VooV Meeting

Privacy Policy

Last Updated: [November 3.2023]

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to VooV Meeting (“Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

Please note that this privacy policy may describe features and functions of VooV Meeting which may or may not be available in your particular jurisdiction.

· “Enterprise Customer” means the organization that has purchased the Enterprise Version for non-personal use by Enterprise Users.

· “Enterprise User” means an individual who belongs to or is affiliated with the Enterprise Customer and is using the Service, in which case they will be using the Enterprise Version of the Service.

· “Enterprise Version” means the version of the Service which is available for use by Enterprise Customers for non-personal use, such as for business use, and which is subject to the Service Agreement (for Enterprise Users) available here (“Enterprise Service Agreement”). The Enterprise Customer is the data controller of all personal information in the Enterprise Version.

· “Personal User” means a user who is using the Service for their own personal use, in which case they will be using the Personal Version of the Service.

· “Personal Version” means the Service that is not the Enterprise Version and which is subject to the Service Agreement (for Personal Users) available here (“Personal Service Agreement”). We are the data controller in respect of all personal information collected and processed in the Personal Version

· “you” refers to the Personal User (in respect of the Personal Version) and the Enterprise User (in respect of the Enterprise Version).

Unless expressly set out in this privacy policy, the information contained in this privacy policy applies to both the Personal Version and Enterprise Version.

SUMMARY

Here is a summary of the information contained in this privacy policy. You can find more detail by clicking ‘More Information’.

*What information do we need to be able to provide the Service?*	· If you register an account to use the Service then we will need some information from you to set this up. If you choose to set up your profile using one of your existing accounts such as WeChat, Google or Apple, (if you are a Personal User), we also collect information from that connected account to set up your account. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.	More Information
*How will we use your information?*	· We use your information to provide the many functions and services that comprise the Service. We also use your information for account verification, security and to support and improve the Service. We do not share your information with any third parties, except where we need to in order to provide the Service (e.g. use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Service), or we are instructed to by a court, authority or compelled by law.	More Information
*Who do we share your information with?*	· We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support the Service). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the Service and we may be required by a court or legal obligation to disclose certain information in some circumstances.	More Information
*Where do we process your information?*	· Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Service in Singapore. The servers applicable to your use of the Service will depend upon your location. We also have support, engineering and other teams who may support the Service, including from Hong Kong and the PRC. · If you are an Enterprise User, your personal information is stored in accordance with the Enterprise Service Agreement. Please contact the relevant Enterprise Customer, who is the data controller, for further information. · For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses.	More Information
*How long do we keep your information?*	· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws. · If you are an Enterprise User, your personal information will be retained in accordance with the Enterprise Service Agreement. Please contact the relevant Enterprise Customer, who is the data controller, for the retention periods for your personal information.	More Information
*How can I exercise my rights over my information?*	· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. · If you are a Personal User, you may contact us here. If you are an Enterprise User, please contact the relevant Enterprise Customer directly, who is the data controller, for more information.	More Information
*How will we notify you of changes?*	· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information

Interoperability with Tencent Meeting

VooV Meeting is interoperable with Tencent Meeting (the PRC version of VooV Meeting ), such that you are able to use certain features operated by Tencent Meeting or join a meeting hosted by a Tencent Meeting user, in accordance with the applicable terms. When you select any of the said feature(s) of Tencent Meeting or join a meeting hosted by a Tencent Meeting user, we will share your information with Tencent Meeting to the extent necessary to facilitate the interoperability between VooV Meeting and Tencent Meeting (“Interoperable Interaction”). Tencent Meeting is operated by a different entity named 深圳市腾讯计算机系统有限公司 ( Shenzhen Tencent Computer Systems Company Limited) located in the PRC. Your use of any Tencent Meeting features or interactions with Tencent Meeting users (if you join their meetings) and the processing of any such information will be subject to Tencent Meeting’s Privacy Policy here [insert hyperlink - https://privacy.qq.com/document/preview/4467add90f9d4baaabd790cb1cb08b26]. You may view the list of the abovementioned features operated by Tencent Meeting, the categories of personal data processed, and the data retention period upon such use here .

Third parties may utilise the abovementioned features of Tencent Meeting above to offer their services to you. When you interact with such services, your information will be shared, collected, retained, stored or otherwise processed by the relevant third party providers in accordance with their own privacy policy.

Contact Information

Personal Version (More Information)

· Data Controller:

o If you are located in Singapore: Aceville Pte. Ltd.

o If you are located outside of Singapore: First App Holdings Limited

o Email: DPO@voovmeeting.com

· EU Representative:

o Tencent International Service Europe B.V

o Email: eudataprotection@tencent.com

Enterprise Version (More Information)

· Data Controller: the relevant Enterprise Customer for your account

Welcome to VooV Meeting!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with VooV Meeting (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

Please note that this privacy policy may describe features and functions of the Service which may or may not be available in your particular jurisdiction.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are accepting our rules regarding your personal information as described in this privacy policy.

This Service is operated by (in the case of persons located in Singapore) Aceville Pte. Ltd. and (in the case of persons located outside of Singapore) First App Holdings Limited (in each case, “we”, “us”, “our”). We are the entity that will be offering the Service to you, that you will be transacting with in relation to the Service, and the data controller of your personal information in relation to the Service.

First App Holdings Limited is a Hong Kong based company within the Tencent group. The registered address of First App Holdings Limited is 29/F, Three Pacific Place, 1 Queen’s Road East, Wanchai, Hong Kong.

