1.This is the Privacy Policy for SoulLinker App (“SoulLinker,” “we,” “Service,” or “our”) and is incorporated into and subject to our Terms of Service, which can be found here. In this Privacy Policy, we refer to our products and services as the “Services.” Please continue reading to learn more about our data handling practices. We respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or limit our use of your personal data; in plain language that keeps legal and technical jargon to a minimum. Your privacy is at the core of how we design and build the Services and products you know and love, so that you can fully trust them and focus on building meaningful connections. Unless we link to a different policy or indicate otherwise, this Privacy Policy applies when you access or use the Services. Your use of the Services signifies your agreement to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services.
2. What data do we collect
This Privacy Policy applies to the websites, applications, and other services we operate. We process personal data that you provide to us as a user of our products, such as through the use of our products, and personal data that users provide to us ("Data"). We cannot help you build meaningful connections without some Data about you, such as basic profile details and the types of people you want to meet. We will also ask you to grant some in-app permissions to access and enable certain features you may want to use, such as photos, videos, gallery, and audio. These are permissions that require your consent and are always reversible. We also collect information generated when you use our Services, such as access logs, and information from third parties, such as when you access our Services through a social media account. We also automatically collect some Data, such as information about your device and which parts of our Services you interact with or spend time using them. To complete a commercial transaction on the SoulLinker Merchandise Store, you will be asked to provide your payment information, including your credit card number, card expiration date, CVV code, and billing address. SoulLinker will collect such information to process and complete your purchase. SoulLinker does not process or store your payment information. However, we may store other information about your purchases on the Services, which may include the name of the merchant, the date, time, and amount of the transaction, and other behavioral information.
2.2 Non-personally identifiable information
SoulLinker may also collect and aggregate non-personally identifiable information, such as certain profile information, including country of residence and preferences. In addition, SoulLinker may collect and store information about you and others’ use and interaction with our Services and our Website, including matches, member matches, call duration, device and connection information, IP addresses, device capabilities, bandwidth, page view statistics, network type, and traffic to and from our Website.
2.3 User Generated Content
SoulLinker allows you to share text messages, photos, screenshots, videos, and other communications with other users in the SoulLinker application, and if you choose to do so, your text messages, photos, screenshots, videos, and other communications will be stored on our servers. In addition, if you choose to share these items with other SoulLinker users, we may not be able to remove them from our servers or make them unavailable to anyone you share them with. Sending and sharing text messages, photos, screenshots, videos, or other communications in the SoulLinker application is your decision. By choosing to share that information, you should understand that you may no longer be able to control how that information is used and that it may become public (depending in part on your actions or the actions of others with whom you share the information). SoulLinker is not responsible for any use or misuse of the information you share.
SoulLinker may also collect User Content (such as photos, screenshots, comments, and other materials) that you create on the Service. Your photos may be taken by other users on SoulLinker, and if they use the capture function provided by SoulLinker, these photos may be stored and used by SoulLinker and third-party services (such as Google, etc.). If you do not agree to all the terms of this Privacy Policy, please do not use the Service.
2.4 System permissions we use
In order to provide you with SoulLinker's products and/or services, we may need to use the system permissions in your device (excluding permissions called by connected third parties) to collect relevant personal information. You can choose whether to authorize us to use the relevant permissions of your device. If you do not authorize us to use the relevant permissions, some services may be unavailable, but it will not affect your use of our other functions.
Photo album and storage permissions : When you agree to enable this permission, we will use the photo album reading and storage function on your device. This function will be used to upload text, images, videos and other content in your device, and can also cache text, images, and video content generated during your use. Please be aware that we will not automatically read the storage content of your local photo album. We will only obtain image/video data after you agree to enable this permission and actively select the corresponding image in the photo album. If you refuse this authorization, the aforementioned functions will not work properly.
Microphone permission : When you agree to enable this permission, we will use the microphone function on your device and recognize the voice information you upload. This permission will be used to implement the voice input function and collect and recognize the voice information input during the implementation of the above function. If you refuse this authorization, the above functions will not be available.
Message push permission : When you agree to enable this permission, we will push messages to you so that you can receive and understand the notifications we send you in a timely manner. If you refuse this authorization, you will not be able to receive the messages we push to you.
