EngageLab プライバシーポリシー

1. 1. How We Collect & Use Your and/or Your End Users` Personal Information
2. 2. Cookies & Similar Technologies
3. 3. Authorization and consent of End User
4. 4. How We Share, Transfer and Disclose Your and/or Your End Users` Personal Information
5. 5. How We Store Your and/or Your End Users` Personal Information
6. 6. How We Protect Your and/or Your End Users` Personal Information
7. 7. How to Access & Control Your Personal Information
8. 8. How We Process Children's Personal Information
9. 9. Updates to This Policy
10. 10. How to Contact Us
11. 11. Other Legal Grounds of Personal Information Processing (EEA Only)
12. Appendix 1: Keyword definition

1. How We Collect & Use Your and/or Your End Users` Personal Information

Regardless of how we collect and use personal information from you and/or your end users, we would usually do so by obtaining consent. In some cases, we may collect and use your and/or your end users' personal information without consent based on legal obligations or in order to protect your or any other individual`s vital interest.

Please understand that in order to better provide technology and services to you and / or your end users, or due to changes in business strategies, the functions of products and / or services on this platform may also be changed and developed. If we want to use the personal information of you and / or your terminal users for other purposes not specified in this policy, or the personal information collected for specific purposes will be used for other purposes, or our processing methods will change, we will inform you in a reasonable way through this platform, and obtain your consent again before use. Please inform your users and obtain the authorization of users.

In order to achieve full functional requirements, EngageLab services may remain open in the front and back of the application. While the EngageLab service is open, the purpose, method, types and rules of personal information we collect and process information about you and your users are as follows:

• 1.1 Information belong to you as a EngageLab developer customer (or potential developer customer)

  In order to realize the basic business functions of the platform, we may need to collect and use relevant personal information from you. The following is a specific description of our basic business functions and the types of your personal information. If you refuse to provide such information you may not be able to use the related products and/or services of the platform.

  When you register/login to the EngageLab account, you need to provide your email address ,password and phone to complete the account registration. You can also complete the registration by authorizing a third-party account. At this time, we will automatically obtain your email address,and you also need to provide us with your business website and phone, so that we can communicate with you about product usage and payment. Even if you do not register an EngageLab account, you can choose to provide us with relevant information (eg, name, work email, job title, phone number, company name) so that we can communicate with you about our products. We collect your payment and billing information when you use our paid services/products. For example, we may ask you to provide a billing address or a billing contact for your EngageLab account in order for us to send you a bill.

  When you browse or log in to use our products/services, we will collect your system time and time zone, so that we can count user traffic according to time and time zone, conduct data analysis and improve our services; we will collect your cookie information , used to identify the logged-in user; we will collect the browser language type you choose when using the service, and switch the website text language according to different language types, so that you can read and use our products; we will also collect User-Agent information, through identification The browser type and version are compatible with differences in browser API, so that you can better use the services of our platform.

  When you use our WhatsApp Business API service, you authorize us to obtain your WhatsApp business account information and sending number information so that you can use WhatsApp to send messages; at the same time, you authorize us to obtain your WhatsApp billing information so that we can collect service fees to you.

• 1.2 Your end user's personal information

  In order to realize the business functions of the platform, we may need to collect and use relevant personal information from your end users. Following is a specific list of our basic business functions and the types of personal information we collect and use. We would collect and use the personal information only if you have confirmed that the end user's consent are already obtained.

  • 1.2.1 Information about end users collected by our APP Push SDK

    When implementing the APP Push service, we will collect the device information to ensure the compatibility of the service on different devices and accurate delivery of messages; ANDROID_ID of your end user to generate the unique user ID of our platform to provide you with a more accurate information push service; Network information (including network type, operator information) used to determine the network connection status between the SDK and the server to ensure the stability and continuity of services;Push information log used for you to query push service records and understand the delivery status of push information.we will also collect the mobile phone manufacturer of your end user Channel information, call different push channels according to manufacturers to improve the reach rate of push information.

  • 1.2.2 Information about end users collected by our Web Push SDK

    When implementing Web push services, we will collect your end user's device information and browser information (browser brand, browser version number) to ensure the compatibility of the service on different devices and accurate delivery of messages.