Aceville Pte Ltd is a Singapore based company within the Tencent group. The registered address of Aceville Pte Ltd is 1 Fullerton Road, #02-095, One Fullerton, Singapore 049213.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. Our data protection officer can be contacted at DPO@voovmeeting.com. We have representatives for data protection purposes listed here.

Please note that this privacy policy describes how we process the personal information you provide to set up your account and use the Service. We are the data controller for such personal information except to the extent you transmit personal information using the Service (for example, setting up a video or audio transmission, or share information on the Service).

To the extent you transmit personal information using the Service, we are the data processo

r and act on your instructions. We describe this further below. Please also see our Data Processing Agreement located here for further information.

Enterprise Version

If you are an Enterprise User, this Service is provided to you by your organization (i.e. relevant Enterprise Customer), who is the data controller. Please reach out to the relevant Enterprise Customer directly if you have any questions or concerns regarding the collection and processing of your personal information.

1. The Types of Personal Information We Use

This section describes the different types of personal information collected from you and how they are collected. If you would like to know more about specific types of data and how that data is used, please see the section entitled “How we use your personal information“ below.

Personal Version

The following is a high level summary of the types of personal information we process:

1. Information you provide to us (either directly or through a third party).

· Registration information: You give us information about you when you register for the Service and create a user identity (“User ID”) or use your WeChat ID (“WeChat ID”): this means that if you register by mobile phone number or email address, we process your mobile phone number or email address and display name, and if you register via WeChat, we process your WeChat account, profile photo, mobile phone number, region (location) and gender. You also provide us with your country or primary location during the registration process. You can also register for the Service with your Google ID or Apple ID. When you register with your Google ID, we process your Google ID, open ID, email, location, bind time, nick name and avatar. When you register with Sign in with Apple, you have the option to share your Apple ID with us or to use an Apple-provided identifier (which will hide your Apple ID). If you use the Service as a guest user, we collect device identifiers from you (depending on the type of device you are using), such as Android ID, IDFV, UUID and hard disk number to ensure you are recognised when you re-visit the Service.

· Guest login information: You give us information about you when you join the Service as a guest: this means that when a registered user invites you to join a meeting, you will provide us with your name and mobile number.

· Picture: We will (i) store your picture when you choose to upload a photo from your camera or device to use as your profile picture; or (ii) process your picture when you upload a photo from your camera or device to use as your personalised virtual background.

· Time zone: You give us information about the time zone you are located in when you schedule a meeting.

2. Information about you generated as part of the Service

We automatically collect certain data from you when you use the Service, namely your:

· IP address and device information - such as device ID, operating system and version, IP address, UDI, battery, audio and video equipment information and system disk storage size;

· software information - namely, your software version number, browser type and technical information regarding your use of the Service;

· service log information - such as operational record information generated when you use the Service, including device IP address, fault log, software operation information (in case of failure, you can also voluntarily submit log files to the administration server), and communication log information, such as the meeting ID, and time and duration of the communications you have made while using the Service;

· audio and video data (Encrypted)- including screen sharing of your desktop or a specific window of your desktop, any sound streaming coming from your desktop;

· audio and video quality data - such as volume, packet loss rate and other relevant data (audio and video quality data does not involve your call content) includes: (i) any audio and video quality data processed through our server (this will be stored and collected by us); and (ii) any audio and video quality that is data processed on your local device (please note that this will not be stored by us on our servers);

· network status data - being the: (i) information which is only processed on your local device, including the status of your WiFi/internet connection and whether you have authorisation to connect to the Service and its network, including CPU usage, memory usage (this will not be stored by us on our servers); and (ii) status of connection between your connecting server and the Service’s server (this will be stored and collected by us);

· landline number – when you dial in to the meeting using your landline number (to the extent this dial-in function is available in your country);

· automatic disconnection / lock screen mode information – your election to have your meeting automatically disconnected when your PC screen goes into screensaver or lock screen mode (such information is only processed and stored your local device and will not be stored by us);

· status of your Bluetooth device – this is only processed and stored on your local device for the duration of the meeting and will not be stored by us;

· sign up source – if you are a registered user, the source from which you signed up to the Service, i.e. sign up for mobile, sign up for PC or sign up for Web (such information is anonymised prior to storage by us); and

We also collect and store your data:

· customer support communications - each time you interact with us, for example, if you contact our support team;

· chat contents - when you communicate with other users in the Service through the meeting group chat function or private chat function, depending on whether the meeting host has enabled the private chat function (e.g., chat and log data);

· blocked meeting participants information - when a meeting host blocks a meeting participant from re-entering the meeting, the meeting participant’s User ID;

· calendar data - when you choose to use particular functions (e.g., if you choose to add a meeting to your calendar when accepting a meeting invite, we process, but do not store on our servers, calendar data);

· communication log - when the host of the meeting logs in to the Service’s web version and exports the following information in relation to the meeting that it hosted: the meeting’s start and end time, subject of meeting, meeting ID, and participants’ personal meeting ID;

· security-related information - when you are using the Service, for security purposes we collect (in addition to the categories of data listed above) device information including equipment brand and model and available space on the device;

· mobile phone locking information - when you use the Service on your mobile device, the Service will detect and lock your mobile device screen when you hold your mobile device to your ear to prevent any inadvertent pressing of your mobile device (this is processed through your local device and we do not store any information generated from this function);

