Shortswave Privacy Policy

1. What Information We Collect

ShortsWave collects information about you as described below. As set out below in more detail, we use and in specific cases combine that information to operate, tailor content, personalize and adjust and improve our Services, and to send you messages or personalized information about our service, new features and more, including for marketing and promotional purposes in accordance with your preferences.

Device information:

When you use any of our applications, we or third party partners will collect and process certain information about you, including your unique device ID (persistent / non-persistent), hardware type, device maker, media access control ("MAC") address, international mobile equipment identity ("IMEI"), the type and version of your operating system ("OS"), language of the OS, your time zone, the screen size of your device, mobile device Advertising ID (known as "IDFA" for iOS devices, or "Android Advertising ID" for Android devices), your general geolocation information (city/country based on your Internet Protocol ("IP") address) and your email address (if you have connected to Facebook or Google+). This information is useful to us for troubleshooting and helps us understand usage trends so that we can improve and personalize the Services for our users. Device identifier / information such as device type, hardware model, device maker, device operating system and its language or other technical data like screen size, or combination of this data, is also collected and used to determine device compatibility and optimal settings.

Log information:

When you register to use the Services, we create a unique user ID to track your use of our Services. If you log into ShortsWave with a social networking credential, such as with a third-party account, we will ask permission to access basic information from that account, such as your name and email address. You can stop sharing that information with us at any time by removing ShortsWave's access to that account. When you do not log in to our services, we store the information we collect with unique identifiers tied to the application and device you're using. This collection helps us do things such as maintain your language preferences across browsing sessions.

Location information：

This refers to data about the user's geographic location, which can be obtained through the device's GPS, Wi-Fi, or cellular network signals. This information can be used to provide location-based services or content within the app.

Mobile Analytics:

Like most mobile applications, we use mobile analytics tools to collect certain information about your usage of our mobile applications, as well as on your device and the health of our Services to allow us to better understand the functionality of our Services on your device and for app optimization purposes. Such tools may record information such as how often you use the application, feature usage, and usage statistics, events that occur within the application, aggregated usage and performance data.

Contact information:

If you provide feedback or contact us, or otherwise provide information voluntarily to us, our employees, or our contractors, you contact information, any information you voluntarily provide and any associated data will be collected by us as well.

Usage information：

We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the ads you view, content you read and problems encountered, the content you like, the content you save.We also infer your preferences, including your interests, gender and age for the purpose of personalising content. Where appropriate, we will also use this information for the purpose of serving personalised advertising and to tell you about new services and opportunities.

In-App purchases:

We may collect your payment information if you are a paying customer. This information is required to complete a commercial transaction on our Platform. We use this information to enable and fulfill your transaction. If you choose to use any third-party's service service to finalize and pay for your order, you will provide your credit card number directly to the third-party. Please review the relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account with the correct value, we keep a record of the purchases you make, the time at which you make those purchases and the amount spent.

Information from Third Parties:

You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:

Social networks
If you choose to register to use the Platform with a social networking credential, such as with a third-party account (e.g. Facebook, Google, Apple), we will ask permission to access basic information from that account, such as your username, email address, public profile and other possible information related to such account. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. You can stop sharing that information with us at any time by removing our access to that account.

Advertisers, Advertising Networks, and Analytic Providers
We use the information collected from you, and your interaction with the Platform and other third-party sites and Apps, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you've visited, apps you've downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our Platform and from similar information received from third parties who advertise on our Platform and whose sites/Apps you visit. For more information on how you can control such information from third party advertisers and advertising networks, please refer to Section "Advertisement; Third Party Content and Services" below.

2. How We Use the Information

We use information collected through our Services, both individually and combined together, for purposes described in this Policy or disclosed to you in connection with our Services. For example, we may use your information to:

Create user accounts and allow users to use our mobile applications;
Identify and suggest connections with other users of our Services;
Facilitate sharing on social networks;
Operate, develop and improve our mobile applications, games and other Services;
Understand you and your preferences to enhance and personalize your experiences and enjoyment using our Service;
Provide you with personalized recommendations for mobile applications;
Respond to your comments and questions and provide customer service;
Provide and deliver products and services you request;
Measure the health of our Services;
Set up and maintain accounts you register for;
Identify, fix and troubleshoot bugs and Service or functionality errors;
Activate or authenticate your mobile applications and save stats (e.g. achievements);
Run competitions and contests;
Serve and measure the effectiveness of advertising;
Send you service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Personalizing advertising for you;
Send you direct marketing information and special offers about our products and services through inbox messages. If you do not want to receive any above-mentioned messages, please contact us through [email protected] at the time you create your account or any point thereafter;
Personalize content and experiences on our Services, including providing you reports, recommendations and feedback based on your preferences;
Optimize or improve our products, services and operations;
Facilitate software updates and automatically update the software on your device;
Protect the integrity of the Services and enforce our Terms of Service and other applicable terms, including to detect and prevent fraud and unauthorized activities, to secure our systems and the Services, to prevent hacking, cheats and spamming and generally to keep our Services safe and fair and to detect, investigate, and prevent activities that may violate our policies or be illegal;
Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
Perform statistical, demographic, and marketing analyses of users of the Services.
We may use information we collect from or about you to create aggregated or de-identified data that does not specifically identify you.
Push Notifications: With your consent in accordance with your device settings, we may send you push notifications through our mobile applications to send you game or app updates, high scores and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

