Last updated: October 2023
This Palpi Privacy Policy explains how Palpi ("Palpi", "Company", "we", "our" or "us") process any personal data we collect from users of Palpi APP , services provided in relation to the applications and website (collectively, the "Palpi Services").
This Privacy Policy ("Policy" ) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit our Website, our App or otherwise use or access our Services.
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. By using the Services, including our Website or App, you signify your acceptance of this Policy. If you do not agree to the terms of this Policy, please do not use our Services. Your continued use of the Services following the posting of changes to this Policy will mean that you accept such changes.
We obtain information about you through the means discussed below when we provide the Palpi Services. Please note that we need certain types of information so that we can provide the Palpi Services to you.
We collect two types of data from you: personal information ( "Personal Information") and non-Personal Information. Personal Information means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Information, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (for example, the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you.
- Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier and language;
- Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;
- User-generated contents ("UGC"), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Palpi Services;
- Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Palpi Services, but such data will only be processed offline to fulfill the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party. In addition, if you utilize Real-Person Profile Picture Authentication, we collect your profile picture and facial-recognition video for Real-Person Profile Picture Authentication on the premise of your approval by comparing your profile picture with face-recognition video. This authentication can protect you from impersonators and fake accounts, or develop the authenticity of Palpi Services. We do not retain your face recognition video in our servers, such video is merely for verifying.
- Payment information, such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number or other payment information where required for payment;
- Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services;
- Information you provide from social media when you create a Palpi account by connecting with a third-party social media, such as Facebook, Google, or if you link a Palpi account with a third-party social media account;
- Governmental-issued ID. In certain instances, you may be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
- Device identifiers and device data. When you visit or access the Services, we also collect your IP address, UDID, your precise geolocation and other information transmitted by your device, including among other things the type of browser and operating system your device uses.
- Log-in history and usage information. In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device when you use the Services, including information related to your behavior and use of the Services.
- Location information. The Company collects information about your general location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located. In addition, the Company collects the precise location of your device (using GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals and cell tower ids that can be used to derive or estimate precise location, or other geo-location data), when location services have been enabled by the end user (you typically have to choose to turn on device-based location services).
- Communication Information. When you send us an email or contact us via the support in our Services, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.
We process, use or share non-Personal Information, aggregated information or Personal Information in non-human readable form (e.g. anonymous or aggregated information concerning the way our user community interacts with the Services) in any of the above circumstances, as well as for the purpose of providing and improving our Services, aggregate statistics, marketing purposes and conduct business and marketing analysis, and enhance your experience with the Service.
We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Policy, and we may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.
If we combine Personal Information with Anonymous Information, the combined information will be treated as Personal Information for as long as it remains combined.
We will only use your Personal Information when the applicable laws allow us to. In general, we use your Personal Information for the following purposes:
Improvement of services: to improve and personalize our services by presenting new services, information, recommendations, and feedback;
Customer management: to manage a registered user’s account, to provide customer support and notices to the registered user about his account or subscription, and notices about changes to Palpi Services or any other product or service we offer or provide through it;
Communication: to communicate and interact with you directly, for an example, we may send notifications regarding upcoming changes, promotion activities or improvements on Palpi Services;
Content review: to review pictures, images and contents posted or generated on Palpi Services to ensure that we comply with any applicable content regulations in any relevant jurisdiction;
Customization of content: to perform research and analysis about your use of, or interest in contents, products, advertising, or services available on Palpi Services in order to develop and display content tailored to your interests on our Website and App;
Performance Analysis: to determine whether users of Palpi Services are unique, or whether the same user is using Palpi Services on multiple occasions, and to monitor aggregate metrics such as total number of visitors, number of videos viewed, demographic patterns;
Functionality and security: to identify users not meeting the age limit, to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
Compliance: to enforce our terms of use and to comply with our legal obligations;
Aggregation: to aggregate information we collect about you to which one or more purposes described above.
Cookie: We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) ("Cookies") to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform and improve our services. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as "pixel tags" or "clear GIFs," that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.
Additionally, we link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.
You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.
Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.
We do not rent, sell, or share your Personal Information with third parties ("Recipients") except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.
We share Personal Information with any of the following recipients:
- Any service provider that we engage with to operate the Service;
- Our affiliated companies;
- Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, fraud prevention services, and other data verifiers;
- Payment service providers and payment processors;
- Auditors, contractors or legal/financial/other advisers of any of our business processes;
- Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable us to enforce our policies, including in order to ascertain your source of income or funds (e.g. governmental authorities, law enforcement bodies, banks and other investigatory bodies);
- Governmental and regulatory bodies, in accordance with applicable laws and regulations;
- Potential purchasers, successors or investors in any of the companies within our group companies, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within our group companies (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Policy).
We may transfer or disclose Personal Information to our subsidiaries, affiliated companies, subcontractors or such other trusted third party service providers or partners, who are located in different jurisdictions across the world for the purpose described in this Policy. Information collected by Company may be stored and processed in any jurisdiction where Company or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities.
If we provide any information about you to any such entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Policy and applicable law.
6. Third party collection of information.
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties on our Services or other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. For example, when making a payment by credit card our third party processors such as the Apple Store and Google Play Store, they may collect your credit card information and other information necessary for processing/authorizing your credit card payments. These payment companies may also provide certain of your details to us.
