Kolkol Privacy Policy

Date of Last Revision: Apr 23th, 2024

1.Introduction

Welcome to Kolkol(the “Platform” or “Kolkol”).

We are committed to protecting and respecting your privacy. This Privacy Policy covers the experience we provide for users age 18 and over on our Platform.

Please read on to learn more about our data handling practices. By visiting our website https://www.kolkolkol.com (“Site”), or accessing or using our mobile application (“App”) or all of the services available or related to therein (collectively referred to in this Privacy Policy as the “Service”), you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the Service.

2.Information we collect

When you visit and use our Site or App , install the App on your device, or register for an account with Kolkol, some personally identifiable information about you is collected in order for us to be able to provide you with the Services. Further details about this are set out below:

2.1.Information we collect when you use

• Once you have created a Profile and used Kolkol, you may choose to edit your gender, birthday and other information,however, please note that these are not required and you have a choice.We may collect information related to when and how you used our Services. The collected information includes your IP, device information(model, system,MCC), timezone. And we also collect infomation about mobile operators, network information (5G\4G\3G\WIFI). That information helps us identify your physical location so that it can be displayed and shared with other users choosing to view "nearby" users and moments. We may from time to time allow our employees to use the product for testing and user engagement purposes.
• When you use our Service, your position, microphone and phone camera shall be used upon your explicit authorization, the certain log file information shall be uploaded by yourself. All such information allows for more accurate reporting and improvement of the Service.
• If you contact our Customer Support team via [email protected], we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you).

2.2.Information you agree to provide

• Registration information, such as age, username and password, language, email or phone number,and social media account
• Profile information, such as name, social media account information(including your nickname as its appears on your social media profile, your user ID and your profile image),and profile image
• User-generated content, including comments, photographs, videos, and virtual item videos that you choose to upload or broadcast on the Platform (“User Content”)
• Payment information, such as PayPal or other third-party payment information (where required for the purpose of payment,we will not retain and collect your credit card name，number or security number)
• Transaction information, such as such as transaction records and history, date, items, amounts
• Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect the names and phone numbers and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social contacts
• Your opt-in choices and communication preferences
• Information to verify an account
• Information in correspondence you send to us
• Information you share through surveys or your participation in challenges, sweepstakes, or contests such as your gender, age, likeness, and preferences.

2.3.Information you agree to provide

• Social Media. if you choose to link or sign up using your social network (such as Facebook or Google), we may collect information from these social media services, including your contact lists for these services and information relating to your use of the Platform in relation to these services,if you authorize and consent us to do so.
• Third-Party Services.We may collect information about you from third-party services, such as advertising partners, payment partners and analytics providers.However, please note that this Policy does not and will not extend, which shall be subject to the respective third-party’s privacy policies.

3.How we use your information

We adopt the data minimization principle when collecting and using your data and ensure that your data will only be used in accordance with the stated purposes below. We will only process your data in connection with the Service and for other related business purposes, including:

3.1.To provide you with the Service

• to connect you with other users within the App
• to enable you to share your Profile with other users on the App
• to provide you with video and audio call functions of the App
• to allow you to send images and videos through the App
• to show you the names of persons you communicate with and to show your name to persons you communicate with on the App
• to provide you with certain features of the App that may be offered from time to time, such as our Premium Services (please see our Terms of Use),play games and share /play music during your video calls
• to enable you to contact us
• connect with third parties for payment processing
• to run analytics to provide you with better and relevant connections, provide you with additional offers and for the purpose of providing you with updates to our Services

3.2.To help us administer and maintain your account and User Profile on the App

• creating and updating your account;
• and delivering to you any administrative notices, alerts and communications relevant to your use of the App.
• To facilitate networking opportunities through the Service and provide you with location or interests information relating to other users of the App.
• We use the information we have to develop, test and improve our Services, including by conducting surveys, compiling research, statistics and analytics as well as habits and behaviors of users such as transactional history, online interactions, and testing and troubleshooting new products and features.
• To handle and process any payments for transactions carried out through the Service via third party providers.
• We use the information we have to send you marketing communications and notifications (including our Membership Loyalty Programme details); and communicate with you about our Services, and let you know about our policies and terms.
• We also use your information to respond to you when you contact us.
• Sharing with Third-Party Partners and the StarBird Group ( see below in section (x)) in order to meet our contractual obligations

3.3.For business management purposes

• To establish, exercise and/or defend our legal rights.
• To comply with our legal, regulatory and reporting requirements to regulatory bodies.
• To ensure the safety of users through content moderation.
• In connection with a corporate transaction involving Livhub, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets, or another similar event.
• To enable us to provide the Services and our contractual commitments to you.
• To enable us to carry out our contractual obligations with our StarBird Group and third parties.

