Vskit Privacy Policy

Update date of this agreement version: March 11, 2024

Effective date of this agreement version: March 11, 2024

Version number of this agreement: 20240311V1.0

Excellent innovation limited (hereinafter referred to as "Vskit", "we", or "our") is the provider and operator of Vskit application software and services (hereinafter referred to as "this software"). We fully respect your privacy rights and will do our best to ensure the security of your personal information. In the process of providing you with products or services (collectively referred to as "this service"), we may collect and use your personal information based on your consent or in accordance with applicable laws and regulations. This Privacy Policy (hereinafter referred to as "this Policy") aims to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using Vskit products or services, your rights to this personal information, and how we maintain your rights. This Policy applies to all products and services provided by Vskit, including applications for computers, mobile smart end points, Mini Programs, web pages, Software Development Kits (SDKs) and application programming interfaces (APIs) for third-party websites and applications, or other forms that may appear in the future.

It should be noted that this policy does not apply to services provided to you by other third parties. You may receive content or network links from third parties, so please choose carefully whether to access the links, content, products, and services provided by third parties. Before submitting personal information to third parties, please carefully read the third party's Privacy Policy.

In order to ensure that you fully understand this Privacy Policy and make your own choices, we will try our best to explain it to you in a clear and easy-to-understand manner, and will clearly mark or highlight the key reading content (especially in bold, capitalized, underlined, etc.). When you use our services for the first time, we will provide pop-up prompts and guide you to pay attention to the core content of this Privacy Policy.

Please read this policy carefully before using our products or services, submitting personal information to us, or agreeing to our collection of your personal information. Please visit us frequently to learn about updates to this policy. If this Privacy Policy is updated, we will post a notice on the relevant product or website to keep you informed of our updates. By accessing or using our services after we issue such a notice, you agree to the updated Privacy Policy. You can check the "Update Date" at the top of the Privacy Policy to confirm the latest update time of the Privacy Policy.

If you have any questions, please feel free to contact us through the following methods:

privacy.help@mbox.ng

You can also access this Privacy Policy by:

•    Vskit-Me-Settings-Privacy Policy

This Privacy Policy will help you understand the following:

1. How we collect and use your personal information

2. How we store and protect your personal information

3. How we share, transfer and disclose your personal information

4. How your personal information is transferred across borders

5. Your rights to your personal information

6. How we handle children's personal information

7. Third-party service providers and their services

8. Supplements and updates to this policy

9. How to contact us

1. How we collect and use your personal information

a. General overview

Vskit firmly believes that basic privacy rights should not vary depending on where you live in the world. Therefore, we believe that regardless of where a natural person resides, Vskit will regard any information related to the natural person that has been identified or identifiable, especially the natural person's name, identity information, location data, online identifiers, or specific physical, physiological, genetic, psychological, or related data, as "personal information".

We will only collect information necessary for specific, specific, explicit and lawful purposes and shall ensure that your information is not further processed in a manner inconsistent with those purposes. If we intend to use your personal information for other purposes not specified in this Privacy Policy, we will obtain your consent again.

When collecting your personal information, we will collect it in the following three ways, including 1) information you provide directly to us; 2) information generated by your use of this software through automated means (such as device information, service log information); 3) information obtained from other sources.

You have the right to choose whether to provide personal information when using Vskit products or services or when we request it. You are not required to provide personal information to Vskit, but in some cases, if you choose not to provide it, Vskit will not be able to provide you with relevant products or services, nor respond to or solve the problems you encounter. We will only collect and use your personal information for the purposes described in this policy. The following examples illustrate the personal information we collect from you:

b. Vskit's main business functions and collection usage scenarios

The main business function of this software is to provide you with online content browsing platform services .

i. Provide you with account registration and login services

In order to facilitate you to use the functions and services of this software more fully, you can register and log in by actively providing your email address. To verify your identity. When you register and log in to Vskit's account, we will send verification to your email, and you need to submit your verification code to complete the login. After you complete the registration, the system will automatically generate a USER ID for you to identify your account. If you refuse to provide this information, you will not be able to register for a Vskit account and use relevant functions, but it will not affect your normal use of other functions of Vskit. You can still browse and use the basic business functions of this software in tourist mode (that is, without becoming a registered user).

