Privacy Policy

Last Modified: 25 December 2023

Your privacy is important to us. 

Xiamen Minger Technology Co. and its affiliates (“we”, “us” or “our”) are dedicated to protecting the privacy of our users (“users” or “you”). This Privacy Policy (this “Policy”) is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal information) as a controller and/or business under applicable data protection laws during your use of CharmChat application including all its features (our “Services”). 

Please note that the scope of this Policy is limited solely to your user information (including your personal information) collected or received by us when you are using our Services. In this Policy, “personal information” refers to any information or combination of information that can be used to identify, contact, or locate an individual to whom the collected information pertains.

BY USING OUR SERVICES, YOU ARE AGREEING TO THIS POLICY AND THE COLLECTION, USE, PROCESSING, RETENTION, DISCLOSURE AND SHARING OF YOUR USER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, IN THE MANNER PROVIDED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY OR ANY SUBSEQUENT CHANGES TO THIS POLICY, PLEASE DO NOT USE OUR SERVICES.

Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with our Services. Also, please note that, unless we define a term in this Policy, all capitalized terms used in this Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

If you have any questions regarding this Policy or any privacy-related matters, please contact our Data Protection Officer via email at support@91ttmj.com (please quote “CharmChat” in your email title). Please note that for all other enquiries, feedback, suggestions and/or complaints not related to privacy or intellectual property infringement (including but not limited to any cancellation of subscription, payment disputes, refund requests and technical support of CharmChat), you should contact us via email at support@91ttmj.com. If your email is sent to an incorrect email address, relating to an incorrect subject matter, it may lead to a potential delay or failure in processing your requests properly.

THE INFORMATION WE COLLECT

In order to provide and improve our Services, we will collect and process your personal information and user information in accordance with this Policy. If you do not provide this information, we may be unable to provide you with our products or Services. You should ensure that all personal information and user information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with all or some of our Services.

Anyone can access our Services, but there are certain services that require a subscription fee, such as accessing to our premium content and enjoying advertisement privileges (“Subscription Service”). If you choose to make a purchase on our Subscription Service, we will collect certain personally identifiable information, such as your device ID. A third-party app store or payment processor may receive, access or use your financial information and billing address for the purpose of processing transactions and renewals. If you purchase content or sign up for Subscription Services through a third-party app store or a payment processor, you should refer to that third party’s terms for information on how it maintains and uses personal financial information for all purchases. For the avoidance of doubt, we will not collect any financial information from you.

Mobile Device Information

When you use our Services on your mobile device, we will collect information about your device, including its International Mobile Equipment Identity (“IMEI”), Unique Device Identifier (“UDID”) or Android ID, Universally Unique Identifier (“GUUID”), Identifier for Advertising (“IDFA”) and Identifier for Vendor (“IDFV”), Integrated Circuit Card Identifier (“ICCID”), Media Access Control (“MAC”) address, the type of device you use, operating system version, a list of mobile applications installed on your device and resolution, which will be used by us for statistical and/or analytical reasons, including without limitation to improve our technical functionality, server load-balancing, analysis of technical data relating to your mobile device so as to optimize our Services and graphics adaptation.

As stated below in the “Location Information” section, we may collect your location-based information from your mobile device if you choose to share it with us. If you subsequently wish to stop sharing Location Information, you may do so at any time by editing the relevant setting on your mobile device.

Mobile Analytics

We use mobile analytics software to allow us to better understand and improve the functionality of our Services. Such software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. 

Network Information

When you use our Services, we will collect information about the network you use, including the name of the operator and the type of network, so as to understand the distribution of operators and networks used by our users. In addition, we will collect information such as the name of the WiFi network to which you connect, the location of the WiFi network, and the duration of your WiFi connection to understand the environment under which you prefer to use our Services.

Location Information

We may collect your location-based information from your mobile device if you choose to share it with us. 

• Mandatory: network information, IP address, and system time zone
• Optional: country code, latitude and longitude, network location, and system country. 

This information will help us understand user distribution and usage scenarios and allow us to provide users with the correct version of our apps, or the reappearance of the geo-location, and improve our Services. Unless we obtain your consent, location data WILL NOT BE ACQUIRED or USED to identify you individually. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device. Please note that we may still continue to receive some Location Information, such as your Network Information, IP address and system time zone, as a result of you using our Services.

Log Information

When you use some of our Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in CharmChat (“Log Information”). Log Information may include (i) details on when and how often you use our Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve our Services and is NOT USED to identify our users individually.

Voice Information

By enabling the microphone on CharmChat, you agree that we may collect your voice data (i.e. audio clips or recordings of your voice). We will not use your voice information for advertising purposes. You can turn off CharmChat’s access to your microphone on your device at any time using the operating system settings on the device or by muting the microphone on your devices.