3.4.Promote safety, integrity and security

• For audit, compliance, controls, security and other risk management purposes we use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent other bad experiences, illegal behavior, maintain the integrity of our Services, and promote safety and security. For example, we use a combination of automated detection technology and manual review of the data we have to investigate suspicious activity or violations of our Terms of Use and policies such as this Privacy Policy and enable you to report and contact us if you have any issues to raise.

4.How we share your information

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

4.1.We share Personal Information with any of the following recipients:

• Any service provider that we engage with to operate the Service;
• Our affiliated companies;
• Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, fraud prevention services, and other data verifiers;
• Payment service providers and payment processors;
• Auditors, contractors or legal/financial/other advisers of any of our business processes;
• Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies, including in order to ascertain your source of income or funds (e.g. governmental authorities, law enforcement bodies, banks and other investigatory bodies);
• Governmental and regulatory bodies, in accordance with applicable laws and regulations;
• Potential purchasers, successors or investors in any of the companies within our group companies, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within our group companies (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Policy).

5.Data Information

5.1.Data Information Security

• We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
• We take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
• User data is stored on the Google Cloud Platform, which is built with strong security features that ensure the continued protection of user information.

5.2.Retention of Personal Data

• If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Information for additional periods, to enable the Company to meet its legal obligations, e.g. Know-Your-Customer and Anti-Money Laundering requirements.
• The Company may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Company’s legitimate interests, such as fraud prevention and record keeping.

6.Your Right In Kolkol

6.1.Right to Maintain Your Personal Information

• To access or delete any Personal Information relating to you;
• To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
• That we will restrict any further use of your Personal Information;
• That we will provide the Personal Information you volunteered to us in a machine-readable format;
• To object to the processing your Personal Information (such as for marketing purposes);

6.2.Right to Withdraw Consent:

• To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);

6.3.Right to Complaint:

• You shall have the right to file a complaint with our Data Protection Officer (details of which are provided below) if you think that one or more of your rights have been infringed by Kolkol.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including any legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.

7.Disclaimer

7.1.Cookies and other technologies

• To make the application work effectively, we sometimes place small data files called cookies on your device. Most application’s developer do this. A cookies is a small text file that website saves when you visit the site. It enable the website to remember your actions and preferences, designed to improved use experience.
• You can control whether or not to accept cookies based on settings or by using other tools. If,however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of our services or access all of its functions, which may limit your overall user experience.

7.2.Other technologies

• We may install modules of other companies in the SUGO to analyze how the service and product have been used or provided. With regard to your personal information that is processed by a third-party through a module provided by such third party,the privacy policy of such third party will aplly and we also encourage you review it(if any).

8.Children's Privacy

You represent and warrant that you have the right capacity and legal capacity required for using SUGO. The Platform otherwise is not directed at children under the age of 18. If we become aware that personal information has been collected on the Platform from a person under the age of 18 we will delete this information and terminate the person's account. If you believe that we have collected information from a child under the age of 18 on the Platform, please contact us at [email protected] will deactivate the relevant Account(s) and will take reasonable measures to promptly delete such Personal Data from our records.

9.How To delete Information

You may delete your personal data by delete your account with the corresponding functionality directly on the service. Or you may ask us to delete or remove your personal Data by contact us at [email protected]

10.Update and Changes

We reserve the right at our discretion to make changes to this Privacy Policy. You may review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the Unearby inc and Kolkol web site, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy. We reserve the right to modify this policy from time to time, so please review it frequently.

11.Contact Us

Questions, comments and requests regarding this policy should be addressed to [email protected]