TABLE OF CONTENTS:
2. Data We Collect
3. How We Use The Information We Collect
4. Cross-App Advertising and Other Interest-Based Advertising Technologies
5. Sharing Your Information
6. Cookies, identifiers and data analysis
7. How We Protect Your Information
8. Information for Residents of California: Your California Privacy Rights
9. Information Relating to Children
10. Social Logins
11. Where We Store Your Information
12. How Long We Store Your Information
13. Data Deletion
14. Access To and Choices Regarding Your Information
15. How To Contact Us
The information we collect about you through your use of Attribute Apps is controlled by ATTRIBUTE in accordance with Hong Kong law and in particular with the Irish Data Protection Acts 2017, as amended or replaced from time to time.
2. DATA WE COLLECT
When you use an Attribute App, ATTRIBUTE or its trusted partners may collect data from your mobile device, including information which directly or indirectly identifies you. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. The information we collect about you (collectively and individually, the "Information") includes:
- If an Attribute App offers you the option to register, we will collect the Information you provide to us in the registration form. This may include identification data such as your name, email address or other account or registration data.
- In some cases, an Attribute App may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "Social Logins" [LINK] below.
- We will also collect your Information when you use Attribute Apps such as when you post or share material, upload data, request further services or make selections using the Attribute Apps, if such functionality is available in the Attribute App.
- We will collect Information about you when you interact with us such as when you report a problem, contact or communicate with us.
- Geolocation data, which is any Information which indicates the geographical position of your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some Attribute Apps may collect this data when the App is not open or actively in use (This may help us or third parties to customize information, content, or offers to you, for instance.) The Attribute App and/or your mobile device may provide options for you to control the use and/or sharing of precise device location data.
- We automatically collect certain Information from your device when you use the Attribute App including Information about your device, carrier and other technical data.
3. HOW WE USE THE INFORMATION WE COLLECT
We may use the Information (elements of which we may use alone or in combination with each other data/Information) we collect to:
- Deliver the Attribute Apps to you and ensure their optimal functionality and operation;
- Enable you to register and create an account with the Attribute Apps;
- Provide you with customer support;
- Perform research and analysis about your use of, or interest in, our products, services, or content;
- If you have registered with an Attribute App using your social media account details, we may use the Information we receive from your social media provider to identify which of your friends are also using the Attribute App so that you can connect with them in our app;
- Communicate with you by e-mail, postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to you either from us, our parent or subsidiary companies or other third parties. If you do not wish to receive in-application advertising, in some cases you can upgrade to the paid version of the app;
- Develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For instance, we, or these third parties may serve music-related ads or offers to users who have installed music-related apps (whether or not these are Attribute Apps). Similarly, users who frequently visit music-related venues may likewise receive ads or offers to install music-related apps;
- Verify your eligibility and deliver prizes in connection with contests and sweepstakes and in order to conduct polls and surveys;
- Enforce our terms, conditions and policies and to communicate with you;
- Manage and improve the Attribute App(s). For this purpose, we may use and combine your Information which we collect across different Attribute used by you;
- When we collect your precise geolocation data (subject to your consent) (which may be via the device's cellular, Wi-Fi, Global Positioning System (GPS) networks and/or Bluetooth information), we do so to provide you with our location-related products and services, for example to provide you with forecast and weather alerts for your location, and also to facilitate, measure, or otherwise support advertising by third parties (through our apps or third parties' apps) that may be related to your location over time.
- When you share your Information with us via a social network provider like Facebook, we use this to show Information on your social network profile (subject to your privacy setting and preferences for such social network) and to allow you to share Information about our services with your connections or on your social network profile.
4. CROSS-APP ADVERTISING AND OTHER INTEREST-BASED ADVERTISING TECHNOLOGIES
If you wish to opt out of interest-based cross-application tracking through your mobile device, you can do so through your device "settings", as follows (but please note that the below is for informational purposes only and Apple, Google, or other device platforms may change the manner in which their "opt out" settings work at any time): Please note that if you opt out through these settings, you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. For instance, that advertising may be based on your real-time or "contextual" application usage or general location inferred from IP address.
Opting Out on iOS Devices Such as iPhones, iPads or iPods
If you have an Apple device, you can opt out of mobile interest-based or "cross-app" advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to 'ON'. On an iPhone 6 for example, you can do this by clicking on Settings -> General -> Privacy -> Advertising and toggling "Limit Ad Tracking" to 'ON'. Our systems are designed to respect your choice and not use Information to provide interest-based advertising when this setting is ON.
Opting Out on Android Devices
If you have an Android device and would like to opt out of mobile interest-based or "cross-app" advertising, you may do this as follows:
- Open the Google Settings app on your device
- Select Ads
- Opt out of interest-based ads
We may sometimes work with partners to help us or help them correlate content or ads provided to users across devices or browsers. For instance, a brand may wish to use the Information that we collect (or data that its own partners collect) to send offers to its customers across both mobile applications and browsers. We thus also provide the links below to the NAI "Consumer Opt-out," DAA opt-out, and Google opt-out that are only applicable to participating third parties, which does not include ATTRIBUTE. You may also block certain App Identifiers by changing the settings of your device. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry has not reached a consensus as to Do Not Track standards, implementations and solutions.
We also use a third party service called Moat and we may transfer your information to Moat in accordance with the following policy: https://moat.com/privacy
We also use a third party service called Integral Ad Science and we may transfer your information to Integral Ad Science in accordance with the following policy https://integralads.com/privacy-policy/
5. SHARING YOUR INFORMATION
We may share your Information as follows:
- We may share your Information with our authorized service providers that perform certain services on our behalf. These services may include providing customer service and marketing assistance, performing business and sales analysis, supporting our Attribute Apps functionality, and supporting marketing promotions (e.g., contests and sweepstakes) surveys and other features offered through our Attribute Apps. These service providers may have limited access to your Information, which is needed to perform their functions, but are not permitted to share or use such Information for any other purposes.
