POKO PRIVACY POLICY

 

 

SECTION 1 GENERAL TERMS

1.1. HUYA PTE.LTD (¡°POKO¡±), a company incorporated under the laws of Singapore, has developed and operated a software program (an app) named ¡°POKO,¡± a live streaming network/platform (the ¡°Platform¡±), designed for you (the ¡°User¡±) to access the contents that is made available on or through the Platform over the Internet (the ¡°Web Service¡±)

 

1.2. This POKO PRIVACY POLICY (the ¡°Privacy Policy¡±) applies to the User¡¯s access and use of the Platform and/or the Web Service and is meant to help the User understand how POKO collects, uses, and discloses the User¡¯s information. By downloading or using the Platform, or accessing the Web Services, the User declares that he/she has read, understood and consented to the provisions of this Privacy Policy in its entirety. If the User does not consent to this Privacy Policy in its entirety, he/she shall not use or access the Platform and/or the Web Service.

 

1.3. The text of this Privacy Policy may be modified from time to time due to changes of applicable regulations and policies, products and operational needs. The modified Privacy Policy will be published on POKO, and the publication of the modified Privacy Policy shall mean that POKO has appropriately informed the User of the modification of this Privacy Policy. If the User objects to the modified Privacy Policy, the User shall stop accessing the Platform, using the Web Service and/or deleting his/her POKO account immediately. If the User continues to access the Platform or use the Service, regardless of the way the User accesses or uses, the User is deemed to have agreed with the modified Privacy Policy.

 

1.4. If the User is a minor, the User must read this Privacy Policy with his/her statutory guardian, and only consents this Privacy Policy upon the approval of his/her statutory guardian.

 

SECTION 2 WHAT AND HOW INFORMATION IS COLLECTED

2.1. ¡°User Information¡± means the personal information and data that can be used to identify such User, including, but not limited to, name, nickname, gender, date of birth, email address, telephone number, credit card number, billing information, personal photo or pictures, other relevant data in connection with the User¡¯s personal account on the Platform and other platforms and service providers, and data and information created, provided or shared by the User.

 

2.2. The User Information may be collected by the following means:

 

2.2.1. Information created and/or provided by the User:

 

When the User creates a POKO account; creates, uploads, purchases, views, or downloads certain content or products on or from the Web Service; or otherwise uses the Web Services, the User may provide POKO with a variety of the User Information.

 

2.2.2. User Information that POKO collects as the User uses the Web Service:

 

i. The User¡¯s apps, browsers and devices: When the User connects to the Web Service, POKO may, by using cookies or other technologies, collect certain User Information about the apps, browsers, and devices the User uses to access the Web Service, such as: unique identifiers, advertisement identifiers, browser type and settings, device type and settings, language, operating system and its version, mobile network information including carrier, and application version number, IP address, unique user ID, crash reports, system activity, date and time of request, and referrer URL, etc. For further information regarding ¡°cookies¡±, please refer to Article 8 below.

 

ii. The User¡¯s activities: POKO may collect information about the User¡¯s activities in the Web Service, which may include: the User¡¯s views and interactions with content on the Web Service, purchase activity, people the User communicates or shares content with, activity on third-party sites and apps that concerns the Web Service, etc.

 

iii. The User¡¯s location information: POKO may collect information about the User¡¯s location whenever the User uses the Web Service. The User¡¯s location can be determined with varying degrees of accuracy by: GPS, IP address, sensor data from the User¡¯s device, information about things near the User¡¯s device such as Wi-Fi access points, cell towers, and Bluetooth enabled devices.

 

2.2.3. Other Sources:

 

POKO may obtain additional User Information from any third party or any source other than the Web Service, for which the User has approved POKO¡¯s access. For the purpose of this Article, when the User accesses the Web Service through a third-party service, connects to a third-party service through the Web Service, or otherwise links the User¡¯s POKO account with a third-party service, the User has approved POKO¡¯s access to the User Information from such third-party service.

 

Please note that in order to provide the Web Service to the User, POKO needs certain types of User Information. If the User does not provide POKO with such information, or asks POKO to delete it, the User may no longer be able to access or use the Web Service.

 

SECTION 3 WHY POKO COLLECTS INFORMATION

POKO uses the User Information that POKO collects for the following purposes:

 

3.1. Provide, maintain and improve the Web Service, and develop new services:

 

POKO uses the User Information to operate, maintain, enhance, provide, create, and develop all of the features, functions and services of the Platform and the Web Service; automatically update the POKO application on the User¡¯s system; and remember the User Information so that the User will not have to re-enter it during the User¡¯s visit or the next time the User accesses the Web Service.

