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Privacy Policy for Dolphin Browser

Last modified: January 1, 2020

Your privacy is extremely important to us at MoboTap, Inc. (“MoboTap”, “we”, or “us”,). At MoboTap, we respect and protect the privacy of our customers and those who use our products and services. We have prepared this Privacy Policy (“Privacy Policy”) to explain how MoboTap collects and uses information about users of (i)dolphin.com and dolphin-browser.com and related website(the “Website”), (ii) the services, features and content offered by MoboTap (the “Services”) (iii) any version of Dolphin Browser and any other mobile browsers or applications provided by MoboTap (together with the Website and the Services, the “Application”). By using the Website, Services or Application, you unconditionally consent to and agree to be bound by all of the terms of this Privacy Policy. If you do not unconditionally agree with all of the terms and conditions of this Privacy Policy, you may not download the Dolphin Browser or use any of the Applications.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Any and all changes will be reflected on this page or the then current link to our Privacy Policy accessible via our Website and/or Applications. When we post changes to this Privacy Policy on our Website, we will include the date when the Privacy Policy was last updated. If we make any material changes in the way we use your Personal Information (as defined below), we will notify you through the standard mechanisms by which MoboTap communicates with its users and community, such as Mobotap’s “announce” mailing list and newsgroup and/or by posting notice of the changes on our Website. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of a notice to you or thirty (30) calendar days following our posting of notice of the changes on our Website. These changes will be effective immediately for new users of our Website, Services or Application. Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail or phone number. In the event that the last e-mail address or phone number that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the notice will nonetheless constitute effective communication of the changes described in the notice. Changes to this Privacy Policy may affect our use of Personal Information that you provided to us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes that you wish to deactivate your account (“Account”) with us. Non-deactivation of your account or continued use of the Website, Services or Application following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

A Note about Children

Mobotap’s products and services are not intended for use by individuals under the age of thirteen (13), and we request that such individuals do not provide Personal Information through our Website, Services or Application.

A Note to Users Outside of the United States.  Your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.  You hereby expressly consent to the collection and processing of your Personal Information as stated throughout this Privacy Policy.

Types of Information

“Personal Information” is information that you provide to us that personally identifies you, such as your name, phone number or email address.  Except as described below, MoboTap does not require users of the Website, Services or Application to actively provide us with Personal Information.

“Non-Personal Information” is information that cannot be directly associated with a specific person or entity.  Non-Personal Information includes but is not limited to your computer’s configuration and the version of Application that you use, or type of mobile device you are using to access our Website or Services or Application.

“Potentially Personal Information” is information that is Non-Personal Information in and of itself, but that could be used in conjunction with other information to personally identify you.  For example, Uniform Resource Locators (“URLs”) (the addresses of web pages) or Internet Protocol (“IP”) addresses (the addresses of computers on the Internet), which are Non-Personal Information in and of themselves, could be Personal Information when combined with Internet service provider (“ISP”) records.

“Aggregate Data” is information that is recorded about users and collected into groups so that it no longer reflects or references an individually identifiable user.

Information the Application Sends to Websites and ISPs

The Application, like other web browsers, sends Non-Personal Information and Potentially Personal Information to the websites you visit when requested by such website. This may include the type of browser you are using, the type of device you are using (desktop or mobile), your language preference, the referring site, and your IP address. This information may be logged by the websites you visit and the internet service provider (“ISP”) you use. What information is logged and how that information is used varies based on the policies of each individual website you visit and the ISPs you use.

Each website determines its own privacy practices for the distribution and use of this Non- Personal Information and Potentially Personal Information. If you care about how a website will use this information, you should check the privacy policy for that website.

Information we collect when you use the Application

You do not need to provide any Personal Information in order to download and use the Application. When you download the Application or use the Application, Website or the Services, we receive only standard Non-Personal Information that web browsers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. MoboTap’s purpose for collecting Non-Personal Information is to better understand how MoboTap’s visitors use the Application. From time to time, MoboTap may release Non-Personally Information in the aggregate, e.g., by publishing a report on trends in the usage of its Website.

