Privacy Policy
Last Updated: December 5, 2025
This Privacy Policy applies to the BibiShort service, including the BibiShort application, website, software, and related services ("BibiShort" or the "Platform"). BibiShort 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," "us," or "our").
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. For jurisdiction-specific provisions, please refer to the "Supplementary Provisions – Specific Jurisdictions" section. This Privacy Policy applies solely to data collection and processing activities on this website/application and does not apply to 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 personal information to them, 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 BibiShort.
This Privacy Policy is very important, and we encourage you to read it carefully before using BibiShort.
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 information of minors
7. International transfers
8. Updates to the Privacy Policy
9. How to contact us
10. Language
11. Governing law and dispute resolution
12. Supplementary Provisions – Specific Jurisdictions
1. What Information We Collect
We may collect the following information about you:
• Information provided when contacting us: To obtain customer service on BibiShort, you may provide your contact information (email address) and text/image/video information related to your request. To better resolve your issue, we need your user ID and a description of the relevant problem. We may also collect information from correspondence you send to us, including letters you send when contacting us for complaints, support, or feedback.
• Clipboard information: With your permission, we may access content stored on your device’s clipboard, including text, images, and videos. For example, if you choose to paste content from the 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 BibiShort, we will automatically collect the following information:
• Usage information: We collect information related to your interactions with BibiShort, 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, so as 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 rewards you earn in coin reward activities. We may also display your transaction and consumption history and reward coin records on relevant product pages within the Platform.
• Device information: We may collect certain information about the device you use to access BibiShort, such as device ID or other unique identifiers; device and software characteristics (e.g., type and configuration), system language, referrer URL, IP address, browser, and standard web server log information; advertising identifier ("IDFA", iOS only) to identify your device, ensure service security, and optimize your browsing experience.
• Advertising-related information: Only with your consent may we collect information about some 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 pages you view most often and how you interact with content), enhance your experience on 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 functions. Web beacons are very small images or small data fragments embedded in images, also known as "pixel tags" or "clear GIFs", which can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. Where required by law, we will obtain your consent to use the Cookies we employ.
1.3 Information from Other Sources
We may receive information described in this Privacy Policy from other sources, such as:
• Third-party account information: You may register and use BibiShort via third-party social network accounts (Facebook or Google) and Apple accounts. If you log in to BibiShort using a third-party account, we will obtain your account information from that platform, including your nickname, Apple ID (iOS only), avatar, and email address, to create or log in to your BibiShort account, provide services to logged-in users, protect your account, and prevent security risks.
• Information from public sources: We may collect information about you from other publicly available sources, such as government-issued information and public information on social media platforms.
• Information received from others: We may receive information about you from others, including mentions of you in direct messages, complaints, appeals, requests, or feedback, or when others provide your contact information to us.
2. How We Use Your Information
The information we collect is used for the following purposes:
• Enter into and perform agreements with you.
• Deliver, provide, process, and maintain the services we offer you.
• Create your account and profile.
• Communicate with you about your use of BibiShort, product announcements, and software updates, and respond to your assistance requests.
• Send you marketing information and special offers about our products and services via in-app messages. If you do not wish to receive any such information, you may contact us through the contact information provided in this Policy at the time of account creation or at any time thereafter.
• Send you advertisements on BibiShort, including targeted advertisements, and measure the effectiveness of advertisements and promotions. Facilitate sales and purchases within BibiShort.
• Personalize the content you see when using BibiShort. For example, show you content we believe will interest you and ensure content is presented in the most effective manner for you and your device.
• Detect and combat abuse, harmful activities, fraud, misuse, spam, and illegal activities on BibiShort; monitor and prevent security risks or technical issues that may harm BibiShort; protect your account and system security; and improve the security and reliability of BibiShort services.
• Comply with legal or regulatory obligations, including but not limited to responding to lawsuits, claims, or investigations within or outside your jurisdiction, or in the event of any merger, acquisition, sale and asset transfer, bankruptcy proceedings, corporate restructuring, winding up, or liquidation.
2.7 Technical Development and Research
• Train and improve our technologies, such as our algorithms; conduct statistics and analysis on BibiShort usage to improve our products and services.