· meeting data – when you

o access the details of a particular meeting, including the start and end time, subject of meeting, meeting ID, meeting link, and dial in details if you access it via the Outlook plugin;

o export a list of the participants of a historical meeting hosted by you, including the start and end time, subject of meeting, meeting ID, display name of the attendees, each participant’s start and end time and the duration of its participation, room type (i.e. meeting room or waiting room);

o access or copy your chat records of historical meetings from chat function (encrypted), (such information is only exported from the data stored on your local device and we do not store such information on our servers);

· meeting position information – the position (or “seat”) in the meeting that is automatically assigned to you and, if the “spotlighting” function is available to the meeting host in your meeting, your user ID, app ID, tiny ID (a unique identifier assigned to you) and platform information (i.e. android, iOS, mac, windows) (this information is processed momentarily by us during the meeting and is not stored on our servers);

· sharing meeting invitation – when you share a meeting invitation through QQ, WeChat, WeCom, WhatsApp and QQ Mail, the duration, time, topic of meeting and meeting number;

· meeting invitation status – whether you have accepted to join a meeting (“Yes or No”) using the meeting invitation that was shared with you (this information is anonymised prior to storage on our servers);

· installation package data – device ID, Android ID, IDFV, UUID and hard disk number (as applicable) to install enable the installation of the Service (this information is anonymised prior to storage on our servers); and

· Outlook plugin information – if you schedule a meeting through the Outlook plugin:

o your nickname and account type (this information is processed and stored on your local device while Outlook is open and we do not store such information on our servers);

o your existing audio and video configurations when using the Service (this information is processed momentarily by us during the meeting when Outlook is open and is not stored on our servers); and

o other plugin information.

We process your data when you share or stream information:

· Audio and video data - each time you screen share your current desktop, or a specific window of your desktop, including any sound streaming coming from your desktop, to remote users (which is encrypted and can only be viewed in real time);

· Face Data – when you choose to use the beauty filters, stickers and avatars ( we only momentarily process this data on your device and we do not upload or store this on our servers, neither share this data with third parties);

· Drawing board - when you stream your drawing board to other users and draw on the drawing board, insert and edit text, draw shapes, and mark up documents (only one user can draw or mark up the document);

· Record a meeting – if a meeting host grants you permission to record a meeting, your recording will be processed and stored on your local device (and it will not be processed or stored on our servers). However, in order to grant you the permission to record the meeting as instructed by the host, we will use your User ID;

· Chat contents - when you share information with other users who are attending the same meeting through the chat function. Please note that this may include your personal information, personal property information and other sensitive information. Please take care when disclosing your personal sensitive information;

You instruct us to modify and adapt such streamed information for technical purposes to operate the application and Service (e.g. making sure content is viewable on smartphones as well as computers and other devices). Please note that some of these sharing functions will not be available in every country.

Enterprise Version

If you are an Enterprise User, in addition to the personal information set out in the “Personal Version” section above, we additionally process the following types of personal information:

· Enterprise login information: When you login to the Service via mobile number, we process your phone number. When you login to the Service via the “single-sign on” function (“SSO”), we process your userID, username, email, mobile number, your Enterprise Customer’s name and logo and any other personal information which you choose to provide to your Enterprise Customer as login credentials.

· Annotation during screen sharing: If you participate in a meeting hosted by an Enterprise User, we will process your drawing board and any collaborative annotations if you stream the screen share of your drawing board. This data is only stored on your device and is not stored on our servers.

· Simultaneous Interpretation: If you join the meeting as a simultaneous interpreter/translator, we process your mobile number. This data is not stored on our servers but in accordance with the Enterprise Service Agreement.

· Profile picture: A picture that is pre-set by the Enterprise Customer as your profile picture, e.g. a picture of the company logo.

· Video sharing information: Your device name in order to enable video screen sharing. This data is only stored on your device and is not stored on our servers.

· Webinar information: the webinar registrant’s name, phone number, email address, company name, company size, role in webinar (e.g. attendee or panelist) and Q&A information (nickname / user ID, time, questions asked and answers).

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

For more information about our Cookies policy, click here.

3. Children

Our Service is not intended for children. Children must not use the Service for any purpose.

By children, we mean users under the age of 18 years old; or in the case of users located in a country where the minimum age for processing personal data differs, the minimum age specified under law. For certain jurisdictions we have listed the minimum age in the table below.

Country in which the user is located	Minimum age of the user
European Economic Area	16
Indonesia	18
Japan	18
Republic of Korea	14
Russia	14
Thailand	20
Vietnam	16
United Kingdom	13
United States	13

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages, please contact us here and we will delete such information.

4. How We Use Your Personal Information

This section provides more details on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), UK, Indonesia, Thailand or Brazil (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

1. Personal Version

Personal Information	Purpose of Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
Information you provide to us (either directly or through a third party).
If you choose to register via creating a new account: Mobile phone number or email address, and display name	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Social media information: If you choose to register via WeChat (WeChat ID): this includes your WeChat account name, profile photo, mobile phone number, region (location) and gender	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
If you choose to register via Google ID: your Google ID, open ID, email, location, bind time, nick name and avatar. If you choose to register via *Sign in with Apple*: you have the choice to share your Apple ID (email) with us or to register using an Apple-provided identifier.	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
If you choose to use the Service as a guest user, we collect the following depending on your device: · Android: Android ID · iOS: IDFV · MAC: UUID · Windows: Hard disk number Please note that this data is anonymised before being stored on our servers.	We use this information to recognize returning guest users in order to display the right information to them and to keep a record of any consents or acknowledgements given.	N/A