  • 1.2.3 Information about your end users provided by you in email,SMS,WhatsApp Business API and OTP

    When you use our email service, you will upload the email address and email content of your end user who intends to send email information in our platform account for sending email information; when you use our SMS service, you will upload the mobile phone number and SMS content of the end user who intends to send the SMS, to realize the sending of theSMS.When you use our WhatsApp Business API service, you will upload the WhatsApp account information and message content of the end user who intends to send WhatsApp messages in our platform; when you use our OTP service, your end user's email address, mobile phone number, and WhatsApp account will be uploaded to our platform account (It depends on the OTP channel you use.) to send and verify the verification code to your end user.

    When you turn on the email tracking function, you can understand the reach of the information you send. We will collect data on your end users opening, clicking, unsubscribing emails, IP, device brand, browser, operating system and other information; when the SMS tracking function is turned on, you can understand the reach of the information you send. We will collect data on whether your end users click on the SMS link, IP, device brand, browser, operating system and other information.

    You know and confirm that when you use our email,SMS,WhatsApp Business API and OTP services, we only accept your entrustment as a technical service provider to achieve the purpose of sending information to your end users, and you agree that we can entrust our partners to achieve the aforementioned purposes . You need to obtain the explicit consent of your end user in advance, that is, you have the right to obtain your end user's email/address or mobile phone number, and agree to you or a third party to send information to him.

    We draw to your attention that in order to realize the above business functions, APP Push SDK require the end users to switch on the permissions of "network access", "device information" , so that we can collect the "device information", "network information" . If your end users are not willing to provide the above information, they can switch off the permissions of "network access", "device information" .

    Prior to processing personal information for other purposes which are not stated in this policy, we will notify you in advance and will also inform you to obtain your end users` consent. When we need to use information collected for other purposes, we will notify you in advance and ask you to notify your end users to obtain their consent.

  • 1.2.4 Your personal information obtained from third parties

    1.We may collect and use your personal information from third parties (our partners) with your authorized consent. We guarantee that your personal information will be processed in strict accordance with the contract with third parties and relevant laws. Please read the third-party privacy policy and user agreement carefully. If you refuse that we process the personal information from third parties, you may not use related services from EngageLab.

    2.We may obtain or properly use your public information from publicly-available sources like web pages, or obtain the business information that your company has publicly disclosed from third-party providers which helps us better understand our customers, such as your industry, the size of your business, and the URL of your business website.

    You are specially reminded to note that if the information cannot identify you and/or your end user individually or in combination with other information, it does not belong to you and/or your end user's personal information in the legal sense; when you and/or your end user User-related information that, alone or in combination with other information, can personally identify you and/or your end users, or we combine data that cannot be linked to any specific personal information with other personal information about you and/or your end users When used, this information will be treated and protected as your and/or your end user's personal information in accordance with this policy during the combined use period.

2. Cookies & Similar Technologies

When you use our services, we store a text file called cookie on your computer or mobile device to keep your site working. Cookies may contain identifiers, site names, and some numbers and characters. We use cookies to improve user experience in the platform`s products and/or services. Meanwhile it can be used to count the number of independent visitors to our website. We are able to provide you with a more thoughtful and customized service and allow you to set your specific service options with cookie technology. Cookies will be sent to your device when you use the products and/or services of the platform. When you interact with the services we provide to partners, we allow cookies (or other anonymous identifiers) to be sent to our servers.

We do not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies stored on your computer, most web browsers can block cookies. However, if you do this, you need to change the user settings yourself each time you visit our website, and you may not be able to log in or use the services and/or functions provided by EngageLab that depend on cookies.

For more information about the types and reason of cookies and how to control, please see AboutCookies.org .

