VooV Meeting Privacy Policy

Welcome to VooV Meeting!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with VooV Meeting (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

Please note that this privacy policy may describe features and functions of the Service which may or may not be available in your particular jurisdiction.

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 accepting our rules regarding your personal information as described in this privacy policy.

This Service is operated by (in the case of persons located in Singapore) Aceville Pte Ltd and (in the case of persons located outside of Singapore) First App Holdings Limited (in each case, “we”, “us”, “our”). We are the entity that will be offering the Service to you, that you will be transacting with in relation to the Service, and the data controller of your personal information in relation to the Service.

First App Holdings Limited is a Hong Kong based company within the Tencent group. The registered address of First App Holdings Limited is 29/F, Three Pacific Place, 1 Queen’s Road East, Wanchai, Hong Kong.

Aceville Pte Ltd is a Singapore based company within the Tencent group. The registered address of Aceville Pte Ltd is 16 Collyer Quay, No. 1829, Level 18, Singapore 049318.

Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V, a Dutch company within the Tencent group, with the registered address 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands. Our representative can be contacted at eudataprotection@tencent.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. Our data protection officer can be contacted at DPO@voovmeeting.com.

Please note that this privacy policy describes how we process the personal information you provide to set up your account and use the Service. We are the data controller for such personal information except to the extent you transmit personal information using the Service (for example, setting up a video or audio transmission, or share information on the Service).

To the extent you transmit personal information using the Service, we are the data processor and act on your instructions. We describe this further below. Please also see our Data Processing Agreement located [here] for further information.

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information“ below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

· Registration: You give us information about you when you register for the Service and create a user identity (“User ID”) or use your WeChat ID (“WeChat ID”): this means that if you register by mobile phone number, we process your mobile phone number and display name, and if you register via WeChat, we process your WeChat account, profile photo, mobile phone number, region (location) and gender.

· Guest: You give us information about you when you join the Service as a guest: this means that when a registered user invites you to join a meeting, you will provide us with your name and mobile number.

2. Information about you generated as part of the Service

We automatically collect certain data from you when you use the Service, namely your:

· IP address and device information (such as device ID, operating system and version, IP address, UDI, battery, audio and video equipment information and system disk storage size);

· software information (software version number, browser type) and technical information regarding your use of the Service;

· Service log information, such as operational record information generated when you use the Service, including device IP address, fault log, software operation information (in case of failure, you can also voluntarily submit log files to the administration server), and communication log information, such as the meeting ID, and time and duration of the communications you have made while using the Service; and

· audio and video quality data, such as volume, packet loss rate and other relevant data (audio and video quality data does not involve your call content).

We also collect and store your data:

· each time you interact with us, for example, if you contact our support team;

· when you communicate with other users in the Service, including through the chat function (e.g., log data);

· when you choose to use particular functions (e.g., if you choose to add a meeting to your calendar when accepting a meeting invite, we process, but do not store, calendar data); and

· when you are using the Service, for security purposes we collect (in addition to the categories of data listed above) device information including equipment brand and model and available space on the device.

3. The information you share

There are two types of information you can share through the Service: (i) shared files (meeting documents that can be viewed and edited before, during or after the meeting); and (ii) screen sharing your current desktop to remote users (which is encrypted and can only be viewed in real time). We process this information on your behalf as a processor.

You instruct us to modify and adapt such shared files for technical purposes to operate the application and Service (e.g. making sure content is viewable on smartphones as well as computers and other devices). Please note that some of these sharing functions will not be available in every country.

You can also share information with other users who are attending the same meeting through our chat function.

Please note that this may include your personal information, personal property information and other sensitive information. Please take care when disclosing your personal sensitive information.

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

For more information about our Cookies policy, click here.

Children

Our Service is not intended for children. Children must not use the Service for any purpose.

By children, we mean users under the age of 18 years old; or in the case of users located in a country where the minimum age for processing personal data differs, the minimum age specified under law. For certain jurisdictions we have listed the minimum age in the table below.

Country in which the user is located	Minimum age of the user
Indonesia	21
Japan	20
Republic of Korea	14*
Russia	14
Thailand	20
Vietnam	16
United States	16*

*Users located in this country and who are below the minimum age, are required to obtain parental/guardian consent prior to using the Service.

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages, please contact us at DPO@voovmeeting.com and we will delete such information.

