Last Updated: June 10, 2019

imoo Privacy Policy

(the "Policy")

imoo (a brand owned by Guangdong Genius Technology Co., Ltd., hereinafter referred to as "we", "us", "our" or the "Company") knows the importance of security of personal information, and we will take security measures to protect your personal information and privacy in accordance with laws and regulations. Therefore, we formulate the imoo Privacy Policy (hereinafter referred to as "the Policy") and remind you to carefully read and thoroughly understand the Policy before using imoo software and related services and submitting personal information, and use related products and services after you fully understand and agree it. If you start using imoo software and related services, it will be considered as your acceptance and approval of the contents hereof.
We attach great importance to the protection of users' personal information and will treat such information with a high degree of diligence and prudence. We will collect, save, use, share, disclose and protect your personal information in accordance with the Policy when you download, install, open, browse, register, log in and use (hereinafter collectively referred to as "use") imoo software and related services. The Policy is intended to introduce how we treat your personal information, so we suggest you read all the terms of the Policy carefully and completely again. We suggest you focus on important parts such as exemption or limitation of liability clauses in bold.
The imoo software and related services described in the Policy may vary depending on phone model, system version, software application version you are using and other factors. Final products and services are subject to imoo software and related services you use.
If you do not agree with the contents of the Policy, the imoo software and related services will not work properly, and we will not be able to provide you with complete products and services. At the same time, please stop using them. When you start using imoo software and related services, it is deemed that you have fully accepted and understood the Policy in whole. Your continuous use after our updates of the Policy (you will be updated via imoo platform on a timely basis) of imoo software and related services means that you fully understand the Policy as updated and consent to our collection, saving, use, sharing, disclosure and protection of information related to you under the Policy.
The Policy applies to all products and services we offer to you, whether you get imoo software and related services through computer devices, mobile devices or other terminal devices.
If you have any questions, opinions or suggestions about the Policy, you can reach us at our service hotline +622122363565.

For the purpose of the Policy:

(1) imoo software and related services refer to the products and services provided to you by the Company and its related parties through legally owned and operated client applications named imoo and imoo website (www.imoo.com/en), including but not limited to displaying personalized information on information platforms and other functions, as well as new services for connecting people and information.

(2) Related parties refer to companies, organizations or individuals related to the Company due to common ownership or control.

(3) Third parties refer to companies, organizations or individuals related to the Company not due to common ownership or control (i.e. non-affiliates) or other non-related individuals.

(4) Personal information refers to various information that is recorded electronically or otherwise and can be used alone or in combination with other information to identify a specific natural person or reflect the activities thereof, including identification information (name, date of birth, ID No., including ID card, military ID, passport, driving license), facial features, address, contact phone, address book, network identification information (including account name, nickname, email address, and password, and passphrase protection questions and answers related to the foregoing);assets, transactions, personal Internet access records (website browsing records, click records and others),information on common device (including hardware model, device MAC address, operating system, unique device identification code of software list (such as information indicating common equipment with IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, etc. included) location, etc.;

(5) Personally sensitive information refers to personal information that may endanger personal and property security and easily results in damages in personal reputation, physical and mental health or discriminatory treatment, if it is revealed, illegally provided, or abused. For the purposes of the Policy, personally sensitive information includes: identification information (ID No., including ID card, military ID, passport, driving license), facial features, property and transaction information, network identification information (including account name and nickname, email address, and password, and passphrase protection questions and answers related to the foregoing), and other information (including address book, personal phone number, mobile phone number, itinerary, web browsing history and accurate positioning information);

With the Policy, you would understand:

I. Scope of Application of the Policy

II. Possible Scope and Manner of Personal Information Collection

II. Possible Scope and Manner of Personal Information Collection

IV. Use of Cookie and Similar Technologies

V. Possible Manner to Use Personal Information

VI. Possible Manner to Share Personal Information

VII. Personal Information Protection

VIII. Information Management

IX. Terms of Use for Minors

X. Changes in the Policy

XI. Disputes Resolution

XII. Miscellaneous

I. Scope of Application of the Policy

Unless otherwise stipulated in the Policy, the terms used herein shall have the same meanings as those defined in imoo User Service Agreement.

I. The Policy does not apply:

1.1 your personal information collected and used through third-party services (including any third-party applications and websites) accessed through imoo software and related services;

1.2 your personal information collected and used via other third parties providing advertising services for imoo software and related services.