MoboTap has and may from time to time partner with third party service providers (such as search result providers, advertising partners, etc.) to directly integrate or bundle certain features and services into or with the Application, which may or may not include switching default search result providers, in order to make your online experiences more convenient, richer and more personalized.  Such third party services providers may collect information, and inform you about what information it collects, in accordance with its own terms of service, privacy policy, and other applicable policies.  By agreeing to this Privacy Policy, you hereby authorize us to pass certain information to such third party service providers.  For example, any information you include in a search query will be passed along to the applicable third party search result provider; such information may include Personal Information to the extent that you include any such information in your search query or otherwise provide such information to the third party service provider directly.  You acknowledge and agree that MoboTap shall have no liability or responsibility for the privacy practices or other actions of any third party site or service or provider that may be used or enabled in the Application, including without limitation, Yahoo or any other search result provider.  If you are using a version of the Application enabled with Yahoo search results, we encourage you to review the Yahoo terms of service located at https://info.yahoo.com/terms/us/yahoo/ and privacy policy located at https://info.yahoo.com/privacy/us/yahoo/ in addition to any other relevant terms made available by Yahoo from time to time. Some of the web search services provided herein are provided by Trovi Search and powered by Trovi search partners. For information on the web search services data collection, please visit http://info.trovi.com/Privacy, and the search provider’s privacy policy, as applicable. Other services may be governed by Privacy Policies such as those located at http://app-privacy.info/.
By using the Website, Services, or Application you expressly agree that MoboTap may collect, transfer and share for use with third parties (including but not limited to third parties with whom MoboTap uses SDKs), Non-Personal Information, Potentially Personal Information, and Aggregate Data collected by MoboTap, including but not limited to: anonymous usage data, URL and IP addresses, web or device IDs and log information, and geolocation information.

In addition, some Application features/services may send limited additional information to MoboTap including:

Search URL: This is Non-Personal Information. When you type URLs or queries in the address bar, the letters you type are sent to your default search engine, so that the search engine’s autocomplete/prediction feature can automatically recommend terms or URLs you may be looking for. If a default search engine is provided on your version of the Dolphin Browser, then the Application will contact your default search engine when it starts or when you change networks so as to determine the best local address to send search queries.  For example, if Yahoo is set as the default search engine, then unless you change this default setting, the Application will contact Yahoo as described herein.  When you type URLs or queries in the Application, the letters you type may be sent to the applicable search engine so that the search engine’s prediction feature can automatically recommend terms or URLs you may be looking for, if applicable.  If you accept a predicted query or URL, the Application may send that information to the applicable search engine you choose as well.  The privacy policies of the third party search engine providers apply with respect to any information you provide to them (including, without limitation, information you provide through the Application).  Please review those policies carefully before providing them with any Personal Information.

Dolphin Connect: This utilizes Personal Information. Dolphin Connect allows you to synchronize certain data between your mobile phones, and other devices that have the Application installed, by utilizing the Dolphin sync Services. The Application will store your browser information, such as bookmarks, on MoboTap’s servers in association with your Dolphin Account, which is created when you first use Dolphin Connect.

Synchronized Bookmarks/Tabs/History/Logins/Passwords/Add-ons/Preferences: We keep a copy of your bookmarks on our servers if you use Dolphin Connect to synchronize your bookmarks, tabs, history, and passwords. We use this data to provide you with backup and synchronization services. The data is transmitted using SSL (a method of protecting data in transit) and helps us understand user preference to provide a range of search services like suggested apps and top sites.

Crash-Reporting Feature: This is Non-Personal Information. The Application has a crash-reporting feature that sends a log report to MoboTap’s support when the Application crashes. MoboTap uses the information in the crash reports to diagnose and correct the problems in the Application that caused the crash. Though this feature starts automatically after the Application crashes, it does not send information to MoboTap until you explicitly authorize it to do so. By default, this feature sends a variety of Non-Personal Information to MoboTap, including the stack trace (a detailed description of which parts of the Application code were active at the time of the crash), the type of mobile device you are using, and the Application crash frequency data.

