Updated Date: December 5, 2025
This Privacy Policy applies to TopReel services, including the TopReel application, website, software, and related services ("TopReel" or the "Platform"). TopReel is provided by TOPREEL GLOBAL PTE. LTD. (a company incorporated under the laws of Singapore with its registered address at 46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE (428766), hereinafter referred to as "we" or "us").
We recognize that your privacy is of great importance, and we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, process, and store your personal information in our services, and describes your choices regarding the use, access, and correction of your personal data. This Privacy Policy applies globally, and provisions related to specific jurisdictions are detailed in the "Supplementary Terms - Specific Jurisdictions" section. This Privacy Policy only applies to the data collection and processing activities of this website/application, and does not apply to the data collection and processing activities of third-party websites/applications or service providers. Please note that when you interact with these third-party websites/applications, you may provide them with personal information, and these third-party websites/applications may have different privacy policies and practices. We recommend that you review the privacy policies of these third parties to understand how they process your personal information.
If you do not agree to this Privacy Policy, please do not use TopReel.
This Privacy Policy is very important, and we ask that you read it carefully before using TopReel.
This Privacy Policy covers the following topics:
1. What Information We Collect
2. How We Use Your Information
3. How We Share Your Information
4. How We Store and Protect Your Information
5. Your Rights and Choices
6. How We Process Minors' Information
7. International Transfers
8. Updates to This Privacy Policy
9. How to Contact Us
10. Language
11. Governing Law and Dispute Resolution
12. Supplementary Terms - Specific Jurisdictions
1. What Information We Collect
We may collect the following information about you:
Information you provide when contacting us. To receive customer service on TopReel, you may provide us with your [contact information (email address) and text/image/video information related to your request]. To better resolve your issue, we need to know your user ID and a description of the relevant problem. We may also collect information from communications you send to us, including those sent when you contact us for complaints, support, or feedback.
With your permission, we may access content in your device's clipboard, including text, images, and videos. For example, if you choose to paste content from your clipboard into the Platform, we will access such information stored in your clipboard to fulfill your request.
1.2 Automatically Collected Information
When you access and use TopReel, we will automatically collect your information and usage data:
• Usage Information: We will collect information related to your interactions with TopReel, including [your click records, follow records, search records, content saved to "My List", browsing history, and transaction records]. We collect such information to analyze your preferences and infer your interests in order to provide you with personalized content recommendations. For example, we may collect [your check-in history, follow records, push notification activation records, and video viewing duration] to calculate the rewards you earn in gold coin reward activities. We may also display [the transaction and consumption history as well as reward coin records we collect] on relevant product pages of the Platform.
• Device Information: We may collect certain information about the device you use to access TopReel, such as device ID or other unique identifiers; device and software characteristics (such as type and configuration), system language, referral URL, IP address, browser and standard web server log information; advertising identifier ("IDFA" for iOS devices only) to identify your device, ensure service security, and optimize your browsing experience.
• Advertising-Related Information: Only with your consent, we may collect information about certain installed applications for advertising recommendations and use such information to better provide advertisements.
• Local Storage: We may use mechanisms such as application data caching to collect and store information on your device, including your personal information.
• Cookies: Cookies are text files placed on your device to collect standard internet log information and visitor behavior information. We may automatically collect information from you through cookies or similar technologies (e.g., web beacons, flash cookies, etc.) ("Cookies") to automatically collect information, measure and analyze how you use the Platform (including the pages you view most frequently and how you interact with content), enhance your experience using the Platform, improve the Platform, provide you with advertisements, and measure the effectiveness of advertisements and other content. We and our partners also use Cookies to promote our Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionalities. Web beacons are very small images or small data snippets embedded in images, also known as "pixel tags" or "clear GIFs", which can identify 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. As required by law, we will obtain your consent for our use of cookies.