 

POKO may also use the User Information POKO collects in the existing Web Service to help POKO develop new services.

 

3.2. Communicate with the User:

 

POKO uses the User Information POKO collects, like the User¡¯s name, email address,  to communicate and interact with the User directly. For example, POKO may send notifications to the User, notify the User about upcoming changes or improvements on the Web Service, or contact the User regarding any content that the User has posted to or downloaded from the Web Service. In addition, if the User contacts POKO, POKO will keep a record of the User¡¯s request in order to help solve any issues the User might be facing.

 

3.3. Provide personalized services, including content and promotion:

 

POKO uses the User Information to customize the Web Service for the User and improve the User¡¯s experience with the Web Service, including providing content recommendations and delivering content that POKO hopes the User will find relevant and interesting, including advertising and marketing messages. POKO may also periodically send promotional materials or notifications to the User in relation to the Web Service.

 

3.4. Measure performance:

 

POKO may use data for analytics and measurement to understand how the User reacts to the Web Service. For example, POKO analyzes data about the User¡¯s visits to the Web Service to do things like optimize product design, monitor and store aggregate site usage metrics, such as total number of visitors and pages accessed, or understand the usage trends of POKO¡¯s user. If applicable, POKO also tracks the User¡¯s entries, submissions, and status in any promotions or other activities, and uses such data about the promotions the User interacts with to help advertisers understand the performance of their promotional campaigns.

 

3.5. Protect POKO, users, and the public:

 

POKO uses information to help improve the safety and reliability of the Web Service. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm POKO, the Platform, POKO¡¯s users, or the public.

 

3.6. Other certain purposes:

 

POKO may collect and process the User Information to perform its obligations as required by law or any court of competent jurisdictions or by any governmental, official or regulatory body.

 

In addition, to the extent permitted by the applicable law, POKO may collect and process the User Information to honor contractual commitments, to take steps in anticipation of entering into contract, to fulfill POKO¡¯s contractual obligations, and to protect POKO¡¯s legitimate interests.

 

SECTION 4 WHEN INFORMATION IS SHARED

4.1. When the User shares the User Information:

 

Many functions of the Web Service let the User share information with other people, and the User has control over how he/she shares. For example, the User can share a content on POKO publicly or the User can decide to keep such content private. Remember, when the User shares information publicly, the User Information may become accessible through search engines.

 

When the User signs in and interacts with others in his/her use of  Web Service, like leaving comments on live-broadcasting, the User¡¯s name and photo may appear next to the User¡¯s activity.

 

4.2. When POKO shares the User Information

 

4.2.1. With the User¡¯s consent:

 

POKO will share User Information outside of POKO when POKO has the User¡¯s consent.

 

4.2.2. Share to affiliates, subsidiaries and personnel:

 

POKO may disclose the User Information to its affiliates (meaning any entity that, directly or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with POKO), subsidiaries, and personnel (meaning any shareholder, director, consultant, officer, employee, servant or other personnel of POKO or its affiliates or subsidiaries, and other professional, financial, legal or accounting advisers of POKO) in order to refine and develop the business strategies and investment plans. POKO¡¯s affiliates, subsidiaries and personnel receiving the User Information shall be subject to this Privacy Policy and will use the User Information within the aforesaid purposes and will strictly keep the User Information confidential.

 

4.2.3. Share to relevant service providers and partners:

 

POKO may disclose the User Information to service providers working on POKO¡¯s behalf, such as those to provide website hosting, maintenance, and security services; to conduct data analysis and create reports; to offer and improve certain functionality; or assist POKO in improving the Web Service and creating new services and features. POKO may also allow specific partners to collect information from the User¡¯s browser or device for advertising and measurement purposes using their own cookies or similar technologies.

 

POKO will require that these parties use the information only for the purposes for which it is provided to them, and process such information in compliance with this Privacy Policy.

 

4.2.4. Share to third-party service to which the User has access:

 

If the User connects to a third-party service through the Web Service or otherwise links the User¡¯s POKO account with a third-party service, the User is requesting and authorizing POKO to share or grant access to information on the User¡¯s behalf with such third party. POKO may also send information about the content the User watches or the User activities on the Web Service to such third party in order to upgrade the User¡¯s experience in his/her use of the Web Service.

 

4.2.5. International data transfer:

 

User Information collected by POKO may be stored and processed in the User¡¯s region, in POKO¡¯s major data centers, or in any other country where POKO or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities.  If POKO provides any information about the User to any such entities, POKO will request such entities to adequately protect the User Information in accordance with this Privacy Policy.