2.8 Automated Decision-Making and Personalized Recommendations
To provide you with content and services that better match your preferences and interests, we may analyze your usage behavior on BibiShort (e.g., viewing history, collection history, search behavior, interactions, etc.) based on automated decision-making technologies (including algorithmic analysis and user profiling) to recommend content or services you may be interested in.
Such automated analysis is solely used to provide personalized recommendations and will not serve as the sole basis for legally binding decisions or decisions that significantly affect you in a similar manner.
You may manage or turn off this function through the "Personalized Recommendations" settings within the product at any time. Once turned off, we will no longer provide personalized content recommendations based on your usage behavior. You may also contact us through the contact information set out in this Privacy Policy to request manual review or learn more information.
3. How We Share Your Information
We will not share your personal information except as expressly 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 via a social media platform, we will disclose necessary information to that platform according to your settings.
3.2 Sharing with Business Partners
You understand and agree that certain of our services will be provided by or in conjunction with our business partners, and you consent to our sharing of necessary personal information with the following partners for the purposes set out in this Privacy Policy:
• Social networks: If you choose to register and use the Platform using social network account details, we will share certain information with the relevant social network, including your nickname and avatar.
• 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, email delivery, customer support, and security and fraud detection services. These service providers may access your personal information when providing services to us. We require these service providers to use data for purposes consistent with this Policy.
• Advertising partners on your device: For example, we share the list of applications installed on your device with AdMob for advertising and marketing purposes.
• Third-party SDK providers: BibiShort 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.). The collection and processing of information by such providers are governed by their own privacy terms, not this Privacy Policy. Nevertheless, we will use our best efforts to review the access qualifications of such third parties and impose requirements on them regarding legality, compliance, and security. To maximize the protection of your information security, we strongly recommend that you first read their privacy terms before using any third-party SDKs. To safeguard your legitimate rights and interests, if you discover any risks associated with such SDKs or similar applications, we recommend that you immediately cancel the relevant operation and contact us promptly.
Our main third-party SDK providers are as follows:
1. TTVideoEngine SDK
Developer: Beijing Volcano Engine Technology Co., Ltd.
Link: https://www.volcengine.com/docs/4/108995?lang=en
Purpose: Video stream decoding and playback
2. Google SDK
Developer: Google Inc.
Link: https://firebase.google.com/support/privacy
Purpose: Push notifications, collection and analysis of application crashes, collection and analysis of user application logs, Google Sign-In for user login
3. AppsFlyer SDK
Developer: AppsFlyer Ltd.
Link: https://www.appsflyer.com/legal/privacy-policy/
Purpose: Analysis of product placement effectiveness
3.3 Sharing in the Event of Merger, Sale, or Other Commercial Transactions
In the context of a merger, financing, acquisition, restructuring, division, bankruptcy, asset transfer, or similar transaction, we may transfer your personal information to another entity.
We will notify you of such matters and require the new holder of the information to comply with and enforce the full terms 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 as required by laws or regulatory bodies.
We may also share your personal information with such authorities for the following legitimate purposes:
• Comply with legal obligations, processes, 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 address security, fraud, or technical issues.
• Protect the rights, property, or safety of us, our users, third parties, or the public as 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 BibiShort are currently located in Singapore. You understand and agree that, under the terms and conditions of this Privacy Policy, we may transfer and store your personal information to such servers in compliance with applicable laws and regulations. Although the privacy protection standards of the jurisdiction where our servers are located may differ from those of your jurisdiction, we will use our best efforts to protect your personal information in accordance with stricter standards and take all reasonable steps to prevent your information from being disclosed.
As described in this Privacy Policy, we may share your personal information with third parties located outside Singapore. We will not transfer your personal information without complying with applicable laws and regulations regarding cross-border transfers.
We will retain your personal information until your account is terminated or as necessary for the purposes set out above. We will also retain personal information for the period necessary to comply with legal obligations, enforce agreements, and resolve disputes.
The retention period varies according to different criteria, such as the type of information, the purposes for which we use the information, and the mandatory retention period prescribed by applicable laws.
After the retention period expires, 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 adopting appropriate technical and organizational measures (e.g., encryption and de-identification). We will maintain these technical and organizational measures and modify them from time to time to improve the overall security of our systems. Despite our commitment to protecting 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 terms, you must stop using BibiShort.
