PRIVACY POLICY HIGHLIGHTS

Introduction

Hyperconnect Inc. ("Company", “we”, “our”, or “us”) 20F, ASEM Tower, 517, Yeongdong-daero, Gangnam-gu, Seoul, Republic of Korea respects your concerns about privacy. This Privacy Policy applies to the personal information we process in the context of the operation of our video communication service AZAR ("Service") and is incorporated into and is subject to our Terms of Service which can be found at  [link]. Please find below a summary of the key topics addressed in this Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below. Your use of the Service signifies that you agree with the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not use the Service and must immediately terminate your use of the Service.

Note that the "Supplementary Terms" contain specific additional regulations for certain jurisdictions such as the EU or California.  

1. Personal Information We Collect

2. How We Use this Information

3. Sharing of Information

4. Retention of Personal Information

5. Your Choices

6. Your Rights

7. How We Protect Personal Information

8. Personal Information of Children

9. Contact Us

10. Updates to Our Privacy Policy

Supplementary Terms


PRIVACY POLICY

Effective Date: September 20, 2022

1. Personal Information We Collect

When we refer to “personal information” in this Privacy Policy, we mean information that relates to an identifiable individual. The following types of personal information are collected in connection with our Service:

Information You Provide Directly to Us or we receive from Third Parties 

We may collect information directly from you or from other companies with whom you have a relationship. For example:

Information about Your Use of Our Service

In addition to the information you provide, we will collect information about your use of our Service through software on your devices and by other electronic means, including by the use of cookies (For more information, please see our Cookie Policy.

This includes:

Links to Other Websites, Devices, Apps and Features

Our Service may enable you to connect to other websites, devices, apps and other features, which may operate independently from us and have their own privacy notices or policies. If you accessed a website, product or service provided by a third party, including through the Service or Company's website, such third party may also collect information about you. Please see the privacy policies of each such third party for more information about how they use the information they collect. This Privacy Policy does not apply to any exchange of information between you and any third party.

2. How We Use this Information

Provision of our Service based on your contractual relationship with us

We process your personal information when this is necessary under our contract with you, to:

Use of information for further purpose

Other

3. Sharing of Information

We transfer or disclose your personal information to third parties as described below:

Any information or content that you voluntarily disclose for posting to the Service ("User Contents") may become available to the public. Once you have shared User Contents or made it public, that User Contents may be re-shared by others. This Privacy Policy does not apply to such public information.

4. Retention of Personal Information

We take appropriate steps to ensure that we process and retain information in accordance with the following principles:

5. Your Choices

Where permitted we may contact you via email, phone call, text messages or push notifications through our mobile apps. To submit a request concerning the receipt of such communications from us, please contact us using the information specified in the “Contact Us” Section below.

You can unsubscribe from our marketing communications at any time by contacting us directly (see “Contact Us” section below). As noted in the Your Rights section below, you have the right to object to use of personal data for direct marketing purposes at any time.

Please note that if you unsubscribe from our marketing communications, we will still send you service messages to provide you with necessary information in relation to your contract and the Service you use (for example, to update you on changes to our Terms of Use).

6. Your Rights

To the extent provided by applicable law, you can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also have the right to request that we delete personal information that we hold about you. You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

To the extent provided by applicable laws, you can also ask us to restrict or limit the processing of your personal information, as well as to provide you with personal information that we have collected from you so that you may use it for your own purposes, and to ask us to share (port) this data to another controller.

In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).

You also may have the right under applicable law to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.

However, these rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make. To make a request concerning your rights or to make an inquiry, use the contact details under the “Contact Us” section below.

 

7. How We Protect Personal Information

We take the protection of your information seriously and we have in place safeguards designed to protect the information we collect through our Service. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

Please note, however, that the Service allows you to share text messages, photos, screenshots, videos and other communications in the Service with other users, and if you choose to share these items with other Service users, we may not be able to remove them from our servers or make them unavailable to anyone you have shared them with. Sending and sharing text messages, photos, screenshots, videos or other communications in the Service 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 publicly available (depending in part on your actions or the actions of others with whom you have shared the information). The Service is not responsible for any use or misuse of information you share.