3. How We Share Your Information

We do not share your personal information except as explicitly provided in this Privacy Policy. We share your personal information in one or multiple of the following circumstances:

Sharing with Your Consent: We may share information with third parties with your consent or at your direction.
Sharing with Service provider. We engage other companies and individuals to provide services to us for any of the purposes described in this Privacy Policy, such as cloud storage providers, payment card processing and verification. We require that these service providers provide the same or equal protection of user information as stated in this Privacy Policy, and prohibit them from retaining, using or disclosing your information except as necessary to provide services to us.
Sharing with Business Partners: You understand and agree that some of our services will be provided by our business partners or jointly with, and that you agree that we can share your necessary personal information with the following partners for the sake of this Privacy Policy:

Platform	Purpose	Link
Google	Third Login	https://policies.google.com/privacy
Apple	Third Login	https://www.apple.com/legal/privacy/en-ww/
Facebook	Third Login	https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
Firebase	Data analysis	https://firebase.google.com/terms/
Byteplus	Data analysis	https://docs.byteplus.com/legal/docs/privacy-policy
AppsFlyer	Data analysis	https://www.appsflyer.com/privacy-policy/
视频点播SDK	Video streaming decoding and playback	https://www.volcengine.com/docs/4/108995
OneSignal	Notification	https://documentation.onesignal.com/docs/data-security
Applovin	advertisement	https://www.applovin.com/privacy/
AdMob	advertisement	https://policies.google.com/privacy
Pangle	advertisement	https://www.pangleglobal.com/privacy
Mintegral	Advertisement	https://www.mintegral.com/en/privacy
Liftoff	Advertisement	https://liftoff.io/privacy-policy/
Paypal	Payment	https://www.paypal.com/us/legalhub/paypal/privacy-full
Onerway	Payment	https://www.onerway.com/privacy

Sharing with Government, public, regulatory, judicial and law enforcement bodies or authorities. We may release your information as required by law, such as to comply with a court order, or when we believe, in good faith, that release is appropriate to comply with the law and reasonably necessary to, including (a) comply with a legal obligation, process or request (including tax and related reporting requirements); (b) enforce our Terms and Conditions, Privacy Policy and other agreements, policies, and standards, including investigation of any potential violation thereof; (c) detect, prevent or otherwise address security, fraud or technical issues; or (d) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Disclosures in the event of merger, sale or asset transfer. We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. Under these circumstances, we will always require the third parties or related companies to comply with this Privacy Policy.
Sharing with Affiliates. We may share your information with any members, subsidiaries, or affiliates of us, to provide our services including improving and optimizing our services, preventing illegal use and supporting users.
Sharing with Advertisers and Advertising Networks. We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We may allow third party advertisers and advertising networks to set technologies and other tracking tools to collect your information described in Section "Advertisement; Third Party Content and Services" below to enable the technical delivery of personalized advertisements to your device.

4. How we protect your personal information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal information, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk. We do not warrant or represent that your information will be protected against loss, misuse or alteration by third parties, since no method of transmission over the internet, or method of electronic storage is 100% secure.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

5. Your rights of personal information

We provide you with the rights described below when you use our Services. Please contact us at [email protected] if you would like to exercise your rights under applicable law. As a user of our app, you have certain rights with respect to your personal information, including:

The right to access the personal information we hold about you;
The right to request that we correct any inaccuracies in the personal information we hold about you;
The right to request that we delete your personal information, except where we are required to retain it by law;
The right to object to the processing of your personal information, including for direct marketing purposes;
The right to request that we provide your personal information to you in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. We will respond to your request as soon as reasonably possible, and in any case within the time limits prescribed by law. We may request proof of your identity before processing your request. Please note that we may need to retain certain personal information for a period of time in order to comply with our legal obligations, such as record keeping obligations, and to complete any transactions that you began prior to requesting a change or deletion.
Delete account. You may remove any content from your account by deleting your account through the built-in online account deletion function. [You may delete your account by clicking "Profile" - "Settings" -- "About"-- "Account Deletion".]