We adopt encryption technologies such as Transport Layer Security to prevent interception, eavesdropping, or hijacking during transmission; implement secure storage measures such as classified and layered data handling; adopt strict data access control systems and multi-factor authentication technology; monitor data processing processes to prevent unauthorized access and use of data; and conduct full lifecycle monitoring and auditing of data to prevent unauthorized access, disclosure, use, alteration, accidental or intentional damage, or loss of personal information.
We have established a dedicated personal information protection department and formulated relevant internal management systems, such as standards for the secure use of business data and management systems for data cooperation standards, to minimize employee authorization; regularly organize employees to participate in relevant security protection training; and adopt other practical security organizational and management measures, such as locking areas where personal information is stored and restricting employee access to such areas.
Under applicable laws and regulations, you have all rights regarding your personal information, including but not limited to:
• The right to access your personal information.
• The right to correct/amend your personal information.
• The right to delete your personal information.
• The right to withdraw consent you have given.
• The right to unsubscribe/opt out of notifications.
• The right to choose personalized content.
• The right to download your information.
• The right to restrict or object to the processing of personal information.
To exercise the above rights or resolve issues you encounter when exercising such rights, you may contact us through the contact information provided in this Privacy Policy. We will assist you after verifying your identity within the appropriate time limit or the time limit prescribed by the laws of your jurisdiction. You may appeal any decision we make regarding your application in accordance with the instructions in our decision notice. As further specified in "Supplementary Provisions – Specific Jurisdictions", you may also be granted other rights in your jurisdiction under applicable laws and regulations.
You may exercise some of your rights on relevant product pages of BibiShort:
• Right to access personal information:
￮ Access profile information: You may access your personal information by clicking "Profile" in the application, including your user ID, nickname, and profile avatar.
￮ Access usage information: You may access part of your usage information at any time through relevant product pages, including content you saved to "My List" (click "My List"), viewing history (click "Profile" – "Viewing History"), transaction history, reward coin records, and consumption records (click "Profile" – "My Wallet").
• Right to copy your personal information: On the profile page, you may also copy your user ID.
• Right to delete your personal information:
￮ Delete usage information: You may delete part of your usage information at any time through relevant product pages. For example, you may delete browsing history by clicking "Profile" – "Viewing History"; you may also delete content saved in "My List" by clicking "My List".
￮ Delete account: You may delete any content from your account through the built-in online account deletion function. You may delete your account by clicking "Profile" – "Settings" – "Delete Account".
￮ Clear cache: You may delete information stored in the cache by clicking "Profile" – "Settings" – "Clear Cache".
• Right to withdraw consent you have given: You may revoke any permissions you have granted us by changing settings on your device, such as permission to access the camera.
6. How We Process Information of Minors
BibiShort is not intended for children under the age of 13, or the minimum age ("Minimum Age") as defined by applicable laws or regulations of your jurisdiction or in "Supplementary Provisions – Specific Jurisdictions". Therefore, we do not knowingly collect personal information from anyone under the Minimum Age. If you are under the Minimum Age, please do not use BibiShort or send us your personal information. If you believe we may have any information from a child under the Minimum Age, you may contact us through the contact information provided in this Privacy Policy. If we become aware that we have collected personal information from a child under the Minimum Age, we will immediately take steps to delete such information and terminate the relevant account.
If you have reached the Minimum Age but have not reached the age of majority under applicable laws and regulations, you may only use BibiShort through the agency of your parent or legal guardian. You should read this Privacy Policy under the supervision and guidance of your parent or legal guardian and submit relevant personal information 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 data protection laws and regulations of your jurisdiction. Information sharing mentioned in this Privacy Policy may involve transferring your personal information to our affiliated entities or other third parties outside your jurisdiction for the purposes described in this Policy. The privacy and data protection laws of these jurisdictions may differ from (and in some cases provide less protection than) the laws of your place of residence. We will take appropriate safeguards to protect your personal information in accordance with this Privacy Policy and applicable laws and regulations.
8. Updates to the Privacy Policy
We may update or revise this Privacy Policy from time to time to respond to changing legal, technical, or business developments. 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 notify you in advance of material changes that we believe affect your privacy rights through one or more means (e.g., announcements, push notifications, pop-ups, and emails). If consent is required under applicable privacy laws, 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 understand 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 email at hemengqiang@aikanhudong.com or by mail at 46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE 428766.