Facial Feature Information

In order to provide certain Services, we may collect your facial feature information (including but not limited to facial images) and use face recognition technology to recognize faces in camera experiences. We may detect and use facial marks to provide face recognition contents and facial manipulation features. The information we collect cannot be used for identifying a specific person, and is used to provide the mentioned features only. When the content recommendation is finished or upon the closing of the application, the facial mapping information is discarded. This information is not shared with any third parties. 

We will neither use the results for other purposes, nor capture any data in the file nor upload data to the server for recording purposes.

Cookies 

We use “cookies” that store and retrieve information of user’s usage from time to time provide customized Services for each user. Cookies are small amounts of information that the server uses to operate the app/website, sends to the user’s device and are also stored on the hard disk in the user’s device. You may refuse the installation of cookies. Information collected may include information about your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating system, dates and timestamps, and clickstream data.

• Purpose of use of cookies: Cookies are used to provide information optimized for each user by identifying the visit to and use type of each service and website that the user has visited, popular search terms, secure access status, etc.
• Installation, operation and refusal of cookies: A user may refuse the installation of cookies by sending an email tosupport@91ttmj.com (please quote “CharmChat” in your email title).
• If a user refuses to store cookies, he or she may experience difficulties in using customized Services.

Advertising-Related Information

We and our third-party service providers may include advertisements within our Services, and with your consent, we may collect and use information about you such as your Advertising ID, geographic location and IP address for the purpose of delivering and tracking these advertisements. If your device does not have Advertising ID, we may use other persistent identifiers. We may also access your App list and collect the application package names of the applications installed on your device. We use the above information to help us better count, track and provide advertisements based on suitability, language, geographic location and other details. If you wish to opt out of interest-based advertising, you may opt out by sending email to support@99ttmj.com. Please note you will continue to receive generic ads after you opt out of interest-based advertising.

Information Collected by Third Party Services

Our Services provided to you may contain our service provider’s Application Programming Interfaces (APIs) or Software Development Kits (SDKs), which may have tracking tools of such service providers. These third parties may use cookies, APIs and SDKs on our Services and collect and analyze user information. In addition, some third-party SDKs may allow advertisers to collect information in order to provide content that is more relevant to you. Third parties may access your information such as your device identifiers, region (defined as the location where a given language is used), location information and IP address under their respective privacy policies. If you want to know more about such third parties, you may send an email to support@91ttmj.com (please quote “CharmChat” in your email title).

Information that You Proactively Provide to Us

When you contact us (including but not limited to our customer support team and Data Protection Officer), we collect the data you provide to us, for example, your contact details (e.g. email address and/or telephone number).

Other Information

We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you.  

HOW WE USE INFORMATION

In addition to the uses listed above, we collect and use your user information and/or personal information for the following purposes: 

• Services. To provide, process, maintain, improve and develop our Services provided to you, including customer support, and other services provided through our products.
• Statistical analysis. To develop and analyze statistics on the use of our products and Services for the purpose of improving our products and our Services.
• To create an account. The personal information that we collect when you use our Services to create an account will be used by us to create your account and profile.
• To provide location-based services. When you use our Services, we or third-party service providers may take advantage of your location information to provide you with advertising, the correct version of our Services and help you gain good user experience.
• To improve user experience. Certain optional features such as user experience programs allow us to analyze data regarding the use of our products and our Services and improve user experience.
• To provide push services. Device information may be used by us to provide push services to assess the performance of adverts and the success of software updates, or provide notifications on new product releases.
• To verify your identity. Verifying your identity using a text message when you log in to your account helps prevent unauthorized logins to your account.
• To collect feedback from you. Your feedback is of great value in helping us to improve our Services. We may collect your email address to contact you and retain the records.
• Other purposes. We will collect, store, maintain and use information about you for purposes under the “The Information We Collect”, and for purposes of running our operations, pursuing our legitimate interests (e.g., research (including marketing research), network and information security, and fraud prevention), and satisfying our legal obligations.

INFORMATION SHARING AND DISCLOSURE 

We may share your information with third parties who provide services on our behalf to help with our business activities. These services may include:

• Providing you with advertising;
• Payment processing;
• Providing customer services;
• Fulfilling subscription services;
• Conducting research and analysis; and
• Providing cloud computing infrastructure.

We will not share with or disclose to third parties (other than our service providers) your personal information in whole or in part except for the purposes of:

• protecting the security of others or their property;
• preventing or dealing with fraud;
• safeguarding our legitimate rights and interests;
• taking action in line with our purposes as described in the “The Information We Collect” or the “How We Use Information” sections;
• complying with laws, rules and regulations or requests by government departments, judicial authorities, law enforcement, or private parties, which are typically designed to uphold Internet security and the rights, property and safety of us, our users and third parties; and/or
• evaluating or completing a transaction where we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or other event where your information may be sold or transferred.

