Website (International Version) Privacy Policy
Last Updated: 30 October 2024
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.Please note that this privacy policy (“Privacy Policy”) only applies to the website and web platform for the international version of Bugly (the “Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Hong Kong Gathering Media Limited.
SUMMARY
Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.
| What information do we need to be able to provide the Service? | - If you need to get in touch with us, we will retain some information (such as your email, name, Company Name, cell phone number, Weixin/WeChat account number, and, if applicable, any messages you send us) so that we can review and respond to your queries/requests. - If you register an account for or log in to use the Service, we will need some information from you to set this up. This includes your country/district, name, and your email address. - Only after you or your company purchases our Service, we will need more information to provide the Service to you or your company. This includes, pending on the scope of the Service purchased by you or your company, the information collected from your Apps/Products via our Service and analysis reports generated therefrom. | More Information. |
|---|---|---|
| How will we use your information? | - We use your information to set up your account, enable you to use the Service, and to comply with our legal obligations and enforce our legal rights. | More Information. |
| Who do we share your information with? | - We use third parties and work with our affiliates to help us deliver the best possible experience to you. - All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above). - In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information. | More Information. |
| Where do we process your information? | - Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. - We have servers for the Service in Singapore. We also have support, engineering and other teams who may support the Service, including from the People’s Republic of China. | **More Information. |
| How long do we keep your information? | - Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws. | **More Information. |
| How can I exercise my rights over my information? | - Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. | **More Information. |
| How will we notify you of changes? | - Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements. | **More Information. |
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the website and web platform for the international version of Bugly (the “Service”) and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.
Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Hong Kong Gathering Media Limited (“we”, “us”, “our”). If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us to reach out data protection officer at dpo@centauriglobal.com.
1. How We Process Your Personal Information
This section provides more detail on the types of personal information we collect from you, and why.
| Personal Information | Use | Legal Basis (where applicable) |
|---|---|---|
| Information you provide to us (either directly or through a third party) | ||
| country/district, name, and email address | We use this information to allow you to register and create your account for the Service and allow you to log in to the Service. | Necessary to perform our contract with you to provide the Service. |
| email, name, Company Name, cell phone number, Weixin/WeChat account number, and, if applicable, any messages you send us | We use this information to allow you to get in touch with us and for us to respond to you. | Necessary to perform our contract with you to provide the Service. |
(Only after you or your company purchases our Service) Pending on the scope of the Service purchased by you or your company, the information collected from your Apps/Products via our Service and analysis reports generated therefrom. Please note, you or your company is solely responsible for notifying your end users of the Apps/Products or seek their consents to collect the information needed for us to perform the Service. | We use this information to allow you to use our Service and check status of the Service provided by us. | Necessary to perform our contract with you to provide the Service. |
2. How We Store and Share Your Personal Information
Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.
We have servers for the Service in Singapore. We also have support, engineering and other teams who may support the Service from the People’s Republic of China.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
- Third parties that provide services in support of the Service, including providing cloud storage services, and platform development services. All third-party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).
- Companies within our corporate group that process your personal information solely for the purpose of providing the Service to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
- Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
- Third parties to ensure safety, security, or compliance with laws. We may disclose your information to (a) enforce our terms and conditions and other agreements, including investigation of any potential violation thereof; (b) detect, prevent or otherwise address security, fraud or technical issues; or (c) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
3. The Security of Your Personal Information
We have information security and access policies that limit access to our systems and technology, and we protect data using technological protection measures such as encryption and implementing system access controls. Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.
4. Data Retention
We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law.** If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.
For further details on how long we keep your data, please refer to the time periods set out below.
| Personal Information | Retention Policy |
|---|---|
| country/district, username, and email address | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. |
| Email, name, Company Name, cell phone number, Weixin/WeChat account number and, if applicable, any messages you send us | Deleted if we do not or cease to respond to your messages within 30 days. |
(Only after you or your company purchases our Service) Pending on the scope of the Service purchased by you or your company, the information collected from your Apps/Products via our Service and analysis reports generated therefrom. Please note, you or your company is solely responsible for notifying your end users of the Apps/Products or seek their consents to collect the information needed for us to perform the Service. | For the information collected from your Apps/Products via our Service, stored for 90 days. For the analysis report generated from the collected information, stored for 2 years. |
5. Your Rights
You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please [**contact us**](#_contact).Access
You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.
Portability
You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in Section 1 (How We Process Your Personal Information). We will provide further information to you about transferring this data if you make such a request.
Correction
You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account or contacting us if there is any need for correction.
Erasure
You may be able to delete your account, or remove certain personal information, by logging into your Service account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You may have the right to object to our processing of your personal information. If you wish to do so, please contact us.
Consent Withdrawal
To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by **contacting us.* Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.* Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.
6. Contact
Please get in touch with us if you have any questions. You can reach us in the first instance at bugly@tencent.com.**
We will endeavor to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.
7. Changes
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
8. Language
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.