2. Personal and Enterprise Versions

Personal Information	Purpose of Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction and are using the Personal Version)
Information you provide to us (either directly or through a third party).
If you choose to register via creating a new account: User ID	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Country or primary location	We use this information to ensure you are delivered the most appropriate version of the Service.	It is in our legitimate interests to use this information to deliver the most appropriate version of the Service.
Picture: We will (i) store your picture when you choose to upload a photo from your device to use as your profile picture; or (ii) process your picture when you choose to upload a photo from your device to use as personalised virtual background (your personalised virtual background is only stored on your device and is not stored on our servers).	We use this information to enable you to upload a profile picture or virtual background.	Upload profile picture: Necessary to perform our contract with you to provide the Service. Personalised virtual background: N/A
Time zone	We use this information to enable you to schedule and host meetings according to your time zone.	Necessary to perform our contract with you to provide the Service.
Information generated or processed by us as part of the Service
IP address	We use this information to allow you to connect to our server.	Necessary to perform our contract with you to provide the Service.
Device information: Device ID, operating system and version, IP address, UDI, battery, audio and video equipment information and system disk storage size	We use this information to ensure the security of the Service.	It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.
Software information: Software version number and browser type	We use this information to ensure the security of the Service.	It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.
Communication log (not collected from guest users): meeting ID, meeting subject, meeting start and end time, personal meeting ID	We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to provide the Service.
Landline number	If you dial in from a landline number, we use this to facilitate your communications with other users.	Necessary to perform our contract with you to provide the Service.
Audio and video quality data: volume and packet loss rate (audio and video quality data is not related to the contents of your call).	We use this information to · optimize compatibility and to ensure this meets your personalized requirements; and · synchronise external audio connection, optimize audio quality and to detect if your audio device is malfunctioning (we do not store data on our servers that is processed for this purpose).	Necessary to perform our contract with you to provide the Service.
Network status data (not stored), being the status of your WiFi/internet connection and whether you have authorisation to connect to the Service and its network, including CPU usage, memory usage. Please note that this data is only stored on your device, and is not stored on our servers.	We use this information to determine your network status data and connectivity to the Service.	N/A
Network status data (Personal Version): status of connection between your connecting server and the Service’s server (this will be collected and stored by the Service). Network status data (Enterprise Version): status of connection between your connecting server and the Service's server, type of operating system used for joining the meeting, network quality (uplink/downlink bitrate, frame rate, resolution, packet loss rate), type of audio input/output and camera used for the meeting (whether it is an external or internal microphone, headset; whether it's a front camera or facetime HD camera).	We use this information to determine your network status data and connectivity to the Service.	Necessary to perform our contract with you to provide the Service.
Security-related information: device operation system settings, device information including Device ID, model, CPU structure, CPU model, kernel version, resolution	We use this information to resolve bugs, optimize compatibility with your device, for authentication, security, anti-fraud monitoring, archive backup, and maintaining security of the Service.	It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.
Service usage data: how often you use the application, service default/error information, overall usage data, performance data, and the version of the application. Service log information: the operational record generated when you use the Service, including device IP address, fault log, software operational data (in case of failure, users can also voluntarily submit log files to the administrating server)	We use this to: · ensure the security of the service, solve and locate problems, help us better understand how our application is running, optimize our services and improve the quality of the Service; and · to determine whether an account has been hacked or whether any improper or illegal act exists.	It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.
Customer support communications: name, mobile phone number, email address, photo (if you choose to upload one to illustrate the error), and details of error	We use this information to: · provide troubleshooting, such as addressing and remediating technical issues and bugs; and · for administering product/ customer support services to you.	Necessary to perform our contract with you to provide and support the Service.
Automatic disconnection from a meeting when your PC screen goes into screensaver or lock screen mode Please note that this data is only stored on your device, and is not stored on our servers.	We use this information to allow you to enable or opt out of the automatic disconnection from meetings when your PC screen goes into screensaver or lock screen mode	N/A
Mobile phone locking (when held next to ear) Please note that this data is only stored on your device, and is not stored on our servers.	We use this information to detect and lock your mobile device screen when you hold your mobile device to your ear to prevent any inadvertent pressing of your mobile device.	N/A
Device name (e.g. John’s iPhone) Please note that this data is only stored on your device, and is not stored on our servers.	We use this information to remind you that your account has been logged into a different device	N/A
Bluetooth status Please note that this data is only processed momentarily during the meeting, and is not stored on our servers.	We use this information to provide the Service.	N/A
Sign up source: if you are a registered user, whether you have signed up via Sign up for Mobile, Sign up for PC or Sign up for Web. Please note that this data is anonymised prior to storage on our servers.	We use this information for statistical information purposes.	N/A
Meeting position information: · the position (or “seat”) in the meeting layout that is automatically assigned to you; and · if the “spotlighting” function is available to the meeting host in your meeting, your user ID, app ID, tiny ID (a unique identifier assigned to you) and platform information (i.e. android, iOS, mac, windows). Please note that this data is processed by us momentarily during the meeting, and is not stored on our servers.	We use this information to: · enable “Together Mode”, a video layout which simulates classrooms and lecture halls; and · allow the meeting host to configure your video feed as the “spotlight” screen in the video layout (i.e. display in the centre) during the meeting.	N/A
Meeting invitation status: whether you have accepted to join a meeting (“Yes or No”) using the meeting invitation that was shared with you. Please note that this data is anonymised prior to storage on our servers.	We use this information to allow the host to see whether you have accepted the meeting invitation.	N/A
Installation package data: device ID, Android ID, IDFV, UUID and hard disk number (as applicable) to install enable the installation of the Service. Please note that this information is anonymised prior to storage on our servers.	We use this information to understand the download source of the Service’s installation package as an application.	N/A
Outlook plugin information: · your nickname and account type (this information is processed and stored on your local device as cache memory while Outlook is open and we do not store such information on our servers); · your existing audio and video configurations when using the Service (this information is processed momentarily by us during the meeting when Outlook is open and we do not store such information on our servers); and · other plugin information: channel from which plugin is downloaded from, plugin version, a randomised plugin number to distinguish the corresponding version (this is not stored on our servers), and plugin UID (this is stored locally on your device and deleted when the plugin is uninstalled).	We use this information to allow you to schedule or cancel a meeting through the Outlook plugin	N/A
Content shared by you
Audio and video data (Encrypted), including screen sharing of your desktop or a specific window of your desktop, any sound streaming coming from your desktop	· You instruct us to use this information solely to facilitate the operation of the Service. We do not access the contents of your communications, which are encrypted. · We use this information to allow other users to receive translation of your communications, such feature is only available if requested by a meeting participant or if this is allowed by the meeting host. · We use this information to mute any incoming participant as a default setting if there are more than 6 participants in a meeting (we do not store this data on our servers for this purpose). · If you are using the Service on your PC, we use this information to allow you to opt to fill in a green screen for virtual background (we do not store this data on our servers for this purpose).	Necessary to perform our contract with you to provide and support the Service.
Face Data in the use of the beauty filters, stickers and avatars	· You instruct us to use this data solely to facilitate the provision and operation of the beauty filter,stickers and avatars . · we only momentarily process this data on your device and we do not upload or store this on our servers, neither share this data with third parties.	N/A
Live Broadcast Data (if you choose to publicly share your current broadcast – userid and enterpriseid)* *functionality subject to availability	To determine if your account can use the live broadcast function.	Necessary to perform our contract to facilitate live broadcast for authorised users.