 

4.2.6. For legal reasons:

 

POKO will share the User Information outside of POKO if POKO has a good-faith belief that access, use, preservation, or disclosure of the User Information is reasonably necessary to:

 

i. meet any applicable law, regulations, legal processes, or enforceable governmental requests;

 

ii. enforce applicable terms of service under the POKO User Agreement and POKO Host Broadcast Agreement, including investigation of violations;

 

iii. detect, prevent, or otherwise address fraud, security, or illegal matters; and

 

iv. protect against harm to the rights, property or safety of POKO, POKO¡¯s users, or the public as required or permitted by the applicable law.

 

4.2.7. Share non-personally identifiable information:

 

POKO may share non-personally identifiable information publicly and with any third party. For example, POKO may share publicly available information to assess or demonstrate trends about the general use of the Web Service.

 

SECTION 5 USER¡¯S PRIVACY CONTROLS

5.1. Declining to share certain User Information

 

The User may decline to share certain User Information with POKO, in which case POKO may not be able to provide to the User some of the features and functions found on the Web Service.

 

5.2. Managing, reviewing, and updating User Information

 

The User can always review and update his/her profile information and preferences by logging in and going to the setting page of the Platform.

 

5.3. Safekeeping account and password

 

After the User is successfully registered, POKO will assign the User a user account with a password, the safekeeping of which shall be the responsibility of the User at all time. The User shall bear full legal liability for all behavior and activities conducted through his/her POKO account.

 

5.4. Account deletion

 

If the User would like to delete his/her POKO account, the User will send a written request to POKO at feedback_EN@POKO.tv. After receiving such request, POKO will verify the User¡¯s identity, review the status and activities performed through the User¡¯s POKO account and decide whether or not to delete the User¡¯s POKO account.

 

To learn more about how the User can exercise his/her privacy choices, the User can contact POKO at feedback_EN@POKO.tv. For other requests to review, update, delete, or otherwise limit POKO¡¯s use of information that the User have provided directly to POKO, the User may also contact feedback_EN@POKO.tv. To protect the User¡¯s privacy and security, POKO may take steps to verify the User¡¯s identity before granting the User access or making corrections to the User Information.

 

SECTION 6 TECHNICAL AND ADMINISTRATIVE MEASURES TO PROTECT USER INFORMATION

6.1. Password encryption

 

The password of the User¡¯s POKO account is stored and managed with secure encryption. No other user or other third-party will be entitled to know the User¡¯s password.

 

6.2. Measures against hacking

 

POKO is doing its best to prevent leakage or damage of personal information of the User caused by hacking or computer viruses. In order to prevent personal information from being damaged, POKO is backing up the data on a regular basis. The latest vaccine program is used to prevent personal information or data from being leaked or damaged, and to securely transmit personal information on the network with encryption. POKO uses intrusion prevention system to control unauthorized access from outside, and tries to have all possible technical devices to secure it systematically.

 

6.3. Data processors and operation of personal information protection department

 

POKO trains its data processors through regular trainings and emphasize to comply with personal information processing policies.

 

In addition, through the internal personal information protection department, POKO checks the implementation of the personal information processing policy and compliance with the person in charge, and is working to correct and rectify any problems that are found. However, POKO shall not be held responsible for damages that are not attributable to POKO, so long as POKO has fulfilled its obligation to protect personal information, such as carelessness of users or accidents in areas not controlled by POKO.

 

POKO uses a variety of managerial, technical, and physical measures to protect the integrity and security of the User Information as aforementioned. These measures may vary based on the sensitivity of the User Information. However, no security precautions or systems can be completely secure. POKO cannot ensure or warrant the security of any information the User transmits to POKO, and the User does so at the User¡¯s own risk. POKO cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of POKO¡¯s physical, technical, or managerial safeguards.

 

SECTION 7 ADVERTISERS AND ANALYTICS PROVIDERS

7.1. POKO may use third-party Web analytics services in connection with the Web Service. These service providers use a variety of tracking technologies such as cookies to analyze how users use the Web Service. The information collected will be collected directly by these service providers to evaluate the User¡¯s use of the Web Service.

 

7.2. POKO may allow advertisers, third-party advertising networks and third-party advertising serving companies to serve advertisements directly to the User within the Web Service and other POKO sites, services and software. By serving these advertisements directly to the User, these companies can set their own cookies on the User¡¯s computer and trigger their own Web beacons and other tracking technologies to measure the effectiveness of their advertisements, and to collect and track information such as demographic information, inferred interests, aggregated information, and activity to assist them in personalizing the advertising content delivered to the User. If the User responds to an advertisement that targets a certain audience, the advertiser or ad-server may conclude that the User fits the description of the audience that they were trying to reach.

