PRIVACY POLICY

Lasted update:2019/10/17

Colorfulnight Limited (hereinafter as “Company“, “we”, “our”, or “us”) understands the importance of protecting your privacy. This Privacy Policy (the “Agreement” or the “Policy”) explains what your information will be collected when you download, install, register with, access, or use this mobile application-Palmistry decoder (the “App” or “Software”) and our related services (the “Services”), and how such information will be used and shared. It also explains choices you have to control the collection, correction and/or deletion of such information. By using our Software, you consent to the Policy and to the collection, processing, disclosure and use of your information as described in this Policy. This Policy applies only to information we collect in our App and in e-mail, text and other electronic communications sent through or in connection with our App. This Policy DOES NOT apply to information that we collect offline, information collected in other apps or websites (including third party websites you may access through the App), or information collected by any third party. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE AND SERVICES. We collect the following types of information automatically when you use our Software and Services.

INFORMATION WE PROCESS AND PURPOSES OF PROCESSING YOUR INFORMATION

1. Information you give us

(1) User Information: Information you choose to submit when you use the Software, such as birth date. Our purposes of collecting the information are: (i) to improve and customize the Software and Services; and/or (ii) to maintain and improve the quality and operation of the Software and Services.

(2) Camera, Photos and Facial Features Information: In order to use some of the features of the Software, you may voluntarily grant us the permission to access to the camera or photo album to obtain photo in your mobile device. Only if you confirm the permission, will we gain access to your camera and album. When you use certain face recognition functions including but not limited to Daily Palmistry, Love Consulant, Wealth Forecast, Palm Compatibility, Future Baby etc, we will use the sdk provided by third parties to analyze the facial features information, automatically capture the position and shape of the five sense organs or other organs in the photos, and process the photos, feedback the effect drawing to you. We capture the facial features information only for operating the face recognition functions and providing better effect drawing for you. For such photos, facial features information and effect drawing, we will neither store nor share them with any third parties after processing.

(3) Support Related Information. If you communicate with us via our support section or via email, we may also collect your email address, name and any information voluntarily submitted by you in connection with such support (for example, your name, company name, and particular support query or request). Such information will only be used to provide you with support services and will not be connected with any other information collected from you on or through the Software, including but not limited to any individual user ID which will be automatically generated by the Software and assigned to you when you use the Software. Our purposes of the support related information are: (i) to take any action in case of a dispute involving you in connection with the Software and Services; (ii) to enforce the terms and conditions applicable to the Software and Services and to prevent unlawful activities and misuse thereof; (iii) to comply and satisfy any applicable law, regulation, legal process or enforceable governmental request; and/or (iv) to provide you with support and handle your complaints and/or feedback.

2. Information we collect automatically

When you use the Software and Services, for analytical, business and operational purposes, we automatically collect and store the following types of information:

(1) Device Data. We may use Cocoa Touch API to collect device data regarding your language settings, time zone, type of device, device settings, operating system, ISP or your mobile carrier, hardware ID, or country. Our purpose is to provide you with better Service. This includes use of personal data to support delivery of the Service under Terms of Service, to ensure that content provided by App is presented in the most effective manner, to prevent or address service errors or technical issues.

(2) Advertising Data. We may use Cocoa Touch API to collect your Apple Identifier for Advertising (IDFA) to recognize your device and support activities on advertising of our Services. These number values are not permanently tied to your device and, depending on your operating system, you can reset them through your device settings. Our purpose is to optimize advertising. We and our partners may use your personal data to inform, optimize and serve advertising based on your past use of this App. This activity is performed by tracking usage data and by using other information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

(3) Analytical Data. We use HTTP Protocol synchronously to record traffic and usage trends for the Services, including how often you use App, referring/exit pages and URLs, device identifiers, events that occur within App, aggregated usage, performance data. Our purpose is to perform research and analysis about your use of App. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design and develop App and our new products. We also use such data for statistical analysis purposes to test and improve our offers.

