Update date: Dec 10, 2023
Effective date: Dec 10, 2023
Welcome to use the Neckee App products and services of Guanwai Technology (Hangzhou) Co., Ltd.
In order to better protect your personal information, please read the following privacy policy carefully before using and registering Neckee App. Any direct or indirect use of Neckee App related products, services or data will be deemed to have known and agreed to this policy. If you do not agree to this Privacy Policy, please stop using Neckee App products and services.
- Introduction
1.1 Guanwai Technology (Hangzhou) Co., Ltd. (herein referred to as "we") has always attached great importance to the protection of users' personal information. When you use our services, we may collect and use your personal information. To this end, we use the Privacy Policy to explain to you how we collect, use, share, store and protect your personal information, as well as the methods we provide you to manage this information. This policy is closely related to your use of our services. Please be sure to read this policy carefully and fully understand it before you use our services. After you confirm that you fully understand and agree, make the choice you think is appropriate.
1.2 If you are a minor under the age of 18 (especially a child under the age of 14), please note that you need to be accompanied by a guardian to read this policy. Minor users can only use our services after obtaining their guardian's consent to this policy.
- How we collect and use your personal information
2.1 In accordance with laws and regulations and following the principles of legitimacy, legality and necessity, we collect information that you actively provide when using the service or that is generated by using the service to provide you with, optimize our services and protect the security of your account. . You can view the details of our collection and use of your personal information through the "Personal Information Collection List". If we are willing to use your personal information for other purposes not specified in this privacy policy, or use the collected information for other purposes based on specific purposes, we will promptly inform you in a reasonable manner and ask you again before use. With your consent.
2.2 There are two types of personal information we collect and use: The first type: information necessary for the core functions of our services. This type of information is necessary for the normal operation of the services. It is recommended that you authorize us to collect it. If you refuse to provide it, you will not be able to use our services normally; second type: information that may need to be collected for additional services. This type of information is information required for non-core functions. You can choose whether to authorize us to collect it. If you refuse to provide it, the corresponding additional services will not be provided to you normally.
2.3 TrueDepth APl
Our app makes use of automatically collected information using the device camera and the TrueDepth APl provided by Apple. The only use of this information is to track the user's head and face so that the user can control the AR experience and the selfie filters by moving their device and their head. None of the information collected by the TrueDepth APl ever leaves the user's device nor is it persistently stored on the device.
We Collect No Personal Information Using Our Apps. We do not collect, use, save, or have access to any of your personal data from within our apps. You might be asked to provide access to your photo library, but this is only so you can store photos created in the app. We don't process that information at all. In addition, if you take a photo, location data is saved in the image, but we have no access to that data and it is not shared with anyone unless you yourself choose to share the image.
2.3 Normally, we will collect and use your personal information in the following scenarios:
2.3.1 User registration and login
2.3.1.1 We will obtain your personal information based on the registration and login method you choose, which may include your mobile phone number, Apple account, and WeChat ID authorization information. This information will be used to bind your membership subscription, synchronize your usage records, etc. If you do not provide this type of information, you will not be able to use these services normally.
2.3.2 Use of product services
When you use our products and services, we will collect your log information, device information, and product identification information for the following purposes. The specific collection purposes and collection types are as follows:
2.3.2.1 When you use our products and services, we will collect your product log information, such as login logs, interaction records, badge records, etc., so that you can view your history and achievements on the client, and also use it for customer service feedback deal with. In order to improve your product experience, we may synchronize the above information to subsequent versions of the product.
2.3.2.2 When you use functions that require Apple smart headphones or Apple smart watches (including but not limited to outdoor diary, seated guardianship, and flight travel), with your authorization, we will receive and Send it your exercise data. This information will be used to identify and judge your activity status. If you do not authorize such information, you will not be able to use these services normally.
2.3.2.3 When you participate in a limited-time challenge, we will collect and disclose your performance data related to the challenge in the App in order to carry out the limited-time challenge normally; if you participate in a friend challenge, we will collect the user IDs of the group members , and disclose the performance data of you and other group members around the challenge in the group so that the friend challenge can be carried out normally; if you complete the time-limited challenge and win a prize, in order to facilitate the delivery of the prize to you, you need to provide the personal identity of the recipient Information, name, shipping address, contact number. If you refuse to provide such information, you will not be able to obtain relevant services or prizes.
2.3.2.4 In order to ensure your normal use of our products and services, maintain the normal operation of basic product functions, improve product experience and ensure account security, we will receive and record the device information of your mobile phone, smart watch, and smart earphones, including device information. Name, device type and version, device identifier, system version, IP address, MAC address, application ID, network type, sensor information.