Camera permission : When you agree to enable this permission, we will use the camera function on your device. This function will be used to realize the photo shooting and video recording functions, and collect and identify the pictures and video information taken or recorded during the implementation of the above functions. If you refuse this authorization, the above functions will not be available.
Display top permission : In order to put the "Voice Chat Room " on top of other content, we will apply for your display top permission. If you refuse such authorization, the above function will not be available.
Device information access permission : When you agree to enable this permission, in order to protect your account and login security, we will collect your corresponding device information for optimizing user experience, security checks, identifying whether it is a commonly used device, and device binding status. If you are an Android user, your refusal to grant this authorization will result in your inability to use this product and/or service normally. If you are an iOS user, you may not be able to directly refuse or close the above authorization due to the restrictions of the iOS system, but for some device information (for example, IDFA information, which is subject to the actual situation updated from time to time by the iOS system policy), you can choose whether to authorize us to collect it. If you refuse to authorize, we may not be able to provide you with the corresponding functions or services (for example, if you refuse us to collect your IDFA information, we will not be able to provide you with personalized display based on the IDFA tracking identifier).
Access the network and obtain network status permissions : Our APP can only connect to the Internet after you agree to enable this permission. At the same time, for the purpose of risk control and providing services, we can also monitor network changes and remind users of the current network environment. If you refuse this authorization, you will not be able to use this product and/or service normally.
2.5 Error Report Information
If the Service crashes or hangs, we also collect error report information so that we can investigate the error and improve the stability of future versions of the Service. Generally, these reports do not contain personally identifiable information, or only occasionally do. As part of these error reports, we receive information about your device type and version, device identifiers, when the error occurred, the features you were using, and the state of the application when the error occurred. We do not use this information for any purpose other than investigating and fixing the error.
2.6 Information from social networking sites
If you choose to link your social network or public forum account to the Platform, you will provide or allow your social network to provide us with information from your social network or public forum account, including your contact list. This data will include information about your use of the Platform on these public forums and/or social networks. For more information on how and for what purposes social network providers process your data, please refer to their privacy policies.
2.7 Technical Information
Technical Information We Collect About You. When you use the Platform, we automatically collect certain information about you, including your IP address, location-related data (as described below) or other unique device identifiers, your browsing history (including the content you view on the Platform), cookies (as defined below), your mobile carrier, time zone setting, mobile or device information, including device model and screen resolution, operating system and platform, and information about your Platform.
2.8 Information about your behavior
We collect information about your behavior: We also collect information about your use of the Services, such as your comments on our Platform or any other user-generated content and video content you generate and broadcast through our Platform. We collect user engagement scores (“likes, comments, repeats”) and connect with users based on your behavior. Finally, we collect opt-in and communication preferences.
2.9 Information from third parties
If you use any other website we operate or other services we provide, we will receive information about you from third parties. We will also receive information from third parties, such as advertising networks and analytics providers, and from other sources, including trade directories and other commercial or public sources.
2.10 Metadata
When you upload a video to the Platform ("User Content"), some metadata associated with the User Content is automatically uploaded. Essentially, metadata describes other data and provides information about the User Content that is not always perceptible to viewers. The metadata associated with your video can describe how, when, and by whom the User Content was collected, as well as how it is formatted. It also includes information such as your account name so that other users can track your user account from a video. Metadata also includes other data you choose to provide with your video, such as any hash tags used to tag the video or comment keywords.
2.11 Purchase of Tokens
You can choose to purchase coins through in-app purchases. You can use these coins to purchase virtual gifts and send them to other users on your stream or channel. When you choose to purchase coins, you will be transferred to the app store on your mobile device to complete the purchase. We will collect your personal information about this purchase.
3. How we use your information
We will use the information we collect about you in the following ways:
To administer the Platform (i.e. to provide services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to ensure the stability and security of the Platform), and to solicit your feedback;
To allow you to participate, when you choose to participate in interactive features of the Platform;
Personalize the content you receive and provide you with content tailored to your interests;
Improve and develop the platform for product development;
measure and understand the effectiveness of our advertising to you and others;
Provide you with services based on the country settings you have selected, such as advertising and other country-related content;
Make suggestions and recommendations to you and other users of the Platform about goods or services that may be of interest to you or them;
To provide you with your profile information for sending to anyone you choose and to enable you to participate on the Platform and interact with other users;
Provide your information to other users in accordance with the information privacy settings you choose;
Show you content that you like or interact with (by following and/or viewing content), content in your region, and content from users you follow;
Show you advertising that is relevant to you;
To promote the services and usage information you provide to us, such as User Content and Video Content, which you may choose to broadcast on our Platform as part of our advertising and marketing activities to promote the Platform;
To ensure that the communication service can function properly (although this information will only be processed if you choose to use this feature), you can choose to delete any information at your discretion through the clear cache function in the platform settings to help us detect abuse, fraud and illegal activities on the platform;
Make sure you are large enough to use our services (legal requirement).