1.3 Information from Other Sources
We may receive the information described in this Privacy Policy from other sources, such as:
• Third-Party Account Information: You may register and use TopReel through third-party social media accounts (Facebook or Google) and Apple ID. If you log in to TopReel using a third-party account, we will obtain your account information from that platform, including your [nickname, Apple ID (for iOS devices only), profile picture, and email address], to create or log in to your TopReel account, provide services to logged-in users, protect your account, and prevent security risks.
• Information from Public Sources: We may collect relevant information about you from other publicly available sources, such as government-released information and public information on social media platforms.
• Information Received from Others: We may receive relevant information about you from others, including: being mentioned or referenced in direct messages, complaints, appeals, requests, or feedback, or others providing your contact information to us.
2. How We Use Your Information
We use the collected information for the following purposes:
• Enter into and perform agreements with you;
• Deliver, provide, process, and maintain the services we offer to you;
• Create your account and profile.
• Communicate with you regarding your use of TopReel, product announcements, and software updates;
• Respond to your requests for assistance.
• Send you marketing information and special offers about our products and services via in-app messages. If you do not wish to receive any of the above information, please contact us through the contact information provided in this Policy when creating your account or at any time thereafter.
• Send you advertisements on TopReel, including targeted advertisements, and measure the effectiveness of advertisements and promotions.
• Facilitate sales and purchases within TopReel.
• Personalize the content you see when using TopReel. For example, show you content we believe will be of interest to you and ensure content is presented in the most effective way for you and your device.
• Detect and combat abuse, harmful activities, fraud, misuse, spam, and illegal activities on TopReel;
• Monitor and prevent security risks or technical issues that may harm TopReel;
• Protect the security of your account and our systems;
• Enhance the security and reliability of TopReel services.
• Comply with legal or regulatory obligations, including but not limited to responding to lawsuits, damages, or investigations within or outside your jurisdiction, or in the event of any mergers, acquisitions, sales, and asset transfers, bankruptcy proceedings, corporate restructuring, liquidation, or winding-up.
2.7 Technical Development and Research
• Train and improve our technologies, such as our algorithms;
• Conduct statistics and analysis on the use of TopReel to improve our products and services.
2.8 Automated Decision-Making and Personalized Recommendations
To provide you with content that better matches your preferences and interests, we may analyze your usage behavior on TopReel (such as viewing history, collection records, search behavior, interaction activities, etc.) based on automated decision-making technologies (including algorithmic analysis and user profiling) to recommend content or services that may be of interest to you.
Such automated analysis is only used to provide personalized recommendations and will not serve as the sole basis for decisions that have legal effect or significantly affect you in a similar manner.
You can manage or disable this feature at any time through the "Personalized Recommendations" setting provided within the product. Once disabled, we will no longer provide personalized content recommendations based on your usage behavior. You may also contact us through the contact information provided in this Privacy Policy to request manual review or obtain more information.
3. How We Share Your Information
We will not share your personal information except as explicitly stated in this Privacy Policy. We may share your personal information in the following circumstances:
We may share information with third parties with your consent or in accordance with your instructions. For example, when you choose to share content through a social media platform, we will disclose necessary information to that platform in accordance with your settings.
3.2 Sharing with Business Partners
You understand and agree that certain of our services will be provided by or jointly provided with our business partners, and you consent to us sharing your necessary personal information with the following partners for the purposes of this Privacy Policy:
• Social Networks: If you choose to register and use the Platform using your social media account details, we will share certain information with the relevant social network, including [nickname, profile picture].
• Service Providers: We engage other companies to provide services for the purposes described in this Privacy Policy. These services include data analysis, IT and related services, sending emails, providing customer support, and security and fraud detection services. These service providers may have access to your personal information when providing services to us. We require these service providers to use the data for purposes consistent with this Policy.
• Advertising Partners: For example, we share [the list of applications installed on your device] with AdMob for advertising and marketing purposes.