8. Personal Information of Children

The Service is not directed to children under the age of fourteen (14) and we do not knowingly solicit or collect personally identifiable information from children under the age of fourteen (14) as part of the Service. Additionally, we do not knowingly sell the personal information of children under the age of sixteen (16). If we become aware that we have inadvertently received personally identifiable information from a user under the age of fourteen (14) as part of the Service, we will immediately delete such information from our records. If you believe that a child under the age of fourteen (14) may have provided us with personal information, please contact us using the information specified in the “Contact Us” section below.

9. Contact Us

For more information about our privacy practices, or to exercise any rights you may have pursuant to applicable law, please contact us at help@azarlive.com or via post 20F, ASEM Tower, 517, Yeongdong-daero, Gangnam-gu, Seoul, Republic of Korea. In addition, our Data Protection Officer can be contacted at dpo@azarlive.com.          

10. Updates to Our Privacy Policy

We reserve the right at our discretion to make changes to this Privacy Policy from time to time. We will notify you before we make changes to this Privacy Policy. You may also review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the Service and our website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy.

If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you may not use the Service at any time.


Supplementary Terms

The following additional terms apply respectively to users having residence in or nationality of certain countries. In the event of any conflict between the following additional terms and the provisions of the main body of this Privacy Policy, the following terms shall prevail.

1. For Users Having Usual Residence in European Economic Area (EEA), UK or Switzerland

A. International Transfer of Personal Information

If you are a resident in the EEA (that is in the European Union and Iceland, Lichtenstein, Norway), UK or Switzerland, we will transfer your personal information to the Republic of Korea and other countries outside the EEA, UK or Switzerland including the United States, Turkey, Malta, Thailand, Egypt, India, Hong Kong and Columbia.

We are a company based in South Korea. In the event that there are no adequacy decisions between South Korea and your country of residence, the data transfer to Korea is      justified because all data we collect is also necessary to provide the Services.

Where we share your data with recipients as described, we will take appropriate measures, in compliance with applicable laws, to ensure that your personal information remains adequately protected. Such measures include for instance the use of EU approved Standard Contractual Clauses or similar instruments under local law. In some instances, we will also rely on your explicit consent, where this is appropriate. To request more information or obtain a copy of the contractual agreements or other safeguards in place, use the contact details set out in the “Contact Us” Section.

B. How We Use this Information – additional information

The purposes and legal grounds for processing personal information are described above in section 2. In this section, we describe in which cases we will rely on consent:

On other occasions where we ask you for consent, we will use the data for the purpose explained to you at that time. When we rely on your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out before you withdrew your consent. To exercise this right, please see the “Your Rights” section.

C. Personal Information of Children

For the users having usual residence in the EEA, UK or Switzerland, Section 8 should read as follows; Our Service is designed for a general audience and is not directed towards children. In connection with our Service, we do not knowingly collect or maintain personal information from anyone under the age of sixteen (16) or knowingly allow such persons to use our Service. If you are under sixteen (16), please do not attempt to register for our Service or provide us with any personal information. If we learn that a person under the age of sixteen (16) has provided us with any personal information, we will promptly delete such personal information. If you believe that a child under age sixteen (16) may have provided us with personal information, please contact us using the information specified in the “Contact Us” section.

D. Contact

To comply with the General Data protection Regulation (2016/679) we have appointed a European and a UK representative. If you wish to contact them, their details are as follows:        

  1. EU Representative

Bird & Bird GDPR Representative Ireland
29 Earlsfort Terrace
Dublin 2
D02 AY28
Ireland

EUrepresentative.Hyperconnect@twobirds.com

Main point of contact : Vincent Rezzouk-Hammachi.

  1. UK Representative

Bird & Bird GDPR Representative Services UK
12 New Fetter Lane
London
EC4A 1JP
United Kingdom

UKrepresentative.Hyperconnect@twobirds.com

You can also contact a data protection authority in case of complaints.


2. For California Consumers

This additional term supplements this Privacy Policy and applies solely to consumers in California (excluding Company job applicants and personnel).