3. Authorization and consent of End User

As our business partner, you know very well that in order to provide you and/or your end users with the EngageLab service you choose, we will collect, store, and process data from your application in a de-identified or anonymized manner. personal information of end users; and you, as the information controller of end users, we provide you with data processing services, but have no control over how you use data belonging to or about your end users. Therefore, by accepting this policy and integrating our SDK, API or other statistical analysis tools and developer tools into your product, you confirm and warrant that:

1. 1.You have informed the end user and obtained sufficient, necessary and explicit authorization, consent and permission from the end user to allow us to collect and use the information for the purpose of providing the service;

2. 2.Except as required by applicable law, you have informed the end user and obtained the necessary authorization, consent and permission from the end user which allow us to de-identify the collected personal information, to use the information that we collected and processed for the purposes of the services listed in Article 1 of this Policy in comply with relevant laws and regulations;

3. 3.You have complied with and will continue to comply with applicable laws, regulations, and regulatory requirements, including but not limited to formulating and publishing policies regarding to the protection of personal information and privacy protection;

4. 4.You have provided end users with a mechanism to exercise their rights in an easy manner, which explains how and when they can exercise their right to opt-out, access, rectification, deletion to their personal information and change their consent scope, etc.

4. How We Share, Transfer and Disclose Your and/or Your End Users` Personal Information

• 4.1 Sharing

  Except as described in this policy, information about you and/or your end users will not be shared with third parties in an identifiable form. Except for the following situations:

  1. 1.Sharing by obtaining explicit consent. Unless agreed by you and/or your end users, we will not share information about you and/or your end users with others;

  2. 2.We may share information about you and/or your end users in accordance with applicable laws, regulations, legal process or governmental requests, including to meet national security, emergency services or law enforcement requirements;

  3. 3.To the extent permitted or required by law, it is necessary to provide personal information of you and/or your end user to third parties (including consumer protection Departments and other authorities) in order to protect the interests, property or safety of you or the public;

  4. 4.Personal information disclosed by you and/or your end users or from other legal public sources;

  5. 5.We may share the information with third parties in anonymization form that can not identify you and/or your end users;

  6. 6.Sharing with our affiliates: Information about you and/or your end users may be shared with EngageLab affiliates. We only share the necessary information and are bound by the purposes stated in this Policy. The affiliate company shall obtain consent from you and/or your end users if the purpose of processing information is changed;

  7. 7.We may work with a trusted third-party vendor, consultant or other service provider ("Contract Partner") to provide us with the necessary maintenance, support and services to provide better customer service and optimize the user experience. We will only share information of you and/or your end users for legitimate, necessary, and specific purposes, and will only share the information necessary to provide the services. Our partners do not have the right to use the shared information for any other purpose.

  If you disagree that your necessary personal information to be collected by our partners when providing the services, you may be unable to use the services provided by the partner through this platform.

• 4.2 Transfer

  We will not transfer personal information of you and/or your end users to any company, organization or individual, except the following situations:

  1. 1.Explicit consent is obtained from you and/or your end users;

  2. 2.Personal information disclosed by you and/or your end users or from other legal public sources; or to comply in accordance with applicable laws and regulations;

  In the event of a merger, acquisition or bankruptcy liquidation, personal information transfer may be involved, in which case we will require new companies and organizations that hold your personal information to continue to be bound by this Policy. If there is any change in the way of collection and processing of personal information stated in this Policy, the company or organization will obtain your or/and your end users' consent once again.

• 4.3 Public disclosure

  Subject to applicable laws and regulations, we will not disclose information of you and/or your end users publicly unless your explicit consent is obtained from you and/or your end users.

5. How We Store Your and/or Your End Users` Personal Information

• 5.1 Storage location

  You are fully aware and understand that different countries or regions have their own regulatory requirements for the collection, storage, use, and sharing of data and personal information, and you should actively comply with the laws, regulations and regulatory requirements of overseas countries or regions. You agree to use the SDK services we provide only in countries or regions other than mainland China. The relevant provisions of the Data Security Law of the People's Republic of China on cross-border transmission, the corresponding risks and consequences arising therefrom shall be borne by you; if EngageLab suffers any form of appeal, appeal, complaint, penalty, etc., you will Responsible for a comprehensive solution; if any form of loss is caused to EngageLab, you are responsible for giving us full compensation. Meanwhile, EngageLab reserves the right to stop your related services.

  When you are using our SDK services, the information and materials that EngageLab collects about your end users will be transferred to EngageLab's servers in Singapore. You shall agree or obtain the consent of the end user regarding this cross-border transfer. We strongly recommend that you consult with local professionals to ensure that this cross-border transfer complies with local regulatory requirements. In particular, when cross-border transfers involve countries or regions such as the European Union, Russia, India, the European Union, the United States, etc., please pay attention to the personal information regulations of these countries and regions. You agree that the risks and responsibilities arising from cross-border transmissions will be borne by you.

