Effective Date: Jan 26, 2021
Thank you for your interest in Vinkle. The protection of personal data is a serious matter for us. Please review our Privacy Policy carefully as it describes our use and collection of your personal information.
Vinkle(“Dupa”, “Vinkle Apps”, “our”, or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive via our Service (as defined in the Terms of Service) as well as your rights and choices about such use and disclosure. Unless otherwise defined in this Privacy Policy, capitalized terms used herein have the same meanings as in our Terms of Service.
By using the Service, you consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, please discontinue use of the Service. This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).
If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.
What face data is our app collecting?
We analyze users' photos and find out the feature points(like eyes, nose, mouth points) of the face in photo for face processing purpose. We do not collect face data. After the analyzing process ends all data will be deleted, no data will be saved.
For what purposes are we collecting this information?
In order to provide users their "Change face" effects, the app needs to find out the feature points(like eyes, nose, mouth points). The complete process is:
(1) You transfer pictures to our server.
(2) The server analyzes your photo and returns the result of facial data processing.
(3) The application automatically synthesizes the facial data processing results and materials into the final effect.
(4) This information is temporarily stored in Alibaba Cloud's encrypted storage. After the synthesis process is completed, your pictures will be automatically deleted immediately.
Will the data be shared with any third parties? Where will this information be stored?
The data will not be shared with any third parties. The photos you uploaded will be deleted after the analyzing process ends.
EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). We may act as either a data controller or a data processor in respect of your personal data, depending on the circumstances.
Vinkle generally is the data controller with respect to information you provide through the Service. Sometimes Vinkle operates as a data processor on behalf of a client, a separate legal entity, which is the data controller. For example, if you subscribe to our promotional communications, Vinkle Apps may send you content on behalf of our clients and share your personal data with our clients for their own marketing purposes. Please visit the applicable client’s privacy policy for information about their privacy practices. Any questions that you may have relating to such personal data and your rights under data protection law should therefore be directed to the client as the data controller, not to Vinkle Apps.
Vinkle is based in the HongKong and the information we collect is governed by HongKong law. Vinkle processes information on our servers in the HongKong and other jurisdictions. Your information may be transferred to, and used, in locations outside of your state, province, country or other governmental jurisdiction where the privacy laws may be different than those in your jurisdiction. Your use of the Service or provision of any information constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the HongKong and other jurisdictions as set forth in this Privacy Policy. If your personal data is collected in Europe, we will transfer your personal data subject to appropriate or suitable safeguards.
Vinkle Apps agree the HongKong-EU Privacy Shield Framework as set forth by the HongKong Department of Commerce regarding the collection, use, and retention of personal data from the European Union to the HongKong Vinkle Apps has certified or will certify to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.
In accordance with our obligations under the Privacy Shield, and subject to the investigatory and enforcement powers of the HongKong Trade Commission, we hereby affirm our commitment to subject to the Privacy Shield Principles all personal data transferred from the EU in reliance on the Privacy Shield. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third party agent to which we transfer your personal data and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.
Information You Provide
We collect information you provide directly via the Service, including when you:
Use our Service, including our websites and any of our mobile applications;
Access our content, including our articles, webinars, and podcasts;
Register or update an account;
Request quotes, product demos, support, information, or access to our information products and services;
Subscribe to newsletters, promotional communications, alerts, sales outreach, updates and other materials;
Register for webinars or other content offers; or
Contact us.
The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:
Contact Data. We collect your first and last name, e-mail address, postal address, phone number, company name, job title, and other similar contact data.
Credentials. We collect passwords, password hints, and other information for authentication and account access.
Demographic Data. We collect demographic information including your country and size of your company.
Payment Data. We collect data necessary to process your payment if you make a purchase, including your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
Contacts. We collect data you provide about your contacts, including information about other employees at your company. By supplying data about your contacts, you acknowledge and agree that you have your contacts’ consent for us to use their contact information in accordance with this Privacy Policy.
Content. We collect the content of communications you send to us, such as feedback, questions, or information you provide to us.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
Information We Automatically Collect
When you access the Service via a web browser, mobile applications, newsletter, or other client, we and our third party service providers use a variety of technologies, now and hereafter devised, that automatically collect information about your device and how your device interacts with our Service. Some examples of information we collect include the following:
Service Use Data. We collect data about your interaction with our Service, the webpage, newsletter, or services feature you were using before you came to our Service, your web or application request, pages of our websites that you visit, information you search for via our Service, access times and dates, and other similar information.
Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other unique identifiers for the particular device you use to access the internet).
Location Data. We collect data about your device’s location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).
We use this information for a variety of purposes (further addressed in “Our Use of Your Information” below), including analyzing and enhancing our products and services, and to help personalize our Service for you.
We and our third party service providers automatically collect this information using various methods, including, the following methods.
Log Files. Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
Cookies. A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service and remember your preferences, to better understand how you interact with our Service, to provide you advertising on and off the Service, and to monitor usage by visitors and online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. If you do not accept cookies, however, you may not be able to use all portions of our Service or all functionality of our Service.