Drawing board (streaming your drawing board, or using the drawing function)	If you voluntarily choose to stream your drawing board or use the drawing function, you instruct us to process that information to share the drawing board contents with the meeting participants.	Necessary to perform our contract with you to provide and support the Service.
Recording Permission Data (if a meeting host grants you permission to record a meeting, your recording will be processed and stored on your local device (and it will not be processed or stored on our servers). However, in order to grant you the permission to record the meeting as instructed by the host, we will use your User ID)	We use this information to facilitate the host granting you permission to record a meeting.	Necessary to perform our contract with you to allow you to record a meeting.
Chat contents	If you voluntarily choose to share information with other users who are attending the same meeting through our chat function (whether via group or private chat, if enabled by the host) or if you are a meeting host and send messages or notices in the meeting room to other users, you instruct us to facilitate that sharing.	Necessary to perform our contract with you to provide and support the Service.
Calendar and meetings data
Calendar data Please note that this data is only stored on your device, and is not processed by our servers.	If you voluntarily choose to add a meeting to your calendar when accepting a meeting invite, you instruct us to process that data for the purpose of notifying you of the meeting.	N/A
Blocked meeting participants (User ID of the blocked participants)	If you as the host of a meeting voluntarily choose to block a meeting participant.	Necessary to perform our contract with you to provide and support the Service.
Details of a particular meeting: the start and end time, subject of meeting, meeting ID, meeting link and dial in details (only if accessing via the Outlook plugin)	If you choose to access the details of a particular meeting and if you choose to schedule a meeting via the Outlook plugin.	Necessary to perform our contract with you to provide and support the Service.
List of participants of historical meetings by a host user: when the host of the meeting exports the following information in relation to the meeting that it hosted (through the Service’s webpage): a list of the participants, the meeting’s start and end time, subject of meeting, meeting ID, each participant’s start and end time, the duration of its participation in the meeting and room type (i.e. meeting room or waiting room).	If you choose to export a list of the participants and the related information of a meeting hosted by you.	Necessary to perform our contract with you to provide and support the Service.
Chat records of your historical meetings from chat function (encrypted) Please note that this data is only stored on your device, and is not stored on our servers.	If choose to access or copy chat records of your historical meetings.	N/A
Sharing meeting invitation: if you share a meeting invitation through QQ, WeChat, WeCom, WhatsApp and QQ Mail: duration, time, and topic of your meeting and meeting number. Please note that this data is only stored on your device, and is not stored on our servers.	We use this information to enable you to share a meeting invitation through QQ, WeChat, WeCom, WhatsApp and QQ Mail.	N/A

3. Enterprise Version

Personal Information	Purpose of Use
Information you provide to us (either directly or through a third party)
If you choose to login using your mobile phone: your mobile phone number	We use this information to create your account for the Service in accordance with your request.
SSO Login: your userID, username, email, mobile number, your Enterprise Customer’s name and logo and any other personal information which you choose to provide to your Enterprise Customer as login credentials	We use this information to create your account for the Service in accordance with your request.
Simultaneous Interpretation: If you join the meeting as a simultaneous interpreter/translator, we process your mobile number.	We use this information to allow you to join the meeting as a simultaneous interpreter in accordance with your request.
Profile picture: Picture selected by the Enterprise Customer as your profile picture.	We use this information to administer your account in accordance with your request.
Video sharing information: Your device name to enable video screen sharing. Please note that this data is only stored on your device, and is not stored on our servers.	We use this information to allow you to share your screen.
Content shared by you
Annotation during Screen Sharing: If you participate in a meeting hosted by an Enterprise User, we will process your drawing board and any collaborative annotations if you stream the screen share of your drawing board. Please note that this data is only stored on your device, and is not stored on our servers.	If you voluntarily choose to stream your drawing board or use the drawing function, you instruct us to process that information to share the drawing board contents with the meeting participants.

