Last Updated: December 22, 2022
Effective date: December 22, 2022
Thank you for using Vskit! Vskit has updated the following content in accordance with relevant laws and regulations:
(1) We have added how we collect and use your personal information in the “Earning center” scenario (refer to Section 2.7 for details)
(2) We have updated how we collect and use your personal information in the content service scenario (refer to Section 2.3 for details)
It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties, please prudently determine whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.
We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.
If you have any questions, please feel free to contact us by the following means:
Vskit->ME > Setting > About us> Terms / Privacy / Community Policy
- I.How We Collect and Use Your Personal Information
- II.How We Store and Protect Your Personal Information
- IV.How We Share, Transfer and Disclose Your Personal Information
- V.How Your Personal Information is Transferred Across Borders
- VI.Your Rights to Your Personal Information
- VII.How We Handle the Personal Information of Children
- VIII.Third-Party Service Providers and Services
- IX.Supplement and Update of the Policy
- X.Joint Controller
- XI.How to Contact Us
I. How We Collect and Use Your Personal Information
Vskit firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by us, regardless of where such natural person lives.
We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.
We may collect your personal information by the following means:
- 1)information you provide directly to us (such as your nickname, profile picture, name and phone number you provide to us when you login to your account or take part in the promotion activity we held);
- 2)information we obtain automatically during your use of this Application (such as device information, service log information);
- 3)information we obtain from other sources.
You have the right to choose whether or not to provide the personal information when you use Vskit and its Service or when we have requested. You are not required to provide your personal information to Vskit, but in some cases, if you choose not to do so, we will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:
2. What information we collect and how we use it in Vskit
Vskit mainly provides you with comprehensive services including posting audios and videos, sending personalized content and allowing for comments and communication.
2.1 To provide you with the service of account registration and login services
To fully use the functions and services of the software conveniently, you can register and log in by providing us with your phone number or email address. To verify your identity, when you log in to your Vskit account, we will send a message to your phone number or email address. You are required to submit the verification code in the message to complete the login. Upon registration, the system will automatically generate a USER ID to identify your account. If you use the password to log in, we will take necessary measures to store your login password to verify your identity. If you refuse to provide this information, you will not be able to register a Vskit account or use relevant functions. However, your normal use of other features of this Application will not be affected. You can still browse and use the basic features of the software in tourist mode (i.e. without being a registered user).
We provide you with fast login through a third-party account. You may use a third-party account (such as Facebook, Google) to log in. In this case, we will obtain the Open ID of your third-party account and link it with your Vskit account. Meanwhile, based on the authorization of the third-party account, we may acquire your nickname and profile photo. In case you login with your Facebook account, based on the authorization of Facebook, we may acquire the date of birth, gender, and list of friends in your Facebook account.
When logging in and using this Application, you may choose to provide, fill in and modify your nickname (including your real name), profile picture (including your real portrait), gender, location in Personal Center. To avoid minors from using our service, you may be required to provide your date of birth. When you choose to provide your information in Personal Center, other users may browse such information through this server to learn more about you. If you have not set a nickname, we will assign a default one to you randomly. You may change your nickname at any time. Your refusal to provide more information will not affect your registration and login. If you refuse to provide such information, you can still use other functions of the application. When you set your profile picture, we will need to access your camera, file and media permission on your device. You may turn off your permission at any time via “System settings->Vskit->Camera permission/File and media permission”.
2.2 Posting local audios and videos
Through this service, you may record audios or videos, take photos and add stickers to them for better effect. You may also post these audio and videos and edit their copywriting in our service. In this case, we will invoke your microphone, camera, media and file permissions. If you refuse to provide the permissions, you will not be able to post videos, but your use of the other functions will not be affected. After turning on the permissions, you may turn them off at any time via “Setting->App manager->App settings->Vskit->Permissions”. When you successfully post a video, we will store your video and copywriting so that they can be displayed to other users in the service. If you refuse to provide the above information, we will not be able to provide you with the video posting service, but you can still use the other services. When you post an audio or video, we will assign an author ID to your account to identify the account from which the video is posted.
When you post a video, you may choose to share the city in which you have recorded the video or your city information. In this case, we will need to access your geographical location permission. After turning on the permission, you can turn it off at any time via “Setting->App manager->App settings->Vskit->Permissions”. After you turn it off, you may still add the tag of your geographical location to your video through manual input/selection. If you refuse to provide your city information, we will not be able to provide you with the location display service when you post an audio or video, but you can still use the other functions.
2.3 Content browse service
- (1)When you use this service, we will record your favorites, likes, your comments, followers and what you have followed so that you can view your use records at any time. Please be aware that when you use the comment function, your account nickname, profile picture and comments will be displayed publicly in the service. Other users can see your comments. If you choose to delete above information, we will no longer store or display it.
- (2)When you browse this service, you may download the content you are interested in. In this case, we will need to access your media and file permissions. If you refuse to provide the permissions, you will not be able to download videos, but your use of the other functions will not be affected. After turning on the permissions, you may turn them off at any time via “Setting->App manager->App settings->Vskit->Permissions”.
