Last Updated: October 10, 2019
Welcome to Vskit mobile application (the “Platform”). The Platform is provided or controlled by Transsnet (HK) Limited, a corporation registered in Hongkong. (“Transsnet”, “we” or “us”). We are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you are accepting and consenting to the practices described in this policy.
Collection of Information
We may collect and use the following information about you:
- 1. Profile information, such as name (you may use your real name if you are comfortable to do so, and you may also use an alias), cell phone number, email address, photo, interests, age, gender, hometown, education and occupation.
- 2. Automatic information, such as your IP address, device id, device model, time zone, location, location information, browser information, information in Vskit cookies (cookie is a small piece of data file that is stored on your computer or mobile device), etc.
- 3. Contact information. If you allow Vskit to access the address book of your device, Vskit may process the information of your address book in order to connect with your contacts via Vskit. You may at any time allow or disallow Vskit to access your address book by changing your settings.
- 4. Uploaded files. You may upload video or audio files to Vskit, which Vskit will process accordingly.
- 5. Face data. If you choose to create an avatar or sticker using your face, Vskit will process your face data accordingly. We will not use your face data for marketing, advertising or use-based data mining, including by third parties.
- 6. If you reach us by your email or phone, we will use your email address or phone number to contact you.
- 7. If you create a Vskit account by connecting with a third-party service, such as Facebook, Google, Instagram or Email, we will use information from such third-party service, including your third-party service user name, gender, profile image, birthday and third-party service friend list.
If you provide us with your phone number or email address, you agree that we may send text messages to that phone number, or email to that email address. We will do so only in compliance with applicable laws and regulations. If you deactivate your Vskit account, you will no longer receive any text or email from us.
We use the following Cookies:
- 1. Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.
- 2. Analytical/performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
- 3. Functionality Cookies. These are used to recognise you when you return to the Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- 4. Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
"Do not track" signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to "do not track" signals in your web browser.
- 1. Vskit guarantees that it will not publicly disclose or provide a third party with your non-public information, unless under the following circumstances:
- a) When prior express authorization is obtained from you;
- b) When and as required by prevailing laws and/or regulations;
- c) When and as required by relevant competent authorities of the government;
- d) When it is necessary to safeguard the public interest;
- e) When it is necessary to protect the safety of any person (including you);
- f) When it is necessary to address fraud, security or technical issues; and
- g) When it is necessary to safeguard the legal rights and interests of Vskit.
Your private message may also be monitored by us if we have reasonable grounds to believe that you are using our private messaging services for criminal activities. Your private messages (including any image or video contained) may be shared with law enforcement agencies if we are requested to do so.
- 2. Vskit may collaborate with a third party (an affiliate or otherwise) to provide you with relevant Services. In this scenario, Vskit has the right to share your information with such third party, if such third party agrees to bear responsibility for providing privacy protection no less favorable to that of Vskit.
- 3. Under the condition that no private information of an individual user is disclosed, Vskit has the right to analyze the entire user database and utilize the database for commercial purposes.
On our Platform, we use third-party analytics tools to help us measure traffic and usage trends for the Services. Traffic refers to the different data flows surrounding activities of the users on the Services. These tools, for example, collect information sent by your device or our Services, including the pages you visit, add-ons, and other information that assists us in improving the Service. The information will be used to report and evaluate your activities and patterns as a user of the Platform to provide services in accordance with these activities.
How We Use Your Personal Data
We will use the information we collect about you in the following ways:
- 1. To administer the Platform (i.e. to provide our Services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to guarantee the Platform's stability and security) and to solicit your feedback;
- 2. To allow you to participate in interactive features of the Platform, when you choose to do so;
- 3. To personalize the content you receive and provide you with tailored content that will be of interest to you;
- 4. To improve and develop our Platform and conduct product development;
- 5. To measure and understand the effectiveness of the advertising we serve to you and others;
- 6. To provide you with services based on the country settings you have chosen, such as advertising and other content that is related to the country settings;
- 7. To make suggestions and recommendations to you and other users of the Platform about goods or services that will interest you or them;
- 8. To allow other users to identify you via the "Find other friends" function as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socializing function of the Services;
- 9. To provide you with your profile information to send to anyone you choose and to enable you to participate on the Platform and interact with other users;
- 10. To make your information available to other users in accordance with the privacy settings you chose for the respective information;
- 11. To show you content that is similar to content you liked or interacted with (by commenting and/or watching the content), content from your region as well as content from users you follow;
- 12. To show you advertisements that are relevant to you;
- 13. To promote the Services and use information that you give to us, such as User Content and video content that you can choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform;
- 14. To enable our messenger service to function;
- 15. To help us detect abuse, fraud, and illegal activity on the Platform;
- 16. To notify you about changes to our Services;
- 17. To communicate with you.
- 18. To provide you with user support;
- 19. To enforce our terms, conditions and policies;
It is in our legitimate interests to promote the Platform, and we may use information that you give to us, such as user-generated content and video content that you may choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform.
How We Share Your Personal Data
We may share your personal data with selected third parties in or outside your country, including:
- 1. Our business partners so that we can make you special offers via the Platform;
- 2. With respect to on-screen ads, advertisers and advertising networks that require the data to select and serve advertisements to you and others. We will not share your contact details with our business parties so they will not contact you directly, but we will share other information so that they can make you offers tailored to your requirements;
- 3. Cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we entered into with you;
- 4. Analytics and search engine providers that assist us in the improvement and optimisation of the Platform.
- 5. IT service providers;
- 6. Our data center and the servers of our host providers.
We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above ("How We Use Your Personal Data").
We may share your information with law enforcement agencies, public or tax authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- 1. Comply with a legal obligation, process or request (including tax and related reporting requirements);
- 2. Enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
- 3. Detect, prevent or otherwise address security, fraud or technical issues; or
- 4. Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We may also disclose your information to third parties:
- 1. In the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets; or
- 2. If we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
The Security of Your Personal Data
We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.
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.
We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. 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 these policies. Please check these policies before you submit any information to these websites.
We use the following criteria to determine the period for which we will keep your information:
- • Our contractual obligations and rights in relation to the information involved;
- • Legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time;
- • Face data will not be retained.
- • Statute of limitations under applicable law(s);
- • Our legitimate business purposes;
- • Disputes or potential disputes.
After you have terminated your use of our Services, we can store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we can also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.
Information Relating to Children
The Platform is not directed at children under the age of 12. Users under the age of 12 are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 12, we will delete this information and terminate the person's account. If you believe that we may have personal data about or collected from a child under the age of 12, please contact us at firstname.lastname@example.org.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.
We will generally notify all users of any material changes to this Policy through a notice on our Platform, however, you should look at this Policy regularly to check for such changes. Your continued access to or use of the Services after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Services.
Questions, comments and requests regarding this policy are welcomed and should be addressed to:
- • mail Address: firstname.lastname@example.org
Supplemental Terms – Jurisdiction-Specific
- 1. The security of your personal data. The personal data shared by you for the purposes of the Services would be safeguarded in accordance with the policies and systems adopted by us.
- 2. Data retention. We will not retain sensitive personal data or information for longer than is required for the purposes for which such information may be lawfully used or is otherwise required under any law for the time being in force.
- 3. Information relating to children. The Platform is not directed at persons under the age of 12. Users under the age of 12 are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 12, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a person under the age of 12, please contact us at email@example.com.
- • Data rights.
- You have the right to access and review personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at firstname.lastname@example.org.