Effective as of October 4, 2018
By accessing, visiting or using our Services, you warrant and represent that you have read, understood and agreed to this Policy and our Terms of Service. If you disagree with anything in this Policy, you must not use or access the Services.
Furthermore, we may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal information.
In this Policy, the term “personal information” includes any information that identifies or makes an individual identifiable. When you access or use our Services, we may generally collect the personal information described below.
A. Registration Information and Profiles. Perspective will allow the end user to use your mobile number or a third party platform account to register in the Product and create an account. When you create an account, we may collect the personal information you provide to Perspective, such as your name, gender, date of birth, username, password, email address, picture, or phone number and so on. We also collect the information from the third party account which can be used to identify you.
B. We may collect information about device or the information that your mobile device sends when using Product such as its operation system, language and Android ID, your IP address and log files as well as your use of our Product.
D. Information you choose to post and/or to publicly display. You may post your photo, voice or other material on our Product and to publicly display and share them with others in/through our Product. These materials post by you would still under your control and you still choose whether you post, display or remove such materials.
E. Log Information. Perspective’s server will automatically record the activity and related information created by you when using Product. This log information may include the links on our Product you clicked on, streams videos that you watched, access date and time spent on pages and features of the Product and other statistics and Cookie information. We may also collect the interaction information with Product from you to know your interest to customize and improve our Product and features.
F. Information you submit. The information you submit to communicate with us, for example, when you give us your opinions to our application and services via our feedback channel, such as your email address, and names and other information provided by you.
G. Your IP address and Location Information. Your IP address or GPS information may be collected by us when using Product to provide more specified feature or services. You could close such collection to stop Product collecting your IP address or GPS information with acknowledge that some feature or service may not be available for such closure.
H. Information You Share on Third Party Websites or through Social Media Services. The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.
You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services. For more information about our cookies and similar tracking technologies, and how to manage them, please read our cookies policy.
4. How We Use the Information We Collect
We use the personal information we gather through the Services for the purposes described below. If we use your personal information in any other ways, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.
A. To provide the Services to you. We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services. We cannot provide you with Services without such information.
B. To provide customer service. We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
C. To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies; enforce our agreements with third parties and partners; and, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.
D. To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.
E. For security purposes. We process your personal information to: improve and enforce our security measures; combat spam, malware, malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
Designated Countries: For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.
F. To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to comply with our legal obligations.
G. To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook, Google, Instagram, Twitter, etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
H. To conduct research and development. We process information about the way you use and interact with our Services to: help us improve our Services; build new Services; and build customized features or Services. Such processing ensures your continued enjoyment of part or all of our Services.
I. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
J. To engage in marketing activities. We may process your contact information or information about your interactions on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars, or other materials, including those of our partners; and, keep you up-to-date with our relevant products and Services. Transnational communications about your account or our Services are not considered “marketing” communications. In addition, when you share your friends’ contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can opt-out of our marketing activities at any time.
Designated Countries: For users located in the Designated Countries, please see section 9.C. below.
We may share your personal information with third parties in the following circumstances:
A. Employees, Third-Party Processors and Third-Party Service Providers
We disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our contract with you.
B. Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies
To the extent permitted by law, we will disclose your personal information if:
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our legal obligations, in the public interest, or your vital interests.
C. Business Transfers or Bankruptcy
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on legitimate interests described above.
D. Our Affiliates and Third-Party Marketing Partners
Based on your consent, we may share some or all of your contact information with our marketing partners, parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you opt-in to receive marketing communications from third parties, we may permit these entities to use your information for their own marketing purposes. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by contacting us as provided in the “How to Contact Us” section.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on your consent.
We do not knowingly collect personal information from children under 17 years old (or the minimum age required for the creation of a Perspective Account absent parental consent in your country), unless permitted to do so by applicable law. Children are not permitted to use our Services unless they provide us with consent from their parent or guardian. If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately at email@example.com.