2.3.2.5 In order to ensure account security and create a healthy and safe product environment, we will collect your installation and usage environment, such as installed application list, process and crash records, overall usage, channel sources and other information to combat interference. , behaviors that disrupt the normal operation of services (such as scanning third-party programs, etc.).
2.3.3 Paid Subscription
If you subscribe as a member, we will collect your subscription records for your inquiry and at the same time protect your membership rights as much as possible.
2.3.4 Feedback
If you provide feedback within the App or contact us in other ways, we will collect and save the feedback information you submit, as well as the personal contact information you may provide. We collect this information to investigate the facts and help you solve your problem. If you refuse to provide the above information, we may not be able to provide you with the results of your complaint, appeal or consultation in a timely manner.
2.3.5 Specific access rights
You understand and agree that in the process of providing services, based on the functions and scenarios of the service, you may be required to enable specific access permissions in order to collect and use the information involved in these permissions. If you refuse to provide it, it will only prevent you from using this feature, but it will not affect your normal use of other features of the product/service. For example:
2.3.6.1 Storage permissions. When you upload pictures and files from your device to the product, or store product images and videos to your device, or obtain product resources, you need to authorize us to access your photo album and file storage permissions.
2.3.6.2 Network permissions. When you use the networking function in the product, you need to authorize us to access the network.
2.3.6.3 Camera (camera) permissions. We need you to authorize us to access your camera permissions to determine whether the user is wearing designated equipment and whether the distance between faces is appropriate, etc.
2.3.6.4 System notification. In order to push system messages or use reminders, we need you to authorize us to use system notifications.
2.4 Exceptions to your consent
In accordance with relevant laws, regulations and national standards, we do not need to seek your authorization and consent to collect and use your relevant personal information in the following situations:
2.4.1.1 Relevant to our performance of obligations stipulated in laws and regulations;
2.4.1.2 Directly related to national security, national defense security and other national interests;
2.4.1.3 Directly related to public security, public health, and major public interests;
2.4.1.4 Directly related to criminal investigation, prosecution, trial and execution of judgment;
2.4.1.5 To protect your or other individuals’ life, property, reputation and other major legitimate rights and interests but it is difficult to obtain my authorization and consent;
2.4.1.6 The personal information involved is disclosed to the public by you yourself;
2.4.1.7 Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
2.4.1.8 Necessary to sign and perform the contract at your request;
2.4.1.9 Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;
2.4.1.10 Other situations specified by laws and regulations.
- How we share, transfer or disclose your personal information
3.1 Sharing
We generally will not share your personal information with other companies, organizations and individuals without your consent or other legitimate reasons. However, in order to provide you with better services, we may share some of your personal information with third-party partners on the premise of following the principles of "lawful and legitimate, minimally necessary, and clear purpose". We share your personal information under the following circumstances:
3.1.1 Providing our services to you. We may share your information with partners and other third parties to implement core functions or services necessary for the product.
3.1.2 Maintain the safe and stable operation of our services. We may share your information with partners and other third parties to help us provide you with more secure and stable services.
3.1.3 To carry out our obligations under this Policy or other agreements we have with you.
3.1.4 Provide you with advertising push services. For the purpose of advertising, evaluation, etc., we may share some of your data with third-party partners such as advertisers and their agents, but we will only provide information about the coverage and effectiveness of the promotion, and will not provide information that can identify you. identifying name, phone number or email address; or we aggregate this information so that it does not identify you personally. For example, we can tell the third-party partner how many people saw their promotional information or purchased goods after seeing this information, or provide them with non-personally identifiable statistical information to help them understand their audience or customers.
3.1.5 Based on your needs, assist in handling disputes or controversies between you and others.
3.1.6 Provide your information at the request of your legal guardian.
3.1.7 Provided according to the individual service agreement signed with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents.
3.1.8 When it is necessary to conduct statistical or academic research for the public interest, and when the results of academic research or description are provided to the outside world, the personal information contained in the results will be de-identified.
3.1.9 Other situations stipulated by laws and regulations.
We will only share your information for legal, legitimate, necessary, specific and clear purposes. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share information, requiring them to handle information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.
3.2 Transfer
We will not transfer your personal information to any company, organization or individual except with your express consent. If your personal information needs to be transferred due to a merger, acquisition or bankruptcy liquidation, we will inform you of the name of the recipient and require the recipient to continue to be bound by this Privacy Policy. If the recipient changes the purpose and method of processing personal information agreed in this privacy policy, we will require the recipient to obtain your authorization and consent again.