To notify you about changes to our services;
Communicate with you.
To provide you with user support;
To enforce our terms, conditions and policies;
You will be paid and/or compensated in accordance with the Diamonds and Fire terms set forth in the Virtual Goods Policy Supplement, or in accordance with the User Terms or a separate Premium Content Creator Agreement, as applicable.
4.Third-party SDKs we use
4.1 SDK: RongCloud
Manufacturer: RongCloud
Purpose of use: To provide real-time messaging functions and services
Information collected: device brand, device model, ANDROID_ID, operating system version, CPU information, memory usage, IP address, network access method and type, user ID under App Key, application package name, time zone, language, App version number, App Key of App, user token, RongCloud SDK version number, operator code MNO, interface call error code, link failure error code
Privacy Policy: https://doc.rongcloud.cn/rcloud/-/-/privacy#%E4%B8%80-imlib-sdk
4.2 SDK: Agora
Manufacturer: Agora
Purpose of use: Voice calls
Information collected: network type, user's local IP address, WLAN and cellular network signal status, operating system, device model, CPU, memory, device power, audio stream data, Bluetooth, network latency, packet loss rate, bit rate, resolution, audio bit rate, sampling rate
Privacy Policy: https://www.shengwang.cn/SDK-privacy-policy/
4.3 SDK: Facebook
Manufacturer: Meta
Purpose: Facebook event manager
Information collected: Please refer to https://www.facebook.com/privacy/policy/?section_id=1-WhatInformationDoWe
Privacy Policy: https://www.facebook.com/privacy/policy/?section_id=0-WhatIsThePrivacy
4.4 SDK: google
Manufacturer: google
Purpose of use: Login
Information collected: OpenID
Privacy Policy: https://policies.google.com/privacy
4.5 SDK: adjust
Manufacturer: Adjust
Purpose of use: Installation data attribution analysis
Information collected: app activity, device or other identifiers
Privacy Policy: https://help.adjust.com/en/article/google-play-data-safety#data-collection-by-adjusts-sdk
We try our best to provide security measures for users' personal information to prevent illegal use, unauthorized access, disclosure, leakage, damage and loss of users' personal information. We will use all possible security measures within a reasonable security level to ensure information security. For example, we will use encryption technology (such as SSL), anonymization, encrypted storage and other means to protect your personal information; we will establish a reliable protection mechanism to prevent personal information from malicious attacks; we will establish an access control mechanism and abide by the principle of minimum access to ensure that only authorized personnel can access personal information; we will conduct training courses on security and personal information protection to enhance employees' understanding of personal information protection. If you find that your personal information, especially your account or password, has been leaked, please contact us immediately so that we can take appropriate measures according to your application.
Please note that when you use our services, you voluntarily share or even disclose your information, which may involve your personal information or the personal information of others. Please carefully consider whether to share or even disclose such information when using our services.
You are responsible for maintaining the confidentiality of your password and account information at all times.
5. Who we share your information with
5.1 Third-party service providers
We share your data with third-party service providers that we rely on to help you provide the Platform. These providers include cloud storage providers and other IT service providers.
5.2 Business partners, advertisers, analytics and search engine providers
We also share your information with our business partners, advertisers, and analytics and search engine providers.
5.3 Law enforcement and public authorities
We may also share your information with law enforcement, public authorities or government agencies as required by law.
5.4 When a business transaction occurs
if we sell or buy any business or assets, in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
If we sell, buy, merge, are acquired by or partner with another company or entity, or sell some or all of our assets, user information would be among the transferred assets in such transactions.
6. Your rights
6.1 Accessing and Updating Information
If you have registered an account, you can access and update some of the personal information you have provided to us by logging into your online account and using the functions and features provided there.
