(Date: April 27, 2023)
If you have any questions, please contact us through the contact information provided in the main text of this policy.
1 The Information We Collect
1.1 Information You Provide
1.1.1 Information you provide when registering for an account. For example, information such as your nickname, avatar, email address, phone number, birthday (optional), gender (optional), etc., that you provide when registering for a Hayo account. Collecting this information helps you register for a Hayo account and log in to Hayo, and if you refuse to provide this information, it will affect your ability to register and use Hayo.
When you register and log in, if you use the one-click login function, based on our cooperation with communication service providers, we will collect your phone number and mobile operator information to provide you with convenient login services.
1.1.2 Information You Provide When Using Hayo Services.
(1) The nicknames, introductions, notes, and identifiers of your friends list.
(2) The content you Input, upload, publish, forward, feedback, or comment on (including text, photos, or video information) which may include your Personal Information, including the dynamic information you post on your personal homepage and the communication content between you and us (we may collect your name, contact information, and the contents of any messages you send).
When you use the group chat, private chat, team function to send pictures and articles or audio and video functions, we will request your authorization through a pop-up window for Hayo to access your device (or photo, camera, microphone) permissions so that we can obtain the pictures and audio and video you want to use for publishing. If you refuse to authorize the provision, you will be unable to use some functions, but it does not affect your normal use of other functions in Hayo.
Please note that this may include your personal identity information, personal property information, and other sensitive information. Please consider carefully before disclosing your relevant Personal Information.
1.1.3 Information from actions you take. We collect information about your use of Hayo and Hayo Service. This includes the users you follow, the users, communities, posts and tools you engage with, the communities you join and participate in, content moderation decisions you make, and other related actions.
1.1.4 Other information you provide directly to us. Like the Information you submit through our customer service or when participating in our events or other information you have the option to submit. For example, the survey questionnaire you fill out when participating in our online activities may contain information such as your name and phone number.
1.2 The Information We Receive Automatically When You Use Hayo Services
1.2.1 User account, operation time, operation type, network source and destination addresses, network source ports, client hardware characteristics.
1.2.2 Log Information. When you use our services, in order to ensure your normal use of our services, provide better services and improve your user experience, as well as network security protection needs, we may automatically collect relevant information and store it as service log information.
(1) Device information. For example, device model, operating system version, IMEI, Mac address, Android ID, installed application list, multimedia files, and other information.
(2) Software information. For example, software version number, browser type. To ensure the security of the operating environment or to provide necessary services, we will collect information about the mobile applications and other software you use.
(3) IP address.
(4) Service log information. For example, log and event information related to how and when you use our services (such as the pages, servers, and channels you visit, the activities you engage in, or the embedded content you interact with).
When you use our search services, we will collect the keyword information you search for, search records, and device information. In order to provide more efficient search services, some information may be temporarily stored on your local device. Here, it should be noted that individual search keyword information cannot identify your personal identity and does not belong to your personal information, so we have the right to use it for other purposes; only when your search keyword information is related to your other information and can be combined to identify your personal identity, we will treat your search keyword information as your personal information and handle and protect it according to this policy along with your search history.
1.2.3 Other Related Information. In order to help you get a more relaxed access experience and better use our products or services, we will collect relevant information.
1.3 Other users' published or shared information contains your information. For example, photos or videos published or shared by other users may contain your information.
1.5 Online Connectivity Information. In order to provide you with corresponding services based on your online status, we need to check your current network status, such as connecting to WLAN networks or disconnecting, checking the status of Wi-Fi on or off.
2 How We Use and Store Your Information
We use the collected information for the following purposes in accordance with relevant jurisdictions and our agreement with you. If we use your information beyond the following purposes, we will explain again and obtain your consent.
2.1 How We Use Your Information
2.1.1 Communicate with you to notify changes of Hayo.
2.1.2 Implement our agreement terms, conditions, and policies.
2.1.3 Provide, administer, maintain Hayo Services and help you use Hayo-related functions. For example, ensure that you can post content, communicate with other users, and provide user support.
We will not combine the information stored in the analysis software with the personal identity information provided by you in the application.
2.1.5 Security protection. For example, we may use your information for identity verification, security prevention, anti-fraud monitoring, archival backup, and customer security services.
2.1.6 Develop new services and improve existing services. For example, conduct software certification, software upgrades, etc., and use the information you provide when using a particular service for user research analysis and statistical services.
2.1.7 Conduct research.
2.1.8 Monitor for and take action against users and content that violate Hayo Terms of Service and other policies.
2.1.9 To comply with legal obligations and to protect any rights, privacy, safety, property, or safety of us, our affiliates, or other third party.
2.1.10 Invite you to participate in surveys related to our services.
2.1.11 Provide customer service. We use your information to respond to your questions about Hayo and Hayo Services, and to investigate bugs or other issues.
2.1.12 We retain and use your information in connection with potential legal claims when necessary and for compliance, regulatory, and auditing purposes. For example, we retain information where we are required by law or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any of your applicable legal rights to access, amend, or delete your personal information, we may request additional information from you for the purpose of confirming your identity.