6. Where we store your personal information

If you choose to use our Platform or provide your information to us, your information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where your are located. It may also be processed by staff operating outside your country who work for us, for one of our suppliers or one of our business partners. By submitting your information, you agree to such transfer, storage or processing. We will implement all necessary technical and organizational measures to ensure that your information is securely protected, in compliance with this Privacy Policy, and in accordance with applicable data protection laws and regulations, including ensuring that appropriate safeguards are in place for cross-border data transfers and ensuring the data is handled in a manner that respects your privacy rights.

7. Retention and Deletion of your data

If you no longer want to use our Services anymore and would like your account deleted, You can use the "Delete account" button to carry out this operation. Once the deletion request is confirmed, we will clear your relevant information stored in the app, subject to applicable laws and regulations. If you have uninstalled the app, you may request deletion of your data at any time by contact us at [email protected]. We will evaluate such requests on a case by case basis. We may keep some of your data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations. You have the ability to delete your Account, and you should understand that upon deletion of your Account, you will lose the right to access or use all or part of the Platform.Once you choose to delete your account, you will not be able to reactivate your account or retrieve any of the content or information you have added (including free content and paid content).

If your account is terminated, access to your username, password, and any related information or content associated with your account may be terminated. As we do not guarantee the permanent availability of your content, you should make and maintain backups of any content you value at your own cost.

8. Advertisement; Third Party Content and Services

We allow other companies, called third party advertisers and advertising networks, to serve advertisements within our Platform to deliver interest-based advertising to you about third party products and services. These third party advertisers and advertising networks use technology to send the advertisements and links that appear on our Platform directly to you.

When you use our Platform, some third party tools (SDKs) integrated within our Platform may collect and use certain information collected from your device for the purpose of advertisement display and optimization. Such information may includes device manufacturer, model, and operating system, screen size, orientation, audio, battery, device memory usage, carrier name, IDFV, IDFA or Android Advertising ID, time zone setting, locale settings (e.g. country and preferred language) and IP address. These third-party tools may also use other technologies (such as cookies, JavaScript, or Web Beacons) to measure their advertisements' effectiveness and personalize the advertising content delivered to you.

If you do not want to receive advertisements targeted to your interests from us, iOS and Android operating systems also provide options to limit tracking and/or reset the advertising IDs (For more information about how to change these settings go to: https://support.google.com/ads/answer/2662922?hl=zh, https://support.apple.com/en-us/HT202074). However, turning off personalized advertisement functions will limit our ability to deliver relevant advertisements to you but may not necessarily reduce the overall number of advertisements you receive.

If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for any of these data protection policies.Please check these policies before you submit any information to these websites.

9. Children's Privacy

Shortswave is not developed for children. This Platform is not directed at children under the age of 18 or equivalent minimum age in the relevant jurisdiction. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [email protected].

10. Changes to the Policy

We may, from time to time, modify the Policy. If such change has been made, we will provide you with clear and adequate notice of such modifications or updates, using appropriate methods as deemed necessary under the circumstances. These notices may include but are not limited to, in-app notifications, email communications, or updates on our website. By continuing to use our app or services after the Policy has been updated, you acknowledge and accept the revised terms. If you do not agree with the changes, you may discontinue using our app or services.

11. Cookies

We, and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) ("Cookies") to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your devices. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as "pixel tags" or "clear GIFs," that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. We are committed to safeguarding your personal information and complying with relevant data protection laws to ensure that your data is protected. If you have any questions or concerns regarding the use of Cookies or your privacy preferences, please refer to our Cookie Policy or contact us directly.

12. Supplemental Terms：Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms -- Jurisdiction-Specific applicable to your jurisdiction from which you access or use the services, and the rest of the Privacy Policy, the relevant jurisdictions' Supplemental Terms -- Jurisdiction-Specific shall prevail.

Additional Notice for California Residents:

This section applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").

How we collect and disclose your personal information

Over the past 12 months, we have collected and disclosed your personal information as mentioned in the "What Information We Collect" and "How We Share Your Information" sections, for purposes set out in the "How We Use Your Information" section. Please refer to these sections to see details.