- (3)You may report the violation when you browse the content, we may collect your User ID, your Violation Report, or any information you choose to provide. Information above is necessary for this service. We will audit content reported relying on your Violation Report. You may choose to upload relevant pictures to describe your problems more clearly. In this case, we will invoke your picture permission. You may turn off the permission via Setting->App manager->App settings->Vskit->Permissions. After turning it off, you may not upload relevant pictures.
- (4)(4) If you grant us permission to obtain your fuzzy geographical location, we will display content from the same city based on your fuzzy geographical location. You may turn off your authorization via Settings->App manager->App settings->Vskit->Permissions.
- (5)To display and recommend to you the content that you may be interested in (only including audio/video recommendations), we will collect your system information (time zone, OS version, ROM version and Android version), device information (phone brand, model and IMEI), the operator’s code, your favorite record, click record, browse record, followed list, as well as the fuzzy geographical location obtained when you turn on the Location service and your device identifier (GAID) information to predict your preferences. If you released works in Vskit in the past, we will filter your works by your author ID to avoid repeated recommendations. We will make adjustments based on the behavior record generated during your browse of Vskit to continuously improve our recommendations. You may turn off the personalized recommendation via Vskit->ME->Setting->Privacy settings. When you turn off this function, we will not process your personal information for the purpose of personalized recommendation, but we will continue to send you works and content irrelevant to your interest.
- (6)Provided that you have given us the permission to access your contacts or when you use a third-party account to log in and have given us the permission to access your list of friends, if you turn on push notifications, we will send you the audio/video content of a friend that you might know. Please be aware that if the contacts uploaded by other users include your information, we might send your works to users that might know you. We will need to link your account with GAID and identify users who you might know. To perform that function, we will need to invoke your contact permission. You may turn off your permission via Settings->App manager->App settings->Vskit->Permissions. After you turn off the permission, we will no longer acquire your contacts. But if you already used friend recommendation and gave us the permission to access your contacts, we will make recommendations based on the contacts for which you gave the permission previously. If you do not wish to have your works recommended to your friends or not to receive your friends’ works, you may turn off friend recommendation via Vskit->ME->Setting->Privacy settings.
2.4 To provide you with online customer service ([App’s name] bot)
If you encounter any problems with your use of this Application, you can contact us via our online customer service and ask for help. We may collect the content of your enquiry, your device information and application information (such as application version). Such information is required for this service. If you refuse to provide feedback and other related information, we may not provide you with this service, but your use of the other functions of the application will not be affected.
When providing relevant information to us, you may choose to upload relevant pictures to describe your problems more clearly. In this case, we will invoke your picture permission. You may turn off the permission via Setting->App manager->App settings->Vskit->Permissions. After turning it off, you may not upload relevant pictures, but you can still describe your problems in other ways.
You may choose to provide us with your contact information (email, mobile phone number, call records and content or other contact details you leave with us) for the purpose of contacting you or helping you resolve the problem, or recording the solution and outcome of the problem.
In order to provide you with online customer service, we will require your permissions to access the contents in your SD card. If you refuse to provide such information, we may not be able to provide you with this service, your ability to use other features of this Application will not be affected.
2.5 Operating and maintaining this service
- (1)To ensure normal operation of this service, we will collect your phone information (phone model and brand), application information (application package), account type (your User ID or author ID), device identifier (IMEI\GAID), system software information (OS version, Android version, Rom version, system language settings, time zone setting), network information (network type, mobile operator code), IP address and error log information. Such information will be used to analyze and solve software errors and maintain stable software operations.
- (2)To improve the security of your use of our services, to protect you, other users or public safety and property from harm, to better prevent security risks such as phishing sites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and to more accurately identify violations of laws and regulations or our relevant agreement rules, we may use or integrate information about your device, as well as information about the applications you have installed, the information about running processes, the overall operation of the application, the usage frequency of the application, crash data, overall installation and usage, performance data and information about the source of the application, to help you conduct security risk detection, prevent security risks, and take the necessary recording, auditing, analysis and disposal measures in accordance with the law.
- (3)We may also acquire your other information out of the reasonable need to improve our products or services, including the relevant feedback information you provide when contacting our customer service and the responses you send to us when participating in our questionnaires. We may combine information from a service with information from other services to provide you with better services, content and suggestions.
2.6 To provide you with notification services
We may also send you service notifications, events, prizes and other messages based on your device identifier, operating system version, user nickname of current device, network information and information about your use of the app. To unsubscribe from notifications, events, prizes, etc., you can withdraw your consent via Vskit》ME 》General 》 Notitications. The path may vary for different versions.
2.7 Earning center
We might provide you with the “Earning center” operating activity in specific operating areas. You may gain a certain amount of gold coins and exchange them for cash by participating in the activity and completing specified tasks. When you choose to participate in our activity, we will record your browses and tasks in the activity. Meanwhile, your activity data will be linked with your User ID under your Vskit account so that the amount of gold coins owned by you can be recorded and displayed to you.