To understand how our users use the Service and to improve the Service, we may also process anonymised data in relation to operation of the Service. For example, we may identify certain locations where there is a high density of users and that will help us to ensure the Service is best serving that particular location.

5. How We Store and Share Your Personal Information

Personal Version

The group operates around the world. Pursuant to our contract with you to provide you with the Service and your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers used for the storage of your personal information are located in Singapore.

For users residing outside Singapore, including users in the UK and the European Economic Area (EEA), the Service is offered by First App Holdings Limited, which is based in Hong Kong. This means that all personal data provided by the user or generated in the context of the Service may be accessed by First App Holding Limited in Hong Kong.

Enterprise Version

Your personal information is stored in accordance with the Enterprise Service Agreement. Please contact the relevant Enterprise Customer, who is the data controller, for further information.

Personal and Enterprise Version

Our support, engineering and other teams are located in our offices around the world (including the People’s Republic of China, which for the purposes of this policy excludes Hong Kong SAR, Taiwan and Macau SAR (“PRC”)).

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, for the purpose of account login and verification, for the purpose of processing support ticket ID and support communication. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within the corporate group who process your personal information in order to operate the Service, such as provision of servers and facilitating log in (e.g., when using WeChat). All related group companies may only use your personal information in accordance with this privacy policy.

· Regulators, judicial authorities, law enforcement agencies, and other third parties for safety, security, or compliance with law. There are circumstances in which we are legally required to disclose information, such as to law enforcement agencies, public authorities or other organisations, or if we have a good faith belief that such use is reasonably necessary to:

o comply with a legal obligation, process or request;

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

1. Personal Version

Personal Information*

Retention Policy

Mobile phone number and Display Name

WeChat ID: Social Media Information

Google ID

Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request, after which it will be deleted immediately).

2. Personal and Enterprise Versions

Personal Information*

Retention Policy

User ID

Picture (profile picture uploaded by you via your camera or device)

Your landline number

Security-Related Information

Customer Support Communications

Communication log (not collected from guest users)

Country or primary location

Your Google login credentials (name, email, authentication code and avatar), if you choose to share a broadcast via YouTube.

Live Broadcast Data (userID and enterpriseID)

Personal Version: Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request, after which it will be deleted immediately).

Enterprise Version: Stored in accordance with the Enterprise Service Agreement.

IP Address

Device information

Software information

Audio and video quality data (under Personal Version)

Service usage data

Service log information

Personal Version: Stored for 7 days from the date of collection.

Enterprise Version: Stored in accordance with the Enterprise Service Agreement.

Audio and video quality data (under Enterprise Version)

Enterprise Version: Stored in accordance with the Enterprise Service Agreement.

Audio and video data (Encrypted), including screen sharing of your desktop or a specific window of your desktop, any sounds streaming processed as part of the screen sharing

Drawing board (streaming your drawing board or using the drawing function)

Recording Permission Data (User ID of the users permitted to record the meeting)

Blocked meeting participants (User ID of the blocked participants)

Time zone

Personal Version: Stored and processed for the duration of the meeting only and solely to facilitate your communications during the meeting (we do not access any contents of your communications).

Enterprise Version: Stored in accordance with the Enterprise Service Agreement.

Face data in the beauty filters, stickers and avatars

Personal and Enterprise Versions: We only momentarily process this data on your device and we do not upload or store this on our servers, neither share this data with third parties.

Chat contents

Personal Version: Stored and processed for the duration of the meeting only and solely to facilitate your communications during the meeting (we do not access any contents of your communications).

When you leave and subsequently re-join a meeting, you will be able to see any chat contents that were sent before you exited the meeting (but not those while you were not part of the meeting).

Enterprise Version: Stored in accordance with the Enterprise Service Agreement.

Network status data (Personal Version)

Network status data (Enterprise Version)

Personal Version: Stored and processed for 7 days.

Enterprise Version: Stored for 105 days, but subject to and in accordance with the Enterprise Service Agreement.

Meeting data:

(i) Details of a particular meeting; and

(ii) A list of the participants and the related information of a meeting hosted by you (including the meeting’s start and end time, subject of meeting, meeting ID, each participant’s start and end time, the duration of its participation in the meeting and room type (i.e. meeting room or waiting room)).

Personal Version: Stored for and processed for 30 days from the date of the meeting

Enterprise Version: Stored in accordance with the Enterprise Service Agreement.

Calendar data

Personal and Enterprise Versions: This data is only stored on your device and not processed by our servers.

Picture (personalised virtual background only)

Network status data: the status of your WiFi/internet connection, whether you have authorisation to connect to the Service and its network, network quality and status, including CPU usage, memory usage.

Your election on whether to allow automatic disconnection from meetings when your PC screen goes into screensaver or lock screen mode)

Audio and video quality data (for the purposes of synchronisation, optimization and detection of audio quality)

Sharing meeting invitation

Audio and video data (for the purposes of muting any incoming participant if there are more than 6 participants in a meeting and for the purposes of filling in a green screen for virtual background)

Device name

Name of your Bluetooth device

Personal and Enterprise Versions: This data is only stored on your device, and is not stored on our servers.

Meeting position information

Outlook plugin information

Personal and Enterprise Versions: This data is processed momentarily by us during the during the meeting when the Outlook plugin is open and is not stored on our servers.

Meeting invitation status

Installation package data

Personal and Enterprise Versions: N/A. This data is anonymised prior to storage on our servers.