How We Use Your Personal Information

This section provides more details on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”) or Brazil (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information	Purpose of Use	Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
Information you provide to us (either directly or through a third party).
If you choose to register via creating a new account (User ID): Mobile phone number and display name	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Social media information: If you choose to register via WeChat (WeChat ID): this includes your WeChat account name, profile photo, mobile phone number, region (location) and gender	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Information generated or processed by us as part of the Service
IP address	We use this information to allow you to connect to our server.	Necessary to perform our contract with you to provide the Service.
Communication log (not collected from guest users): meeting ID, meeting subject, meeting start and end time	We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to provide the Service.
Landline number	If you dial in from a landline number, we use this to facilitate your communications with other users.	Necessary to perform our contract with you to provide the Service.
Audio and video quality data: volume and packet loss rate (audio and video quality data is not related to the contents of your call)	We use this information to optimize compatibility and to ensure this meets your personalized requirements.	Necessary to perform our contract with you to provide the Service.
Security-related information: device operation system settings, device information including Device ID, model, CPU structure, CPU model, kernel version, resolution	We use this information to resolve bugs, optimize compatibility with your device, for authentication, security, anti-fraud monitoring, archive backup, and maintaining security of the Service.	It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.
Service usage data: how often you use the application, service default/error information, overall usage data, performance data, and the version of the application. Service log information: the operational record generated when you use the Service, including device IP address, fault log, software operational data (in case of failure, users can also voluntarily submit log files to the administrating server)	We use this to: · ensure the security of the service, solve and locate problems, help us better understand how our application is running, optimize our services and improve the quality of the Service; and · to determine whether an account has been hacked or whether any improper or illegal act exists.	It is in our legitimate interests to use this information to protect the integrity of the Service and improve its operation.
Customer support communications: name, mobile phone number, email address, photo (if you choose to upload one to illustrate the error), and details of error	We use this information to: · provide troubleshooting, such as addressing and remediating technical issues and bugs; and · for administering product/ customer support services to you.	Necessary to perform our contract with you to provide and support the Service.
Content shared by you, which we process on your behalf as a processor
Audio and video data, including screen sharing (Encrypted)	You instruct us to use this information solely to facilitate the operation of the Service. We do not access the contents of your communications, which are encrypted.	We process this data on your behalf as your processor.
Shared files (if this function is available in your country)	If you voluntarily choose to share a file (such as a document) during a meeting (“User Content”), you instruct us to process that information to share the file with the meeting participants.	We process this data on your behalf as your processor.
Chat contents	If you voluntarily choose to share information with other users who are attending the same meeting through our chat function you instruct us to facilitate that sharing.	We process this data on your behalf as your processor.
Calendar data	If you voluntarily choose to add a meeting to your calendar when accepting a meeting invite you instruct us to process that data for the purpose of notifying you of the meeting.	We process this data on your behalf as your processor.

To understand how our users use the Service and to improve the Service, we may also process anonymised data in relation to operation of the Service. For example, we may identify certain locations where there is a high density of users and that will help us to ensure the Service is best serving that particular location.

How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers are located in:

· the PRC;

· Hong Kong SAR;

· Thailand;

· India

· Singapore;

· Japan;

· Germany;

· Korea;

· Canada;

· Russia;

· South Africa; and

· the United States.

For users residing outside Singapore, including users in the UK and the European Economic Area (EEA), the Service is offered by First App Holdings Limited, which is based in Hong Kong. This means that all personal data provided by the user or generated in the context of the Service may be accessed by First App Holding Limited in Hong Kong.

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 providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, for the purpose of processing support ticket ID and support communication. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within the Tencent corporate group who process your personal information in order to operate the Service, such as provision of servers and facilitating log in (e.g., when using WeChat). All related group companies may only use your personal information in accordance with this privacy policy.

Regulators, judicial authorities, law enforcement agencies, and other third parties for safety, security, or compliance with law. There are circumstances in which we are legally required to disclose information, such as to law enforcement agencies, public authorities or other organisations, or if we have a good faith belief that such use is reasonably necessary to:

comply with a legal obligation, process or request;
enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (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.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

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 to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention

Personal Information*	Retention Policy
User ID: Mobile phone number and Display Name WeChat ID: Social Media Information Your landline number Security-Related Information Customer Support Communications Communication log (not collected from guest users)	Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request, after which it will be deleted immediately).
IP Address Device information Software information Audio and video quality data Service usage data Service log information	Stored for 7 days from the date of collection.
Audio and video data, including screen sharing (Encrypted) Shared files (if this function is available in your country) Chat contents	Stored and processed for the duration of the meeting only and solely to facilitate your communications during the meeting (we do not access any contents of your communications).
Calendar data	Not stored.

*Please see the section above titled “How We Use Your Personal Information” for a full description of each category of data.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in Brazil, the European Economic Area, United Kingdom and Switzerland (“Relevant Location”). If you are located in a territory outside a Relevant Location, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

You 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). To exercise any of your rights, please contact us at DPO@voovmeeting.com. The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Russia.

Access

You 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. If you believe we hold any other personal information about you, please contact us at DPO@voovmeeting.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at DPO@voovmeeting.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your Service account. If there is any other personal information you believe we process that you would like us to erase, please contact us at DPO@voovmeeting.com.