The category of the above information is reiterated with terms specified in CCPA as follows:

Category Defined in CCPA	Source
Identifiers, including your email address and account name.	Information from other sources and information you provide.
Commercial information, including your transaction history, reward coins history and consumption records.	Automatically collected information.
Internet or other electronic network activity information, including your clicking and following records, collection, searching and browsing history, and information regarding your interaction with us.	Automatically collected information.
Audio, electronic, visual, thermal, olfactory, or similar information. This may be contained in the information you provide when contacting us.	Information you provide.
Sensitive personal information. Account log-in, in combination with any required security or access code, password, or credentials allowing access to an account.	Information from other sources.
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, and other attributes.	We may make inferences from information obtained directly from you or automatically collected during your use.

We do not knowingly collect any information about anyone under the age of 16.

Do we sell or share your personal information

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of "sold" and "shared" in the CCPA. We will not sell or share your personal information without providing you with notice and an opportunity to opt-out of such sale and sharing.

Your California rights

Depending on your residency, you have the following rights with respect to your personal information:

The right to know. You have the right to request to know what personal information about you we have collected, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected.
The right to delete. You have the right to request us to delete your personal information, subject to certain exceptions.
The right to correct. You have the right to request us to correct inaccurate personal information that we maintain about you. Note that correction requests are subject to certain limitations, and we may choose to delete rather than correct your personal information in some circumstances.
The right to opt-out. You have the right to opt-out of the sale or sharing of your information under CCPA. However, as aforesaid, we do not sell or share your personal information in the context of CCPA. Tfore, we do not have an opt-out. We will not sell or share your personal information without providing you with notice and an opportunity to opt-out of such sale and sharing.
The right to limit. You have the right to request us to limit the use and disclosure of sensitive personal information in accordance with CCPA, subject to certain limitations.
The right to non-discrimination. We will not discriminate against you for your exercise of privacy rights conferred by the CCPA.

How you exercise your rights

Method. You may exercise your rights by using methods described in the "Your rights of personal information" section. You may only make a verifiable consumer request for your "right to know" twice within a 12-month period.
Verifying your request. We only respond to your requests to your request when we can verify your request. In order to verify your request, we may need additional information, If we cannot verify your identity, we will let you know.
Range of our response. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If we cannot comply with any portion of a request, the response we provide will also explain the reason, if applicable.
Authorized agent. If you choose to use an authorized agent to submit your request, we may require your agent to provide proof that you have given signed permission to submit the request. We may also require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with us. We will not require these steps if we have received proof that you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4121 to 4130. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf or from an agent that does not meet the requirements for authorized agents under the CCPA.
Fees and charges. We do not ordinarily charge a fee for our response to your requests. However, if a request is excessive, repetitive, or manifestly unfounded, we may determine to charge a reasonable fee to comply with your request.
Response timing. We will use good faith efforts to respond to your request within 45 days of receipt of such a request. If an extension (up to a total of 90 days) is necessary, we will inform you of the reason and the needed extension period in writing. We will comply with your request to limit within 15 business days from the date of our receipt of your request.

Additional Notice for Illinois, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Tennessee, Texas, Utah, and Virginia Residents

This section applies to Illinois, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Tennessee, Texas, Utah, and Virginia residents covered by the applicable data protection laws in these states, including but not limited to the Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA), and Virginia Consumer Data Protection Act (VCDPA).

You may exercise the following personal information rights with us.

Right to Access: You have the right to request access to the personal data we have collected about you, including the categories of data, the sources of collection, purposes of use, and disclosures to third parties.
Right to Correct: If your personal data is inaccurate or incomplete, you have the right to request its correction.
Right to Delete: You may request the deletion of personal data we have collected, except where retention is required by law or for legitimate business purposes.
Right to Data Portability: Where applicable, you may request your personal data in a portable format.
Right to Object: You may object to the processing of your personal data for purposes based on our legitimate interests or for targeted advertising.
Right to Restrict Processing (where applicable): Certain state laws allow you to request the restriction of data processing, for example, during the verification or correction of your data.
Right Regarding Automated Decision-Making: If your data is subject to automated decision-making, you have the right to challenge the decision or request a human review.

As set forth in the applicable data protection laws, you have the right to exercise the above rights without discrimination.

You may exercise your rights to personal information as described above by sending email [email protected] to refuse personalized advertising, refuse the sale of your personalinformation, and refuse user profiles that have a significant legal or similar impact on you. If you fail toprovide valid information for our effective feedback, etc. When exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise suchdispute by sending email to [email protected].

Additional Notice for European Economic Area ("EEA") Residents

This section applies to residents in EEA, Switzerland, and the United Kingdom covered by the General Data Protection Regulation ("GDPR") and related applicable laws.