Web Beacons (“Tracking Pixels). Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons are used in combination with cookies for various purposes, including to allow us to count the number of visitors to the Service, to monitor how users navigate the Service, to count content views, and to provide you advertising on and off the Service.
Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.
Click-Through URLs. In some of our e-mail communications, we use a “click-through URL” linked to content on our websites. When users click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data for various purposes, including to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the e-mail messages.
Location-identifying Technologies. GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
Device Fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and applications.
App Technologies. Certain of our mobile applications may include a unique application number or other device identifiers to associate user activity to a particular mobile application or device and track user activity across mobile applications and devices. This number and other device data may be sent to us when you install or uninstall mobile applications or when such mobile applications periodically contact our servers (for example, to request automatic software updates).
Some information about your use of the Service and certain third party services may be collected using these and other tracking technologies across time and services and used by Vinkle Apps and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain third party services.
For further information on tracking technologies and your choices regarding them, please see “Third Party Analytics and Advertising Technology” and “Your Rights and Choices” below.
Information from Other Sources
We also obtain information about you from other third party sources. To the extent we combine such third party sourced information with information we have collected about you on the Service, we will treat the combined information in accordance with the practices described under this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included or may include:
Data brokers from which we purchase demographic data to supplement the data we collect.
Social networks when you reference our Service or grant permission to Vinkle Apps to access your data on one or more of these services.
Our clients or other partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
Publicly-available sources such as open government databases or other data in the public domain.
We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.
De-Identified or Aggregated Information
We may collect, use, transfer, and disclose information that is de-identified or does not identify you without obligation to you except as prohibited by applicable law. To the extent we combine information that is de-identified or does not identify you with information that does identify you that we collected directly from you on the Service, we will treat the combined information in accordance with the practices described under this Privacy Policy. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
We use your information for our legitimate interests, including:
To manage our Service, including your registration and account;
To provide the products and services you purchase, respond to your questions, and carry out the transactions you have requested;
To provide you with customer support;
To communicate with you regarding updates, technical notices, orders, security alerts, administrative messages, and information regarding changes to our policies;
To help authenticate any account you create with us;
To protect the rights or property of Vinkle, our users, or other third parties, and prevent fraud and other prohibited or illegal activities;
To protect the security of our products, services, and business;
To enhance and personalize our Service and our marketing efforts;
To develop and serve advertisements on our Service or through e-mails or other communications; and
For our internal purposes (such as auditing, data analysis, and research to improve and develop our products, services, content, advertising, and communications).
We also use your information with your consent, including:
To administer promotions you have entered;
To serve advertising tailored to your interests on our Service and third party services;
To send you newsletters and other promotional communications about our and third party products, offers, promotions, rewards, events, and services; and
Fulfill any other purpose disclosed to you and with your consent.
We share your information as follows:
Our Service Providers
We engage third party companies and individuals to perform services on our behalf (e.g., software maintenance services, advertising serving technologies, e-mail service providers, delivery services, database management, web analytics, payment processing and other services). These third parties have access to your information so that they may perform these tasks on our behalf and they are prohibited by us from using or disclosing your information for any purpose other than to provide this assistance, except to the extent required by law. We may permit our service providers to use aggregate information which does not identify you or de-identified data for other purposes.
Affiliates
We share your information with our affiliates for internal business purposes, including for customer support, marketing, and technical operations.
Clients
We share your information with our clients in connection with us processing your information on their behalf. For example, if you subscribe to our newsletters and promotional communications, Vinkle Apps may send you content on behalf of our clients and share your personal data with our clients for their own marketing purposes.
Business Partners
We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. In addition, if you choose to participate in certain of our programs or to receive certain content we make available (e.g., webinar programs), we may share your information with participating sponsors, content providers, and related vendors in connection with such programs and content.
Third Parties
In order to provide services to you, we may integrate third-party SDK, for example, we use a third party MobTech SDK service to provide you with [Share] functions.
In order to successfully implement this function, you need to authorize MobTech SDK to provide the corresponding service; after you authorize it, MobTech will collect your relevant personal information.
For more information about the types and uses of information collected by MobTech, the rules for the protection of personal information and the exit mechanism, please see the Privacy Policy (www.mob.com/about/policy) clause on the official website of MobTech (www.mob.com).
We may share your information with third parties for purposes of facilitating your requests and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
Compliance with Laws, Legal Process and Authorities
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We must disclose your information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. We may also disclose information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
Business Transfers
Circumstances may arise where, whether for strategic or other business reasons, we may sell, transfer or otherwise disclose some or all of our assets, including your information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. It’s Vinkle’s practice to seek appropriate protection for information in these types of transactions.
Consent and Disclosure
We may share your information for purposes disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
Blogs, Social Media and other Public Forums
We may offer blogs, social media profiles, message boards, bulletin boards or similar public forums where you and other users of our Service can post content or otherwise communicate. If you post information on a public forum, we will assume you intend to make that information public. We may use your name to identify you with a posting in a public forum and may use your post on or in connection with our Service (e.g., when using a hashtag associated with Vinkle Apps in a tweet or status update). Any information you share in a public forum is public information and may be seen or collected by other persons, including third parties that do not adhere to the standards set forth in this Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our online services.