• Third-Party SDK Providers:
TopReel may contain third-party SDKs or other similar applications. If you use such services provided by third parties, you agree that they may directly collect and process your information (by inserting code or widgets, etc.). Such providers' collection and processing of information are subject to their own privacy terms, not this Privacy Policy. However, we will make every effort to review the access qualifications of such third parties and impose legal, compliant, and security requirements on them. To maximize the security of your information, we strongly recommend that you read the privacy terms of any third-party SDK before using it. To protect your legitimate rights and interests, if you find any risks associated with such SDKs or similar applications, we recommend that you immediately cancel the relevant operations and contact us in a timely manner. The following is information about our main third-party SDK providers:
1. TTVideoEngine SDK
Developer: Beijing Volcengine Technology Co., Ltd.
Link: https://www.volcengine.com/docs/4/108995?lang=zh
Purpose: For video stream decoding and playback
2. Google SDK
Developer: Google Inc.
Link: https://firebase.google.com/support/privacy
Purpose: For push notifications, collecting and analyzing app crashes, collecting and analyzing app logs, and user login via Google Sign-In
3. AppsFlyer SDK
Developer: AppsFlyer Ltd.
Link: https://www.appsflyer.com/legal/privacy-policy/
Purpose: For analyzing the effectiveness of product placements
3.3 Sharing in the Event of Mergers, Sales, or Other Commercial Transactions
In the context of mergers, financing, acquisitions, restructurings, divisions, bankruptcies, asset transfers, or similar transactions, we may transfer your personal information to another entity.
We will notify you of this matter and require the new holder of the information to comply with and implement all provisions of this Privacy Policy.
To fulfill our legal obligations, we may share your personal information with law enforcement agencies, government regulators, courts, and other public authorities in response to legal or regulatory requirements.
We may also share your personal information with such authorities for the following legitimate needs:
• Comply with legal obligations, procedures, or requests;
• Enforce our Terms of Service and other agreements, policies, and standards, including investigating any potential violations;
• Exercise, establish, or defend legal rights;
• Detect, prevent, or resolve security, fraud, or technical issues;
• Protect the rights, property, or safety of us, our users, third parties, or the public when required or permitted by law.
4. How We Store and Protect Your Information
4.1 How We Store Your Information
The servers we use to store personal information related to TopReel are currently located in Singapore. You understand and agree that, subject to the terms and conditions of this Privacy Policy, we may transmit and store your personal information to such servers in compliance with applicable laws and regulations. Although the standards for personal information protection in the jurisdiction where our servers are located and your jurisdiction may differ, we will make every effort to protect your personal information in accordance with stricter standards and take all reasonable measures to prevent the leakage of your information.
As described in this Privacy Policy, we may share your personal information with third parties located outside Singapore. We will not transmit your personal information prior to complying with applicable laws and regulations regarding cross-border transmission.
We will retain your personal information until the termination of your account or as necessary for the purposes stated above. We will also retain personal information for such periods as may be necessary to fulfill legal obligations, perform agreements, and resolve disputes.
The retention period varies based on different criteria, such as [the type of information, the purpose for which we use the information, and the mandatory retention periods stipulated by applicable laws].
After the expiration of the retention period, we will delete or anonymize your personal information, unless otherwise required by applicable laws and regulations.
If you wish to cancel your account or request that we no longer use your information to provide you with services, please contact us through the contact information provided in this Privacy Policy.
4.2 How We Protect Your Information
We will help protect your personal information and ensure its security by implementing appropriate technical and administrative measures (such as encryption and desensitization). We will maintain and modify these technical and organizational measures from time to time to enhance the overall security of our systems. Despite our efforts to protect your personal information, no electronic data transmission or information storage can be completely secure. Therefore, we cannot guarantee, and you should not expect, that your personal information will always remain secure. If you do not agree to these risks and conditions, you must stop using TopReel.