A. Collection and Disclosure

In the past 12 months, we may have:

  1. Collected the following categories of personal information about you:
  1. Collected personal information about you from the following categories of sources:
  1. Collected personal information about you for the following business or commercial purposes (in addition to the purposes listed above in this Privacy Policy [-     ]):

We may share or disclose all of the above categories of information with service partners that assist with our internal functions, such as analyzing data, maintain the security of our systems, ensuring our compliance with the law. We may also share the above information with our affiliates (e.g., Movefast Company Co. Ltd., Belogical Pte. Ltd.) in order to better serve you or maintain our business

Category of Personal Information

Recipient Categories

Identifiers

Our affiliated companies, solution provider, partners, system management and operation service provider

Commercial Information

Solution provider, system management and operation service provider

Geolocation Data

Solution provider, system management and operation service provider

Internet and Other Electronic Network Activity Information

Our affiliated companies, partners, solution provider, system management and operation service provider

Audio, Electronic, Visual, or Similar Information

Solution provider, system management and operation service provider

Inferences

Solution provider, system management and operation service provider

  1. Sold the following categories of personal information about you to third parties particularly online advertising networks:

B. Privacy Rights

You have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. In addition, you have the right to request that we delete the personal information we have collected from you. You also have the right to opt out of the sale of your personal information by clicking here: Do Not Sell My Information. Additionally, you have the right to not be discriminated against as a result of exercising these rights.

You or your authorized agents may submit an access or deletion request, by  clicking here  or by contacting us as specified in the Contact Us     section of this Privacy Policy. In order for us to honor a request made by your agent, you must submit proof of your written authorization of the agent. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign into your account. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

3. For Japan

This additional term supplements this Privacy Policy and applies solely to Users in Japan

A. How We Use this Information

Provision of our Service based on your contractual relationship with us

We process your personal information when this is necessary under our contract with you, to:

Use of information for further purpose

Other

B. Sharing of Information

Company does not provide personal information to a third party without obtaining in advance your consent, except in those cases set forth in the following.

  1. cases based on laws and regulations;
  2. cases in which there is a need to protect a human life, body or fortune, and when it is difficult to obtain your consent;
  3. cases in which there is a special need to enhance public hygiene or promote fostering healthy children, and when it is difficult to obtain your consent;
  4. cases in which there is a need to cooperate in regard to a central government organization or a local government, or a person entrusted by them performing affairs prescribed by laws and regulations, and when there is a possibility that obtaining your consent would interfere with the performance of the said affairs;
  5. cases in which personal information is provided accompanied by Company entrusting a whole or part of the handling of the personal information within the necessary scope to achieve a utilization purpose; or
  6. cases in which personal information is provided accompanied with business succession caused by a merger or other reason.

Company may transfer personal information to foreign third parties as follows:

Name of third parties

Transferred Country

Transferred Item

Purpose

Happymind Co. Ltd.

Thailand

Video, Captured picture of the video, Voice, User generated contents, Profile, Gender, Age, Nationality, Device information, Device language

To improve the Service

Twilio

U.S.A.

Mobile Phone Number

To improve the Service

Amazon Web Services Inc.

U.S.A.

All information collected in connection with the Service

To analyze the Service and the usage of the Service

Google Cloud Platform

U.S.A.

All information collected in connection with the Service

Data Storage and System Operation

Google Analytics

U.S.A.

Device information, Gender, Age, IP, Location Information, Purchase history

To analyze the usage of the Service

Google Firebase

U.S.A.

Device information, Gender, Age, IP, Location Information, Purchase history

To analyze the usage of the Service

Sentry

U.S.A.

IP, User ID     

To analyze error information

Facebook

U.S.A.

Device information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history(including Gender), Mobile network information      

To analyze statistics

Braze Inc.

U.S.A.

Gender, Date of birth, Country information, Device Information, IP, Purchase history, Access history, App activity history

To analyze the usage of the Service

Branch

U.S.A.

Device Infomation, Device Information, Advertising identifier, IP, Location Information        Access history, Purchase history,  App activity history, Mobile network information

To analyze statistics

Play Co., Ltd.

Republic of Korea

Video, Captured picture of the video, Voice, User generated contents, Profile, Gender, Age, Nationality, Device information

To improve the Service

Tiktok Pte. Ltd.

Singapore

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history, Mobile network information

To analyze statistics

Apple search ads

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history, Mobile network information

To analyze statistics

Snapchat

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history, Mobile network information

To analyze statistics

Google Ads

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history (including Gender), Mobile network information

To analyze statistics

Twitter

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history (including Gender), Mobile network information

To analyze statistics

Google DV360

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history (including Gender), Mobile network information

To analyze statistics

Liftoff

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history (including Gender), Mobile network information

To analyze statistics

Moloco

U.S.A.