2. imoo software and related services may include or link to information or other services provided by third parties (including websites). Such third party services may be operated by relevant third parties. Your use of such third party services (including any personal information you provide to such third party) is subject to the terms of service and privacy policy of such third party (rather than the Policy), and you need to read its terms carefully. Please properly protect your personal information and provide it to others only when necessary. The Policy applies only to the information we collect, save, use, share and disclose, rather than any third party's services or third party's information usage rules. We disclaim liability for any third party's use of the information provided by you.

II. Possible Scope and Manner of Personal Information Collection

When you use imoo software and related services, you understand and agree that we will probably collect, store and use the following data related to your personal information, which can be used for functions such as registering, logging in, binding accounts and receiving verification codes for retrieving passwords. If you do not provide the related information, you may not be able to register as our users or enjoy some of our services or some of our services as desired.

When you use some functions of imoo software and related services, you may need to provide your real identity information through your account as required by the relevant laws and regulations of the People's Republic of China, and we will help you select an appropriate way to complete real name verification according to your identity attributes. If you only need basic functions such as browsing and searching, you neither need to register an imoo account nor provide the relevant information.

1. Information provided by you to us

1.1 We will collect your nickname, head portrait and mobile phone number from the information filled and/or provided by you when you register, log in or use imoo software and related services, to help you complete registration and protect the security of your account. Mobile phone numbers are sensitive information, which is collected to comply with the relevant laws and regulations on the network real-name system. If you do not provide, you will not be able to enjoy our services normally.

2. Information obtained from your use of imoo software and services

2.1 Log information: when you use imoo software and related services, we will automatically collect your use of our services and save them as related weblogs, for example, your device model, system version, network, abnormal information, etc.

2.2 Device or application information: some mobile devices or applications contain unique application numbers, for example, the configuration, device version number, device identification number, etc. provided by the mobile device, browser or other programs used to access imoo software and related services. In order to provide you with better services and improve your user experience, imoo software and related services may record hardware and software data such as hardware model, operating system version number, international mobile equipment identification code, MAC address, etc.

2.3 Location information: When you enable the location function and enjoy location-based related services via imoo software and related services, we will use various information to locate the device with your consent, so that you can obtain related services without manually entering your own geographic coordinates. This information includes IP addresses, GPS signals and other sensor information that can indicate the relevant location information (such as information about nearby devices, WLAN access points and base stations may be required). We will collect the location information of the mobile phone and the bound watch, which will be used for the basic positioning, school guarding, holiday guarding, drowning reminding and other functions in the software. Because location is the basic function of the watch, we hope you can understand that the location function of the watch cannot be disabled. You can stop providing your geographic location information to imoo software and related services by disabling the location function on mobile phone. We understand that most mobile devices allow you to make unavailable positioning system (for specific products or services). For specific suggestions, please contact your mobile device service provider or manufacturer.

2.4 Address book. When you make available your address book to us, after obtaining your express consent, we will detect whether members of the phone address book have bound their watches only based on your address book information subject to irreversible encryption to help children quickly add friends. The above information is personally sensitive information. Refusal to provide this information will only make you unable to use the abovementioned function, but will not affect your normal use of other functions of imoo software and related services. In addition, you can also deactivate related functions at any time.

2.5 Watch call record. When you use the watch charge function, after obtaining your express consent, we will obtain the call record of the bound watch for rejecting calls from strangers, and the rejection record on the watch side will be displayed simultaneously in imoo client. The above information is personally sensitive information. Refusal to provide this information will only make you unable to use the abovementioned function, but will not affect your normal use of other functions of imoo software and related services. In addition, you can also deactivate related functions at any time.

2.6 Information on number of steps. When you use the movement function in your watch, we need to collect your step information and compare it with your watch friends. The above information is sensitive information. Refusal to provide this information will only make you unable to use such functions as display of parents and friends, but will not affect your normal use of other imoo functions.

2.6 Information on number of steps. When you use the movement function in your watch, we need to collect your step information and compare it with your watch friends. The above information is sensitive information. Refusal to provide this information will only make you unable to use such functions as display of parents and friends, but will not affect your normal use of other imoo functions.

3. When you search on imoo, we will collect your keyword, equipment and other information. In order to provide search services on an efficient basis, some of the above information will be temporarily stored in your local storage device. You understand and agree that if your search keyword information cannot identify you alone or in combination with other information, it does not belong to your personal information in the sense of law, and we have the right to use it for other purposes; only when you can be identified via your search keyword information alone or in combination with other information, we will take it as your personal information and process and protect in accordance with the Policy together with your search history during the combination period.