We provide you with convenient login services for third-party accounts. You can use third-party accounts (such as Google account login). At this time, we will obtain your third-party account Open ID, username, avatar, and establish an association with your Vskit account.

During the process of login, registration, and use of this software, You can choose to supplement, fill in, and modify your nickname (including real name), avatar (including real portrait), gender, and birthday information in your personal center. If you have not set a nickname, we will randomly assign you a default nickname, and you can modify your nickname at any time. Your refusal to provide supplementary information will not affect your experience of registration and login functions. If you refuse to provide such information, you can still use other functions of this software normally. When you set your avatar, we need to access the Camera, File, and Media Permissions. You can turn off your authorization at any time through "System Settings - > Vskit - > Camera Permissions/File and Media Permissions".

ii. Content browsing service

1. When you use this service, we will record your search, like, favorite, share, download, and watch records so that you can check your usage records and provide breakpoint playback function at any time.

2. In order to show you and recommend content that you may be interested in, we will collect your system information (time zone, OS version number, ROM version number, Android version number), device information (mobile phone brand, model, IMEI), carrier code, collection records, click records, browsing records, download records, and your Device ID (GAID) information to predict your preferences. We will adjust in real time based on the behavior records generated by your browsing of Vskit, and continuously optimize our recommended content. You can turn off the customized recommendation function through privacy.help@mbox.ng. When you turn off this function, we will not process your personal information for the purpose of customized recommendation, but we will still push works and content unrelated to the content you are interested in.

3. During the use of this service, you can provide us with any feedback you find at any time. At this time, we will record your User ID, report content, and feedback issues. We will handle abnormal issues based on the information you submit.

iii. Operate and maintain this service

1. In order to ensure the normal operation of this service, we will collect your mobile phone information (phone model, brand), application information (application package name), account type (your User ID), Device ID symbols (IMEI\ GAID), system software information (OS version number, Android version number, Rom version number, system language setting, time zone setting), network information (network type, mobile operator code), and exception log information. Such information will be used for analysis, resolution of software exceptions, and maintenance of stable software operation.

2. We may also obtain information provided by you for the reasonable need to improve our products or services. Specifically, the relevant feedback information you provide through the Feedback function, mobile phone model, application version number information, and the contact information you submit (optional), so that we can contact you and provide solutions. If you need to upload pictures for feedback issues, we will call your file and media permissions, you can turn off your authorization by setting the path through your mobile phone . The questionnaire replies to information sent to us when you participate in a survey. We may combine information from one service with information from other services to provide you with better services, content, and suggestions.

iv. Coin recharge service

You can exchange coins for corresponding rewards through platform rules. You can obtain coins by recharging or completing coin tasks. If you use the coin recharge function, we will record your order information (recharge time, order number, recharge amount, payment method) and payment status (whether the payment is successful) . You can also choose to participate in the task to obtain coins. When you perform the task, we will record your task completion record , the number of coins obtained.

When you receive coins unlocking rewards based on specific operational activity task rules, we will record your coin exchange records and coin balance. You can check relevant information in your account's wallet.

v. Provide you with messages TTpush

We may also TTpush notifications, events, and other messages to you based on your Device ID, operating system version, current device user nickname, network information, and information about your use of this app . To unsubscribe from notifications, events, and other messages, you can go to " Set up-Vskit- Notifications"  to withdraw your consent. The closing path may vary depending on the version.

c. Other situations where your information may be collected

In some legal cases, we may obtain your personal information from other individuals, business entities, public channels, or other third parties you instruct, as well as from other partners who provide our products or services and assist us in ensuring information security and preventing fraud. We will explain to you when collecting and obtain your consent.

We may also collect other information about you, your device, or your use of the Services in other ways that we inform you of and consent to at the time of collection.

In order to better improve our product layout and provide you with better services, we may conduct research, statistical analysis, and prediction on the collected information through anonymization (including using anonymous data for Machine Learning or model algorithm training). We will take technical measures and other necessary measures to process the collected personal information, so that such data cannot be re-identified to specific individuals or restored. According to applicable laws and regulations, the use of such processed data does not require further notice to you and your consent.

2. How we store and protect your personal information

a. How we store your personal information

We will store personal information collected based on your consent in accordance with the relevant national laws and regulations on the protection of personal privacy data. In cases where local laws and regulations do not prohibit it, we may also store the collected personal information in countries or regions outside the country where our business is located.