To the extent you interact with social networks or other third party services through the Service (such as “liking” or “sharing” our content or otherwise connecting our Service to a third party service), understand that information collected and stored by third parties through your interaction remains subject to their policies and practices, including whether they continue to share the information with us, the types of information shared, and your choices on what is visible to others. We are not responsible for and make no representations regarding the policies or business practices of any third parties or third party services and encourage you to familiarize yourself with and consult their privacy policies and terms of use.
Third Party Analytics and Advertising Technology
Our Service contains tracking technologies owned and operated by third parties. For example, we use tracking technologies from traffic measurement services, such as Google Analytics, to analyze traffic and for analytics purposes.
We also work with third party ad network providers, advertisers, and other services to serve advertisements on the Service and/or third party services. These third parties may set and access cookies and other technologies on your personal computer and/or device and track certain behavioral information regarding users of your personal computer and/or device. These third party cookies and other technologies are set to, among other things: (a) track your activities across time and services for purposes of associating different devices you use, and delivering relevant ads and/or other content to you on the Service and third party services after you have left the Service (“Interest-based Advertising”); (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. Note that any images (or any other parts of a web page) served by third parties in association with third party cookies may serve as web beacons, which enable third parties to carry out the previously described activities.
For further information on your choices regarding these third party tracking technologies, please see the sections entitled “Information We Automatically Collect” above and “Your Rights and Choices” below.
Third Party Products and Services
Our Service contains links to, or content from, third party websites and other products and services. The fact that we link to a website or display an advertisement or other third party content is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices.
We do not exercise control over third party websites, products or services, and whether they store information in the U.S. or elsewhere. These other products and services may place their own cookies or other technologies on your computer or other device, collect data, or solicit information from you. Other persons and entities follow different rules regarding the use or disclosure of the information you submit to them or they collect from you. We encourage you to learn about the privacy practices of those third parties.
Review and Update of Account Information
You may access information that you have voluntarily provided to Vinkle through your account on the Service, and to review, correct, or delete it by following the instructions on the Service, or contacting us in writing as set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note we will retain and use your data, including server/backup copies, to comply with our legal obligations, resolve disputes, and enforce our agreements, and we may decline to process change or deletion requests that require disproportionate technical effort or jeopardize the privacy of others.
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. You can stop all collection of information via our mobile applications by uninstalling them. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. Please be aware that if you disable or remove these technologies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.
Analytics and Advertising Tracking Technologies
You may exercise choices regarding the use of cookies from Google Analytics by downloading the Google Analytics Opt-out Browser Add-on.
Some of the advertisers and service providers that perform advertising-related services for us and our partners participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, information on the DAA’s opt-out program for mobile applications. Some of these companies are also members of the Network Advertising Initiative (“NAI”). Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Vinkle is not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Communications
If you decide at any time that you no longer wish to receive newsletters or promotional communications from us, please follow any unsubscribe instructions provided in our communications to you, update your user preferences via our subscription management tools on our Service (which are available here), or contact us as set forth in the section below entitled “Contact Us” and specify your request. Please note that you cannot opt out of non-promotional e-mails, and we may use your information to contact you with important notifications, such as notices with respect to purchases, safety, or changes to our terms, conditions, and policies. Also your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Further, if we are processing your information on behalf of one of our clients, we will refer you to that client, and will support them to the extent required by applicable law in responding to your request. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
Your HongKong Rights
HongKong’s law permits customers in Hongkong to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide Hongkong customers certain information upon request or permit Hongkong customers to opt-in to, or opt-out of, this type of sharing.
Vinkle Apps may share personal information as defined by Hongkong’s law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a Hongkong resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “Hongkong Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided e-mail address or mail address.
Your European Privacy Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Further, if we are processing your information on behalf of one of our clients, we will refer you to that client, and will support them to the extent required by applicable law in responding to your request. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with a HongKong supervisory authority.
We employ appropriate security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These security measures include reasonable administrative, technical, and physical precautions to help safeguard your information against loss, theft, and misuse. Vinkle has also implemented technology, management processes and policies to help maintain data accuracy. Please be advised, however, that while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your information.
We do not knowingly collect personal information as defined by the HongKong Children’s Privacy Protection Act (“COPPA”) from children under 13 via our Service, and do not target our Service to children under 13. We encourage parents and guardians to take an active role in their children’s online activities and interests. If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please contact us and we will remove such information to the extent required by COPPA.
This Privacy Policy may be updated from time to time. If we make changes, we will revise this Privacy Policy to reflect such changes and revise the effective date included at the beginning of this policy. We may provide you additional notice (such as to your e-mail address) if the changes are material. Your use of the Service following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy.
If you have any questions about this Privacy Policy, including our compliance with applicable law, please feel free to contact Vinkle directly by e-mail at DupaGlobal@gmail.com.