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 defence 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 have a right to require us to 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 defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at DPO@voovmeeting.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at DPO@voovmeeting.com. 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.

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). You may not opt-out of these service-related announcements, which are not promotional in nature.

Contact & Complaints

Questions, comments and requests regarding this policy are welcomed and should be addressed to DPO@voovmeeting.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at DPO@voovmeeting.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated policy here. Please check this page frequently to see if there are any updates or changes to this privacy policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Australia

This section applies to users located in Australia:

Overseas recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

Correction

Your rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

Identifiers, such as your name as it appears on your social media profile, IP address, device ID, phone number and email address.
Internet or other electronic network activity information, such as your information regarding your use of the Service, including the account, time and duration of the communications made while using the Service, Device Information; Communication Log; and Service usage data, all as described in the main privacy policy.
Audio and visual information such as your social media profile picture.
Other information described in subdivision (e) of Section 1798.80, including information about your gender or age. This information is collected directly from you in the context of being our consumer.

Purposes

We collect your personal information for the following purposes:

To provide you with the Service, including maintaining your account, providing customer service, and facilitating the posting of your communications with other users.
To improve our services, including the functionality of the Service.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see this chart in the main portion of the privacy policy.

We disclose personal information to the following types of entities:

Other companies within the Tencent group who process your personal information in order to operate the Service
Other companies that provide services on our behalf in support of the Service and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us
Regulators, judicial authorities, law enforcement agencies, and other third parties for safety, security, or compliance with law
Entities that acquire all or substantially all of our business

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA

If you are a California resident, you have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the purpose for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
the specific pieces of personal information we collected about you;

Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at DPO@voovmeeting.com.

Canada

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR).

Our designated data protection officer can be contacted at DPO@voovmeeting.com.

Your Rights

Consent revocation

You may revoke consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account within the Service or you can contact DPO@voovmeeting.com. This may affect our provision of the Service to you.

Access

You have the right to access personal information we hold about you, to be provided with an account of how we use it, and to whom we disclose it. You can access the personal information you have made available as part of your account by logging into your account or my making a request in writing to DPO@voovmeeting.com. We may require further information to verify your identity, which information will only be used for that purpose.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at DPO@voovmeeting.com.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions, in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, the heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us at DPO@voovmeeting.com.

Hong Kong SAR

If you choose not to provide your personal information, you may not be able to use the Service properly. For example: If you do not provide your mobile phone number, we will not be able to complete the registration process. If you do not provide your WeChat account details, we cannot upgrade you from a free user to a paid user. As a Hong Kong SAR data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request (to receive a copy of the data we process about you). You can also exercise your right to data correction as well as your right to stop the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Sensitive Personal Information

“Sensitive Personal Information” means passwords, financial information (such as bank account or credit card or debit card or other payment instrument details), biometric data, data relating to physical or mental health, sex life or sexual orientation, and/ or medical records or history, and similar information, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

Sharing Of Your Sensitive Personal Information

Where we permit any third parties to collect and use your Sensitive Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information.

Age Restrictions

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years who wish to use our services.

Withdrawal Of Consent

To the extent provided by applicable law and regulation, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at DPO@voovmeeting.com. 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.

Your Rights

You have the right to access, correct and update your information. To do so, you may contact us at DPO@voovmeeting.com.

Indonesia

Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Accuracy of Information

You are responsible for ensuring that any personal information which you provide to us is accurate and up-to-date. In order to confirm the accuracy of the information, we may also verify the information you provided to us, at any time. You hereby represent that you have already secured all necessary consent before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claim whatsoever from any party as a result of the absence of such consent.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Data Subject Rights

You have the right to access, update, correct and request erasure of personal information on our Service from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations, at the latest 14 days from when we acknowledge the confidentiality breach.

Data Retention

Notwithstanding the provision on the erasure of personal information, to the extent required by local law and regulation, we will retain your personal information, for a maximum of 5 years.

Notification to Amendment of this Privacy Policy

In the event we amend this policy, we will provide notify you regarding the effective date of the changes at the latest 14 (fourteen) days prior to the effective date, through (i) a notice to be posted on the landing page of our website, pop-up notification, or the splash screen of our Service; or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended policy within the above advance notification period, you will be considered as accepting the changes, therefore you will be considered to have agreed to the new policy. However, you may stop using or accessing our Service at any time, if you cease to agree with the amended policy.

Japan

Consent

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR).

Your Rights

You may request that we notify you about the purposes of use, the disclosure of, any correction to, the discontinuation of the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided for by the Act on the Protection of Personal Information of Japan. If you wish to make such a request, please contact us at DPO@voovmeeting.com.