Please refer to the "Supplementary Provisions – Specific Jurisdictions" section below to see if your country has a local representative or local contact person.
After receiving your inquiry or request, we will respond to you within the time limit prescribed by applicable laws after verifying your identity. We will endeavor to process your request as soon as possible. Where applicable, this does not affect your right to complain to the relevant data protection authority.
This Privacy Policy is drafted in English and may be translated into other languages. In the event of any inconsistency, conflict, or ambiguity between the English version and translated versions of this Privacy Policy, the English version shall prevail.
11. Governing Law and Dispute Resolution
This Privacy Policy is governed by, takes effect under, executed, and construed in accordance with the laws of Singapore, without regard to its conflict of law provisions. Any dispute arising out of this Privacy Policy shall also be resolved in accordance with the Terms of Service.
12. Supplementary Provisions – Specific Jurisdictions
If the provisions of the "Supplementary Provisions – Specific Jurisdictions" applicable to your jurisdiction of access to or use of the Services conflict with the rest of the Privacy Policy, the "Supplementary Provisions – Specific Jurisdictions" of the relevant jurisdiction shall prevail.
12.1 Supplemental 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 described in the sections "What Information We Collect" and "How We Share Your Information" for the purposes listed in "How We Use Your Information". We do not use sensitive personal information for purposes other than those permitted under the CCPA. Please refer to these sections for relevant details.
The categories of the above information are restated using the terms defined in the CCPA:
• Identifiers, including your email address and account name.
• Commercial information, including your transaction history, reward coin history, and consumption records.
• Internet or other electronic network activity information, including information about your clicks, follow records, saves, searches, browsing history, and interactions with us.
• Audio, electronic, visual, thermal, olfactory, or similar information, which may include information you provide when contacting us.
• Sensitive personal information: Account login credentials, combined with any necessary security or access codes, passwords, or credentials when accessing the account.
• Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, and other attributes.
Sources:
• Information from other sources and information you provide.
• Automatically collected information.
• Automatically collected information.
• Information you provide.
• Information from other sources.
We may draw inferences based on information you directly provide or automatically collected during use.
We do not knowingly collect information from individuals under the age of 16.
12.1.2 Whether We Sell or Share Your Personal Information
Under the CCPA and California Privacy Rights Act ("CPRA"), "Sell" means the disclosure of personal information to a third party for monetary or other valuable consideration; "Share" means the disclosure of personal information to a third party for cross-context behavioral advertising purposes.
We do not sell your personal information. However, we may share certain technical or usage information (e.g., 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 considered "sharing" or "Targeted Advertising" under applicable laws.
You have the right to opt out of the sale or sharing of your personal information by us 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 the settings of our website or App.
We will not sell or share the personal information of consumers we know to be under the age of 16.
If you have any questions about how we handle such data disclosures or wish to learn more, please contact us using the contact information provided in this Privacy Policy.
12.1.3 Your Rights Under California Law
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 pieces of personal information we have collected about you.
• 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 relating to 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, we do not offer an opt-out. We will not sell or share your personal information without notifying you and giving you the opportunity to opt out of such sale or sharing.
• 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 under 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
• Method: You may exercise your rights using the methods described in "Your Rights and Choices". You may make no more than two verifiable consumer "right to know" requests per 12 months.
• Verification of your request: We will respond to your request only if we can verify it. To verify your request, we may require additional information. If we cannot verify your identity, we will notify you.
• Scope of our response: Any disclosure we provide will cover only the 12 months prior to receipt of the verifiable consumer request. If we cannot fulfill any part of the request, our response will also explain the reason (if applicable).
• Authorized agent: If you choose to submit a request through an authorized agent, we may require your agent to provide proof that you have signed a written consent to submit 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 such steps if we have received proof that you have provided a power of attorney to the authorized agent in accordance with Sections 4121 to 4130 of the California Probate Code. If the agent fails to submit proof that you have authorized them to act on your behalf or if the agent does not comply with the CCPA regarding fees and charges.
• Fees: We generally do not charge fees for responding to your requests. However, if a request is excessively lengthy, repetitive, or clearly unfounded, we may decide to charge a reasonable fee to fulfill the request.