6.2 Opting out of marketing or advertising emails
You may opt-out of marketing or advertising emails from us by using the unsubscribe link or mechanism stated in the marketing or advertising emails you receive from us.
6.3 Right to be informed
You have the right to know if your personal data has been sold or shared by SoulLinker. We will provide this information upon request. You can exercise this right by contacting us at liu358437@gmail.com.
6.4 Opting out of data sales and sharing
You can opt out of the sale or sharing of your personal data. To exercise this right, you may contact us at liu358437@gmail.com. We will take the necessary steps to ensure that your request is fulfilled.
6.5 CCPA and VCDPA Rights
For users in California, you have additional rights with respect to your personal data under the California Consumer Privacy Act (CCPA). These rights include requesting deletion of your personal data, knowing what personal data is being collected about you, and opting out of the sale of your personal data. We will honor these rights upon request.
For users in Virginia, you have similar rights under the Virginia Consumer Data Protection Act (VCDPA). We will honor and respect those rights, too. You may exercise any of these rights related to the CCPA or VCDPA by contacting us at liu358437@gmail.com.
7. How long do we retain your information
We retain your information as long as necessary to (1) fulfill our contractual obligations and rights with respect to the relevant information, (2) our legal obligations under applicable laws and regulations to retain data for a certain period of time, taking into account the time limits imposed by applicable laws; (3) our legitimate business purposes; and (4) respond to disputes or potential disputes.
After you terminate our service, we may store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we may also retain any personal information that is reasonably necessary to comply with our legal obligations, to enable us to resolve and litigate disputes and to enforce our agreements.
8. Notification of Changes
We will usually notify all users of any significant changes to this Policy by means of a platform notification. However, you should check this Policy regularly to see if there are any changes. We will also update the "Last Updated" date at the top of this Policy, which reflects the effective date of this Policy. If you continue to access or use the Service after the renewal date of this Policy, you accept the renewed policy. If you do not agree to the updated policy, you must stop accessing or using the Service.
If the provisions of the Supplemental Terms (Specific Jurisdiction related to the jurisdiction where you access or use the Services) conflict with the provisions of other parts of this Policy, the Supplemental Terms (Specific Jurisdiction) for the relevant jurisdiction will prevail.
9. Information Security
We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, for example through encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.
We implement appropriate technical and organizational measures to ensure a level of security commensurate with the potential and severity of the risk to your and other users' rights and freedoms. We maintain these technical and organizational measures and revise them from time to time to improve the overall security of our systems.
From time to time we may add links to our partner networks, advertisers and affiliate sites. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before submitting any information to these sites.
10. Information about children
The Platform is not intended for children under the age of 18. If we discover that someone has collected personal information from a person under the age of 18, we will delete that information and terminate that person's account. If you believe that we have collected information from a child under the age of 18, please contact us through online feedback.
11. Information about the Data Controller and DPO
11.1 Data Controller
The data controller of SoulLinker is SoulLinker itself, and the contact information of the data controller is liu358437@gmail.com. SoulLinker is an online communication platform that enables users to interact with each other, share various types of content, and participate in different activities, such as commercial transactions and virtual gift exchanges. It collects and processes user information to provide these services and improve user experience.
11.2 Data Protection Officer (DPO)
The contact information for SoulLinker's Data Protection Officer (DPO) is liu358437@gmail.com. The Data Protection Officer (DPO) is responsible for ensuring that SoulLinker complies with all relevant data protection laws and regulations. He is responsible for overseeing the processing of user data, monitoring the security of data storage and transmission, and ensuring that the user's rights regarding their personal data are respected. For any questions regarding data protection, you can contact the DPO at liu358437@gmail.com.
12. Data minimization and purpose limitation
We are committed to the principles of data minimization and purpose limitation. This means that we only collect data that is necessary for the specific purposes outlined in this Privacy Policy. We regularly review our data collection practices to ensure that we are not collecting any unnecessary information. If during the course of operations, we discover that certain data is no longer necessary for the intended purpose, we will take steps to delete or anonymize that data. For example, if a specific feature that once required certain user data is no longer used or has been updated to operate without that specific data, we will delete or anonymize the relevant user data associated with that feature.