 

7.3. This Privacy Policy does not apply to, and POKO cannot control the tracking technologies and activities of, other advertisers, third-party advertising networks, or third-party advertising servers. The User should consult the respective privacy policies of these advertisers, third-party advertising networks, or third-party advertising servers.

 

SECTION 8 COOKIES

8.1. When the User uses or accesses the Web Service, the User¡¯s device will automatically be issued with a cookie. Cookies are small text files containing a string of alphanumeric characters that are sent to the User¡¯s browser. POKO may from time to time circulate and modify a policy regulating about what cookies are, how they work, how POKO uses them, and how to remove them, etc.

 

8.2. Depending upon the type of device the User is using, the User may set his/her device to accept all cookies, to notify the User when a cookie is issued, or not to receive cookies at any time. If the User sets his/her device not to receive cookies, certain personalized services cannot then be provided to the User.

 

8.3. POKO uses ¡°cookies¡± to store and track information about the User and the User¡¯s use of the Web Service. Information retrieved from POKO¡¯s cookie is used in line with the uses set out in this Privacy Policy and more specifically to:

 

i. help save and retrieve passwords used on the Web Service. This way, the User will not have to re-enter information upon every new visit to the Web Service;

 

ii. track information such as the frequency and duration of the User¡¯s use or visit to the Web Service, the User¡¯s click-stream as the User goes through the Web Service, the User¡¯s preferred websites and to help POKO determine whether the User came to the Web Service from a particular Internet link or banner advertisement;

 

iii. analyze the profile of visitors and users to help POKO provide the User with better services and to enhance the Web Service; and/or

 

iv. personalize the content, banners and promotions that the User will see on the Web Service.

 

8.4. Most cookies are ¡°session cookies¡±, meaning that they are automatically deleted from the User¡¯s device at the end of a session. The User is always free to decline cookies if the User¡¯s device permits, although in that case the User may not be able to use certain features of the Web Service and the User may be required to re-enter his/her password more frequently during a session.

 

8.5. POKO may use other third-party advertising companies to serve ads when the User accesses and/or uses the Web Service. In the course of serving advertisements, the third-party advertisers may place or recognize a unique cookie in the User¡¯s device. These companies may use information retrieved from their cookies to provide advertisements on the Web Service and other services about goods and services that may be of interest to the User.

 

8.6. POKO has no access or control over third party cookies and they are not subject to this Privacy Policy. Please review the respective privacy policies of these third party websites for further details in this regard. If the User wants to prevent one of these third-party companies from sending and reading cookies on his/her device, he/she will need to visit each of their websites individually to request that he/she be removed from that system.

 

SECTION 9 COMPLIANCE AND COOPERATION WITH REGULATORS

9.1. POKO maintains servers around the world and the User Information may be processed on servers located outside of the country where the User lives. Data protection laws vary among countries, with some providing more protection than others. Regardless of where the User Information is processed, POKO applies the same protections described in this Privacy Policy.

 

9.2. When POKO receives formal written complaints, POKO responds by contacting the person who made the complaint. POKO works with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of the User¡¯s data that POKO cannot resolve with the User directly.

 

9.3 Please note that in some circumstances, POKO may need to keep processing the User Information for certain legitimate interests or to comply with a legal obligation.

 

SECTION 10 MISCELLANEOUS

10.1. In the event that POKO, or some or all assets in relation to the Web Service are acquired by or merged with a third-party entity or in connection with a contemplated change of ownership transaction, POKO reserves the right, in any of these circumstances, to transfer or assign the information that POKO has collected from users as part of that merger, acquisition, sale, or other change of control event, including in the course of diligence.

 

10.2. The Web Service may link to third-party websites or services. The privacy practices of those third parties are not governed by this Privacy Policy. Therefore, it is advisable that the User reviews the privacy policies of these third-party websites and services to understand their practices.

 

10.3. The articles titles and headings used in this Privacy Policy are provided solely for convenience, and shall have no contractual or legal significance.

 

10.4. This Privacy Policy may appear in different languages, and if there occurs any discrepancy or inconsistency, the English version shall prevail.

 

10.5. The User can contact POKO with any questions or comments about this Privacy Policy by email to pokogameteam@gmail.com.

 

 

 

 

 

Date :March 19, 2019