• 5.2 Storage Term

  We store personal information of you and/or your end users only for the minimum term necessary for the purposes described in this policy or in accordance with applicable laws and regulations. However, part of personal information of you and/or your end users may be stored longer in order to comply with applicable laws and regulations and other relevant regulations and it is necessary for legal claims, protection of public interest, personal property safety or legal rights of our customers, us, our affiliates and other users or employees.

6. How We Protect Your and/or Your End Users` Personal Information

1. 1.We have taken industry-standard security measures to protect the information you provide to prevent unauthorized access, breach, misuse, alteration, damage or loss. We will take all reasonable and practicable steps to protect your and/or your end users' data. For example, the data exchange between your browser and the serve is protected by SSL encryption; we also provide https secure browsing for the EngageLab website; we make encryption to ensure data confidentiality; we use trusted protection mechanisms to prevent data from being maliciously attacked; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we regularly conduct security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

2. 2.Our data security capabilities: we build security defenses based on the data life-cycle, which covers all data processing stages: data collection, transfer, storage, using, circulation, archiving, and deletion.

3. 3.We will take all reasonable and practicable steps to ensure that unrelated personal information is not collected. Unless an extension is required or permitted by laws, we will never retain information of you and/or your end users longer than necessary to fulfill the purposes stated in this Policy.

4. 4.The Internet is not an absolutely safe environment, and email, instant messaging and other communication with other users are not encrypted. We strongly recommend you do not send personal information in this way. Please use complex passwords and change your password regularly to help us keep your account secure.

5. 5.The Internet environment is not absolutely safe and we will do our best to ensure or guarantee the security of any information you send to us. Although we have made necessary and reasonable efforts, personal information may still be stolen, illegally possessed or misused, which pose a risk to you and your end users in terms of personal, property and reputation. You understand the above risks and assume to take the risk on your own.

6. 6.If the personal information security incident occurs, we will promptly notify you according to the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have taken or will take, the proposal of how you can prevent and reduce the risk, remedies provide for you, etc. We will notify you the incident in a timely manner by email or push notification. If it is difficult to notify personal information subject one by one, we will publish announcement in a reasonable and effective way.

7. 7.At the same time, we will also report the circumstance of personal information security incidents in accordance with the requirements of the regulatory authorities.

7. How to Access & Control Your Personal Information

We attach great importance to the management of personal information by you and/or your end users and we do our best to protect your rights to information access, information rectification, information erasure, restriction of processing information and to information portability, in order to protect your and/or your end users` privacy and information security.

• 7.1 For the direct user of EngageLab

  1. 1.Access and rectification of your personal information

     You have the right to access your personal information, except as provided by laws and regulations. If you want to exercise data access right, such as you wish to access or edit corporate/personal information and payment information in your account, change your password, add security information, or close your account, you can access the EngageLab User Center to do this.

     If you are unable to access your personal information through the above link, you can send us an email at support@engagelab.com. Before accessing relevant information, we may ask you to ensure your account security.

     Please understand that due to technical limitations and legal or regulatory requirements, some of your requests may not be able to respond. Some of your information may not be accessible due to legal and regulatory requirements and information security.

  2. 2.Deletion of your personal information

     In any of the following situations, you can contact us through E-mail at support@engagelab.com to delete your personal information:

     1. (1)We collect and use personal information in violation of laws and regulations;
     2. (2)We collect and use personal information in violation of the agreement with you;
     3. (3)We share and transfer your personal information to third parties in violation of the laws and regulations or in violation of the agreement with you, we will immediately stop the sharing and transfer, and notify the third party to delete;
     4. (4)We disclose your personal information to public in violation of the laws and regulations or in violation of the agreement with you, we will immediately stop the public disclosure and issue a notice requesting the relevant recipient to delete the corresponding information.

     When deleting relevant information, we may verify your identification to protect your account. Once the request of deletion is responded, your personal information will be deleted except for information required by law and regulations.

  3. 3.Change of your consent scope

     Each business function needs basic personal information. For the collection and use of your personal information, you can send an email at support@engagelab.com to contact customer service to withdraw consent.