Enable Location Feature: This is Non-Personal Information. This feature remains inoperative until you visit a website that requests your location and you choose to opt in to the feature. If you elect not to use the feature, the Application will not send information about your location to such website. Each time you visit such website, the Application will ask you if you want it to provide the site with your current location. Additionally, you may elect to have the Application remember your choice to allow or not allow the feature for each site. You are able to opt out at any time of having the Application remember your choice, just like any other preference setting.  Except as otherwise stated in this Agreement or the applicable third party service provider’s policies, we only permit our third party providers that are acting on our behalf (as opposed to search results providers) to use this information in connection with the service(s) they are providing to us.  They are required to ensure that any information collected on our behalf is anonymized and aggregated before they are permitted to use such information to develop new features or products and services, or to improve the overall quality of their products and services.  This means that they are required to ensure that your IP address and unique identifier of your Application will be stripped out before being used by any of our third party provider’s other products or features.  For more information on how our geolocation services providers use information sent by the Application, please see the privacy policy links in our list of third party service providers.  Please carefully consider any website or service provider’s privacy practices before agreeing to share your location.

Update Service and Push Notification: This is Potentially Personal Information. This feature periodically checks if a newer version of the Application is released and if a revised set of certain Services, such as “Speed Dial” and “Webzine,” are available. Specifically, this feature checks the package ID, Android ID, location information, and the version of Dolphin Browser on your device. Using this information, MoboTap may provide you with a newer version of the Application and recommends novel features.

Webzine Toggle Feature: This is Non-Personal Information. Each time you visit a website, the Application needs to send your current user URL to the Application server to check whether there is a matched Webzine column for that URL. None of the URLs are stored by MoboTap. Instead, these URLs are used to cross-index if a Webzine for the current website exists. If it does, the current website is immediately converted to Webzine format; if not, it remains the standard mobile site. This feature is turned off unless you click the “Toggle Webzine” button.

Active User Tracking: This is Non-Personal Information.  The Application includes functionality to send MoboTap completely anonymous user ID to track the number of active users of the Website, Services and Application. Active User statistics are transmitted using SSL (a method of protecting data in transit) and help us understand downloads status of the Application. Once sent to MoboTap, active statistics are stored in an aggregate format so that it no longer reflects or references an individually identifiable user.

Usage Statistics: This is Non-Personal Information.  The Application includes functionality to send MoboTap non-personal usage, performance, and responsiveness statistics about user interface features and hardware configuration. Usage statistics are transmitted using SSL (a method of protecting data in transit) and help us improve future versions of the Application. Once sent to MoboTap, usage statistics are stored in an aggregate format so that it no longer reflects or references an individually identifiable user.

Dolphin Sonar: This is Non-Personal Information. Dolphin Sonar allows you to search and navigate the Application using voice control. Each time you use Dolphin Sonar, the Application will send your voice commands and response duration to MoboTap and help us improve. The Application interprets your voice commands and transmits text using SSL (a method of protecting data in transit). These data is encrypted and stored in an aggregate format. It does not reflect or reference any individual user information.

Uninstall tracking: This is Non-Personal Information. The Application will ask you to leave some info when you want to uninstall the Application on a voluntary basis, such as the date when you installed the Application, the date when you updated the Application and the date when you wanted to uninstall the Application. Specifically, this feature checks the Application-crashing time, launch speed, Jetpack installation, location information, language, mobile device version and carrier on your device. Using this information, MoboTap will make an analysis of the uninstallation and keep making further improvements to the Application.

Hot Apps: This is Non-Personal Information.  When accessing the HotApps property, the Application may share the sending mobile device’s ID with our partners to measure the effects of any ongoing marketing campaigns.  No personally identifiable information is transmitted along with these values.  As an additional measure to protect privacy, the ability to send mobile device IDs is restricted within the Application to Websites

Other Critical Bugs: This is Personal Information. When you come across some critical issues in the Application, you can send a bug report to the MoboTap team via Help – Send Feedback page —Other Critical Bugs. You can choose to send which types of information you are willing to send from this dialog before submitting.  MoboTap will only use this data to assist in reproducing the issues which was reported and correct the issue within the Application.