3. Enterprise Version only

Personal Information*	Retention Policy
Login via mobile phone SSO Login Simultaneous Interpretation (mobile number) Profile picture	Stored in accordance with the Enterprise Service Agreement. Please contact the relevant Enterprise Customer, who is the data controller, for the retention periods for your personal information.
Annotation during screen sharing Video sharing information	Stored in accordance with the Enterprise Service Agreement: this data is only stored locally on your device.
Webinar information	Stored in accordance with the Enterprise Service Agreement and deleted within 180 days of a lawful request for deletion (except for the role in webinar which is deleted within 2 months of a lawful request for deletion), unless otherwise specified. Please contact the relevant Enterprise Customer, who is the data controller, for the retention periods for your personal information.

*Please see the section above titled “How We Use Your Personal Information” for a full description of each category of data.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

7. Your Rights

Personal Version

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

This section entitled “Your Rights” applies to users that are located a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). To exercise any of your rights, please contact us. The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Russia.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us.

Erasure

You can delete your account, or remove certain personal information, by logging into your Service account. If there is any other personal information you believe we process that you would like us to erase, please contact us.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Enterprise Version

If you are an Enterprise User, please contact the relevant Enterprise Customer directly, who is the data controller, for more information on your data subject rights.

8. Contact & Complaints

Personal Version

Questions, comments and requests regarding this policy are welcomed and should be addressed to us here.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at DPO@voovmeeting.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

Enterprise Version

If you are an Enterprise User, please contact the relevant Enterprise Customer directly, who is the data controller, for any questions, comments and requests regarding this policy.

9. Changes

If we make any material changes to this privacy policy, we will post the updated policy here. Please check this page frequently to see if there are any updates or changes to this privacy policy.

10. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

11. Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Tencent International Service Europe B.V.	Buitenveldertselaan 3-5 1082 VA Amsterdam	eudataprotection@tencent.com
Korea	Tencent Korea Yuhan Hoesa	152, Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea	DPO@voovmeeting.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	[DPO@voovmeeting.com]

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Australia

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-Service purchases.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Service.

You are acknowledging your consent to the processing, storage, and cross-border transfer for your personal data. The cross border transfer may occur to any country in which we have databases or affiliates, in particular Singapore where our servers used for the storage of your personal information are located.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions, in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, the heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

Indonesia

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right not to provide you with access to our services.

You are responsible for ensuring that any personal information which you provide to us is accurate and up-to-date. In order to confirm the accuracy of the information, we may also verify the information you provided to us, at any time. You hereby represent that you have already secured all necessary consent before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claim whatsoever from any party as a result of the absence of such consent.

In the event we fail to maintain the confidentiality of your personal information, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in the section How We Store and Share Your Personal Information.

The categories of personal information specified in to the jurisdictions specified in the section How We Store and Share Your Personal Information may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 8 (Contact).

Macau

You have the right not to provide your personal information. If you do so, however, we may not be able to provide the Service. As a Macau data subject you have legal rights in relation to the personal data we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal data for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In relation to users in Malaysia, our servers are located in the Singapore and you consent to the transfer of your data outside of your country.

Right of access: You have the right to request access to and obtain a copy of the personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts permitted by law. When handling a data access request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request limiting the processing of your personal information by using the contact details provided above. However this may affect our provision of the Service to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information:

· Telephone: +603-22872388

· Email: DPO@voovmeeting.com

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: as set out in Section 8 (Contact)

Philippines

You are entitled to the following rights:

· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in the section “How We Use Your Personal Information;

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines when the processing shall need to occur outside the Philippines, as described in the section “How We Store and Share Your Personal Information”.

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Republic of Korea

How We Store and Share Your Personal Information

Provision of personal information to 3rd parties (if applicable)

We provide your personal information to third parties as described below:

Name of Recipient	Types of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient
腾讯云计算（北京）有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd.	All personal information	processing and support in relation to the Service	For the data retention period specified under “How Do We Store and Share Your Personal Information”

Delegation of Processing

For the performance of the services detailed in this privacy policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee	Descriptions of Delegated Services
Aceville Pte. Ltd.	Data processor: Processes and stores data on behalf of the data controller

Overseas Transfer of Personal Information

We transfer Personal Information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)	Country to Which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purpose of Use by Recipient	Period of Retention and Use by Recipient
Aceville Pte. Ltd.	Singapore	Transmitted from time to time	All personal information	Storage of personal information	For the data retention period specified under “How Do We Store and Share Your Personal Information”
腾讯云计算（北京）有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd. (meeting_info@tencent.com)	PRC	Transmitted from time to time	All personal information	Processing of personal information in support of the Service	For the data retention period specified under “How Do We Store and Share Your Personal Information”
Beijing Yufu Feiyang Technology Co., Ltd. (北京玉符飞扬科技有限公司) (cloud@yufuid.com)	PRC	Transmitted during account login and verification only under Enterprise Version Not applicable for Personal Version	SSO login data (Enterprise Customer’s name, logo, userid, username, e-mail, and mobile number)	Account login and credentials verification	For the data retention period specified under “How Do We Store and Share Your Personal Information”
Google Inc. https://policies.google.com/privacy	United States	Transmitted if user logs in using Google ID or uses YouTube API Services	Log-in Data, YouTube API Services Data	Log-in	In accordance with the Google Identity Platform terms (https://developers.google.com/identity) and in the case of YouTube API Services the Google Privacy Policy (https://policies.google.com/privacy)
Apple Inc. (Sign in with Apple ID) https://www.apple.com/legal/privacy/contact/	United States	Transmitted if user logs in using Sign in with Apple	Log-in Data	Log-in	In accordance with the Apple Developer License Agreement (https://developer.apple.com/sign-in-with-apple/)
深圳市腾讯计算机系统有限公司 (Shenzhen Tencent Computer Systems Company Limited) Tencent Meeting privacy policy	PRC	Transmitted if there is an Interoperable Interaction with Tencent Meeting	Personal information specified in the list of interoperable features here	Interoperable Interaction	For the data retention period specified under the list of interoperable features here

