Tencent Meeting

PRIVACY POLICY

Last Updated: [February 26, 2020]

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

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

What information do we need to provide the Services?

If you register an account to use the Service then we will need some information from you to set this up. If you choose to set up your profile using a social media account such as WeChat, we also collect information from that social media account to set up your account. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Service. We also use your information for account verification, security and to support and improve the Service. We do not share your information with any third parties, except where we need to in order to provide the Service (e.g. use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Service), or we are instructed to by a court, authority or compelled by law. More Information .

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support the Service). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the Service and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information .

Where do we process your information?

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), Hong Kong SAR, Singapore and Japan. Our support, engineering and other teams are located in our offices around the world. More Information.

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for the Service, after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here .

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the privacy policy here. More Information. .

Contact Information

Data Controller:

If you are located in Singapore: Aceville Pte Ltd If you are located outside of Singapore: First App Holdings Limited Email: DPO_TencentMeeting@tencent.com

Welcome to Tencent Meeting!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with Tencent 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 you 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.

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_TencentMeeting@tencent.com.

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.

  1. 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); 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.

  1. 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 will 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.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct your device or website (as applicable to the Service) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device or website (as applicable to the Service). However, in the event of your refusal to install cookies, our Service may be unable to operate as designed.

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
Hong Kong 18*
India 18*
Japan 20
Macau 18*
Malaysia 18
Singapore 13
Thailand 13**

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

**If you live in Thailand, and you are under the age of 20 (Thailand), you will need the consent of your parent or guardian before you can use 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_TencentMeeting@tencent.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 a Relevant Jurisdiction (if specified in the section titled “Supplemental Terms – Jurisdiction Specific” which is appended to this policy), 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.
Device information (Android: Device ID (IMEI), device hardware; iOS: device model, operating system and version, UDI, battery, audio and video technical information and the storage size of system disk.)

Software information: software version number, browser type
We use this information:

• for security and verification purposes; and

• for software authentication and to effect software upgrades.
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 data, including screen sharing (Encrypted) We use this information solely to facilitate the operation of the Service. We do not access the contents of your communications, which are encrypted. 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 monitor and 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:

• improve our services;

• 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.
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”), we will process that information to share the file with the meeting participants. Necessary to perform our contract with you to provide the Service.
Chat contents If you voluntarily choose to share information with other users who are attending the same meeting through our chat function. Necessary to perform our contract with you to provide the Service.

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.

For the storage of user account information, IP address, device information, software information and service log information (including any data related to audio and video quality), this data will be stored on our servers 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). For transmitting and processing of shared files (if applicable in your jurisdiction) and chat contents, solely to facilitate your communications during the meeting (we do not access any contents of your communications), this data will be processed on our servers 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).

For transmitting and processing audio and video data (encrypted), including screen sharing, solely to facilitate your communications during the meeting (we do not access any contents of your communications), if you are a user in:

• Hong Kong or Macau, this data will be processed on our servers in Hong Kong;

• Thailand, Malaysia or India, this data will be processed on our servers in Singapore; and

• Japan or Singapore, this data will be processed on our servers in the country where you are located.

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:

o comply with a legal obligation, process or request;

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o 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).

*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.

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_TencentMeeting@tencent.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_TencentMeeting@tencent.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.

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 your registration process. If you do not provide a WeChat account, 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, a data correction request as well as a right to reject to 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, 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 to avail our services.

Withdrawal Of Consent

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_TencentMeeting@tencent.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_TencentMeeting@tencent.com.

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 us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue 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 by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at DPO_TencentMeeting@tencent.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 for the Service 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 your 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 as permitted under law. When handling a data access request, we are permitted to request for certain information 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 for certain information 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 to limit 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:

o Telephone: +603-22872388

o Email: DPO_TencentMeeting@tencent.com

Singapore

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 for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at DPO_TencentMeeting@tencent.com.

Your Rights

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_TencentMeeting@tencent.com.

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_TencentMeeting@tencent.com.

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 the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at DPO_TencentMeeting@tencent.com