Third-Party Channel:  This is Non-Personal Information. If you download the Application from a link provided by a third-party channel, the first time you launch the Application, it will send your mobile device ID and referrer code to the Application Server. The Application may share the mobile device’s ID with our partners to measure the effects of any ongoing marketing campaigns. No personally identifiable information is transmitted along with these values.

Other Information We Collect

Your installation and use of this product involves the collection and use of certain data by third parties, according to the terms set forth on the following third-party privacy policy: dolprivacy-policy.com.

MoboTap may collect Personal Information about you, but only if you voluntarily provide it to us. The types of Personal Information collected will vary depending on the activity. The requested information may include: (i) your name, (ii) mailing address, and (iii) telephone number

Use of Cookies

MoboTap may use cookies on its Website. A “cookie” is a small bit of record-keeping information that sites often store on a user’s computer. Cookies do not include individual’s names, email addresses, or other information that is personally identifiable; they are typically used to quickly identify a user’s computer and to “remember” things about the user’s visit. By default, the activities of storing and sending cookies are invisible to you.  However, you can disable cookies or set your browser to alert you when cookies are being sent to your computer.

(a) Information You Provide to Us.

  • We may collect Personal Information from you, such as your first and last name, gender, and e-mail and mailing addresses when you access certain Services offered via the Application.
  • We may collect Personal Information from you, such as your first and last name and your e-mail address, when you subscribe to our Dolphin Newsletter.
  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
  • When you participate in one of our surveys, we may collect additional profile information.
  • We also collect other types of Personal Information that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Application.
  • When you access or use our Services, you may provide the following information to us:
    • Customer Support Information: If you are a visitor to the Site, or a user of the Apps, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.
    • Contact Information: When you sign up to create an account with some of our Apps, you will be required to provide an email address, phone number or other contact information as part of the registration process. Alternatively, you can use your Facebook Account or other third party social network accounts (together, “Social Media Account”) to register for the Services.
    • Social Media Account Information: When you sign up with a Social Media Account, you will be asked to choose which information you would like to share with us, such as your email address, birthday, friends list, or public profile information. When you decide to use a Social Media Account to sign up for our Services, we only require the collection of the email address associated with your Social Media Account; all other information provided by you is voluntary.
    • Profile Information: When using some of our Services, you may be able to add information to your profile, such as an avatar or profile picture, birthday, nickname or username, or country. You voluntarily provide this information to us.

    Your Content: When using some of our Services, you can create, post, upload or share content by providing us with access to your photos, media and files, and your device’s camera and microphone. You voluntarily provide this information to us.

(b) Information Collected via Technology.

  • To make the Application more useful to you, our servers (which may be hosted by a third party service provider) may collect information from you, including your browser type, operating system, IP address, domain name, and/or a date/time stamp for your visit.
  • We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Application.  Persistent cookies can be removed by following Internet browser help file directions.

(c) Information Collected from Third Party Companies.

We may receive Personal and/or Non-Personal Information about you from third party companies that provide the Application by way of a co-branded or private-labeled website, or third party companies that offer their products and/or services on the Application. These third party companies may supply us with Personal Information. We may add this information to the information we have already collected from you via the Application in order to improve the Application.

We automatically collect information about you when you use the Services, such as:

  • Device Information: If you access the Services through a mobile device, we may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background, mobile device’s advertising ID, other unique identifiers and other information related to device setting.
  • Cookies & Similar Tracking Information: We use cookies and similar tracking technologies to collect information about your interactions with our Services. The information we collect includes, but is not limited to, account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your Internet Protocol (“IP”) address, your mobile country code, and your user ID.
  • Content Sharing: When you choose to share content with us, we automatically collect information about your Wi-Fi connection, and call information.