3.3 Public disclosure
We will only disclose your personal information under the following circumstances and under the premise of adopting industry standard security rules:
3.3.1 After obtaining your explicit consent.
3.3.2 In accordance with laws and regulations, national standards, litigation or mandatory requirements of government departments.
3.4 Exceptions to sharing, transferring or disclosing your personal information
According to relevant laws and regulations, we do not need to obtain your prior authorization to share, transfer, and disclose your personal information in the following situations:
3.4.1 Necessary for the conclusion and performance of the contract signed between us and you.
3.4.2 Necessary to perform legal duties or obligations, such as those directly related to national security, national defense security, criminal investigation, prosecution, trial and judgment execution, etc.
3.4.3 In order to respond to public health emergencies, or necessary to protect the life, health and property safety of natural persons in emergency situations.
3.4.4 Conduct news reporting, public opinion supervision and other activities for the public interest, and process personal information within a reasonable scope.
3.4.5 Process personal information disclosed by individuals themselves or that has been legally disclosed by others within a reasonable scope.
3.4.6 Other situations stipulated by laws and regulations.
- Your right to manage personal information
We understand your concerns about personal information and respect your rights to your personal information. We will provide you with corresponding operation settings depending on the product/service situation so that you can exercise your rights to your personal information. Your rights include:
4.1 Query your personal information
4.1.1 Account information
You can contact customer service or query the personal information you have provided to us within the product (for example: Settings-Personal Information), including account number, avatar, nickname, and other personal information you choose to fill in. The details are subject to the specific product settings function.
4.2 Modify your personal information
We encourage you to update and modify your personal information to make it more accurate and effective.
4.2.1 For some of your personal information, we provide you with a modification operation path on the relevant product function page (for example: Settings - Personal Information). You can modify your personal information within our products/services.
4.2.2 For the difficulties you encounter in modifying the above information, or other online self-modification services that are currently not available to you, you can contact us through customer service. After verifying your identity, we will help you modify the relevant information. However, according to the requirements of laws and regulations, and for security and identification reasons, you may not be able to modify some of the initial registration information submitted during registration.
4.3 Delete your personal information
If you want to delete your personal information, you can contact us through customer service and submit a deletion request. We will verify your information and help you delete it within 15 working days. In the following circumstances, you may make a request to us to delete your personal information, unless it has been anonymized or otherwise provided by laws and regulations:
4.3.1 The processing purposes stated in this Agreement have been achieved, cannot be achieved or are no longer necessary to achieve the processing purposes.
4.3.2 Your personal information is processed based on consent and you withdraw your consent.
4.3.3 The storage period of personal information has expired.
4.3.4 We collect, use and store your personal information in violation of laws, administrative regulations or agreements with you.
4.3.5 If we provide your personal information to a third party in violation of laws, administrative regulations or our agreement with you, we will immediately stop the information transmission and notify the third party to delete it in a timely manner.
4.3.6 If we publicly disclose your personal information in violation of laws, administrative regulations or our agreement with you, we will immediately stop the public disclosure and issue a notice requiring the relevant recipient to delete the corresponding information.
4.3.7 You no longer use our products or services, or you cancel your account.
4.3.8 We stop providing products or services.
4.3.9 Other situations stipulated by laws and regulations.
It should be noted that if the personal information retention period stipulated by laws and administrative regulations has not expired, or if it is technically difficult for us to realize your request to delete part of the personal information, we may not be able to respond to your request to delete part of the personal information. However, we The relevant information will no longer be processed except for storage and taking necessary security protection measures. If you still want to delete this part of your personal information, we will recommend that you apply to delete all personal information or apply to cancel your account.
4.4 Account cancellation
Subject to the conditions agreed in our service agreement and relevant national laws and regulations, you can log out of your account by going to "Settings" - "Account Logout" within the app. When the account is canceled, all service information and data related to the account and under the individual service will be deleted or processed in accordance with the service agreement of the individual service, unless otherwise agreed by laws, regulations or cancellation agreement. After your account is canceled, you will not be able to retrieve your account information, so please operate with caution.
- How we use cookies and third-party services
5.1 When you use our products/services, we may use Cookies and similar technologies to collect some of your personal information, such as your website visit habits, your browsing information, and your login information. Cookies and similar technologies collect this information. Such information is necessary for you to use our products/services, remember your identity, analyze your use of our services, provide you with service content that better meets your personal needs, protect your information and account security, and improve Our products/services etc.
