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********Privacy Policy********
This Privacy Policy describes HeYa’s practices for collecting, using, disclosing, maintaining and protecting your personal information on the media platforms we operate, including the HeYa app on the iOS or Android platforms (the “App”), our Website, or any other platform on which you see this Privacy Policy (collectively, the “Services”). We will refer to our users as “you” in this Privacy Policy. This Privacy Policy is incorporated into, and part of, the Terms of Use (the “Terms of Use”), which governs your use of our Services.
Please read this notice carefully to understand our policies and practices for processing and storing your personal information. By accessing and utilizing our Services, you accept and consent to the practices described in this Privacy Policy. This Privacy Policy may change from time to time (see Changes to our Privacy Policy). Your continued access and/or use of our Services after any such revisions indicates that you accept and consent to them. Please check periodically for updates.
1. Who We Are
We are HeYa Limited (“HeYa,” “we,” “our,” “us”).
Third-Party Links
The platforms on which our Services run may include links to third-party services, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every other website or app you visit.
2. The Data We Collect About You
We collect several different types of personal information from you depending on how you interact with our Services. Personal information means any information about an individual from which that person can be identified. It does not include information where the identity has been removed or is not able to be associated with an individual.
We may process the following types of personal data about you, which we have grouped together as follows:
Identifiers：
This may include your name (first and last), a username (or similar identifier), data of birth, gender, and profile photo if you upload it.
Contact Information：
This may include your email address, mailing address, telephone number.
Marketing and Communications Information：
This may include your communications preferences in receiving marketing from us and/or third parties.
3. How We Collect Your Personal Information
We collect information about you in many different ways. Most of the time we collect through your direct interactions with our Services, but we may also automatically collect personal information from your devices, and occasionally from third parties or publicly available sources.
We collect information about you in the following ways:
Direct Interactions. When you interact with our Services, you may provide us your personal information by filling in forms, communicating with us by email, telephone, text/SMS, post, or otherwise. This may include personal information you provide when you:
· Subscribe for our Services/Register for an Account;
· Request that the App be texted to you;
· Request marketing be sent to you;
· Provide us feedback, requests support, or otherwise communicate with Us.
4. How We Use Your Personal information
We will only use your personal information when allowed by law. Generally, we will use your personal information: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and (c) where we need to comply with a legal or regulatory obligation.
5. Disclosures Of Your Personal information
From time to time, we may need to share your personal information with others, including in the following circumstances.
Protection of HeYa and Others. We may share personal information when we believe it is appropriate to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of HeYa, our products and services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.
6. Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU Data Subjects Legal Rights”). In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. International Data Transfers
HeYa has its headquarters in Hongkong. Information we collect from you will be processed in Hongkong. Where we transfer EU data subject’s personal information to third parties outside of the European Economic Area (EEA), we rely on appropriate suitable safeguards or specific derogations recognized under data protections law, including the GDPR. The European Commission has adopted standard data protection clauses, which provide safeguards for Personal information transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal information from a country in the EEA to a country outside the EEA.
9. EU Data Subjects Privacy Rights
EU data subjects have certain rights with respect to your personal information that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
· Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal information. You can often go directly into the Service under Account Settings to take these actions. Please note that even if you request for your personal information to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us); exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our Service. Data retained for these purposes will be handled as described in Section 9 “Data Retention”, above.
· Objection. You may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Portability. You have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw Consent. If we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
· File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information.
10. Children’s Privacy
We are committed to complying with the laws protecting the privacy of children, including the United States’ Children’s Online Privacy Protection Act (COPPA). Our Services are not directed to children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If we receive personal information that we discover was provided by a child under the age of 18, we will promptly destroy such information.
11. Changes to our Privacy Policy
By using this website, you agree to the terms and conditions contained in this Privacy Policy and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this website. You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California. You also agree to arbitrate such disputes in California, and to abide by any limitation on damages contained in any agreement we may have with you.
This Policy is expected to change from time to time. We reserve the right to amend this Privacy Policy at any time and provide notice to you by posting of the amended Privacy Policy on the website. We may also email you to give you notice of material changes to this Privacy Policy. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of this Services.
12. How to Contact Us
If you have any questions or wish to register a complaint in relation to this Privacy Policy or the manner in which your personal information is used by us, please contact us: [email protected]

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