PT. XOON TECHNOLOGY INDONESIA and its affiliates (hereinafter referred to as "we") highly value your personal information and privacy. We are committed to protecting your personal information in accordance with applicable laws and regulations. To this end, we have drafted this "Privacy Policy" and specifically remind you: Before using Xoon Show and its related services, please read and fully understand this policy so that you can make an informed choice.
This Privacy Policy aims to help you understand:
· We will collect and use your information strictly in accordance with this Privacy Policy. Your consent to this policy does not mean we will forcibly bundle the collection of personal information.
· When you enable or use certain functions and services, we will collect and use the relevant information necessary to realize those purposes. You may refuse to provide information that is not essential for basic business functions or not required by law, without affecting your use of other functions or services. We will explain what information is necessary in detail within this policy.
· If you are not logged into an account, we will use a device-appropriate identifier to ensure basic functions like notifications. If you are logged into an account, we will deliver content based on your account information.
· Sensitive permissions such as camera, microphone, and photo album are disabled by default. They will only be enabled for specific functions or services with your explicit authorization, and you can withdraw such authorization at any time. Please note, even with your authorization, we will not collect your information when the related function or service is not in use.
· This Privacy Policy applies to your access and use of our products and services through the Xoon Show application, as well as through third-party websites and applications that integrate the Xoon Show Software Development Kit (SDK) and Application Programming Interface (API).
The following sections will help you understand in detail how we collect, use, store, share, transfer (if applicable), and protect personal information, as well as inform you of how to inquire about, access, delete, correct, and withdraw authorization for your personal information.
1. How We Collect and Use Personal Information
2. How We Share, Transfer, and Publicly Disclose Personal Information
3. How We Store Personal Information
4. How We Protect the Security of Personal Information
5. Managing Your Personal Information
6. Provisions for Minors
7. How to Delete Personal Information
8. Revisions and Notifications of the Privacy Policy
9. Contact Us
1. How We Collect and Use Personal Information
During your use of our services, we will collect information that you proactively provide and information generated through automated means as you use functions or receive services:
1.1 Registration, Login, and Authentication
1.1.1 Registering and Logging into an Account a. When you register for and log into Xoon Show and its related services, you can create an account and provide relevant network identification information (such as an avatar, nickname, and password). This information is collected to help you complete your registration. You can also choose to provide information such as your gender, date of birth, region, and personal bio to complete your profile. b. When you log into our products using a third-party account, you will need to authorize us to access the public information from your third-party account (such as your avatar, nickname, gender, and other information you authorize) and link it to your product account. If you do not agree to this authorization or refuse to provide the above information, you will not be able to log in via a third-party account, but this will not affect your normal use of other Xoon Show functions.
1.2 Secure Operation
1.2.1 Security Functions We are committed to providing a safe and reliable product and user environment. Providing high-quality and trustworthy services and information is our primary goal. The information collected to enable security functions is necessary information.
1.2.2 Device and Log Information a. To ensure the secure operation of our software and services, we will collect your operating system version, device identifiers, IP address, software version, call information (such as carrier and subscriber identity module information), network access method, type, status, network quality data, as well as operation, usage, and service logs. b. To prevent malicious programs and for secure operation, we will collect information about installed applications or running processes, overall application operation, usage and frequency, application crashes, overall installation and usage, performance data, and application sources. c. We may use your account information, device information, service log information, and information that our affiliates and partners are authorized or legally permitted to share to determine account security, perform identity verification, and detect and prevent security incidents.
1.3 Changes in the Purpose of Collecting and Using Personal Information
Please understand that as our business develops, the functions and services of Xoon Show may be adjusted and changed. In principle, when a new function or service is related to a function or service we currently provide, the personal information collected and used will be directly or reasonably related to the original processing purpose. In scenarios that are not directly or reasonably related to the original purpose, we will notify you again and obtain your consent before collecting and using your personal information.
1.4 Collection and Use of Personal Information Exempted from Consent by Law
Please understand that in the following situations, in accordance with laws, regulations, and relevant national standards, we do not require your authorization to collect and use your personal information:
a. Directly related to national security and defense;
b. Directly related to public safety, public health, and major public interests;
c. Directly related to criminal investigation, prosecution, trial, and judgment execution;
d. For the purpose of protecting the life, property, and other major legitimate rights of the personal information subject or other individuals, but it is difficult to obtain the person's consent;
e. Personal information that you have disclosed to the public on your own;
f. Personal information collected from legally and publicly disclosed sources, such as legal news reports and government information disclosures;
g. Necessary for signing or performing a contract at your request;
h. Necessary for maintaining the safe and stable operation of the software and related services, such as discovering and handling faults;
i. Necessary for legitimate news reporting;
j. Other circumstances stipulated by laws and regulations.