5.2 If you refuse our use of cookies and similar technologies to collect and use your relevant information, you can manage cookies and/or similar technologies through the settings of your browser if the browser has this function; or delete the stored information Cookies and/or similar technical applications in your computer, mobile device or other devices so that we cannot track your personal information through relevant means. If you want to learn more about how to change browser settings, please check the relevant settings page of the browser you are using. You understand and know that some of our products/services can only be realized through the use of cookies or similar technologies. If you refuse to use or delete them, you may not be able to use our related products/services normally or be unable to pass our To obtain the best service experience for products/services, it may also have a certain impact on your information protection and account security.
- How we store and protect your personal information
6.1 Storage of personal information
6.1.1 In accordance with relevant laws and regulations, we will store the personal information we collect about you within the territory of the People's Republic of China. If cross-border data transfer is necessary, we will clearly inform you separately and obtain your authorization and consent. We will not transfer your personal information out of the country without your express authorization, or in accordance with clear provisions of laws and regulations, or as required by relevant competent authorities.
6.1.2 We will only store your personal information for the shortest period of time necessary to achieve the purpose of the service or within the period required by laws and regulations. If we terminate product services or operations, or if the storage period exceeds other circumstances, we will stop it in a timely manner. Continue to collect your personal information, and delete or anonymize your personal information after the termination of services or operations and the expiration of the retention period prescribed by law. Notwithstanding this, you will not be able to exercise your right to delete, withdraw, or cancel your account, or as otherwise provided by laws and regulations.
6.2 Protection of personal information
6.2.1 We will adopt security protection measures that comply with industry standards to prevent the loss, leakage, unauthorized access or improper use of information. Including but not limited to the use of encryption technology (such as SSL) to protect your personal information, the use of a variety of data desensitization technologies to enhance the security of information in use, the use of data access permission control, etc.
6.2.2 We manage and regulate the storage and use of information by establishing management systems, processes and organizations to ensure the security of personal information. For example, comprehensive security control of data is carried out through information contact confidentiality agreements, monitoring and auditing mechanisms; security and privacy protection training courses are held to enhance employees' awareness of the importance of protecting information.
6.2.3 We only allow our employees and partners who need to know this information to access your personal information, and have set up strict access control and monitoring mechanisms for this purpose. At the same time, all persons who may have access to your personal information are required to perform corresponding confidentiality obligations. Failure to meet these obligations may result in legal liability or termination of your partnership with us.
6.2.4 Please understand that due to technical limitations and limitations of risk prevention, we cannot guarantee the absolute security of information. If a security incident such as a personal information leak occurs, we will activate an emergency plan to prevent the security incident from expanding. We will inform you of the basic situation of the security incident, the handling or remedial measures we are about to take or have taken, and our response suggestions for you in the form of announcements, emails, text messages, or official website notifications.
- Our protection of personal information of minors
7.1 We expect parents or guardians to guide minors in using our functions and services. Minors are not allowed to create their own user accounts without the consent of their parents or guardians. We will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations.
7.2 If you are a minor, please ask your parents or guardians to read this personal information protection policy and use our functions and services or provide us with your information with the consent of your parents or guardians. For situations where we collect your information with the consent of your parents or guardians, we will only use or publicly disclose this information when permitted by laws and regulations, with the explicit consent of your parents or guardians, or when necessary to protect your rights and interests. If your guardian does not agree with you using our functions and services or providing information to us in accordance with this personal information protection policy, please immediately terminate the use of our functions and services and notify us in time so that we can take appropriate measures.
7.3 If you are the parent or guardian of a minor, please read this personal information protection policy carefully. When you have questions about the processing of personal information of minors under your custody, please contact us through the contact information in this Personal Information Protection Policy.
7.4 In particular, if you are a minor under the age of fourteen (hereinafter referred to as a "child"), please use the functions and functions provided by the software (including us and third parties) with the consent of your parents or other guardians. Services or provide your information to us and third parties. For the collection of your information with the consent of parents or other guardians, in addition to complying with the provisions of this personal information protection policy regarding user personal information, we will also adhere to the principles of legitimate necessity, informed consent, clear purpose, safety protection, and legal use. , strictly comply with the requirements of laws and regulations such as the "Provisions on the Internet Protection of Children's Personal Information" and other laws and regulations for storage, use, and disclosure, and will not exceed the period necessary to achieve the purpose of collection and use. After expiration, we will delete or anonymize children's personal information. chemical treatment. If your guardian does not agree with you using our functions and services or providing information to us in accordance with this policy, please immediately terminate the use of our functions and services and notify us in time so that we can take appropriate measures.