You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services. For more information about our cookies and similar tracking technologies, and how to manage them, please read the Advertising Choices Policy.

(d) Information Collected from Social Networking Sites. 

After you create a Dolphin Connect Account, you will have the option of granting the Application access to certain Social Networking Sites (“SNS”) accounts (“SNS Accounts”). By granting such access to the Application, you understand that Application will access, render and store content from your SNS Account(s), so that it is available and viewable through your Dolphin Connect Account. In some instances, information that you post to your SNS Account(s) will be viewable via Dolphin Connect. Please review the privacy policies of the SNS services you use. You have the ability to disable the connection between Dolphin Connect with any SNS Account, at any time.

(e) Information You Share on Third Party Websites or through Social Media Services.

The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

Use of Information Received

General Use. In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your Personal Information in the following ways:

  • identify you as a user in our system;
  • provide improved administration of the Application;
  • improve the quality of experience when you interact with the Application;
  • send you administrative e-mail notifications, such as security or support and maintenance advisories;
  • respond to your inquiries related to employment opportunities or other requests;
  • for editorial and feedback purposes;
  • for statistical analyses of our users’ behavior;
  • for product development and content improvement; and
  • to send newsletters, surveys, offers, and other promotional materials related to the Application and for other marketing purposes of MoboTap and its third party partners.

Creation of Anonymous Data.

We may create Anonymous Data records from Personal Information by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of the Application and improve Website navigation.  MoboTap reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

Disclosure of Information Received

MoboTap generally does not sell or rent your Personal Information with other companies as a matter of policy. However, we may disclose your Personal Information as described below and as described elsewhere in this Privacy Policy.

Third-Party Service Providers. We may share your Personal Information with third-party service providers to: provide you with the services that we offer you through the Application; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services. These third party service providers are required not to use your Personal Information other than to provide the services requested by MoboTap.

Affiliates and Acquisitions.  We may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. In some cases, we may choose to buy or sell assets.  In these types of transactions, user information is typically one of the transferred business assets.  Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy or other reorganization, user information would be one of the assets that is transferred or acquired by a third party.  You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as described in this Privacy Policy or in accordance with any policies of any such third party to which you may be bound, following any such acquisition.

Co-branded Service Offerings. We may enter into co-branding or co-promotional agreements with third parties pursuant to which we may share Personal Information with such third parties. For example, we may enter into agreements with a third party company pursuant to which we provide the company with a URL and a customer registration page co-branded with, or private labeled by, the third party company, and the third party company distributes and promotes the URL to its customers. The third party company may have access to Personal Information that we collect from their customers. As a result, if you register for the Services or the Application on a website provided by such third party company, we may provide your Personal Information to that company. Please note, however, that we do not control the privacy practices of these third parties.  We encourage you to review the privacy policies of those third parties.

Other Disclosures.  Regardless of any choices you make regarding your Personal Information (as described herein), MoboTap may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on MoboTap; (c) to protect or defend the rights or property of MoboTap or users of the Services or the Application; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms of Use located at dolphin-browser.com/terms-of-use-for-dolphin-browser.

If you have any questions regarding the management and use of personal information, please contact us at the address legal@mobotap.com.

We use the personal information we gather through the Services for the purposes described below. If we use your personal information in any other ways, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.

  • To provide the Services to you.We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services. We cannot provide you with Services without such information.
  • To provide customer service. We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
  • To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies; enforce our agreements with third parties and partners; and, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.
  • To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.
  • For security purposes. We process your personal information to: improve and enforce our security measures; combat spam, malware, malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes.Designated Countries: For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data  Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the   “Designated Countries”) based on our contract with you.
  • To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and/or to manage risk  as  required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes. Designated Countries:Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to comply with our    legal obligations.
  • To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook, Google, Instagram, Twitter, etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services. Designated Countries:Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
  • To conduct research and development. We process information about the way you use and interact with our Services to: help us improve our Services; build new Services; and build customized features or Services. Such processing ensures your continued enjoyment of part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
  • To engage in marketing activities.We may process your contact information or information about your interactions on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars, or other materials, including those of our partners; and, keep you up-to-date with our relevant products and Services. Transactional communications about your account or our Services are not considered “marketing” communications. In addition, when you share your friends’ contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can opt-out of our marketing activities at any time. Designated Countries: For users located in the Designated Countries, please see section 9.C. below.