When you click on a link to any other website, mobile application or third-party content through Palpi Services, you will go to another website or other mobile application and another entity may collect information from or about you. We have no control over, do not review, and cannot be responsible for, these third-party websites or mobile applications or their contents. Please be aware that the terms of this privacy policy do not apply to these third-party websites or mobile applications or content, or to any collection of information after you click on links to these third-party websites, mobile applications or content.
You are knowingly and voluntarily assuming all risks of using any Third Party Services. You agree that we shall have no liability whatsoever with respect to such Third Party Services and your usage of them.
The Services are not directed at children under the age of consent (namely, below the age where consent must be given or authorized by the holder of parental responsibility over the child, as required under the applicable law in the jurisdiction you reside in ( "Age of Consent")). If you are under the Age of Consent you may use the Services only if consent is given or authorized by the holder of parental responsibility.
If Company learns that Personal Information of persons under the Age of Consent has been collected on or through the Services without parental or guardian consent, Company will take appropriate steps to delete this information unless it is needed to comply with any legal or statutory obligation.
If you are the parent or legal guardian of a child under the Age of Consent who has become a member, then please contact us at cwmtech@126.com to have that child’s account terminated and the Personal Information deleted.
Some jurisdictions’ laws grant specific rights to Palpi users, which are set out in this section. You may have all or some of the following rights set forth below according to applicable laws. We will respond to your request consistent with the applicable laws as soon as practicable, normally within one month, after proper verification procedures. Your exercise of these rights is usually free of charge, unless we deem it is chargeable under the applicable laws.
You may submit a request by (a) using help or feedback function on Palpi Services, or (b) by sending your request to us via email at cwmtech@126.com
- To access or delete any Personal Information relating to you;
- To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
- That we will restrict any further use of your Personal Information;
- That we will provide the Personal Information you volunteered to us in a machine-readable format;
- To object to the processing your Personal Information (such as for marketing purposes);
- To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significant affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.
- Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including any legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.
We will retain your Personal Information and other information for as long as you maintain your Palpi account.
You may request deletion of your account at any time through the Me > Settings > Account & Security > Delete Account in the app. Following such request with appropriate review by us, we will delete the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements.
All Account Deletion Requests of registered users will be processed within thirty (14) days period ( "Processing Period"). You can reactivated your user within the Processing Period. After the Processing Period will end, you will no longer we able to access your account and the Company will remove all Personal Information related to your account.
When you submit an Account Deletion Request, we delete the content you have posted, streamed or created, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted.
Please note that all Account Deletion Requests are subject to our retention policy, and the Company reserves the right to retain certain Personal Information for the purpose of meeting its legal obligations, for fraud prevention and for record keeping purposes.
We may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if we deactivate a user’s account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new Palpi account in the future.
We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version so you are aware of any changes, as they are binding on you.
This California Privacy disclosure page supplements the Palpi Privacy Policy. These additional disclosures are required by the California Consumer Privacy Act. This privacy disclosure page applies to California residents and information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with California consumers ("California Information").
The personal information that Palpi collects, or has collected from you in the twelve months prior to the effective date of this disclosure page, fall into the following categories.
- Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier and language;
- Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;
- User-generated contents ("UGC"), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Palpi Services;
- Payment information, such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number or other payment information where required for payment;
- Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Palpi Services, but such data will only be processed offline to fulfill the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party.
- Your location information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device, and the information based on your SIM card;
- Information you provide, such as your opt-in choices and correspondence with us, and information you provide when you participate in in-app surveys and activities.
- Information you provide from social media when you create a Palpi account by connecting with a third-party social media;
- Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed to, and information regarding your interaction with other users;
- Information from Other Sources: We may obtain additional information from third parties and sources other than the Palpi Services. For example, we may obtain additional information from games or services you use, or social media networks (such as Facebook) for which you have approved our access. When you access the Palpi Services through social media networks or when you connect the Palpi Services to social media networks, you are authorizing Palpi to collect, store, and use such additional information and content in accordance with this Privacy Policy
- Device information, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, media access control address, and mobile advertising identifiers;
- Metadata, associating with the UGC you provided us, which describes other data and provides information about how, when, and by whom the piece of UGC was collected and how that UGC was formatted, such as hashtags used to label the keywords to the video and captions;
- Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Palpi Services, enhance your experience using Palpi Services.
The personal information that Palpi disclosed about you for a business purpose in the twelve months prior to the effective date of this Disclosure fall into the following categories:
Identifiers such as your IP address;
Personal information, such as your credit card number, email address, phone number and name, for example if we use a service provider to process payments;
Internet or other electronic network activity information, such as if we use a service provider to help us gather crash reports for analyzing the health of our services;
We disclose personal information to the following types of entities in the twelve months prior to the effective date of this Disclosure
We may disclose your Personal Information to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, analytics, facilitating your register or login, and supporting our functionality.
You may have the right under the California Consumer Privacy Act to request information about the collection of your personal information by Palpi, or access to or deletion of your personal information. If you wish to request information about the collection of your personal information, please send an email to us via cwmtech@126.com. If you wish to delete your personal information, please send an email to us via cwmtech@126.com.
Please note that certain information may be exempt from such requests under California law and that, depending on your data choices, certain services may be limited or unavailable.
No sale of personal information. In the twelve months prior to the effective date of this Disclosure, Palpi has not sold any personal information of you, as those terms are defined under the California Consumer Privacy Act.
No discrimination. Palpi will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at cwmtech@126.com