4. When you get involved in the relevant marketing activities held by us, we may collect your name, mailing address, contact information, bank account number and other information according to the needs of the activities. This information is necessary for receiving transfer or gift. If you refuse to provide it, we may not be able to transfer or distribute gifts to you.

III. Information Storage

1. Storage location

We will store your personal information collected and generated during our operations at home within the territory of China in accordance with laws and regulations.

2. Storage term

We only keep your personal information during the period necessary for providing imoo software and services, unless otherwise stipulated by laws and regulations.

IV. Use of Cookie and Similar Technologies

1. You understand and agree that in order to enable you access to imoo software and related services easier, we may use various technologies to collect and store information, for which, we may send one or more cookies or anonymous identifiers to your device.

2. When you use imoo software and related services, we may use cookies and similar technologies to collect your information to understand your preferences and usage habits, based on which, we may, via consultation or data analysis, improve product services and user experience, improve advertising effects, discover and guard against security risks in time, so as to provide you with better services.

2. When you use imoo software and related services, we may use cookies and similar technologies to collect your information to understand your preferences and usage habits, based on which, we may, via consultation or data analysis, improve product services and user experience, improve advertising effects, discover and guard against security risks in time, so as to provide you with better services.

V. Possible Manner to Use Personal Information

1. We will use the personal information collected in accordance with the Policy to enable functions intended by imoo software and related services. If we intend to use it for any other purposes, we will seek your consent in advance. We will use your personal information for the following purposes:

(1) providing you with personalized and high-quality services as much as possible through imoo software and related services;

(2) providing you with more relevant advertisements to replace the traditional common advertisements;

(3) for authentication, customer service, security prevention, fraud monitoring, archiving and backup purposes when necessary for us to provide corresponding services, so as to strive to ensure the security of the products and services we provide to you;

(4) better understanding, through data analysis, how you access and use our services, so as to respond to your personalized needs, such as language settings, location settings, personalized help services and instructions.

2. To ensure the service security and help us better understand the operations of imoo software and related services, we may record information or data related thereto, such as how often you use them, crash data, overall usage, performance data.

3. In order to provide you with better experiences, improve our service or for other purposes with your consent, we may use the information or data collected through one service for other services in a way of gathering information or data or personalization, subject to compliance with the relevant laws and regulations. For example, we might use the information we gathered when you use one of our services to provide you with specific content in another service, or show you the information that is related to you but not generally released. If we provide corresponding options in related services, you can also authorize us to use the information provided and stored by the service for our other services.

4. After collecting your personal information, we will de-identify the data through technical means, to reduce the risk that other organizations or individuals identify you through the de-identified information, and take technical and management measures to store the said data separately from the information that can be used to restore and identify individuals. Please understand and agree that in this case we have the right to use information that has been de-identified and to analyze the user database and use it commercially subject to non-disclosure of your personal information.

5. Please note that unless you delete (reject our collection and use through system settings), we are authorized to use all personal information you provide when using imoo software and related services within the scope of the Policy during your use of foregoing services. After you stop using your account, we will stop providing you with imoo software and related services, delete your personal information as required or anonymize it, except otherwise agreed in laws and regulations.

6. We will make statistics on the use of imoo software and related services and may share the statistical information with the public or any third parties to demonstrate the overall trends of our software and related services. However, these statistics do not include any of your personal information.

VI. Possible Manner to Share Personal Information

1. We will exercise a high degree of duty of care in treating your information. We may share your personal information with third parties with your explicit consent. In addition, we may share it with relevant third parties as required by laws and regulations or mandatorily required by governments or judicial decisions.

2. We may share your personal information with our affiliates with your consent. Subject to the manner to use and purpose of using personal information that you agree in the Policy, we will only share necessary personal information with our related parties. If our affiliates need to use your personal information beyond the foregoing scope for business concern, they will seek for your consent again.

3. To achieve some of the purposes stated in the Policy, we may source certain services from authorized third parties. We may share some of your personal information with these authorized third parties to provide better customer service and user experience. However, we will only share necessary personal information for legitimate, just, necessary, specific, and explicit purposes. The said third parties have no right to use the shared personal information for any other purposes.