• Response time: We will use our best efforts to respond to your request within 45 days of receipt. If an extension is needed (up to 90 days), we will notify you in writing of the reason for the extension and the required extension period. We will comply with your limitation request within 15 business days of receiving your request.
12.1.5 Financial Incentive Program Description
We may offer you financial incentive programs related to the collection, retention, or use of your personal information. These incentives are designed to reward user participation or usage behavior; for example, we may grant you virtual currency, points, coupons, discounts, or other similar benefits (collectively, "Rewards") when you complete specific tasks, participate in activities, or use our services.
Participation in such programs is completely voluntary. You may choose to join or leave the program at any time and will not be discriminated against for leaving.
The categories of personal information that may be involved in these financial incentives include: identifiers (e.g., email address, user ID); commercial information (e.g., transaction records, points history); and information related to your interactive activities (e.g., task completion status, usage frequency, or preferences).
We use the personal information collected solely to provide, operate, and improve the program and will not use it beyond the scope specified in this Privacy Policy.
12.2 Supplemental Notice for Residents of the European Economic Area ("EEA"), United Kingdom, and Switzerland
This section applies to residents of the European Economic Area (EEA), United Kingdom ("UK"), and Switzerland and supplements our general Privacy Policy. If this section conflicts with other parts of this Privacy Policy, this section shall prevail.
12.2.1 Data Controller and Representative
• Identity and contact information of the controller: The controller in relation to the processing described in this Privacy Policy is TOPREEL GLOBAL PTE. LTD. Contact details of the controller: 46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE 428766; Email: hemengqiang@aikanhudong.com.
• Identity and contact information of the controller’s representative: In accordance with applicable data protection laws (including GDPR, UK GDPR, and Swiss FADP), we have appointed a representative for the EEA/UK/Switzerland region: Zhang Hong. Contact details of the representative: 46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE 428766; Email: hemegnqiang@aikanhudong.com.
12.2.2 Legal Bases for Processing
We will only process your personal information if we have a valid legal basis under applicable data protection laws (including GDPR (and UK GDPR) and Swiss FADP). These legal bases include:
• Your consent: We will obtain your consent to access or use your personal information for specific purposes. With your consent, we will use your personal information.
• Contract necessity: We may process your personal information to perform a contract we are about to enter into or have entered into with you.
• Legitimate interests: We may process your personal information when necessary for the legitimate interests of us or a third party, provided that your interests and fundamental rights and freedoms do not override those interests. The legitimate interests we rely on include: (1) improving your experience; (2) sending you marketing information, advertisements, and promotions about our products and services; (3) developing, testing, and improving our products and services; (4) ensuring the security, safety, and integrity of BibiShort; (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 our and our customers’ rights and property, resolving disputes, and enforcing agreements.
• Compliance with law: We may process your personal information to fulfill a legal obligation. Such circumstances include: when required by law, or when we are obligated to comply with valid legal requirements such as orders or disclosure requests from law enforcement agencies, government regulators, courts, and other public authorities.
• Public interest: We may process your personal information when necessary to perform a task carried out in the public interest (including conducting research, preventing and detecting crime, protecting children, and promoting public safety, security, and integrity as prescribed by applicable laws and regulations).
• Vital interests: We may process your personal information when necessary to protect your or another person’s life, physical integrity, or safety. For example, in an emergency, information may be provided to law enforcement or emergency services to protect health or life.
12.2.3 Your Rights Under GDPR/UK GDPR/Swiss FADP
Under GDPR/UK GDPR/Swiss FADP, your specific rights regarding personal information 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 correction of inaccurate personal information without undue delay. You may also supplement any incomplete personal information, taking into account the purposes of processing.
• Right to withdraw consent: Where processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on your consent before withdrawal.
• Right to erasure (right to be forgotten): You have the right to request the erasure of your personal information in the following cases: (1) the personal information is no longer necessary for the purposes for which it was processed; (2) you withdraw consent where processing is based solely on consent; (3) you object to processing and we do not have overriding legitimate grounds, or you object to processing for direct marketing purposes; (4) your personal information has been unlawfully processed; or (5) we are required to erase your personal information by law. However, the right to erasure (right to be forgotten) does not apply if your personal information is processed for specific purposes set out in Article 17(3) of the GDPR.