- When you engage in promotions offered through the Attribute Apps, we may share your Information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes; unless, we have otherwise committed to you that we will not share specific Information you provided. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other Information to that merchant.
- We may also allow third-parties, including our authorized service providers, parent and subsidiary companies, affiliates, advertising companies and ad networks, to display advertisements in the Attribute Apps or other apps or use App Identifiers for the purpose of advertising and direct marketing. These companies may use technologies to collect data about users, including non-precise and/or precise location data, to help them tailor relevant ads and content and analyze and measure ads' effectiveness or, more generally, brand and mobile audiences. These companies may collect this data through SDKs or from users who view or interact with their advertisements. We combine Information internally at ATTRIBUTE across different Attribute Apps. This means, for example, that we may combine your Information from our Notepad app with Information we have about you in our Emoji app. This will enable us to provide more tailored and personal experiences and services to you across our family of Attribute Apps which are described www.attributetech.com
- Other Situations. We may disclose your Information (i) to respond in good faith to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others; (iv) to comply with applicable law or cooperate with law enforcement; (v) to enforce our Attribute Apps terms and conditions or other agreements or policies; and (vi) in connection with a substantial corporate transaction, such as the sale of our business or the Attribute Apps, a divestiture, merger, consolidation, or asset sale or transfer, or in the unlikely event of bankruptcy. In addition, we may share aggregated Information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other legitimate business purposes. Please note that such aggregated Information will not include any Information which allows third parties to identity you.
6. COOKIES, IDENTIFIERS AND DATA ANALYSIS
We may collect certain device data and electronic identifiers such as the mobile device identifier provided by your mobile device operating system, your mobile operating system details and the name of your mobile carrier. For example, if you use the iOS platform then Advertiser IDs (also known as "IDFAs" if you have an Apple device or "Android Ad IDs" if you have an Android device) may be collected. Other identifiers collected may include IP addresses, OpenUDID, Session ID, ODIn1, iOS Vendor IDs, MAC addresses, IMEI, Android ID for Android platform, and ODIN1 for OS X (together with the IDFAs, the "App Identifiers").
When you use the Attribute App(s), we may use the App Identifiers to facilitate access to the Attribute Apps, help us recognize you across different Attribute Apps, to enable you to use the Attribute Apps, to personalize your experience, to increase security, measure the use and effectiveness of our Attribute Apps and serve advertising. You can block certain App Identifiers by changing the settings of your device.
We also collect information about how and when you use the Attribute App. This includes the amount of times you used the Attribute App, which parts of it you viewed and other technical data such as country settings and timestamps.
For further information on how Google's Firebase analytics tool uses data, please see the site "How Google uses data when you use our partners' sites or apps", (located at www.google.com/policies/privacy/partners/).
Cookies and our Websites
- tracking the duration of visits and content accessed; and
- storing frequently used user information to personalize your online experience and ease the log-in process.
7. HOW WE PROTECT YOUR INFORMATION
The security and confidentiality of your Information is very important to us, so we take security measures (including physical, electronic and procedural measures) to help safeguard your information from unauthorized access and disclosure. Please know that, despite our efforts, no security measures are perfect or impenetrable.
8. Information for Residents of California: Your California Privacy Rights
Access to Information and Data Portability Rights
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of personal information we have collected about you.
- The categories of sources from which we collected your personal information.
- The business or commercial purposes for our collecting or selling your personal information.
- The categories of third parties to whom we have shared your personal information.
- The specific pieces of personal information we have collected about you.
- A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain:
• The categories of your personal information we have sold.
• The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.
Data Deletion Rights
Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.
Exercising Your Rights
To make a request for access, portability or deletion according to your rights under CCPA, click here or mail your request for the attention of the Privacy / Legal Department to Attribute Trading Co., Limited., NO.3 10F WITTY COMM BLDG 1A-1L, TUNG CHOI ST. MONGKOK KL HK, Hong Kong. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process ("Verifiable Consumer Request").
The Verifiable Consumer Request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer's personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
We do not "sell" personal information that we collect from you, in accordance with the definition of "sell" in the CCPA and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a "sale" of your PI as defined by the CCPA. See the "Online Privacy Choices and Rights" section to learn how you can exercise your rights regarding interest-based advertising.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request here (please include your name, mailing address, and email address).
9. INFORMATION RELATING TO CHILDREN
The Attribute Apps are not directed to children under the age of 13. If we become aware that Information has been collected from a person under the age of 13, we will delete this Information and terminate the person's account as quickly as possible. If you believe that we may have Information from or about a child under the age of 13, please contact us at firstname.lastname@example.org and we will promptly delete that Information.
10. SOCIAL LOGINS
11. WHERE WE STORE YOUR INFORMATION
12. HOW LONG WE STORE YOUR INFORMATION
13. DATA DELETION
Uninstallation and removal methods vary depending on your device. To uninstall and remove the Attribute Apps, please use the application manager provided with your device or consult your device manual or online instructions provided by the device provider for reference.
14. ACCESS TO AND CHOICES REGARDING YOUR INFORMATION
You may have the right to access Information held about you or require it to be modified (if inaccurate) or deleted. Your right of access can be exercised by contacting us using the details set out below. Any access request may be subject to a fee to meet our costs in providing you with details of the Information we hold about you.
15. HOW TO CONTACT US
Attribute Trading Co., Limited
OFFICE NO.3 10F WITTY COMM BLDG 1A-1L, TUNG CHOI ST. MONGKOK KL HK ATTN: Legal Dept.
© 2021 Attribute Trading Co., Limited. All rights reserved.