Currently, Vskit may store your personal information in: Frankfurt

Depending on the business situation, we may introduce servers from other regions or countries, and we will update this policy at that time.

Regardless of whether personal information is stored in the country where the business is located or in other countries or regions where it does not violate legal provisions, we will store it in accordance with relevant laws and regulations on data storage. We will also consider the characteristics, scope, purpose, risks that may be encountered during the processing of personal information, as well as the serious consequences once damage is caused, and implement necessary security measures. For example, we will use encryption and de-identification methods to store collected personal information. At the same time, we will store the information according to the minimum storage period required for business operations, unless you agree to extend the retention period or are allowed by law. Data that exceeds the storage period or data that you request us to delete will be deleted or other appropriate measures will be taken without violating relevant laws and regulations.

b. How we protect your personal information

We will take other necessary measures to protect the security of your personal information to prevent data from being misused, unauthorized access, and unauthorized modification, disclosure, or destruction.

We implement security measures to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical and physical protection measures to protect your personal information by considering the nature, processing and security of your personal information. We continuously strive to improve these protection measures to ensure the security of your personal data.

Of course, it should be reminded that no matter how perfect the measures are taken, it is impossible to absolutely guarantee the avoidance of data storage security accidents. If a security breach occurs, we will report to the corresponding regulatory authorities in accordance with relevant laws and regulations, and provide the types of personal data involved in the data breach, the number of data principals, the possible consequences of the data breach, and the remedial measures we plan to take. We will take all possible measures to remedy or mitigate the damage and consequences caused by the data breach. If permitted or required by laws and regulations, we will promptly inform you of the possible consequences or significant damage caused by the data breach, so that you can take appropriate measures in a timely manner and protect your rights as much as possible.

Due to the fact that no website, Internet transmission, computer system, or wireless connection is absolutely secure, in addition to taking necessary security measures, users also need to strengthen their awareness of privacy and security risks. For example, if you jump to a third-party website, link, product, or service through our service, please be careful and carefully read the terms of the agreement of the website, link, product, or service for the security of any data information collected by these websites, links, products, or services. We do not assume any legal responsibility for data security issues caused by such third parties. If you find that some content, advertisements, or functions of our website, product, or service may be provided by third parties and may endanger your personal privacy and security, please contact us in a timely manner, and we will give priority to processing according to law and regulations.

3. How we share, transfer and disclose your personal information

In terms of sharing, transferring, and disclosing your personal information, we adhere to the principles and requirements of minimization, necessity, and legal compulsion. Generally, we will not share, transfer, or disclose your personal information externally, but where relevant laws and regulations apply or permit, we may share, transfer, or disclose your personal information in the following situations:

a. How we share your personal information

We will not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with Vskit's affiliates. We will only share your information within Vskit's affiliates for legitimate and clear purposes, and will only share information necessary to provide services, and will be bound by the purposes stated in this Privacy Policy. If the relevant purposes are not included in this policy, we will explain them in the corresponding specific product or service Privacy Policy or notice.

We may share necessary personal information with authorized third-party partners (including Payment service providers, data storage service providers, marketing promotion service providers, third-party SDK service providers, etc.) to perform certain functions or provide you with better services and User Experience. Specifically, (1) our Cloud as a Service provider will provide us with cloud storage services to ensure the normal operation of the service; (2) our Payment service providers will obtain the information required for your payment order to complete the payment service

We will embed software tool development kits (SDKs) or other similar applications from authorized partners in this software (we will conduct strict security checks to protect data security).

We adhere to the principles of minimization, necessity, and legal permission for such sharing activities. Before sharing information, we will sign a strict Non Disclosure Agreement with authorized partners, requiring them to take relevant confidentiality and security measures to handle personal information in accordance with this policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security functions and information security qualifications (such as level protection assessment, information security management system, etc.). When we embed an authorized partner's SDK or other similar application in this software, we will fulfill our duty of caution and require the SDK that obtains the information to protect your data security.

In order to provide evaluation, analysis or other commercial services, we may also share your non-personal information with third parties, for example: we may use the summarized information to help partners (such as advertising service providers) understand the effectiveness of their services, feedback and usage trends.

When it comes to transactions related to mergers, acquisitions, bankruptcy liquidation, asset transfers, etc., if it involves the transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy through agreements or other appropriate measures, and require such entities to take no less than the confidentiality and security measures required by this policy to handle personal information.

b. How we transfer your personal information

Vskit will not transfer your information to any other party unless:

(1) Obtain your affirmative consent.