2.1.13 A limited number of authorized Hayo personnel may view and access Your Content (as defined in Hayo Terms of Service) only as needed for these reasons: (1) investigating abuse or a security incident; (2) to provide support to you if you reach out to us with questions about your account; (3) to comply with legal obligations; or (4) fine tune our models using user-submitted data.
2.2 How We Store Your Information
2.2.1 We will transfer personal information collected from you to servers located in the Hong Kong Special Administrative Region of the People's Republic of China and store or process information there. We may also store information on servers and equipment in other countries or territories depending on a variety of factors, including the locations of our users and service providers. By accessing or using Hayo Services or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the Hong Kong and other countries or territories, where different data protection standards may apply and/or you may not have the same rights as you do under local law.
2.2.2 Minimization of Personal Information Storage Time. We will only store your personal information for the shortest time required for the authorized use purposes and as required by applicable laws. How long we store your Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.
Beyond the above personal information storage period or until you request removal of relevant information or your account is deleted (whichever is earlier), we will delete or aggregate or anonymize your personal information.
2.2.3 De-identification Processing. After collecting your personal information, we will immediately perform de-identification processing on your personal information and take technical and managerial measures to separate the information that can be used to identify individuals from de-identified information and strengthen permission management for access and use. When we anonymize or de-identify your Personal Information for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
2.2.4 Transmission and Storage of Personal Sensitive Information.In certain jurisdictions, certain types of personal information (such as information about your race, religion, political or philosophical beliefs, sexual orientation, and health status) may be considered "personal sensitive information" and subject to more stringent regulation than other types of personal information.
Some of our services may require you to provide specific personal sensitive information to achieve specific functions. If you choose not to provide such information, you may not be able to use specific functions in the service normally but this does not affect your use of other functions in the service. If you voluntarily provide us with your personal sensitive information, it means that you agree to allow us to process your personal sensitive information for the purposes and methods described in this policy. We will take encryption and security measures for the sensitive information you provide to us. When transmitting and storing your personal sensitive information, we will adopt security measures such as encryption.
2.2.5 If Hayo terminates its operation or services, we will promptly stop collecting your personal information and notify you of the termination of operation by delivering notices or public announcements, and delete or anonymize your personal information.
3.1 We or our third-party partners may collect your information by placing secure cookies, identifiers, and related technologies in order to provide you with better experiences and services. We will strictly require third-party partners to comply with relevant provisions of this Policy.
3.2 You can also manage cookies through your browser or device settings. However, please note that if you disable cookies, you may not be able to enjoy the best service experience, and some services may not function properly.
4 Your Rights
4.1 Depending on location, individuals across the globe may have certain statutory rights in relation to their Personal Information. For example, you may access, correct, and delete your registration information and other personal information you provided, and contact us for processing in accordance with the notification guidance. The scope and method of accessing, correcting, and deleting personal information will depend on the specific service you use. The rights and provisions set forth under this clause apply only to users located within relevant jurisdictions. If there are special regulations in your jurisdiction, please contact us promptly and inform us of the requirements.
4.2 If you find that we collect and use your personal information in violation of applicable laws, regulations, or agreements between us, or if you are unable to exercise your rights through your account, you may send your request to us.
4.3 When you access, correct, and delete relevant information, we may require you to verify your identity to ensure account security.
4.4 You can click "My-Settings" to select privacy settings and notification settings. However, please understand that once you change relevant settings, we will no longer be able to provide you with specific functions and/or services corresponding to the settings. Your decision to change settings does not affect the effectiveness of personal information processing activities previously carried out based on your consent or authorization.
4.5 You may edit or delete specific pieces of information within Hayo. For example, you can clear chat history, delete any posts you have sent or content you have posted.
4.5 You can click "My-Account Related-Cancel Account" and select "Confirm Cancellation" to cancel your account if the conditions for account cancellation are met. Please understand that canceling an account is irreversible. Once you cancel your account, we will delete all information related to your account, except where otherwise provided by applicable laws and regulations. You will also be unable to regain access to Hayo's related services through a canceled account. After you cancel your account, we will promptly delete your personal information or aggregate or anonymize it.
5 How We Share Your Information
We strictly limit the sharing of your information in accordance with applicable laws and regulations and prioritize risk management. We only share your information with selected recipients under reasonable and necessary circumstances, including:
5.2 With your prior consent, we may share your personal information with third-party partners.
5.3 We may need to entrust or share anonymized or de-identified information with third-party partners for processing, primarily for the following purposes:
5.3.1 To provide you with our services;
5.3.2 To realize the purposes described in the "How We Use Your Information" section;
5.3.3 To fulfill our obligations and exercise our rights under this Policy;
5.3.4 To understand, maintain, and improve our services.
For organizations or individuals to assist us in meeting business operations needs and to perform certain services and functions that accept our entrusted processing of your personal information, we will sign strict agreements with them to clarify the entrusted matters, purpose, deadline, processing methods, types of personal information processed, protection measures, and the rights and obligations of both parties. We require them to process your personal information according to our requirements, this Policy, and relevant confidentiality and security measures, and these parties will access, process, or store information only in the course of performing their duties.