- Contact us
8.1 If you have complaints or reports about network information security, or if you have any questions, comments or suggestions about this policy or your personal information, please contact us through customer service. You can also send your questions to the email contact@guanwaii.com. We will review the issues involved as soon as possible and respond within 15 working days after verifying your user identity.
8.2 You understand and know that we will not be able to respond to your request under the following circumstances related to personal information:
8.2.1 Related to national security and national defense security.
8.2.2 Related to public safety, public health, and major public interests.
8.2.3 Related to criminal investigation, prosecution and trial.
8.2.4 There is sufficient evidence that you have subjective malice or abused your rights.
8.2.5 Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.
8.2.6 Involving business secrets.
8.2.7 Other situations stipulated by laws and regulations.
- How to update this policy
9.1 In accordance with national laws and regulations and the needs of providing functions and services and business operations, we may revise part or all of this privacy policy. The modified content will be notified to you through methods including but not limited to push notifications, pop-up windows, announcements on our official website, announcements in the software, etc. In particular, we will provide more prominent notices for major changes.
9.2 Major changes referred to in this Privacy Policy include but are not limited to:
9.2.1 Our service model undergoes significant changes. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
9.2.2 We have undergone major changes in ownership structure, organizational structure, etc. Such as business adjustments, changes in owners caused by bankruptcy mergers and acquisitions, etc.;
9.2.3 The main objects and types of personal information shared, transferred or publicly disclosed change;
9.2.4 There are significant changes in your rights to participate in the processing of personal information and how you exercise them;
9.2.5 When our responsible department, contact information and complaint channels for handling personal information security change;
9.2.6 When there are high risks in the personal information protection impact assessment report.
9.3 You have the right to choose whether to continue to authorize us to collect, process and use your personal information. Please make the choice you think is appropriate based on fully understanding our revised privacy policy. If you do not agree to the revised Privacy Policy, you have the right and should immediately stop using our features and services.
9.4 You can view this privacy policy through "Settings" within the software (for example: Settings-Privacy Policy). We encourage you to review our Privacy Policy each time you use the Software.
- Dispute Resolution
10.1 The interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of the mainland of the People's Republic of China. Any dispute arising from this Privacy Policy or our processing of your personal information shall be resolved by filing a lawsuit with the Hangzhou Yuhang District People's Court.
10.2 If you believe that our processing of personal information has harmed your legitimate rights and interests, you may also choose to report it to the relevant government departments.
10.3 The titles of this Privacy Policy are for convenience and readability only and do not affect the meaning or interpretation of any provisions contained in the text.
- Definition and explanation
Unless otherwise agreed, the terms used in this privacy policy are usually defined as follows:
11.1 Personal information: refers to various information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information.
11.2 Personal sensitive information: refers to personal information that, once leaked or illegally used, may easily cause the dignity of a natural person to be infringed or the personal and property safety to be endangered, including biometrics, religious beliefs, specific identities, medical health, financial accounts, and whereabouts and other information, as well as the personal information of minors under the age of fourteen.
11.3 Device information: usually includes device name, device model, hardware serial number, MAC address, device identification information (IMEI/MEID/AndroidID/OpenUDID/IMSI/IDFA/IDFV/OAID/ICCID and other comprehensive device parameters and system information) Device identifier), mobile application list and other software and hardware characteristic information, operating system and application version, language settings, resolution, service provider network ID (PLMN), IP address, browser type.
11.4 SSL: SSL (Secure Socket Layer), also known as Secure Socket Layer, is a security protocol implemented on the Transport Communication Protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which achieve information confidentiality through the use of public key and symmetric key technology.
11.5 Cookies: Cookies are small files containing strings of characters that are sent and stored on your computer, mobile device or other devices (usually encrypted) when you log in and use the website or other online content. Cookie-like technologies are other technologies that can be used for similar purposes to Cookies, such as: Web Beacon, Proxy, embedded scripts, etc.
11.6 Anonymization: refers to the process of technical processing of personal information so that the subject of personal information cannot be identified or associated, and the processed information cannot be restored.
11.7 We: refers to Guanwai Technology (Hangzhou) Co., Ltd. and its affiliated companies
11.8 Affiliated companies: refers to companies that currently and in the future control, are controlled by, or are under common control with Guanwai Technology (Hangzhou) Co., Ltd. mechanism. Control refers to the ability to directly or indirectly influence the management/operation of the controlled object through ownership, voting shares, contracts, actual operating relationships or other legally recognized means.
Translation discrepancies may result in variations between different language versions of the privacy policy. In instances of conflict, in either content or interpretation, the Chinese version takes precedence.