We adopt encryption technologies such as Transport Layer Security (TLS) to prevent transmission from being detected, eavesdropped, or intercepted; implement classified and hierarchical data storage measures; adopt strict data access control systems and multi-factor authentication technologies; avoid unauthorized access and use of data by monitoring the data processing process; conduct full-lifecycle monitoring and auditing of data to prevent unauthorized access, disclosure, use, alteration, or accidental or intentional damage or loss of personal information.
We have established a dedicated personal information protection department and formulated relevant internal control and management systems, such as standards for the secure use of business data and standardized management systems for data cooperation, to minimize employee authorization; regularly organize employees to participate in relevant security protection training; and adopt other practical security organization and management measures, such as locking the personal information storage area and restricting employee access to the storage area.
Pursuant to applicable laws and regulations, you have all rights related to your personal information, including but not limited to:
• The right to access your personal information;
• The right to correct/modify your personal information;
• The right to delete your personal information;
• The right to withdraw your consent;
• The right to unsubscribe/cancel notifications;
• The right to choose personalized content;
• The right to download your information;
• The right to restrict or object to the processing of your personal information.
To exercise the above rights or resolve any issues encountered when exercising these rights, you may contact us through the contact information provided in this Privacy Policy. We will provide assistance after verifying your identity within a reasonable period or as required by the laws of your jurisdiction. You may appeal against any decision we make regarding your request in accordance with the instructions in our decision notification. As further specified in the "Supplementary Terms - Specific Jurisdictions" section, you may also be entitled to other rights in your jurisdiction under applicable laws and regulations.
You may exercise some of these rights on the relevant product pages of TopReel:
• Right to Access Personal Information:
￮ Access profile information: You can access your personal information by clicking "Profile" in the application, including [your user ID, nickname, and profile picture].
￮ Access usage information: You can access certain usage information through relevant product pages at any time, including [content saved to "My List" (click "My List"), watch history (click "Profile" - "Watch History"), transaction history, reward coin records, and consumption records (click "Profile" - "My Wallet")].
• Right to Copy Your Personal Information: On the profile page, you can also copy your [user ID].
• Right to Delete Your Personal Information:
￮ Delete usage information: You can delete part of your usage information through relevant product pages at any time. For example, [you can delete browsing history by clicking "Profile" - "Watch History"; you can also delete content saved in "My List" by clicking "My List"].
￮ Delete account: You can delete any content from your account through the built-in online account deletion feature. [You can delete your account by clicking "Profile" - "Settings" - "Account Deletion".]
￮ Clear cache: [You can clear information stored in the cache by clicking "Profile" - "Settings" - "Clear Cache".]
• Right to Withdraw Your Consent: You can revoke any permissions you have granted us by changing settings on your device, such as permission to access the camera.
6. How We Process Minors' Information
TopReel is not intended for children under the age of 13, or the minimum age defined in the "Supplementary Terms - Specific Jurisdictions" in accordance with applicable laws or regulations of your jurisdiction ("Minimum Age"). Therefore, we will not intentionally collect personal information from anyone under the Minimum Age. If you are under the Minimum Age, please do not use TopReel or provide us with your personal information. If you believe we may have information about any child under the Minimum Age, you may contact us through the contact information provided in this Privacy Policy. If we learn that we have collected personal information from a child under the Minimum Age, we will immediately take measures to delete such information and terminate the relevant account.
If you have reached the Minimum Age but not the age of majority as stipulated by applicable laws and regulations, you may only use TopReel through the agency of your parent or legal guardian. You should read this Privacy Policy under the guardianship and guidance of your parent or legal guardian, and submit relevant personal information only after your parent or legal guardian has agreed to this Privacy Policy. You and your parent or legal guardian hereby accept this Privacy Policy.
To provide you with services, we will process your personal information in compliance with applicable protection laws and regulations of your jurisdiction. The information sharing mentioned in this Privacy Policy may involve transmitting your personal information to our affiliated entities or other third parties outside your jurisdiction for the purposes stated in this Policy. The privacy and data protection laws in these jurisdictions may differ from those in your place of residence (and in some cases, provide a lower level of protection). We will implement appropriate safeguards to protect your personal information in accordance with this Privacy Policy and applicable laws and regulations.