We will not proactively share identifiable personal information (such as your name or email address) with third-party partners unless you explicitly authorize it. We will only share your personal information for legitimate, legal, necessary, specific, and explicit purposes, and only the necessary personal information will be shared.
5.4 Business Transfers. In the event of a merger, acquisition, asset transfer, restructuring, sale, or other transaction, or for other reasons, we may transfer your personal information to third parties or group companies in the diligence process with counterparties or transferred to a successor or affiliate as part of that transaction along with other assets in order to continue providing you with services. At the same time, we will notify you of the relevant situation through push notifications, announcements, and other means, and continue to protect or require new recipients to protect your personal information according to applicable laws and regulations and standards no lower than those required by this Policy.
5.5 We may use the collected information for big data analysis. For example, we may use the collected information to analyze and form heat maps of cities or industry insight reports that do not contain any personal information. We may publicly disclose and share information that has been statistically processed and does not contain identifiable content with our partners for the purpose of understanding how users use our services or letting the public know about overall usage trends of our services.
5.6 Government, public sectors, regulatory, judicial and law enforcement agencies, or authorities. In certain circumstances, we may disclose your personal information for the following purposes:
5.6.1 To comply with applicable laws and regulations;
5.6.2 To comply with provisions of court judgments, rulings, or other legal procedures;
5.6.3 To comply with requests from relevant government agencies or other legally authorized organizations;
5.6.4 When we have reason to believe that it is necessary to comply with applicable laws and regulations;
5.6.5 For reasonable and necessary purposes, such as enforcing relevant service agreements or this Policy, maintaining social public interests, protecting the personal and property safety or other legitimate rights and interests of our customers, us or our affiliates, other users, or employees.
6 Information We May Send to You
6.1 Information Push
When you use our services, we may send you text messages or push notifications. You can unsubscribe from these notifications by following our related instructions on your device.
6.2 Service-Related Announcements
We may send you service-related announcements when necessary (such as when a certain service is suspended due to system maintenance). You may not be able to unsubscribe from these non-advertising service-related announcements.
7 Information Security
We attach great importance to information security and make every effort to provide appropriate security measures for your information to prevent its loss, improper use, unauthorized access, or disclosure.
7.1 Regardless of where your personal information is stored or accessed, we will strictly follow the applicable laws and regulations to protect users' personal information, maintain their privacy and integrity.
7.2 We will use various security measures within a reasonable level of security to ensure information security. For example, we use encryption technology (such as TLS, SSL), anonymization methods, and other means to protect your personal information. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information.
7.3 We establish special management systems, processes, and organizations to ensure information security. For example, we strictly limit the scope of personnel who access the information, require them to comply with confidentiality obligations, and conduct reviews. In the event of a security incident such as personal information leakage, we will initiate an emergency plan to prevent the incident from spreading, and notify you through push notifications, announcements, and other means.
7.4 Despite the reasonable and effective measures we have taken and our compliance with applicable legal requirements, please understand that due to technical limitations and possible malicious methods, in the internet industry, even with strengthened security measures, it is impossible to ensure information security 100 percent of the time. You need to understand that the systems and communication networks you use to access our services may have problems due to factors beyond our control. Therefore, you should take active measures to protect the security of personal information, such as regularly changing passwords and not disclosing personal information such as your account password to others. You should be aware that the personal information protection measures provided by Hayo only apply to the Hayo platform. Once you leave the Hayo platform and browse or use other websites, services, and content resources, we are unable and have no obligation to protect any personal information you submit on websites outside of the Hayo platform, whether or not you log in or browse those websites based on links or guidance from the Hayo platform.
7.5 Responding to Your Requests
To ensure safety, we will process your requests promptly after verifying your identity. We may refuse requests that are unreasonably repetitive, require excessive technical means (such as requiring new systems to be developed or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are extremely impractical. We may not be able to respond to your request if:
7.5.1 It is related to our compliance with applicable laws and regulations;
7.5.2 We have reason to believe that you have subjective malice or abuse of rights;
7.5.3 It is difficult to obtain your authorization for the purpose of protecting your or others' significant legitimate rights and interests such as life and property;
7.5.4 Responding to your request would cause serious damage to your or others' legitimate rights and interests;
7.5.5 It involves trade secrets.
8 Information about Minors
9 Scope of Application
9.1 This policy applies to all of our services.
9.2 Some services have their own specific privacy guidelines/statements, which more specifically explain how we handle your information in that service.
9.3 In case of any inconsistency between this policy and the specific privacy guidelines/statement of a particular service, the specific privacy guidelines/statement shall prevail.
9.4 Please be aware that this policy does not apply to third-party services accessed through the Hayo platform and related services (including information accessed through any third-party website). Your use of such third-party services is subject to their own privacy policies (rather than this policy), and you should carefully read the relevant terms of the third party. Please protect your personal information properly and only provide it to third parties when necessary.
10 Contact Us
Hayo and related services are provided by NICETALK (HONG KONG) LIMITED. If you have any questions about this policy or other related matters, you can provide relevant information and send your question to firstname.lastname@example.org.
We will review the issues involved as soon as possible and respond within 15 days after verifying your user identity.