4. You agree that we share with the following authorized third parties:

(1) Software service provider, intelligent device provider or system service provider. When third-party software, device and systems are combined with imoo products and related services to provide you with location-based services, we may collect your location information and related information on device (such as hardware model number, operating system version number, IMEI and MAC address) based on your authorization and settings in terms of system positioning and provide them to the aforementioned providers. Other information you fill out separately will be included under special circumstances. If you refuse, you can set up or enable the software that provides services in the device system.

(2) Advertising service providers. Without your authorization, we will not share your personal information with any advertising service providers. However, we may share the user portrait label that is difficult to identify you with the advertising service provider to help it improve the effective reach rate of advertisements without identifying you. For example, only after advertisers agree to abide by our advertising standards can we notify how effective their advertisements are, or how many people have watched their advertisements or installed applications after being advertised, or provide these partners with information that cannot identify individuals (e.g., "woman, 25 - 29 years old, located in Beijing") to help them understand their audience or customers.

5. For third parties with whom we share your personal information, we will investigate their data security capability, sign strict confidentiality agreements with them, requesting them to process personal information in accordance with the Policy in a manner and for purposes you agree and by taking other relevant confidentiality and security measures.

6. With the continuous development of our business, we may conduct mergers, acquisitions, asset transfers or similar transactions, in which case, your personal information may be transferred as part thereof. In the event of any of the foregoing changes, we will inform you prior to transfer of your personal information and continue protecting or requiring new controllers to protect your personal information in accordance with laws and regulations and standards not lower than those required by the Policy.

7. Without your prior consent, we will not share your personal information with any third party other than the Company and its related parties, except for the following circumstances:

(1) with your explicit authorization in advance;

(2) you share it with a third party by yourself;

(3) directly related to national security, national defense security, public safety, public health, and public interests;

(4) required by the applicable laws and regulations and mandatory administrative or judicial requirements; or directly related to criminal investigation, prosecution, trial, execution of judgment and others. Subject to laws and regulations, when we are requested to disclose, we will require for corresponding legal documents, such as summons or investigation letters. All requests have been carefully and prudently reviewed to ensure that they are legal and we will only disclose the data that the administrative and judicial agencies have legal right to obtain for specific purposes;

(5) necessary for safeguarding the lives, properties and other legitimate rights and interests of other imoo users, the Company and its related parties, or the safe and stable operation of rights protection products or services to the extent permitted by laws and regulations, such as finding, preventing and handling illegal activities such as fraud and reducing credit risk (excluding disclosing or providing personal information for profit-making purposes in violation of the commitments made in the Policy);

(6) personal information collected from legally disclosed information, such as legitimate news reports, government information disclosure, etc.;

(7) other circumstances stipulated by laws and regulations.

VII. Personal Information Protection

1. We attach great importance to the security of your personal information, and will strive to protect it via various reasonable security measures in both technical and management aspects generally accepted in the industry, and prevent the personal information provided by you, and data from being improperly used or unauthorized access, public disclosure, use, modification, damage, loss or disclosure.

2. We will protect your personal information by reasonable and feasible means such as encryption technology and anonymous processing, and apply a reliable protection mechanism to prevent it from being maliciously attacked.

3. We will establish a special security department, which will adopt our security management system and data security process to ensure the security of your personal information. We adopt a strict data use and access system to ensure that only those authorized can access your personal information and conduct security audits of data and technology in a timely manner.

4. Notwithstanding the adoption of the above-mentioned reasonable and effective measures and the standards required by relevant laws, you understand that even if every effort is made to strengthen the security measures, we cannot absolutely ensure information safety due to restrictions on technology and possible malicious means in the Internet industry; however, we will do our best to ensure the security of the personal information you provide. You understand and acknowledge that the systems and communication networks you use to access our services may go wrong due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of personal information, including but not limited to using complex passwords, changing passwords regularly, and keeping confidential personal information such as your account password to others.

5. We will formulate emergency plans and immediately initiate them in the event of any user information security incidents to prevent the impact and consequences of such security incidents from expanding. In the event of a personal information security incident (leakage, loss, etc.), we will promptly inform you in accordance with the laws and regulations of the basic information and possible impact of the security incident, measures we have taken or will take, suggestions on the precautions you can take to reduce risks, remedial measures for you, etc. We will timely inform you by notice, mail, letter, SMS, etc. When it is difficult to update on an individual basis, we will issue an announcement in a reasonable and effective manner. At the same time, we will report the handling of user information security incidents as required by the related regulators.

