Last updated: August 30, 2023
This Privacy Policy describes our personal data handling practices in relation to the Services. If you have any questions about this Policy, please contact us at nayo@thvine.com.
1. Acceptance
By accepting the Terms of Service, you warrant and represent that you have read, understood and agreed to our privacy practices described in this Policy and our Terms of Service. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. If you disagree with anything in this Policy, you should immediately terminate access or use of our Services.
2. Changes
We may periodically make changes to this Policy as we update or expand our Services. If you do not agree to the changes, you should discontinue your use of the Services prior to the time the modified Policy takes effect. If you continue using the Services after the modified Policy takes effect, you will be bound by the modified Policy.
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.
3. Information Collected
In this Policy, the term “Personal Information” includes any information that identifies or makes an individual identifiable. Our primary purpose in collecting your personal information is to optimize and enhance your nayo experience. Please do not share special categories of personal information when using our Services. Examples of “special categories of personal information” include information related to racial or ethnic origin, political opinions, religious or physiological beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership or data concerning data subject’s sex life or sexual orientation.
When you access or use our Services, we may generally collect the personal information described below.
Information you provide us directly:
Registration Information and Profiles. When you create an account, we may collect the personal information you provide to nayo, such as your name, gender, date of birth, picture, or phone number.
User Content. We collect the content, communications and other information you provide when you use our Services, including when you create, post or share your photo, voice, videos, messages or communications in our Services，whether displayed publicly or not. Your posted content is still under your control after you post, and you can choose whether you want to continue to post, display or delete such materials.
Communications Between Users and nayo. When you contact us with questions, concerns or for purposes of customer/technical support, we collect the information contained in your message, which may include your name, contact details and any other personal information you provide. We may collect some personal information, such as your name, and other information provided by you when you communicate your opinions or inquiries about our application and services via our feedback channel.
Geolocation Data. We will collect geolocation data if you choose to share it with us so that we can more accurately filter results on our Services. We may be able to approximate your geolocation based on other information you provide, such as your profile.
Images and Audio. We may collect information about the images and audios that are a part of your user content.
Information we automatically collect about you:
Device Information. When you use a mobile device (e.g., a tablet or smartphone) to access our Services, we may access, collect, monitor, store on your device, and/or remotely store one or more \"device identifiers.\" Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by nayo. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Cookies and Similar Technologies. We may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use our Product and its features. 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.
Automatic log updates. Automated data collection does not lead to profiling that significantly affects nayo users, but simply gives nayo a broad picture of its users and broadcasters.
INSTALLED APPLICATION INFORMATION. INSTALLED APPLICATION INFORMATION MAY BE COLLECTED FOR COMPLIANCE PURPOSE. THE DATA COLLECTION DOES NOT LEAD TO PERSONAL PROFILING THAT SIGNIFICANTLY IMPACTS nayo USERS. FOR INSTANCE, IF USERS INSTALLED CRACK APPLICATIONS INTO THEIR DEVICES, THE SUBJECT ACCOUNTS MAY BE CONSIDERED HIGH RISK AND CERTAIN FUNCTIONS OF nayo APP MAY BE CEASED DUE TO SUCH RISKS.
Things Others Do and Information They Provide About You. We also receive and analyze content, communications and information that other people provide when they use our Service. This can include information about you, such as when others share or comment on a photo or a video of you, send a message to you, or upload, sync or import your contact information.
How We Use Your Information
We use the personal information we gather through the Services for the purposes described below.
A. Provide Services to You. We require certain information to provide you with the Services you requested. Such information may include your contact and device information. We cannot provide you with Services without such information.
B. Send 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.
C.Provide Customer Support. 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 of the Services.
D. 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.
E. 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.
F. 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.
5. How We Share Your Information with Third Parties
We may share your personal information with third parties in the following circumstances:
Affiliated Businesses. We may share your personal information with businesses that are legally within the group of companies that nayo is part of, or will become part of that group (\"Affiliates\"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).
Service Providers. We also may share your personal information with our service providers for the realization of relevant functions and the safe and stable operation of applications.
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 the third parties. We will notify you via email or notice within our Services of any change in data ownership and/or uses of your personal information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal information will be subject to this Privacy Policy. However, any personal information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
Responding to Legal Requests and Preventing Harm. We may access, preserve and share your information if:
1.Required by law, or in response to a subpoena or court order or similar request from judicial authority, law enforcement authorities or other eligible public authorities;
2.We believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or
3.We believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.
Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We may promptly notify you about the legal requests, including a copy of the original request, unless we are prohibited from doing so.
6. Transfer of Your 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.
Update and Access Your Information
You may update your account at any time by logging in and changing your profile settings.
7.Minor's Privacy
We do not knowingly collect personal information from minors under 18 years old (or the minimum age requirement for creation of an nayo Account without parental consent in your country), unless permitted to do so by applicable law. Children under 18 years old are not permitted to use our Services. If we become aware that we have unknowingly collected personal information from a minor, we will make reasonable efforts to delete such information in our database. If you are a parent or guardian of a minor, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately at nayo@thvine.com.
8. Security
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 all 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 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. Do not leave your device unlocked while your are away. Make sure to use trusted wireless connections 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 nayo@thvine.com.
9. Retention of Personal Information
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 is processed, to enforce our agreements, 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.
10. Individual Rights
We provide you with the rights described below when you use our Services. Please contact us at nayo@thvine.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. We may limit your individual rights in the following ways:
Where denial of access is required or authorized by law;
When granting access would have a negative impact on other's privacy;
To protect our rights and properties; and
Where the request is frivolous or burdensome.
Right to withdraw consent. If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right of access and rectification. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.
Right to erasure . You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
You can close your account by using the corresponding functionality directly on the service.We also want you to be aware of your privacy rights. Here are a few key points to remember:
Access/know. You may have the right to request a copy of the information we keep about you, and in certain circumstances to receive this in a portable format.
Delete/erase. You can delete your account by using the corresponding functionality directly on the service. To do so, please follow these instructions:
· Log into your account;
· Tap the last button at the bottom of the screen;
· Choose 'Settings' at the bottom of the screen;
· Choose 'Delete Account';
· Tap 'Delete'.
Right to restriction. You have the right to restrict our processing your personal information where one of the following applies:
You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;
The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
We will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another person or legal entity or for reasons of important public interest. We will inform you if or when the restriction is lifted.
Right to object to processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
15. How to Contact Us
If you have any questions about this Privacy Policy or the Services, please contact us at nayo@thvine.com.