8. Updates to This Privacy Policy
To respond to changing legal, technological, or business developments, we may update or revise this Privacy Policy from time to time. When we update this Privacy Policy, we will post the updated version and change the "Last Updated" date at the top of this Privacy Policy. We will also take appropriate measures to provide you with prior notice of material changes that we believe will affect your privacy rights through one or more methods [such as announcements, push notifications, pop-ups, and emails]. If applicable privacy laws require it, we will obtain your consent to the changes before the revised Privacy Policy applies to you. We recommend that you review this Privacy Policy each time you use our services to ensure you are aware of the latest version.
If you have any questions, comments, complaints, requests, or suggestions regarding this Privacy Policy or any other privacy-related matters, you may:
• Submit online feedback through [ "Profile" - "Help & Feedback" ] in the application;
• Contact us by sending an email to [hemengqiang@aikanhudong.com] or by mail to [46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE (428766)].
Please refer to the "Supplementary Terms - Specific Jurisdictions" section below to see if there is a local representative or local contact in your country.
After receiving your inquiry or request, we will respond to you within the time limit stipulated by applicable laws after verifying your identity. We will make every effort to process your request as soon as possible. Where applicable, this does not affect your right to lodge a complaint with the relevant data protection authority.
This Privacy Policy is written in English and may be translated into other languages. In case of any inconsistencies, conflicts, or ambiguities between the English version and the translated versions, the English version shall prevail.
11. Governing Law and Dispute Resolution
This Privacy Policy is made, effective, enforced, and construed in accordance with the laws of Singapore, without regard to conflict of law provisions. Any disputes arising out of or in connection with this Privacy Policy shall also be resolved in accordance with the Terms of Service.
12. Supplementary Terms - Specific Jurisdictions
If there is a conflict between the provisions of the "Supplementary Terms - Specific Jurisdictions" applicable to the jurisdiction where you access or use the services and the rest of the Privacy Policy, the "Supplementary Terms - Specific Jurisdictions" of the relevant jurisdiction shall prevail.
12.1 Supplementary Notice for California Residents
This section applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").
12.1.1 How We Collect and Disclose Your Personal Information
In the past 12 months, we have collected and disclosed your personal information as mentioned in the sections "What Information We Collect" and "How We Share Your Information" for the purposes listed in "How We Use Your Information". We will not use sensitive personal information for purposes other than those stipulated by the CCPA. Please refer to these sections for details.
The categories of the above information are restated using the following terms under the CCPA:
Categories as Defined by the CCPA | Sources |
Identifiers, including your email address and account name. | Information from other sources and information you provide |
Commercial information, including your transaction history, reward coin history, and consumption records. | Automatically collected information |
Internet or other electronic network activity information, including information about your clicks, follow records, collections, search and browsing history, and your interactions with us. | Automatically collected information |
Audio, electronic, visual, thermal, olfactory, or similar information. This may include information you provide when contacting us. | Information you provide |
Sensitive personal information: Account logins, combined with any necessary security or access codes, passwords, or credentials required to access the account. | Information from other sources |
Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, and other attributes. | Inferences we may draw based on information you provide directly or that we collect automatically during use |
We do not intentionally collect information from anyone under the age of 16.
12.1.2 Whether We Sell or Share Your Personal Information
Under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"), "Sell" means disclosing personal information to a third party for valuable consideration, such as money; "Share" means disclosing personal information to a third party for the purpose of cross-context behavioral advertising.
We do not sell your personal information. However, we may share certain technical or usage information (such as device identifiers, Cookies, or browsing data) with our advertising or analytics partners to deliver, measure, and improve cross-context behavioral advertising. Such sharing may be deemed "sharing" or "Targeted Advertising" under applicable law.