     When you withdraw your consent, we will no longer collect and use your corresponding personal information, but please understand that when you withdraw your consent, we will not be able to continue to provide you with the specific functions and/or service. Your decision of withdrawing your consent will not affect the processing of personal information which has been authorized before.

  4. 4.Closure of your account

     You can close your previously registered account at any time. You can contact customer service by email at support@engagelab.com. You should be aware that closure of your EngageLab account will result in you permanently loss of your access to your account and the data in your account. We will provide you with an account closure service after verifying your identity and negotiating with you to process the assets in your account. In order to provide you with a more convenient way to close your account, we will continue to optimize our products and inform you through the page announcement. After closing the EngageLab account, we will stop providing products or services for you, and delete your personal information as soon as possible or anonymize it as requested by you, except required by laws and regulations.

  5. 5.Get a copy of your personal information

     You have the right to obtain a copy of your personal information, you can always send an email to support@engagelab.com to contact our customer service. Under technical premise, such as data interface matching, we can also directly transfer a copy of your personal information to your designated third party upon your requirements.

  6. 6.Opt-out of direct marketing

     You can choose not to receive promotional emails from EngageLab by following the unsubscribe/opt-out instructions in these emails. You can also opt-out by sending an email to support@engagelab.com to contact customer service. Please note that even if you decide to opt-out of promotional communications, we may also send you non-promotional information related to our terms of service or privacy policy updates, security alerts, and other notices related to your access to or use of our products and services.

  7. 7.Respond to your request

     For the account safety, we need to verify your identity before handling your request. You may be required to provide a written request or through other ways to prove your identity. We will, in principle, give you the feedback within 15 days after receiving your request after verifying your identity.

• 7.1 If you are an end user of an application using EngageLab products or services, not a direct customer of EngageLab, we suggest you:

  According to your application provider's privacy policy, send your request related to your personal information directly to the relevant application provider for processing and assistance. After receiving the relevant request from your application provider and verifying the authenticity of the request, EngageLab will immediately cooperate with the application provide and respond the request.

• 7.2 In principle, we do not charge a fee for your reasonable request from you and/or your end user. We may refuse the request that (1) is unreasonably repetitive; (2) need too much technical means (for example, need to develop a new systems or fundamentally change to the existing practices); (3) may lead to risks to other individuals` legitimate right; or very impractical (for example, involving information stored on backup tapes).

  We are not able to respond to your and/or your end user's request in the following situations:

  1. 1.Related to our performance of obligations under laws and regulations;

  2. 2.Directly related to public safety, public health, and significant public interests;

  3. 3.We have sufficient evidence to prove that you have subjective malice or abuse of your rights;

  4. 4.It is difficult to obtain the consent of the person for the protection of the life and property of you or other individuals;

  5. 5.Responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;

  6. 6.Trade secrets related.

• 7.3 If you and/or your end user have doubts about the realization of the above rights, you may contact us in accordance with the relevant contact information in the way described in Article 10 of this policy.

8. How We Process Children's Personal Information

We have made it clear in the service premise that minors are not accepted to register as our users. In principle, we also do not accept the personal information of minors as end users provided by you, please pay attention and provide it with caution. If your app is designed and developed for minors, please make sure that your end user is a guardian who has read and agreed to the app's privacy policy.

Subject to the existing technology and business model, it is difficult for us to actively identify the information of minors. If the guardian of the minor finds that the personal information of the minor has been collected without authorization, the guardian can notify us to delete it. In the aforementioned cases, we will also actively delete such information, unless we are required by law to retain such information.

9. Updates to This Policy

For providing you with better service, the platform and related services will be updated and changed from time to time. We will revise this policy in due course. These amendments are part of this policy and have the same effect as this policy. Without your explicit consent, we will not reduce the rights of you and/or your end users in accordance with this Policy.

Once we update our policy, we will release an updated version on the official website and remind you of the updated content in an appropriate manner before the updated terms become effective, so that you can keep up to date with the latest version of this policy.

For major changes, we will also provide more noticeable notifications (including for certain services, we will send a notification by email or in the form of a letter or announcement to indicate the specific changes to the privacy policy). Therefore, please feel free to review and understand the policy you are subject to. If you do not agree to this Policy, please stop accessing and using our services.