We are committed to ensuring the security of your personal information. We have physical, technical and administrative safeguards in place to protect the confidentiality of your personal information. In addition, we require that our service providers handling personal information also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you provide to us.
However, we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.
Maintaining the security of your personal information is also your responsibility. Where we require you to register an account, you should choose a password of sufficient length and complexity and keep your password confidential. Do not leave your device unlocked so that other individuals may access it. Make sure you trust the wireless connections you are using to access or use our Services.
If you think there has been unauthorized access to or use of your account, please contact us immediately at firstname.lastname@example.org.
We will try to limit the storage of your personal information to the time necessary to serve the purpose(s) for which your personal information was processed, to enforce our agreement, policies or terms, to resolve disputes, or as otherwise required or permitted by law. Please contact us if you have any questions about our retention periods. While retention requirements can vary by country, we generally apply the retention periods noted below.
Marketing. We store information used for marketing purposes indefinitely until you unsubscribe. Once you unsubscribe from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request.
Your Interactions and Content on Our Services. We may store any information about your interactions on our Services or any content created, posted or shared by you on our Services (e.g., pictures, comments, support tickets, and other content) indefinitely after the closure your account for the establishment or defense of legal claims, audit and crime prevention purposes.
Web Behavior Data. We retain any information collected via cookies, clear gifs, flash cookies, webpage counters and other technical or analytical tools in our system for a certain date and time from expiry of the cookie or the date of collection.
This section only applies to users of our Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address, MCC(mobile county code) to identify which country you are located in.
Where we rely on your IP address or MCC, we cannot apply the terms of this section to any user that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries.
A. Our Relationship to You
Perspective is a data controller with regard to any personal information collected from users of its Services. A “user” is an individual providing personal information to us via our Services, such as by creating an account with our Apps, signing up for our newsletter(s), or otherwise accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.
B. Legal bases for processing Personal Information
We describe our legal bases for processing in Section 4 (“How We Use the Information We Collect”) and Section 5 (“How We Share Your Information With Third Parties”) under headings entitled “Designated Countries.” The legal bases on which we rely on to process your personal information include: your consent to the processing; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; necessity to process in the public interest; or for our legitimate interests as described in those sections.
C. Marketing Activities
If you are located in the Designated Countries and are a current user, we will only contact you by electronic means (such as email or SMS) per your communication preferences and/or with information about our Services that are similar to the Services you previously purchased from us or negotiated to purchase from us.
For new users located in the Designated Countries, we will contact you by electronic means for marketing purposes only based on your consent or based on your friends’ consent. You can always withdraw your consent or change your marketing communication preferences at any time and free of charge. To opt out of the emails, please click the “unsubscribe” link in the footer of marketing emails. Marketing communications are promotional in nature and do not include transactional or Service-related communications.
D. Individual Rights
We provide you with the rights described below when you use our Services. Please contact us email@example.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity.Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:
E. Transfer of Personal Information
If you choose to use the Services or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Designated Countries: We transfer your personal information subject to appropriate safeguards as permitted under the Data Protection Laws. Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for transferring personal information in place with the third-parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.
California law allows users of the Services who are California residents to request and receive once a year, free of charge, a notice from us describing what categories of personal information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If you are a California resident and would like to request a copy of this notice, please contact contacting us as provided in the “How to Contact Us” section. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty (30) days for a response.
In addition, if you are a California resident under the age of 18 and are a registered user of the Services, you may request that we remove content or information that you posted on Services or stored on our servers by: submitting a request as provided in the “How to Contact Us” section and (ii) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.
However, please note that we are not required to erase or otherwise eliminate content or information
Waiver of Rights to upload log. In Settings, users’ log, including all your activities in our Product, such as gifting, commenting, logging in, recharging details and chatting within 3-4 days, will be uploaded to the Company to help fix bugs, etc. After uploading, users waive any and all rights of privacy for the above personal information. With VIP Feedback, VIP users can upload log and waive the same rights of the above personal information.