You have the right to opt out of the sale or sharing of your personal information and to refuse the use of your data for targeted advertising. You may exercise this right at any time by clicking the "Do Not Sell or Share My Personal Information" link provided in our website or App settings.
We do not sell or share personal information of consumers under the age of 16 that we know of.
If you have any questions about how we handle such data disclosures or wish to learn more, please contact us through the contact information provided in this Privacy Policy.
12.1.3 Your Rights in California
Depending on your place of residence, you have the following rights regarding your personal information:
• Right to Know: You have the right to request to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific personal information we have collected.
• Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you. Please note that correction requests are subject to certain limitations, and in some cases, we may choose to delete rather than correct your personal information.
• Right to Opt Out: Under the CCPA, you have the right to opt out of the sale or sharing of your information. [However, as stated above, we do not sell or share your personal information in the context of the CCPA. Therefore, there is no opt-out for such activities. We will not sell or share your personal information without notifying you and giving you the opportunity to opt out.]
• Right to Limit: Under the CCPA, you have the right to limit our use and disclosure of your sensitive personal information. However, since we currently only use sensitive personal information for necessary purposes permitted by the CCPA, such as providing the services you request, we currently have no use scenarios beyond this scope. If you have any questions about this, please feel free to contact us.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights under the CCPA.
12.1.4 How to Exercise Your Rights
• Methods: You may exercise your rights using the methods described in "Your Rights and Choices". You may submit no more than two verifiable consumer "Right to Know" requests per 12-month period.
• Verifying Your Request: We will only respond to your request if we can verify it. To verify your request, we may need additional information. We will notify you if we cannot verify your identity.
• Scope of Our Response: Any disclosed information we provide will only cover the 12 months prior to receiving the verifiable consumer request. If we cannot fulfill any part of the request, our response will also explain the reasons (if applicable).
• Authorized Agent: If you choose to use an authorized agent to submit a request, we may require the agent to provide proof that you have signed to consent to the submission of the request. We may also require you to: (1) provide written permission to the authorized agent; (2) verify your identity directly with us. We will not require these steps if we have received proof that you have provided a power of attorney to the authorized agent in accordance with California Probate Code sections 4121 to 4130. If the agent does not submit proof that you have authorized them to act on your behalf, or if the agent does not comply with the CCPA's requirements regarding fees and charges, we may deny the request.
• Fees: We generally do not charge a fee for responding to your request. However, if the request is excessively lengthy, repetitive, or manifestly unfounded, we may decide to charge a reasonable fee to fulfill your request.
• Response Time: We will make every effort to respond to your request within 45 days of receipt. If an extension is necessary (by up to 90 days), we will notify you in writing of the reason for the extension and the required extension period. We will fulfill your restriction request within 15 business days of receiving it.
12.1.5 Description of Financial Incentive Programs
We may offer financial incentive programs related to the collection, retention, or use of your personal information. These incentives are designed to reward users for their participation or usage behavior. For example, when you complete specific tasks, participate in activities, or use our services, we may grant you virtual currency, points, coupons, discounts, or other similar benefits (collectively referred to as "Rewards").
Participation in such programs is completely voluntary. You may join or withdraw from the program at any time and will not be discriminated against for withdrawing.
The categories of personal information involved in these financial incentives may include: Identifiers (such as email address, user ID); Commercial information (such as transaction records, points history); Information related to your interaction activities (such as task completion status, usage frequency, or preferences).
The personal information we collect is only used to provide, operate, and improve the program and will not be used beyond the scope stipulated in this Privacy Policy.
12.2 Supplementary Notice for Residents of the European Economic Area ("EEA"), the United Kingdom, and Switzerland
This section applies to residents of the European Economic Area ("EEA"), the United Kingdom ("UK"), and Switzerland, and supplements our general Privacy Policy. In case of any conflict between this section and other parts of this Privacy Policy, the provisions of this section shall prevail.