Macau SAR

You have the right not to provide your personal information. If you do so, however, we may not be able to provide the Service. As a Macau SAR data subject you have legal rights in relation to the personal data we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal data for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Malay version, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the Service.

In the event you are agreeing to this privacy policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this privacy policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this privacy policy.

How We Store and Share Your Personal Information

In relation to users in Malaysia, our servers are located in the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, the Hong Kong SAR and the Macau SAR) and Singapore and you consent to the transfer of your data outside of your country.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of the personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts permitted by law. When handling a data access request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request limiting the processing of your personal information by using the contact details provided above. However this may affect our provision of the Service to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information:

· Telephone: +603-22872388

· Email: DPO@voovmeeting.com

Peru

Transfers and delegation of personal information occur as set out in this privacy policy and the section “Republic of Korea”.

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: DPO@voovmeeting.com

Republic of Korea

How We Store and Share Your Personal Information

Provision of personal information to 3rd parties (if applicable)

We provide your personal information to third parties as described below:

Name of Recipient

Types of Personal Information provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

腾讯云计算（北京）有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd.

User account information, IP address/device information, software information and service log information

Storage of personal information

· User account information and Communication Log: retained for the duration of our services (until the user cancels the account), and deleted immediately upon account deletion.

· IP address/device information, software information and service log information: 7 days from the date on which such data is provided/generated.

Delegation of Processing

For the performance of the services detailed in this privacy policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee	Descriptions of Delegated Services
腾讯云计算（北京）有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd.	Data processor: Processes and stores data on behalf of the data controller

Overseas Transfer of Personal Information

We transfer Personal Information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)

Country to Which Your Personal Information is to be Transferred

Date and Method of Transfer

Types of Your Personal Information to be Transferred

Purpose of Use by Recipient

Period of Retention and Use by Recipient

腾讯云计算（北京）有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd. (info@voovmeeting.com)

The People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong and Macau)

Transmitted from time to time

User account information, IP address/device information, software information and service log information

Storage of personal information

· User account information and Communication Log: retained for the duration of our services (until the user cancels the account), and deleted immediately upon account deletion.

· IP address/device information, software information and service log information: 7 days from the date on which such data is provided/generated.

Data Destruction

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Your Rights

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Network Act.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Contact

· Data Protection Team, responsible for the management and safety of your personal information

Contact: DPO@voovmeeting.com
Telephone number: +82-2-2185-0902

Russia

If you are using the services in Russia, you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this privacy policy of your information. You also consent to the cross-border transfer of your information to any country where we (or third parties to which we may transfer data in accordance with this privacy policy) have databases or affiliates and, in particular, to Hong Kong SAR, the United States, Singapore, Canada and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR).

Singapore

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at DPO@voovmeeting.com.

Your Rights

Access

Correction

South Africa

Terminology

Where this privacy policy refers to "data controller" and "data processor" then for the purposes of South Africa, this respectfully refers to "responsibility party" and "operator" as defined in the Protection of Personal Information Act 4 of 2013.

Your Rights

Access

Correction

Erasure

We may need to retain personal information if there are valid grounds under data protection laws and/or other laws for us to do so (for example, for the defence of legal claims) 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

You have a right to require us to stop processing the personal information we hold about you 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 defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too and shall specifically enforce this where the third party is our data processor.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at DPO@voovmeeting.com.

You have a right to lodge a complaint with the South African Information Regulator by contacting them on inforeg@justice.gov.za.

Withdrawal of Consent

Notification of data breaches

Where we are required to do so under law, we shall promptly notify you and the South African Information Regulator in writing where we have determined that there are reasonable grounds to believe that your personal information has been acquired and/or accessed by an unauthorised third party. Cross-border transfers

Additional Security Measures of Your Personal Information

In accordance with applicable data privacy laws and regulations in South Africa, we shall take appropriate, reasonable technical and organisational measures to prevent the loss of, damage to or unauthorised access to or processing of your personal information.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the Service.

You may withdraw your consent to the processing of your personal information. You may request us to provide access to, make any correction to, discontinue, restrict the use or provision of, erase any and all of your personal information and/or to provide you or transfer to third party such information which is stored by us in a machine readable format as well as file a complaint to a relevant authority, to the extent provided by applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. Where you wish to make such requests, please contact us at DPO@voovmeeting.com.

Vietnam

By accepting this privacy policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this privacy policy.

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

Your personal information, if required to be disclosed to the competent law enforcement agencies, public authorities or other judicial bodies and organisations, will be disclosed upon receipt of written request from such organizations.

Where required by the law and regulatory requirements of your jurisdiction from time to time, we may retain all or part of your personal information for a period longer than described above in this privacy policy.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your consent to collect, store, process, use and disclose your personal information and to request us to stop processing or providing your personal information to a third party.