Data Destruction

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information is required to be retained beyond the data retention periods as detailed in section “Data Retention” are required to be retained pursuant to the following laws:

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

· Records regarding labelling and advertising (6 months)

· Records regarding execution or withdrawal of a contract (5 years)

· Records regarding the payment of a price and the supply of goods and services (5 years)

· Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

· Log records, IP address (3 months)

· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your Rights

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the PIPA.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:

· whether the additional use/provision is related to the initial purpose of the collection;

· whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;

· whether the additional use/provision unfairly infringe on the interests of the data subject; and

· whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative (if applicable)

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA the information regarding the domestic agent is as follows:

Name and Representative: Tencent Korea Yuhan Hoesa (Representative: Li Yan)

Address: 152 Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Republic of Korea

Telephone number: +82-2-2185-0926

Email: as specified in Section 8 (Contact)

Contact

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: as specified in Section 8 (Contact)

· Telephone number: +82-2-2185-0926

Russia

If you are using the Service in Russia, this section “Russia” applies to you.

By using the Service, you consent to:

· for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Service or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);

· the cross-border transfer of your information to any country where we or third parties to which we may transfer data in accordance with this privacy policy) have databases or affiliates and, in particular as described in Section 5 (How We Store and Share Your Personal Information); and

· for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Service after the notification.

As regards the representative for Russia, you can contact us. Please include the word “Russia” in the subject line of your email.

Separate consent for using certain data

For the purposes of the operation of the Service, as part of its activities, we do not distribute (publically disclose) personal data without the appropriate consent of the data subject and in compliance with the requirements of Article 10.1 of Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended).

By using the Service you also consent to the sharing of your personal information with certain third parties for the purposes set out under section “How We Store and Share Your Personal Information”.

You determine, in your discretion, the terms of disclosure to the general public of your personal data, by choosing to use certain features of the Service and by choosing the appropriate privacy settings in respect of your personal information in the Service.

We process your personal information subject to the terms of this Privacy Policy and your chosen features and settings.

This consent is granted for as long as you use the Services. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us : please include the word “Russia” in the subject line of your email.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 5 (How We Store and Share Your Personal Information).

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted here.

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

South Africa

You have a right to lodge a complaint with the South African Information Regulator by contacting them on inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the Service.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Turkey

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

· learn whether or not your personal data has been processed;

· request information about processing if your personal data has been processed;

· learn the purpose of processing of your personal data and whether they have been used accordingly;

· know the third parties in the country or abroad to whom personal data has been transferred;

· request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and

· demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient	Location of the recipient (or as otherwise stated in the recipient’s privacy policy)	Purposes of use of Personal Information by the recipient	Items of Personal Information to be provided
Aceville Pte. Ltd.	Singapore	Storage of personal information	All personal information
腾讯云计算（北京）有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd. (meeting_info@tencent.com)	PRC	Processing of personal information in support of the Service	All personal information
Beijing Yufu Feiyang Technology Co., Ltd. (北京玉符飞扬科技有限公司) (cloud@yufuid.com)	PRC	Account login and credentials verification	SSO login data (Enterprise Customer’s name, logo, userid, username, e-mail, and mobile number)
Google Inc. https://policies.google.com/privacy	United States	Log-in	Log-in Data, YouTube API Services Data
Apple Inc. (Sign in with Apple ID) https://www.apple.com/legal/privacy/contact/	United States	Log-in	Log-in Data
深圳市腾讯计算机系统有限公司 (Shenzhen Tencent Computer Systems Company Limited) Tencent Meeting privacy policy	PRC	Interoperable Interaction	Personal information specified in the list of interoperable features here

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

· Identifiers, such as your name as it appears on your social media profile, user ID, IP address, device ID, phone number, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· Personal information categories listed in the California Customer Records statute, including information covered by other categories such as your phone number. This information is collected directly from you.

· Characteristics of protected classifications under California or federal law such as gender. This information is collected directly from you in the context of being our consumer or, if you choose to set up your profile using a social media account, your gender may be provided by your social media account provider.

· Internet or other electronic network activity information, such as your information regarding your use of the Service, including and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.

· Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.

· Audio and visual information such as your social media profile picture, photos shared in the Service, and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.

· Account log-in information, including the username and password used to access your Service account.*

· Contents of your chat messages sent on Service*. This information is collected from your device, is only stored on your device, and is not retained by our servers.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

· To provide you with the Service, maintain your account, provide customer service and deliver audio and text messages.

· To improve our services, including the functionality of the Service.

· For security and verification purposes, including to prevent and detect fraudulent activity.

· To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 4 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 5 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

· Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the business or commercial purposes for collecting personal information about you;

o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o the specific pieces of personal information we collected about you;

· Request to Delete. Request we delete personal information we collected about you;

· Request to Correct. Request we correct inaccurate personal information that we maintain about you;;and

· Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).

Vietnam

By accepting this privacy policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this privacy policy.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your consent to collect, store, process, use and disclose your personal information and to request us to stop processing or providing your personal information to a third party.