BASES FOR USING YOUR INFORMATION

We will only collect and process personal information where we have lawful bases and we typically rely on one of the following four legal bases: 

• consent(where you have given consent);
• contract (where processing is necessary for the performance of a contract with you, for example, to operate the site or deliver any services you have requested);
• legitimate interests (for example we need to use your information to provide and improve our Services, including protecting your account, providing customer support). We rely on our legitimate interests as our lawful basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law); and
• legal obligations (to comply with the laws, rules and regulations or requests by government departments, judicial authorities or law enforcement).

If you have questions about the lawful bases on how we process your personal information, please contact us at support@91ttmj.com (please quote “CharmChat” in your email title).

THIRD PARTY WEBSITES AND SERVICES

Our Services may contain links to other websites and services. In addition, other websites and services may reference or link to our Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about third party websites or services. We encourage our users to read the privacy policies of each and every website and service with which they interact. Visiting these other websites or services is at your own risk. 

INFORMATION SECURITY

We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal information. However, you understand and accept that (in the Internet industry) even though we take reasonable security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. Further, you understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.

INFORMATION ACCESS AND CONTROL

We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal information or other personal information provided to us by you when using our Services. Before you access, update, correct or remove such personal information, we may verify your identity in order to protect the security of your account.

DATA RETENTION

Subject to applicable laws, rules and regulations and the fulfillment of our business or legal purposes, we will delete your information (including your personal information) promptly upon your deletion of CharmChat.

PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (“right to data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

If you wish to exercise your rights, you may send an email to support@91ttmj.com (please quote “CharmChat” in your email title). We will process your request in line with applicable laws within a reasonable period of time after receiving your email or mail, and will cease collecting, using and disclosing your personal information thereafter, subject to certain exceptions prescribed by law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you withdraw your consent or delete your personal information, your use of some of our Services may be affected.

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act. 

INFORMATION ABOUT CHILDREN

We will not knowingly collect or request personal information from children under 16 (or any other age stipulated by law applicable to your region). If you are under such age, please do not send your personal information to us, including but not limited to your name, address, phone number or email address. If you believe we may have any information about children under 16 (or any other age stipulated by law applicable to your region), you may send an email to support@91ttmj.com (please quote “CharmChat” in your email title). If we learn that we have collected personal information from children under 16 (or any other age stipulated by law applicable to your region), we will promptly take steps to delete such information and terminate the associated account. 

CROSS-BORDER DATA TRANSFERS

You understand and agree that all information collected via or by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the People’s Republic of China, the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), Japan, South Korea, Singapore, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide our Services.

GOVERNING LAW

This Policy is established, comes into force, and will be enforced and interpreted under the laws of Hong Kong, without regard to its conflict of law provisions. Any disputes arising hereunder will also be resolved in accordance with the Terms of Service. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.

AMENDMENTS TO THIS POLICY

You agree that we may update this Policy according to relevant laws and regulations or based on our business decisions, and you agree to be bound by any such revisions hereto. We will post any significant changes to this Policy on CharmChat or notify you by other means as required by law.

FOR USERS IN JAPAN

Right to data disclosure, correction, erasure or suspension of use 

If you are in Japan, as a data subject, you have the right to request the disclosure, correction, erasure or suspension of use of your personal information, and we are obliged to meet your request without undue delay. You may send your request by email to support@91ttmj.com (please quote “CharmChat” in your email title).

FOR USERS IN THE UNITED STATES OF AMERICA

You agree that CharmChat and the Companies may use facial recognition technology to collect biometric information when you use CharmChat. CharmChat and the Companies may use such information to verify your identity, to provide and improve the Service, and for our internal research purposes. If your biometric information is subject to the Illinois Biometric Information Privacy Act, we will delete your biometric information within three years of your last interaction with the Service.  

In accordance with applicable law, you may have the right to:

• confirm whether or not we are processing your personal information;
• obtain access to or a copy of your personal information with accompanying details;
• receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company i.e., right of data portability;
• correct your personal information;
• request to opt-out of certain processing activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in profiling in furtherance of certain decisions that produce legal or similarly significant effects concerning you;
• request erasure of personal information held about you by us; and
• appeal our decision to decline to process your request.

If you would like to exercise any of your rights under the applicable privacy laws, please contact our Data Protection Officer via email at support@91ttmj.com (please quote “CharmChat” in your email title). We will process such requests in accordance with applicable laws.

If you are a Virginia resident and would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

The following paragraphs only apply to our processing of your personal information that is subject to the California Consumer Privacy Act (as amended from time to time) (“CCPA”).