13. User consent management
We keep detailed records of the consent you provide for data use. This includes not only your initial consent when you first register or start using our Services, but also your subsequent consent for new features or changes to data processing. You can review and update your consent preferences at any time through your account settings. We ensure that any new data processing activities are accompanied by clear notice of consent, and we record and store this information securely. If you withdraw your consent for a specific aspect of data processing, we will take appropriate measures to stop that specific processing activity while still ensuring that the overall functionality of the Service remains as intact as possible.
14. Data Transfers and International Considerations
As SoulLinker is a global platform, your data may be transferred across borders. When such transfers occur, we ensure that appropriate safeguards are in place to protect your data. We comply with relevant international data protection frameworks and regulations, such as applicable Standard Contractual Clauses (SCCs). In addition, we perform due diligence on recipients of your data in other countries to ensure that they have adequate data protection measures in place. For example, if we transfer data to a service provider in another country, we will verify that they have appropriate security systems, privacy policies, and compliance mechanisms in place to handle your data in a manner that respects your privacy rights.
15. Transparency of data processing
We strive to be as transparent as possible in all of our data processing activities. In addition to this detailed Privacy Policy, we may provide additional information on the App or Website to help you understand how your data is used. For example, we may detail specific features that collect certain types of data and how that data affects your overall experience. We also maintain an open channel of communication with our users about data processing. If you have any questions or concerns about how your data is processed, you can always contact us at liu358437@gmail.com and we will provide you with a clear and comprehensive response.
16. Data Breach Response Plan
We have developed a comprehensive response plan in the event of a data breach. The plan includes steps such as quickly assessing the scope and impact of the breach, notifying affected users and relevant authorities as required by law, and taking measures to contain and remediate the situation. Our response plan is reviewed and updated regularly to ensure that it is effective in dealing with different types of data breaches. We will also notify you of any data breach that may affect your personal information through our platform notifications or other communication channels, depending on the nature of the incident and the requirements of applicable law.
17. Use of Anonymous Data
We may use Anonymous Data for various purposes, such as research, analysis, and improving our services. Anonymous Data does not contain any personally identifiable information and cannot be used to identify you. This data helps us understand user behavior, preferences, and trends, allowing us to make more informed decisions about product development and improvements. We ensure that the anonymization process is done in a reliable and secure manner to maintain the integrity of the data and protect your privacy.
18. Marketing and Promotional Communications
You have the right to control the marketing and promotional communications you receive from SoulLinker. You can manage your communication preferences in your account settings. We will respect your choices and ensure that you only receive communications to which you consent. If you opt out of certain types of communications, we will not use your data for those purposes. In addition, we will clearly explain in our marketing materials how you can manage your preferences and unsubscribe from unwanted communications.
19. User-generated content review
We have systems in place to review user-generated content to ensure it complies with our Terms of Service and does not violate the privacy of other users. This includes reviewing photos, messages, and other content shared within SoulLinker. If we become aware of content that may pose a privacy risk or violate our policies, we will take appropriate action, such as removing the content and notifying the user who posted it. We also encourage users to report any inappropriate content they encounter, and we will promptly investigate and take action if necessary.
20. Third Party Advertisers and Analytics
We work with third-party advertisers and analytics providers to serve relevant ads and gain insights into user behavior. While these third parties may have access to certain non-personally identifiable information to target ads and perform analytics, we have strict protocols in place to ensure they do not misuse your data. We require them to comply with privacy laws and best practices. You can learn more about our advertising practices and your options for controlling ad-related data in your account settings. We also regularly review and audit these third-party relationships to ensure ongoing compliance with our privacy policy and relevant laws.
21. Data classification and processing
We classify data based on its sensitivity and importance. And apply different levels of security and handling procedures accordingly. For example, highly sensitive data such as account passwords and payment information are protected by additional encryption and access controls. Our employees and third-party partners are trained to handle different types of data appropriately based on their classification. We also maintain our data inventory list to ensure that we can easily identify and manage each type of data according to specific requirements.
22. User-driven privacy controls
We are continually exploring ways to give you more control over your privacy in SoulLinker. This may include features such as more granular consent options, the ability to limit data sharing on a per-feature basis, or enhanced privacy settings for specific types of user-generated content. We value your input in shaping these privacy enhancements. We also conduct user surveys and collect feedback to understand your privacy needs and expectations and use this information to improve our privacy products.