Significant changes referred to in this policy include but are not limited to:

1. 1.Our service model has been significantly changed, such as the purpose of processing personal information, the type of personal information is processed, how personal information is used, etc.;

2. 2.We have significant changes in ownership structure, organizational structure, etc. Such as the change of owner which is caused by business adjustments, bankruptcy, mergers, etc.;

3. 3.The main objects of personal information sharing, transfer or public disclosure have changed;

4. 4.Significant changes in your rights to participate in the processing of personal information and how you exercise your rights;

5. 5.When the responsible department, contact methods and complaint channels related to the personal information security are changed;

6. 6.The privacy impact assessment report indicates that there is a high risk.

This Policy is an integral part of the EngageLab Service Agreement. All rights not expressly granted in this Privacy Policy are reserved by EngageLab.

10. How to Contact Us

We hope to resolve any disputes related to our data protection practices. EngageLab has built a dedicated privacy protection team. You can contact us by sending an email to our privacy team at compliance@engagelab.com , ask your questions or ask for help.

If you have questions, suggestions or complaints about your account information, personal information or other documentation technology or you want to exercise your rights, you can contact us through email at support@engagelab.com or through other channels we have stated. In general, we will respond within 15 working days.

11. Other Legal Grounds of Personal Information Processing (EEA Only)

Please pay special attention: When you process personal information, if you meet any of the following conditions, please comply with the General Data Protection Regulation (GDPR):

1. (1)You are in the European Economic Area ("EEA"), regardless of whether the processing is carried out in the EU;

2. (2)Offering goods or services (whether paid or not) to individuals at the EEA, or monitoring their behavior within the EEA;

3. (3)Not in the EEA, but in a place where Member State law applies by virtue of public international law. (such as embassies or consulates of EEA member states).

If you and/or your end users are from the EEA, the legal basis for our collection and use of the above personal information will depend on the personal information and the specific context in which we collect the information.

However, we usually only do so if we need personal information to perform the contract with you and/or your end users, or if we are in compliance with our legitimate interests and are not overridden by the interests or fundamental rights and freedoms of you and/or your end users, or we have obtained your and/or your end users` consent. In some cases, we may also be obligated to collect personal information from you and/or your end users, or we may need personal information to protect the vital interests of you or other individuals. For instance, we may be requested to offer personal information by public authority or making respond as requested by law enforcement.

If you have questions about our legal basis for collecting and using your and/or your end users' personal information or if you need further information, please contact us according to the information listed in the introductory of this Policy.

Appendix 1: Keyword definition

The specific words used in this policy is defined as follows:

1. 1. We or EngageLab: Metaverse Cloud PTE.LTD..

2. 2. Affiliates: it refers to a subsidiary company or other affiliated enterprise within the scope of the consolidated statement with Metaverse Cloud PTE.LTD. company or other entity which controls, is and will be controlled by or is under common control with EngageLab.

3. 2. Affiliates: it refers to a subsidiary company or other affiliated enterprise within the scope of the consolidated statement with Metaverse Cloud PTE.LTD. company or other entity which controls, is and will be controlled by or is under common control with EngageLab.

4. 4. You: means the registered user who uses our products and/or services and the purchaser of the paid service.

5. 5. Your End User: Refers to the end users who use the applications/services you provide.

6. 6. EngageLab or the platform: refers to the EngageLab platform.

7. 7. Personal Information: Information that is electronically or otherwise recorded that can be used alone or in combination with other information to identify a natural person or to reflect the behavior of a natural person. Personal information includes personal basic information, personal identification information, personal biometric information, network identity information, personal health information, personal education and occupation information, personal property information, personal communication information, contact information, personal online records, personal device Information, personal location information, etc. For the avoidance of doubt, personal information includes, but is not limited to, personally sensitive information.

8. 8. Personal information subject: It refers to the natural person identified by personal information.

9. 9. De-identification: It refers to the technical processing of personal information. The personal information subject cannot be identified without additional information after this processing.

10. 10. Anonymization: It refers to the process of making personal information subject unrecognizable through the technical processing of personal information, and the processed information cannot be recovered.