Data Controller and Representative

Identity and contact details of the controller. The controller with respect to the processing in this Privacy Policy is HALOFUN PTE. LTD. The contact details of the controller are: [email protected]

Legal Bases for Processing

We may only use your personal information when we have a legal basis to do so. In accordance with GDPR, we rely on the following legal basis to process your personal information:

Your consent. We ask for your consent to access or use your personal information for specific purposes. With your consent, we will use your personal information.
Contractual necessity. We may process your personal information, to perform the contract we are about to enter into or have entered into with you.
Legitimate interests. We may process your personal information, if it is necessary to pursue legitimate interests of us or third parties, provided that your interests and fundamental rights and freedoms do not override those interests. The legitimate interests we rely on include (1) to improve your experience, (2) to send you marketing information, advertising and promotions about our products and services, (3) to develop, test and improve our products and services, (4) to ensure promote the safety, security and integrity of Shortswave, and (5) to comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA law enforcement agencies, government regulators, courts and other public authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
Legal compliance. We may process your personal information, if it is necessary to comply with a legal obligation. This includes situations if we are legally required to do so or we have obligations to comply with a valid legal request such as an order or disclosure request from law enforcement agencies, government regulators, courts and other public authorities.
Public interests. We may process your personal information, if it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable laws and regulations.
Vital interests. We may process your personal information, if it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life.

Your GDPR Rights

Your rights regarding your personal information in accordance with GDPR specifically include the following:

The right of access. You have the right to request access to your personal information, which enables you to receive a copy of information undergoing processing.
The right to rectification. You may request correction of inaccurate personal information without undue delay. You may also supplement any incomplete personal information, taking into account the purposes of the processing.
The right to withdraw consent. your personal information is processed based on consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal.
The right to erasure (right to be forgotten). You have the right to request erasure of your personal information under the following circumstances: (1) the personal information is no longer necessary for the purposes of processing, (2) you withdraw your consent if the processing is solely based on consent, (3) you object to the processing and we have no overriding legitimate grounds or you object to the processing for direct marketing purposes, (4) your personal information has been unlawfully processed or (5) t is a legal obligation imposed on us to erase your personal information.
You may exercise the above rights by using methods described in the "What Are Your Rights and Choices" section.
The right to restriction. You have the right to restrict the processing of your personal information if (1) the accuracy of your personal information is contested by you, for the period in which we have to verify the accuracy of the personal information, (2) the processing is unlawful, and you oppose the deletion of your personal information and request restriction, (3) we no longer need your personal information for the purposes of processing, but your personal information is required by you for legal claims, (4) you have objected to the processing for the period in which we have to verify overriding legitimate grounds.
The right to portability. You have the right to portability, if (1) the processing of your personal information is based on a legal basis of contractual necessity or consent, and (2) the processing is carried out by automated means. This means that you have the right to receive your personal information you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that information to another controller without hindrance from us.
The right to object. You have the right to object to the processing of your personal information at any time. We will comply with your request, unless we have an overriding legitimate ground or we need to continue processing your personal information to establish, exercise, or defend a legal claim. When you object to the processing of your personal information for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing, we will no longer process your personal information for these purposes.
The right related to Automated Decision-Making and Profiling:You have the right not to be subject to decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects on you unless such decisions comply with legal requirements.
The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint about our processing of your personal information with your national data protection authority. You can find contact details for data protection authorities in the EEA by clicking on the following link:

European Economic Area: https://edpb.europa.eu/about-edpb/about-edpb/members_en
Switzerland: https://www.edoeb.admin.ch
United Kingdom: https://ico.org.uk

You may contact us via the contact information provided in, if you wish to exercise all the above-mentioned rights or if you have any problems related to those rights. You will not usually have to pay a fee to exercise your rights. However, if your requests are manifestly unfounded, repetitive, or excessive, we may charge a reasonable fee. We may need to request specific information from you to help us confirm your identity and ensure your rights. If a third party submits a request on your behalf, we may need to take reasonable measures to verify the authenticity of the request. In order to speed up our response, we may ask for further information in relation to your request.

International Transfer

We may transfer your personal information outside the EEA for the purposes described in this Privacy Policy. When transferring personal information from EEA to non-EEA jurisdiction, we rely on one or more of the following mechanisms:

Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) if they recognize that a jurisdiction offers an adequate level of data protection. The list of jurisdictions with adequate decisions is available here.
Other measures. If we transfer your personal information to jurisdictions without an adequate decision, we will rely on standard contractual clauses or other cross-border transfer solutions in accordance with GDPR to provide adequate protection.

13. How to contact us

If you have any questions or suggestions about my Privacy Policy, do not hesitate to contact us at：

HALOFUN PTE. LTD.

3 PHILLIP STREET #10-04 ROYAL GROUP BUILDING SINGAPORE (048693)

Email：[email protected]