You may exchange your gold coins according to the activity rules. When you choose to use the gold coins to exchange for mobile phone top-ups, you will be required to fill in your mobile phone number on the activity page to complete the top-up. If you choose to exchange the gold coins for cash, you will be required to provide your PalmPay account ID to complete the exchange. At the same time, we will record your gold coin exchange and cash withdrawal so you can review them. You may exit from the gold coin task via [Activity Page Operation].
To enhance the security of your use of our service and identify violations against laws, regulations, or our relevant protocols or rules more accurately, we might use or integrate your device information (device identifier, UID, IP address) and your activity records to comprehensively detect safety risks, prevent safety risk accidents, take necessary measures in accordance with laws, including recording, auditing, analyzing, and handling.
3. Other situations in which your information may be collected
Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
In order to better improve our product layout and provide you with great services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take technical measures and other necessary measures to process such data, so that the data cannot be re-identified to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such processed data can be used without separately notifying you or obtaining your consent.
1. What are Cookies and Similar Technologies
III. How We Store and Protect Your Personal Information
1. How we store your personal information
The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Currently, Vskit may store your personal information in: Ireland.
According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.
2. How we protect your personal information
We will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
IV. How We Share, Transfer and Disclose Your Personal Information
When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
1. How we share your personal information
We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, (1) To improve the service stability and solve errors immediately, the service has integrated Google’s firebase SDK to acquire your phone information and crash logs. This will help notify us of high-frequency crashes and other errors so that we can perform the repair promptly. (2) To help us do statistics and analysis of the product use, the service has integrated Umeng’s SDK to analyze your personal device information, browse records, click records, IP address and other data. we may embed third party SDK or other similar applications of authorized partners in this Application (We will perform strict safety inspection of them to protect data security).(3) We will share your mobile phone number or payment account ID and the exchange amount with the top-up and payment service providers to complete the exchange of gold coins. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system). When we embed the third party SDK or other similar applications of authorized partners in this Application, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.
In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated data to help partners (e.g., advertising service providers) understand the effectiveness, feedback and usage trends of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.
2. How we transfer your personal information
Vskit will not transfer your information to any other parties, except in the following circumstances:
- (1)Obtain your explicit consent.
- (2)If Vskit is involved in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your personal information, and any choices you may have about your personal information.
3. How we disclose your personal information
According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, Vskit may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
- (1)Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.
- (2)Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.
- (3)Other third parties, for example, the disclosure of specific information with your authorization.
V. How Your Personal Information is Transferred Across Borders
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
VI. Your Rights to Your Personal Information
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
1. Right to confirm and access
2. Right to correct and delete
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when we are legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
3. Right to withdraw consent
To achieve the respective features of our various products or services, we will require necessary personal information in accordance with the applicable local laws. This is described in the "How We Collect and Use Your Personal Information" part of this Policy. You can withdraw your consent previously granted to us for a specific purpose by deleting information, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your personal information that we manage or control. You can email us at firstname.lastname@example.org for above operations. We will process your request within a reasonable time after you send the request, and thereafter will not collect, use and/or disclose your personal information in accordance with your request.
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of Vskit and its Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
4. Right to complain
You have the right to lodge a complaint by sending us an email at email@example.com. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
5. Right to control your privacy settings
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via “Setting->App manager->App settings->Vskit->Permissions” or contact us via firstname.lastname@example.org to change your decision.
6. Right to cancel a service or account
You can request to cancel through the “Logout” settings provided in the service or by contacting us via email@example.com. We hereby kindly remind you that, if you wish to cancel a certain service or account, such cancellation may prevent you from using some of Vskit features and its services, and such act of account cancellation is irreversible. Once you cancel your account, we will delete or de-identification your relevant information. If you sign in to the accounts of Vskit through a third-party account, you need to apply for cancellation of the account from the third party.
7. Rights in some jurisdictions
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:
- (1)Right to restriction processing. You have the right to request our restriction on the processing of your personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the compliance with applicable data protection laws, we will process your personal information under applicable circumstances in such laws and notify you before the restriction of processing is lifted.
- (2)Right to automated decision-making. You have the right to refuse the processing based on automated decision-making, including profiling and other automated processing which may have legal or similar effects on you.
- (3)Right to data portability. You have the right to apply for your personal information to be transmitted to another data controller in a structured and commonly used format.
We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
VII. How We Handle the Personal Information of Children
Vskit does not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal information for the purposes of marketing. If you find that a child’s information has been collected to us, please send an email to firstname.lastname@example.org to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from Vskit as soon as possible.
VIII. Third-Party Service Providers and Services
IX. Supplement and Update of the Policy
The content of Vskit and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
X. Joint Controller
Shanghai Xiaochuan Technology Co., Ltd. is a joint controller with us and we are jointly responsible for processing your personal information. COIHUB TECHNOLOGY LIMITED and Shanghai Xiaochuan Technology Co., Ltd. have allocated respective responsibilities according to applicable laws. You can contact us for more details regarding the joint controllership by the contact information in section x. "How to Contact Us".
XI. How to Contact Us
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.