We would like to remind you that if information cannot identify your personal identity on its own or in combination with other information, it does not legally constitute personal information. When your information can identify your personal identity on its own or in combination with other information, or when we combine data that cannot be linked to any specific personal information with your other personal information, this combined information will be treated and protected as your personal information in accordance with this Privacy Policy during the period of combined use.
2. How We Share, Transfer, and Publicly Disclose Personal Information
2.1 Sharing
2.1.1 Principles of Sharing
a. Authorization and Consent Principle: We will not share your personal information without your consent, unless the shared information has been anonymized and the third party cannot re-identify the natural person subject from the information. If the third party intends to use the information for purposes beyond the scope of the original authorization, they must obtain your consent again.
b. Legality, Legitimacy, and Minimum Necessity Principle: The data shared must have a lawful and legitimate purpose, and the scope of the shared data is limited to what is necessary to achieve that purpose.
c. Security and Prudence Principle: We will carefully evaluate the purpose for which third parties use the shared information, conduct a comprehensive assessment of the security capabilities of these partners, and require them to comply with a legal cooperation agreement. We will conduct strict security monitoring on the Software Development Kits (SDKs) and Application Programming Interfaces (APIs) used by partners to obtain information in order to protect data security.
Third-Party SDK Access Directory
To ensure the functionality of the Xoon Show App and its safe and stable operation, we may integrate SDKs provided by third parties for relevant purposes. We conduct strict security monitoring of the SDKs used by our partners to protect data security. The relevant third-party SDKs we access are listed in the directory below.
Zego SDK
Company: Shenzhen Jigo Technology Co., Ltd.
Type of Data Collected by SDK: Network status, reading storage space, camera, microphone, photo album
Use of SDK: To enable low-latency, high-synchronization, high-quality live streaming, as well as low-frequency audio/video interaction between the audience and the host.
Privacy Policy Link: Privacy Policy - Zego
Solar Engine SDK
Company: Huiliangyun (Beijing) Technology Co., Ltd.
Type of Data Collected by SDK: Device information, network information, application usage behavior
Use of SDK: To analyze advertising campaign performance and conversion attribution, as well as to optimize user experience and application performance.
Privacy Policy Link:Privacy Policy - Solar Engine
Google SDK
Company: Google Inc.
Type of Data Collected by SDK: Network status, reading storage space
Use of SDK: For third-party login.
2.1.2 Sharing Information for Security and Statistical Analysis a. Security Purposes: We place great importance on account, service, and content security. To protect your and other users' accounts and property, and to protect your and our legitimate rights and interests from unlawful infringement, we and our affiliates or service providers may share necessary device, account, and log information. b. Product Usage Analysis: To analyze the usage of our services and improve the user experience, we may share statistical data about product usage (e.g., crashes) with affiliates or third parties. This data is difficult to combine with other information to identify your personal identity.
2.2 Transfer
a. We will not transfer your personal information to any other third party without your explicit consent.
b. As our business develops, we may engage in mergers, acquisitions, or asset transfers, which may result in the transfer of your personal information. In the event of such changes, we will require the successor to continue to protect your personal information in accordance with laws, regulations, and security standards no less stringent than those in this Privacy Policy. Otherwise, we will require the successor to obtain your authorization and consent again.
2.3 Public Disclosure
a. We will not publicly disclose your information unless required by national laws and regulations or with your consent. When we publicly disclose your personal information, we will use security measures that meet industry standards.
b. We will disclose relevant account information when announcing penalties for illegal accounts and fraudulent activities.
2.4 Personal Information Exempted from Consent for Sharing, Transfer, and Public Disclosure by Law
Please understand that in the following situations, in accordance with laws, regulations, and national standards, we do not require your authorization to share, transfer, or publicly disclose your personal information:
a. Directly related to national security and defense;
b. Directly related to public safety, public health, and major public interests;
c. c. Directly related to criminal investigation, prosecution, trial, and judgment execution;
d. For the purpose of protecting the life, property, and other major legitimate rights of you or other individuals, but it is difficult to obtain the person's consent;
e. Personal information that you have disclosed to the public on your own;
f. Personal information collected from legally and publicly disclosed sources, such as legal news reports and government information disclosures.
3. How We Store Personal Information
3.1 Storage Period
We store your personal information only for the period necessary to provide the Xoon Show services: information you post, comments, likes, and related information will be stored as long as you have not withdrawn, deleted, or canceled your account. After the necessary period, we will delete or anonymize your personal information, unless otherwise required by laws and regulations.