12.2.1 Data Controller and Representative
• Identity and Contact Information of the Controller: The controller responsible for the processing described in this Privacy Policy is TOPREEL GLOBAL PTE. LTD. The controller's contact information is as follows:
[46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE (428766)] Email: hemengqiang@aikanhudong.com
• Identity and Contact Information of the Controller's Representative: Pursuant to applicable data protection laws (including the GDPR, UK GDPR, and Swiss FADP), we have designated a representative for the EEA/UK/Switzerland region: [Zhang Hong]. The representative's contact information is as follows:
[46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE (428766)] Email: hemengqiang@aikanhudong.com
12.2.2 Legal Bases for Processing
We will only process your personal information if there is a legal basis under applicable data protection laws (including the GDPR, UK GDPR, and Swiss FADP). These legal bases include:
• Your Consent: We need 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 fulfill the contracts we are about to enter into or have entered into with you.
• Legitimate Interests: We may process your personal information if it is necessary for our legitimate interests or those of a third party, provided that your interests, fundamental rights, and freedoms do not override these interests. The legitimate interests we rely on include: (1) improving your experience; (2) sending you marketing information, advertisements, and promotional materials about our products and services; (3) developing, testing, and improving our products and services; (4) ensuring and promoting the safety, security, and integrity of TopReel; (5) complying with applicable laws, regulations, codes of conduct, or rules, responding to requests from competent law enforcement agencies, government regulators, courts, and other public authorities, fulfilling our corporate and social responsibility commitments, protecting the rights and property of us and our customers, and resolving disputes and enforcing agreements.
• Compliance with Law: We may process your personal information to fulfill legal obligations. Such circumstances include: when required by law, or when we are obligated to comply with valid legal requirements, such as orders or disclosure requirements from law enforcement agencies, government regulators, courts, and other public authorities.
• Public Interest: We may process your personal information when necessary to perform tasks in the public interest (including conducting research, preventing and detecting crimes, protecting children, and promoting public safety, security, and integrity as stipulated by applicable laws and regulations).
• Vital Interests: We may process your personal information when necessary to protect your or others' life, physical integrity, or safety. For example, in emergency situations, information may be provided to law enforcement agencies or emergency services to protect health or life.
12.2.3 Your Rights Under the GDPR/UK GDPR/Swiss FADP
Under the GDPR/UK GDPR/Swiss FADP, your rights regarding personal information specifically include:
• Right of Access: You have the right to request access to your personal information, enabling you to receive a copy of the information being processed.
• Right to Rectification: You may request the rectification of inaccurate personal information (without undue delay). You may also complete any incomplete personal information taking into account the purposes of processing.
• Right to Withdraw Consent: When your personal information is processed based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal information in the following circumstances: (1) the personal information is no longer necessary for the purposes of processing; (2) you withdraw your consent where processing is based solely on consent; (3) you object to processing and we have no overriding legitimate grounds, or you object to processing for direct marketing purposes; (4) your personal information has been processed unlawfully; or (5) we are obligated to delete your personal information under law. However, the right to erasure (right to be forgotten) does not apply if your personal information is processed for specific purposes stipulated in Article 17(3) of the GDPR.
• You may exercise the above rights using the methods described in "Your Rights and Choices".
• Right to Restriction of Processing: You have the right to restrict the processing of your personal information in the following circumstances: (1) you contest the accuracy of your personal information, during which time we must verify the accuracy of the personal information; (2) processing is unlawful and you object to the deletion of your personal information and request restriction; (3) we no longer need to process your personal information, but you require it for the establishment, exercise, or defence of legal claims; (4) you have objected to processing pursuant to Article 21(1) of GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the EU or of a member state.
• Right to Data Portability: You have the right to data portability in the following circumstances: (1) the processing of your personal information is based on contractual necessity or your consent; (2) the processing is carried out by automated means. This means you have the right to receive the personal information you have provided to us in a structured, commonly used and machine-readable format, and the right to transmit such information to another controller without hindrance from us.