• Right to restriction: You have the right to restrict the processing of your personal information in the following cases: (1) you contest the accuracy of your personal information, for a period enabling us to verify the accuracy of the personal information; (2) processing is unlawful and you oppose the erasure of your personal information and request restriction instead; (3) we no longer need the personal information for processing, but you require it for the establishment, exercise, or defense of legal claims; (4) you object to processing pending verification whether our legitimate grounds override yours.
• Right to data portability: You have the right to data portability if: (1) processing is based on contract necessity or consent; (2) processing is carried out by automated means. This means you have the right to receive the personal information you provided to us in a structured, commonly used, and machine-readable format and to transmit that 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 compelling legitimate grounds for the processing or we need to continue processing for the establishment, exercise, or defense of legal claims. If you object to processing 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 of your country regarding our processing of your personal information.
If you are an EEA resident, you may click here to find contact details for EEA data protection authorities.
If you wish to exercise all of the above rights or encounter any issues related to these rights, you may contact us through the contact information provided herein. You generally do not need to pay a fee to exercise your rights. However, if your request is manifestly unfounded, repetitive, or excessive, we may charge a reasonable fee. We may need to request specific information from you to help us confirm your identity and ensure your rights. If a request is submitted by a third party on your behalf, we may take reasonable steps to verify the authenticity of the request. To speed up our response, we may ask you to provide further information regarding your request.
12.2.4 International Transfers
We may transfer your personal information outside the EEA, UK, and Switzerland for the purposes described in this Privacy Policy. For example, we may transfer your personal information to our headquarters in Singapore or other countries or regions where our service providers and partners are located. When transferring personal information from the EEA, UK, and Switzerland to jurisdictions outside these regions, we will take appropriate safeguards to ensure that your personal information receives a level of protection equivalent to that within the EEA, UK, or Switzerland. Specifically, we rely on one or more of the following mechanisms:
• Adequacy decisions: These are decisions made by the European Commission under Article 45 of the GDPR (or equivalent decisions under other laws) recognizing that a jurisdiction provides an adequate level of data protection. A list of jurisdictions for which adequacy decisions have been adopted is available here.
• Other measures: If we transfer your personal information to a jurisdiction for which no adequacy decision has been made, we will implement one or more of the following appropriate safeguards to ensure the lawfulness of the transfer and data security:
￮ Standard Contractual Clauses: Rely on standard contractual clauses approved and issued by the European Commission under Article 46 of the GDPR as binding contractual safeguards with data importers.
￮ Binding Corporate Rules: For intra-group data transfers, we may rely on Binding Corporate Rules approved by the competent supervisory authority.
￮ Other safeguards permitted by applicable law: Rely on other supervisory authority-approved tools, such as approved codes of conduct or certification mechanisms.
We will provide you with key information about the appropriate safeguards we rely on in accordance with applicable data protection laws and internal policies, which you may request through the contact information set out in this Privacy Policy.
12.3 Supplemental Notice for Korean Residents
This section applies to users residing in the Republic of Korea (South Korea) and supplements specific practices we follow when processing personal information of Korean users. This section shall prevail in the event of any inconsistency with other parts of this Privacy Policy.
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 persons aged 19 and above), we will verify your age in accordance with the requirements of relevant 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 licensed Korean telecommunications carriers.
• Collected fields: Mobile phone number, name, date of birth, gender, telecommunications carrier, verification result (adult/non-adult), etc.
• Purpose of use: Solely to verify your eligibility to access adult content in accordance with Korean laws and regulations.
• Retention period: Verification results will be retained for a maximum of one (1) year to allow users to reuse the verification results during this period without re-verification. After one year: verification records will be permanently and irreversibly deleted, and users will need to undergo age verification again.
• Third-party recipients: Your identity information will be transmitted to the authentication service provider solely for identity verification, and the provider will process your information strictly in accordance with applicable laws and its privacy policy.
We are committed to protecting your data security by adopting appropriate technical and organizational measures in accordance with the Personal Information Protection Act of South Korea and other applicable laws.
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 DPO:
Name: Zhang Hong
Email: hemengqiang@aikanhudong.com
Address: 46 EAST COAST ROAD #10-01 EASTGATE SINGAPORE 428766