What information do we collect about you?

We collect and process information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform.  We also collect information about you if you download the app and interact with the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it.

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as HOOH, content moderation services, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise or defence of legal claims.

How will we notify you of any changes to this Privacy Policy?

We will generally notify all users of any material changes to this policy through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

We collect and use the following information about you:

Your Profile Information. You give us information when you register on the Platform, including your username, password, email address， information you disclose in your user profile, and your photograph.

User Content and Behavioural Information. We process the content you generate and view on the Platform, including preferences you set (such as choice of language) photographs, text content、and comments you make (“User Content”). We may access text content found in your device’s clipboard, with your permission. For example, if you choose to initiate content sharing with a third- party platform, or choose to paste content from the clipboard into the HOOH App, we access this information stored in your clipboard in order to fulfill your request. We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the content you view, the content you like, the content you save to ‘My Favourites’, the users you follow and how you engage with mutual followers. 

Information from Third Parties. You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:

Advertisers, Advertising Networks, and Analytic Providers

We use the information collected from you, and your interaction with the Platform and other third-party sites and Apps, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you’ve visited, apps you’ve downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our Platform and from similar information received from third parties who advertise on our Platform and whose sites/Apps you visit.

Technical Information we collect about you. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform. 

Location. We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

We will use the information we collect about you in the following ways:

• notify you about changes to our service;
• provide you with user support;
• personalise the content you receive and provide you with tailored content that will be of interest to you;
• enable you to share User Content and interact with other users;
• enable our messenger service to function if you choose to use this function;
• enable you to participate in the virtual items program;
• communicate with you;
• to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform;
• ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
• ensure content is presented in the most effective manner for you and your device;
• improve, promote and develop the Platform and promote popular topics, hashtags and campaigns on the Platform;
• carry out data analysis and test the Platform to ensure its stability and security;
• allow you to participate in interactive features of the Platform;
• to enable you to socialise on the Platform;
• provide you with personalised advertising;
• provide you with location-based services (where those services are available in your jurisdiction);
• To inform our algorithms；
• enforce our terms, conditions and policies;
• administer the Platform including troubleshooting.

We share your data with the following selected third parties:

Service Providers 

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place and service providers that assist us in marketing the Platform.

Analytics providers 

We use analytics providers to help us in the optimisation and improvement of the Platform.  Our third-party analytics providers also help us serve targeted adverts

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

• comply with legal obligation, process or request;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Public Profiles

Please note that if your profile is public, your content will be visible to anyone on the Platform. You can change who can see your content each time you post.

Sale or Merger

We will also disclose your information to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets;
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

The personal data we collect from you may be stored on a server located in Singapore or the United States, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

You can access and edit most of your profile information by signing into HOOH. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your videos, send you messages, or post comments to your videos. Should you choose to do so, you may delete your entire account in Settings. You may also be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. If you have any questions on how to use the above tools, want to know about what rights you may have or want to exercise them, or have any requests, inquiries, or complaints, please contact us at: hooh-contact@hooh.zone

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

We retain your information for as long as it is necessary, for example, to comply with our contractual relationship or to provide you with our service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, as may be allowed by applicable laws. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

In the event that you wish to make a complaint about how we process your personal data, contact us immediately at: hooh-contact@hooh.zone. We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

If you have questions, comments, or requests regarding this policy, contact us at: hooh-contact@hooh.zone