 

Information for Residents in the European Economic Area, United Kingdom and Switzerland (the “Designated Countries”)

This section only applies to users of our Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in.

Where we rely on your IP address, we cannot apply the terms of this section to any user that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries.

A. Our Relationship to You

Cheetah Mobile Inc. and its affilates are data controllers with regard to any personal information collected from users of its Services. A “user” is an individual providing personal information to us via our Services, such as by creating an account with our Apps, signing up for our newsletter(s), or otherwise accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.

B. Legal bases for processing Personal Information

We describe our legal bases for processing in Section 4 (“How We Use the Information We Collect”) and Section 5 (“How We Share Your Information With Third Parties”) under headings entitled “Designated Countries.” The legal bases on which we rely on to process your personal information include: your consent to the processing; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; necessity to process in the public interest; or for our legitimate interests as described in those sections.

C. Marketing Activities

If you are located in the Designated Countries and are a current user, we will only contact you by electronic means (such as email or SMS) per your communication preferences and/or with information about our Services that are similar to the Services you previously purchased from us or negotiated to purchase from us.

For new users located in the Designated Countries, we will contact you by electronic means for marketing purposes only based on your consent or based on your friends’ consent. You can always withdraw your consent or change your marketing communication preferences at any time and free of charge. To opt out of the emails, please click the “unsubscribe” link in the footer of marketing emails or contact us at legal@mobotap.com.  Marketing communications are promotional in nature and do not include transactional or Service-related communications.

D. Individual Rights

We provide you with the rights described below when you use our Services. Please contact us at legal@mobotap.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity.  Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

  • Where denial of access is required or authorized by law;
  • When granting access would have a negative impact on other’s privacy;
  • To protect our rights and properties; and
  • Where the request is frivolous or burdensome.

Right to withdraw consent. If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

Right of access and rectification. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.

Right to erasure (the “Right to be Forgotten”). You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

Right to restriction. You have the right to restrict our processing your personal information where one of the following applies:

  • You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;
  • The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
  • We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
  • You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

Right to object to processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

Notification to third-parties. If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

Right to Lodge a Complaint. If you believe we have infringed or violated your privacy rights, please contact us at legal@mobotap.com so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

You may reach our Data Protection Officer at eudpo@cmcm.com.

E. Transfer of Personal Information

If you choose to use the Services or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.

Designated Countries:  We transfer your personal information subject to appropriate safeguards as permitted under the Data Protection Laws. Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for transferring personal information in place with the third-parties to which your information is transferred.  For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

Special Information for California Residents.

We provide a separate <Privacy Notice for California Consumerswhich addresses how we respect California’s users’ privacy.

Changes to Personal Information

You may change any of your Personal Information in your Account by editing your profile within your Account or by sending an e-mail to us at the e-mail address set forth below.  You may request deletion of your Personal Information by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).  When we delete any information, it will be deleted from the active database, but may remain in our archives.  We may retain your information for fraud or similar purposes or to comply with document retention policies.

Security of Information Received

MoboTap is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. MoboTap has strict restrictions on access to user data. Only a limited number of MoboTap employees have access. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while MoboTap uses reasonable efforts to protect your Personal Information, MoboTap cannot guarantee its absolute security.

Contact Information

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the address below.

MoboTap welcomes your comments or questions regarding this Privacy Policy. Please e-mail us at legal@mobotap.com or contact us at the following address or phone number:

MoboTap Inc

Attn: Legal Notices – Privacy

620 Folsom Street, Suite 100

San Francisco, CA 94107

E-mail: legal@mobotap.com