4. How We Protect the Security of Personal Information
a. We take the security of your personal information very seriously and will strive to take reasonable security measures (both technical and managerial) to protect your personal information and prevent it from being improperly used or accessed, publicly disclosed, used, modified, damaged, lost, or leaked without authorization.
b. We will use encryption technology, anonymization, and other reasonable and feasible means that are no less protective than industry standards to protect your personal information, and we will use security protection mechanisms to prevent malicious attacks on your personal information.
c. We will establish a dedicated security department, security management system, and data security procedures to ensure the security of your personal information. We adopt a strict data usage and access system to ensure that only authorized personnel can access your personal information, and we conduct regular data security and technology audits.
d. Although we have taken the reasonable and effective measures above and have complied with the standards required by relevant laws and regulations, please understand that due to technical limitations and various malicious methods that may exist in the internet industry, it is impossible to always guarantee 100% information security, even with our best efforts to strengthen security measures. We will do our best to ensure the security of the personal information you provide to us.
e. You acknowledge and understand that the systems and communication networks you use to access our services may experience issues due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect your personal information, including but not limited to using complex passwords, changing your password regularly, and not disclosing your account password and related personal information to others.
f. We will formulate an emergency response plan and immediately activate it in the event of a user information security incident, striving to prevent the impact and consequences of such an incident from expanding. Once a user information security incident (leakage, loss) occurs, we will promptly inform you in accordance with the requirements of laws and regulations about: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, advice for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the situation through notifications or other relevant forms. If it is difficult to inform you individually, we will adopt a reasonable and effective way to issue an announcement. At the same time, we will also report the handling of the user information security incident in accordance with the requirements of the relevant regulatory authorities.
5. Managing Your Personal Information
We place great importance on the management of your personal information and do our best to protect your rights to inquire about, access, modify, delete, withdraw consent and authorization, file complaints and reports, and set privacy functions, so that you have the ability to protect your privacy and information security.
5.1 Changing or Withdrawing the Scope of Authorization
5.1.1 Changing or Withdrawing Sensitive Permission Settings
a. You can turn off camera, microphone, and photo album permissions in your device's operating system to change the scope of consent or withdraw your authorization. After withdrawal, we will no longer collect information related to these permissions.
b. The software does not enable auto-start by default; you can change this setting on your phone.
5.1.2 Processing of Information after Changing or Withdrawing Authorization Certain business functions and services require your information to be completed. When you withdraw your consent or authorization, we can no longer provide you with the corresponding functions and services, and we will no longer process your related personal information. However, your decision to withdraw consent or authorization will not affect our previous processing of personal information based on your authorization.
5.2 Complaints and Reports
You can file a complaint or report in accordance with the system we have published. If you believe your personal information rights may have been infringed, or if you discover clues of such infringement, you can contact us through the designated channels within the app. We will process your complaint and report within 30 days after verification.
5.3 Accessing the Privacy Policy
You can view the full content of this Privacy Policy on the registration page or by logging into your personal account and navigating to [Me]-[Settings]-[About Us]-[Privacy Policy].
5.4 Notifying You of Operation Stoppage
If we cease operations, we will promptly stop collecting your personal information, notify you of the cessation of operations through individual delivery or public announcement, and delete or anonymize the personal information we hold.
6. Provisions for Minors
6.1 General Provisions for Minors
a. If you are a minor under the age of 18, you must read and agree to this Privacy Policy under the supervision and guidance of a parent or other guardian before using Xoon Show and its related services.
b. We protect the personal information of minors in accordance with relevant national laws and regulations and will only collect, use, share, or disclose the personal information of minors when permitted by law, with the explicit consent of a parent or other guardian, or when necessary to protect the minor. If we discover that we have collected a minor's personal information without prior verifiable consent from a parent or other guardian, we will endeavor to delete the relevant information as soon as possible. We have also established strict rules for the collection and use of minor's information.
c. If you are the guardian of a minor and have questions about the personal information of the minor under your care, please contact us through the contact information disclosed in this Privacy Policy.
7. How to Delete Personal Information
Xoon Show provides an account deletion function within the application. You can apply to delete your account by contacting customer service or by submitting a deletion request within the app. You can apply for account deletion via the path [Me]-[Settings]-[Account and Security]-[Delete Account] in the Xoon Show app. We recommend that you ensure all relevant information and services in your account have been properly handled before applying for deletion. We provide a 15-day appeal period, during which users can revoke their deletion request. At the end of the appeal period, the account information will be automatically deleted and cannot be recovered. The deleted information may include all device information (including phone model, unique device identifier, etc.), account information, personal data, account assets, member benefits, chat history, etc.
8. Revisions and Notifications of the Privacy Policy
To provide you with better services, Xoon Show and its related services will be updated and changed from time to time, and we will revise this Privacy Policy accordingly. These revisions are part of this Privacy Policy and have the same effect. You expressly agree that we will not reduce your rights under the current effective Privacy Policy.
9. Contact Us
If you have any complaints, suggestions, or questions regarding your personal information protection, you can contact us at the following address:
PT. XOON TECHNOLOGY INDONESIA
Jl. Tanjung Duren Raya No. 1B, Kel. Tanjung Duren Selatan, Kec. Grogol Petamburan Kota Administrasi Jakarta Barat, DKI Jakarta 11470 Indonesia
We will review the issue as soon as possible and handle it within fifteen working days after verifying your user identity.