Device Information, Device language, Advertising identifier, IP, Location information, Access history, Purchase history, App activity history (including Gender), Mobile network information

To analyze statistics

Zendesk, Inc.

U.S.A.

Email address, Name or nickname, Azar ID, Phone number, Device information, Country information

To improve the Service

Besedo Ltd.

Colombia

Video, Captured picture of the video, Voice, User generated contents, Gender, Age, Nationality, Device information, Device language

To improve the Service

Denkai Digital Limited

Egypt, India, Bulgaria

Profile contents, Gender, Age, Nationality, Device information, Device language, User generated contents

To improve the Service

MoPub Inc.

U.S.A.

Device information, Advertising identifier, IP, Ad types and usage information

To analyze statistics

Unity Technologies

U.S.A.

Device information, Advertising identifier, IP, Ad types and usage information, App activity history, Purchase history

To analyze statistics

Cloudflare, Inc.

U.S.A. and/or other countries

All information collected in connection with the Service

Data Storage and System Operation

AppsFlyer Ltd.

U. S. A

Gender, Country information, Device language, Purchase history, Access history,

To analyze statistics and      to improve      the Service

ADM Value

Morocco

Voice, Nationality, Device information, Device language

To improve the Service

Huawei Services (Hong Kong) Co., Limited

Singapore

Advertising identifier, IP, App activity history (such as ad exposure, click and download)

To analyze statistics

Bigo Technology Pte. Ltd.

Singapore

Advertising identifier, App activity history, Device IP address

To analyze statistics

Payoneer Europe Ltd.

Ireland

Name, ID number, Settlement Information, Address, Date of birth, Email address, Phone number

To provide the Service

Reddit Ads

U.S.A.

Advertising identifier, Device information, Purchase history

To analyze statistics

Taboola

U.S.A.

Advertising identifier, Purchase history, App activity history

To analyze statistics

Appier

Taiwan

Country and city information, Advertising identifier, Access history, IP, Mobile network information, Device information, Purchase history, App activity history

To analyze statistics

Typeform

Spain

Name, Email address, User generated contents, App activity history, Account history

To improve the Service and analyze statistics

MONITRIBE REKLAM EĞİTİM DANIŞMANLIK GIDA TİCARET LİMİTED ŞİRKETİ

Turkiye

Profile contents (nickname, status message, hashtags), Gender, Age, Nationality, Device information, Device language, User generated contents

To improve the Service

Paybox Elektronik Ticaret Anonim Sirketi (Gpay)

Turkiye

Name, Settlement Information, Phone number, Payment information (payment history)

To provide and improve the Service

UnityAds

U.S.A.

Device information, Device identifier, IP, Ad types and usage information, App activity history, Purchase history

To analyze statistics

Massive Media Match NV

Belgium

Video, User generated contents, Device language, Captured picture of the video, Profile, Contents, Gender, Age, Nationality, Device language

To provide the Service

Any information or content that you voluntarily disclose for posting to the Service ("User Contents") may become available to the public. Once you have shared User Contents or made it public, that User Contents may be re-shared by others. This Privacy Policy does not apply to such public information.

C. Updates to Our Privacy Policy

We reserve the right at our discretion to make changes to this Privacy Policy from time to time. We will notify you before we make changes to this Privacy Policy. You may also review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on the Service and our website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy.

If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you may not use the Service at any time. Notwithstanding the foregoing, the Company shall obtain the User’s consent in a manner specified by the Company for the amendment or change of the Privacy Policy which requires such consent under the applicable laws. In this case, the modified Policy will only apply to those Users who have consented to the change in a manner prescribed by us.

4. For Singapore

This section supplements this Privacy Policy and applies solely to any collection, use and disclosure of personal information to which the Singapore Personal Data Protection Act (No. 26 of 2012) applies:

  1. The first sentence of Section 1 of the Privacy Policy shall be deleted and replaced with: "When we refer to "personal information" in this Privacy Policy, we mean data, whether true or not, about an individual who can be identified from that data alone or with other information which we have or are likely to have access to".