(4) Payment Data. We use In-app purchase API provided by the third party to collect information about your subscription orders, such as purchase items, subscription time, order status, payment time. We do not collect and we are not responsible for the collection or security of payment details. Payment information is processed and stored using third-party companies (such as Apple). These companies can be contacted through their websites e.g. https://www.apple.com. Before entering your personal details, we suggest that you read and become familiar with the privacy policy of these third-party companies. Our purpose is to manage your account and provide you with customer support. We may use your payment data to respond to your requests for technical support, service information or to any other communication you initiate. This includes accessing your account to address technical support requests. Please note that irrespective of your email settings, we may send you messages about the availability of our Service, security, payment transactions, status of your orders, legal notices regarding revision of our Terms of Use or this Privacy Policy, or other Service-related information.Our Service is dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data as described above, we will notify you and may also modify this Privacy Policy.

SHARING INFORMATION WITH THIRD PARTIES

We will not share any personal identifiable information (the “PII”) that we have collected from you except for the following events: If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the Company’s users, its partners, or the general public). In the event the Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred. We may share your information with certain third parties (including, without limitation, search engines, content providers, and advertising networks and platforms) that provide various services (such as advertising, marketing, analysis, content, and search) in connection with the Software and Services. We take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with Services and (iii) to use the data solely in compliance with this Privacy Policy. If you want to delete any personal data which we have shared with the third parties, please contact our Data Protection Officer by email at:[feedback@palmdecoder.com]. We would try our best to notify the third party of deleting the relative personal data, but no warranty as to the deletion is made by us. We may also share PII and non-personally identifiable information with our subsidiaries, affiliated and parent companies but their use of such information must comply with this Privacy Policy.

PROTECTION OF PERSONAL INFORMATION

We take precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. We use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s information. We also protect user’s privacy by seeking to minimize the amount of sensitive data and PII. We also seek appropriate contractual protection from our partners regarding their treatment of user data. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

DATA RETENTION

We retain the information we collect as described in this Privacy Policy for as necessary for the provision of the Services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the Services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

INFORMATION MAY BE COLLECTED BY THIRD-PARTY

Certain Services may contain contents linking to advertisements, websites, products and other services provided by third parties in our Software (collectively, “Third Party Services”). The use of such Third Party Services is subject to their privacy policies. You shall be aware that the use of the Third Party Services may give these third parties the ability to access, collect, store, and/or share your information, both your PII and non-personally identifiable information. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Services and your access to any Third Party Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Services. You expressly relieve us from any and all liability arising from your use of such Third Party Services. We recommended that you read the terms, conditions and privacy policies of such Third Party Services before using or accessing any of them. For providing customized advertisement, the third-party advertising companies may collection or use your personal information (not including your name, address, email address or telephone number) when you use the Software or Services.

OUR POLICY TOWARD CHILDREN

Our Services are not directed to children under 16 or other statutory minimum age according to the applicable laws and regulations in your country (the “Minimum Age”). We do not knowingly collect PII from children under the Minimum Age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

YOUR DATA RIGHTS

You have the right to access, modify, correct or delete any personal data which we may have collected. If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA. To exercise this right, please contact our Data Protection Officer by email at: [feedback@palmdecoder.com].

NOTICES

If we are required to provide you with notice of a particular event or incident, we will send you such notice by email. TRANSFER OF DATA OUTSIDE YOUR TERRITORY The Software and Services work over the Internet. We may store and process your information in various locations throughout the world. Where you located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where may be outside of EEA once you use the Software and/or Services. You may withdraw your consent at any time.

PRIVACY QUESTIONS

If you have any questions or concerns about our Privacy Policy or data processing, please contact us at [feedback@palmdecoder.com]. We may modify, update and publish this Privacy Policy in the Software from time to time. Please continue to play close attention to this Policy.