6. We would like to remind you in particular that the personal information protection measures provided in the Policy are only applicable to imoo software and related services. Once you disenable imoo and related services for browsing or using other websites, services and contents, we have no ability and are not obliged to protect any personal information submitted via applications and websites other than imoo software and related services, regardless of whether you log in or browse the above software or websites via links on or as guided by imoo and we do not have any legal liability for this.

VIII. Information Management

We attaches great importance to your management of personal information and makes every effort to protect your right to access, change (update or correct), delete and withdraw consent from your personal information, so that you have full capacity to protect your privacy and security.

1. After you successfully register with imoo, login in it via a registered account and conduct reasonable and necessary authentication, you can review and modify your personal information submitted to imoo software and related services. You understand and agree that generally, you can view and modify the information you submit at any time, but you may not be able to modify some of information submitted at the time of registration due to security and identity considerations such as the number declaring service.

2. Certain business functions made available by imoo software and related services may be decided only based on non-manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appropriate remedies.

3. We do not charge you for any of your reasonable requests in principle. However, we will charge a certain amount of cost for repeated requests that exceed a reasonable limit. We may reject those requests that are duplicative, require excessive technical means (for example, developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving backup of information stored on tapes).

4. Under any of the following situations, we may not respond to your request as required by laws and regulations:

(1) your information is related to national security and national defense security;

(2) your information is related to public safety, public health, and major public interests;

(3) your information is related to criminal investigation, prosecution, trial and execution of judgment;

(4) there is sufficient evidence that you have subjective intentions or abuse rights;

(5) response will result in serious damages to the legitimate rights and interests of you or other individuals and organizations.

(6) your information involves trade secrets;

(7) other circumstances stipulated by laws and regulations.

IX. Terms of Use for Minors

If you are a minor under the age of 18, you shall read and agree to the Policy under the supervision and guidance of your parents or other guardians before using imoo software and related services. The Company protects personal information of minors in accordance with the relevant laws and regulations of the State. We will only collect, use or publicly disclose it when permitted by laws, explicitly consented by their parents or other guardians or required for protecting them. If we find ourselves collecting personal information of a minor without the prior consent of a verifiable parent, we will try to delete it as soon as possible.

X. Changes in the Policy

In order to provide you with better services, imoo software and related services will be updated and changed from time to time. We will revise the Policy in due course and these revisions form integral parts hereof and have the same effect as the Policy. However, without your explicit consent, we will not reduce your rights entitled under the Policy in current effect.

After the Policy is updated, we will issue an updated version on imoo platform (i.e. mobile application client-side and official website) and remind you of the updated content through issuing announcement on our official website (www.imoo.com/en) or other appropriate means before the updated terms take effect, so that you can keep abreast of the latest version of the Policy.

For significant changes, we will also announce in a noticeable manner, explaining specific changes in the Policy in a manner including but not limited to emails, text messages, private letters or special tips on the browsing page.

For the purpose of the Policy, significant changes include but are not limited to:

significant changes in our service model, for example, the purpose of processing personal information, the types of personal information handled, the manner to use personal information, etc.;

major changes in ownership structure, organizational structure, and so on such as changes in owner as a result of business adjustment, bankruptcy mergers and others;

changes in the main person with which the personal information is shared, and to which it is transferred or made available;

major changes in your rights to participate in the processing of personal information and the way to exercise them;

any changes in the departments in charge of handling personal information security, contact information, and reporting channels;

there is a high risk indicated in the personal information security impact assessment report.

XI. Disputes Resolution

The interpretation and disputes settlement hereof shall be governed by the laws of mainland of the People's Republic of China. When any dispute arises between you and the Company due to the implementation of the Policy, both parties shall first negotiate and settle it amicably; if no settlement can be reached through negotiation, you agree to submit the dispute to Dongguan No.2 People's Court for settlement via litigation in accordance with imoo User Agreement.

XII. Miscellaneous

1. Headings hereof are only inserted for convenience and will not affect the implications or interpretation of the Policy.

2. If you have any comments or suggestions about the Policy or the functions related to the collection, storage, use, sharing, disclosure and protection of your personal information, you can give feedbacks or complain through function page or channel enabled by imoo for user feedbacks. We will reply as soon as we receive your comments and suggestions.

3. The copyright of the Policy is owned by the Company, which reserves the right of final interpretation and modification to the extent permitted by law.