Privacy Policy

The privacy policy is provided by HUNDRED YEARS LIMITED (hereinafter as "We" , "we" , “our”, “us”) and applies to Circle APP. Circle collects information from you in order to provide better service and give you a better user experience. We always put your privacy as the first consideration. We respect the privacy of every individual user of our applications and services.

WHAT INFORMATION WE COLLECT AND USE

We collect personal information to implement significant features and provide you better experience. This information includes:

Device Information. We collect device-specific information (your hardware manufacturer & model, operating system version, screen size, CPU model, unique device identifiers, mobile network information, country, language) by the API in our App provided by IOS and third-party automatic data processing technologies (Google FireBase, Twitter Fabric, Appsflyer). We collect this information to implement app features, provide our services, and improve the app performance for all our users. The purposes of the Device Information is: (i) to operate and update the Circle APP and our services; (ii) to provide you with existing and new functionality and features, and notify you about our new personalized service in advance; (iii) to maintain and improve the quality and operation of the Circle APP and our services; and/or (iv) to analyze what media source user comes from.

App Usage Data. When you use our App, we, by API provided by IOS, Google FireBase, Twitter Fabric or Appsflyer, will collect your behavior information including how frequency you use our App, how long you may use and your usage path when using our features. We collection such information to improve the user experience. The purpose of the App Usage Data is: (i) to improve and customize the Circle APP and our services; (ii) to take any action in case of a dispute involving you in connection with the Circle APP and our services; and/or (iii) to enforce the terms and conditions applicable to the Circle APP and our services and to prevent unlawful activities and misuse thereof.

Social Networks. Such information we collect including your profile (such as your nickname, photos of your avatar), your relationship and your interactions on social networks through our Circle APP and our services. All of this information is submitted by you, and we will upload it to our server. The purposes of the social networks is: (i) to improve and customize the Circle APP and our services; and/or (ii) to provide you personalized content.

HOW WE PROTECT YOUR INFORMATION AND HOW LONG WE RETAIN YOUR INFORMATION

The security of user’s information is our utmost priority, and we take strict measures in order to protect the data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s information.

We also protect user’s privacy by seeking to minimize the amount of sensitive data and PRI. We also seek appropriate contractual protection from our partners regarding their treatment of user data. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

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

HOW WE SHARE YOUR INFORMATION

We may share with third parties the information collected in any of the following events: If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the our users, its partners, or the general public).

In the event we goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred.

For your better use of the Circle APP, our services and services provided by third parties , we may share your information with certain third parties (including, without limitation, search engines, content providers, and advertising networks and platforms) that provide various services (such as advertising, marketing, analysis, content, and search) in connection with the Circle APP and our services. We take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with services, and (iii) to use the data solely in compliance with this Privacy Policy. If you want to delete any personal data which we have shared with the third parties, please contact us by email at: hundredyears.app@gmail.com. We would try our best to notify the third party of deleting the relative personal data, but no warranty as to the deletion is made by us.

We may also share PII with our subsidiaries, affiliated and parent companies, but their use of such information must comply with this Privacy Policy. In any case other than the above, we will not share your PII with third parties without your prior consent.

INFORMATION MAY BE COLLECTED BY THIRD-PARTY

Certain software and services may include and/or enable you to add content to them. The content may be in the form of buttons, gadgets, links to third party advertisements, websites, products and services (including search services) as well as additional means that are provided to you by third parties (collectively, "Third Party Content and Services"). The use of such Third Party Content and Services is subject to their privacy policies. You shall be aware that the use of the Third Party Content and Services may give these third parties the ability to access, collect, store, and/or share your information, both your PII and non-personally identifiable information. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Content and Services and your access to any Third Party Content and Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Content and Services. You expressly relieve us from any and all liability arising from your use of such Third Party Content and Services. We recommended that you read the terms, conditions and privacy policies of such Third Party Content and Services before using or accessing any of them.

For providing customized advertisement, the third-party advertising companies may collection or use your personal information (not including your name, address, email address or telephone number) when you use the Circle APP or our services.

YOUR DATA RIGHTS

You have the right to access, modify, correct or delete any personal data which we may have collected.

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA. To exercise this right please contact us by email at: hundredyears.app@gmail.com.

NOTICES

If we are required to provide you with notice of a particular event or incident, we will send you such notice by mail, email or telephone.

CHILDREN'S PRIVACY

We ensure that we comply with the Children's Online Privacy Protection Act (COPPA), and does not knowingly collect personal information about Users of Apps directed to children under the age of thirteen (13). If you are in the EEA, our services are not directed to children under 16 and we do not knowingly collect PII from children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.

TRANSFER OF DATA OUTSIDE YOUR TERRITORY

The Software and services work over the Internet. We may store and process your information in various locations throughout the world. Where you located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where may be outside of EEA once you use the Circle APP and/or our services. You may withdraw your consent at any time by contacting us.

CHANGES TO THE PRIVACY POLICY

In its sole discretion, Circle may change this Privacy Policy from time to time, any and all changes will be reflected here. The date of new versions posted will be stated at the top of this Privacy Policy, so please review it periodically. We’ve tried to keep the Policy simple, but if you have any questions on the privacy or our privacy practices, or to report any violations of the Policy or abuse of the Circle APP or our services, please feel free to contact us via email: hundredyears.app@gmail.com.

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