The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected	Category of Third Parties to Whom Personal Information is Disclosed to for a Business Purpose
Identifiers	· Service Providers · Our Affiliates
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	· N/A
Protected classification characteristics under California or federal law	· N/A
Commercial information	· Service Providers · Our Affiliates
Biometric information	· Service Providers · Our Affiliates
Internet or other electronic network activity	· Service Providers · Our Affiliates
Geolocation data	· Service Providers · Our Affiliates
Sensory data	· Service Providers · Our Affiliates
Professional or employment-related information	N/A
Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99))	N/A
Inferences drawn from other personal information to create a profile about a consumer	· N/A
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number	N/A
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	· N/A
Personal information that reveals a consumer’s precise geolocation	· Service Providers · Our Affiliates
Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership	· N/A
Personal information that reveals the contents of a consumer’s mail, email, and text messages unless Figma is the intended recipient of the communication	N/A
Personal information that reveals consumer’s genetic data	N/A
Biometric information that is processed for the purpose of uniquely identifying a consumer	N/A
Personal information collected and analyzed concerning a consumer’s health	N/A
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation	N/A

The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing Personal Information are set forth in “The Information We Collect”, “How We Use Information”, and “Information Sharing and Disclosure” above, respectively. We will retain personal information in accordance with the time periods set forth in “Data Retention” above.

In the preceding twelve months, we have not “sold” any personal information (as defined by the CCPA), nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

In the preceding twelve months, we have not “shared” any personal information for “cross-context behavioral advertising” (as such terms are defined in the CCPA), nor do we have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising”

We only use and disclose sensitive personal information for the following purposes:

• To provide the Services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of our products, Services, or devices, and to improve, upgrade, or enhance our Services or devices.
• For purposes that do not infer characteristics about individuals.

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide the email address or phone number we have associated with you and providing a verification code that is sent to your email address or phone number.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent and contact us using the information in “Privacy Rights” above for additional instructions.

We do not “sell” personal information or “share” personal information for “cross-context behavioral advertising” so we do not respond to opt-out preference signals.

If you are a Nevada resident, we do not “sell” your personal information.

FOR USERS IN BRAZIL

Legal basis for processing data

If you are in Brazil, the legal basis for processing your personal information that we may rely on are:

• consent(where you have given consent);
• contract (where processing is necessary for the performance of a contract with you, for example, to operate the site or deliver any services you have requested);
• legal obligations (to comply with the laws, rules and regulations or requests by government departments, judicial authorities or law enforcement); and
• to prevent fraud and for the purpose of protect credit.

If you have questions about the lawful bases on how we process your personal information, please contact us at support@91ttmj.com (please quote “CharmChat” in your email title). 

Right to data disclosure, correction, erasure or suspension of use, portability and to withdraw consent

If you are in Brazil, as a data subject, you have the right to request the disclosure, correction, erasure, suspension of use or portability of your personal data, as well as the rights to withdraw consent and to be informed about the potential negative consequences of such withdrawal, and to be informed about public and private entities with which we have shared your personal data, and we are obliged to meet your request without undue delay. You may send your request by email to support@91ttmj.com (please quote “CharmChat” in your email title).

Sensitive personal information

If you are in Brazil, you understand and agree that, in order to be able to render our Services to you, we may collect sensitive personal information, such as facial features of the characters when you use CharmChat.

Representative

If you are in Brazil, you can contact our Data Protection Officer via email at support@91ttmj.com (please quote “CharmChat” in your email title).

International Data Transfers

To provide our Services to you, we may collect your personal information from, transfer it to, and store and process it elsewhere.

• Personal information transferred: please refer to the section “The Information We Collect” of this Policy above
• Transfer date and method: transferred on submission for storage and processing
• Country to which personal information is transferred: the People’s Republic of China
• Retention of personal information: please refer to the section “Data Retention” of this Policy above

Whenever we share information outside of where you live, we ensure that the transfer complies with your local law so that your personal information is adequately protected.

Data Retention

Subject to applicable laws, rules and regulations and the fulfillment of our business or legal purposes, we will retain your information (including your personal information) for such period as is required for us to continue to provide you with our Services, as well as during the limitations statutes set forth in the Brazilian Civil Core, LGPD, Brazilian Civil Rights Framework for the Internet, and Brazilian Consumer Protection Code.

We will destroy your personal information without delay when your personal information becomes unnecessary. When we destroy your personal information, we will take commercially reasonable and technically feasible measures to ensure the personal information is permanently deleted.

After the termination of Services we may retain your personal information to comply with legal or regulatory obligations, transfer to third parties, provided that the requirements for data processing as provided in LGPD are obeyed, and for our exclusive use, provided the information will be anonymized.

Choice of law

If you are resident in Brazil, this Policy will be enforced and interpreted under the laws of Brazil.