Regulators, judicial authorities, and law enforcement agencies, and other third parties for safety, security or compliance with law.

·               Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold personal information of California residents within the meaning of “sold” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

 

Retention of Your Personal Information

 

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

 

California Users Under 18

 

Any California residents under the age of eighteen (18) who have registered to use the Service and who have posted content or information on the Service can request that such information be removed from the Service by contacting us. Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

 

  • Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
    • the categories of personal information about you that we collected;
    • the categories of sources from which the personal information was collected;
    • the business or commercial purposes for collecting personal information about you;
    • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
    • the specific pieces of personal information we collected about you;
  • Request to Delete. Request we delete personal information we collected about you;
  • Request to Correct. Request we correct inaccurate personal information that we maintain about you;
  • Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and
  • Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

 

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us. We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

 

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

 

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

 

Questions

 

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).

 

Vietnam

By accepting this privacy policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including lawfully disclosing and transferring it to third parties, as described in this privacy policy.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.