• 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 overriding legitimate grounds, or we need to continue processing your personal information to establish, exercise or defend legal claims. If you object to the processing of your personal information for direct marketing purposes (including profiling related to such direct marketing), we will no longer process your personal information for such purposes.
• Right to Lodge a Complaint with a Supervisory Authority: You have the right to lodge a complaint with the data protection authority in your country regarding our processing of your personal information. If you are a resident of the EEA, you can find the contact information of the EEA data protection authorities by clicking the relevant link.
12.2.4 International Transfers
We may transfer your personal information outside the EEA, the UK, or Switzerland for the purposes stated in this Privacy Policy. For example, we may transfer your personal information to our headquarters in Singapore or to other countries or regions where our service providers and partners are located. When transferring personal information from the EEA, the UK, or Switzerland to jurisdictions outside these areas, we will take appropriate protective measures to ensure that your personal information receives a level of protection equivalent to that within the EEA, the UK, or Switzerland. Specifically, we rely on one or more of the following mechanisms:
• Adequacy Decisions: These are decisions made by the European Commission pursuant to Article 45 of the GDPR (or equivalent decisions under other laws) that recognize that a jurisdiction provides an adequate level of data protection. A list of jurisdictions for which adequacy decisions have been made can be accessed via the relevant link.
• Other Measures: If we transfer your personal information to a jurisdiction for which no adequacy decision has been made, we will take one or more of the following appropriate safeguards to ensure the lawfulness of the transfer and data security:
Standard Contractual Clauses: Relying on standard contractual clauses approved and issued by the European Commission pursuant to Article 46 of the GDPR as binding contractual safeguards signed with data importers.
• Binding Corporate Rules: When transferring data within our group, we may rely on binding corporate rules approved by the competent supervisory authority.
• Other Safeguards Permitted by Applicable Law: Relying on other supervisor-approved tools, such as approved codes of conduct or certification mechanisms.
In accordance with applicable data protection laws and internal policies, we will provide you with key information about the appropriate safeguards we rely on, and you may request such information through the contact details provided in this Privacy Policy.
12.3 Supplementary Notice for Residents of South Korea
This section applies to users residing in the Republic of Korea (South Korea) and supplements our specific practices when processing personal information of South Korean users. In the event of any inconsistency between the provisions of this section and other parts of this Privacy Policy, this section shall prevail.
12.3.1 Age Verification and Data Processing for Adult Content (19+)
If you attempt to access adult content in our services (i.e., content accessible only to individuals aged 19 and above), we will verify your age in accordance with the requirements of relevant South Korean laws and regulations. This verification process involves the collection and processing of the following personal information:
• Verification Method: We may verify your age through a third-party identity verification service provided by a licensed South Korean telecommunications operator.
• Collected Fields: Mobile phone number, name, date of birth, gender, telecommunications operator, verification result (adult/minor), etc.
• Purpose of Use: The sole purpose is to verify your eligibility to access adult content in accordance with South Korean laws and regulations.
• Retention Period: The verification result will be retained for a maximum of one (1) year to allow you to reuse the verification result during this period without re-verification. After the one-year period expires, the verification records will be permanently and irreversibly deleted, and you will need to re-verify your age.
• Third-Party Recipients of Shared Information: Your identity information will be transmitted to the authentication service provider solely for identity verification purposes, and the provider will process your information in strict accordance with applicable laws and its own privacy policy.
We commit to taking appropriate technical measures to protect the security of your data in accordance with South Korea's Personal Information Protection Act and other applicable laws.
12.3.2 Contact Information
If you reside in South Korea and have any questions or complaints regarding this Privacy Policy or the processing of your personal information, you may contact our Data Protection Officer (DPO):
• Name: Zhang Hong
• Email: hemengqiang@aikanhudong.com
• Address: 46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE (428766)