(2) If Vskit is involved in a merger, acquisition or sale of all or part of its assets that may affect your personal information, we will post a prominent notice via email and/or our website or other appropriate methods to inform you of any changes to your ownership, rights and choices regarding your personal information.

(3) In cases where this Privacy Policy has been described or otherwise notified to you.

c. How we disclose your personal information

Vskit may need to disclose your personal information as required by law, due process, litigation and/or requests from government departments and authorities. We may also disclose information about you if disclosure is necessary or appropriate for national security, law enforcement or other matters of public importance.

In addition, we may share your personal information with:

(1) We may share your personal information with our lawyers, accountants, auditors or similar advisors when we ask them for professional advice.

(2) Investors and other relevant third parties, if there are actual or potential sales or other corporate transactions related to entities within our group.

(3) Other third parties, for example, disclose specific information under your authorization.

4. How your personal information is transferred across borders

For the purposes described in this Privacy Agreement, after complying with applicable laws and regulations in your region and obtaining your authorization and consent, we may transfer your personal information to the resources or servers mentioned in Article 3 of this policy for storage or processing. We may also transfer your personal information to third-party service providers and business partners, so your data may also be transferred to other countries or regions. The privacy protection laws in these countries or regions may not be the same, and the jurisdictions where these servers are located may or may not protect personal information according to the same standards as your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal information, and we will carry out corresponding cross-border transfers and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.

If we transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with applicable laws. We will take appropriate security and protection measures to ensure that all such transfers comply with applicable local data protection laws.

5. Your rights to your personal information

As a data principal, you have a series of rights regarding personal information, such as confirmation, access, correction, deletion, withdrawal of consent, and complaints (hereinafter referred to as "requests"). We fully understand and respect these rights, and according to applicable law, such rights will also be subject to specific exclusions and exceptions. We will also take active measures to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. For your legitimate and reasonable requests, we generally do not charge fees. However, for requests that are repeated multiple times and exceed reasonable limits, we will charge a certain reasonable fee based on actual management expenses and within the scope permitted by applicable law. For requests that are unreasonably repeated, require excessive technical means (such as the need to develop new systems or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are very unrealistic, or violate mandatory legal provisions, we may refuse them.

a. Recognition and Right of access

We inform you of how we collect and process personal information through this Privacy Policy or the Privacy Policy or notice in specific product and service scenarios. You have the right to confirm or refuse this collection and processing behavior by checking and other means. However, when you refuse, some functions that require your explicit authorization and consent may not be available. For the personal information you have provided to us, you can directly query it at the interface of our products or services. For situations that cannot be queried, you can send an email to privacy.help@mbox.ng, and we will deal with it in a timely manner after receiving your email.

b. Right of correction and deletion

When your personal information changes, or when you find that the personal information we collect and process is incorrect or incomplete, you have the right to request us to make corrections or supplements. For some of your personal information, you can directly correct or modify it on the relevant function page of the product or service. For example, you can edit your personal information through the personal center page. When we have collected your personal information for the purpose of collection or it is no longer necessary, or when you find that we have collected and processed your personal information in violation of laws, administrative regulations or the provisions of this Privacy Policy, you have the right to request us to delete the relevant personal information. For personal information that has not been provided with a correction or deletion channel, you can request correction or deletion by contacting privacy.help@mbox.ng.

However, in some cases, we may not approve your deletion request, such as when you request us to delete transaction data, and Vskit is legally obligated to retain records of the transaction to comply with applicable local laws. Please also note that if you request the deletion of your information from our products and services, due to certain applicable local laws and technical restrictions, we may not immediately delete the corresponding information from the backup system, but we will securely store your personal information and prevent it from being further processed until the backup system is updated, your information can be deleted, or your information can be anonymized.

c. Right to withdraw consent

In order to achieve the corresponding functions of our different products or services, we will need necessary personal information according to applicable local laws and regulations. This Privacy Policy explains "How we collect and use your personal information". You can revoke the consent previously granted to us for specific purposes by deleting information, turning off device functions, and withdrawing consent requests, including collecting, using, and/or disclosing your personal information that we hold or control. You can contact us by email to privacy.help@mbox.ng for relevant operations. We will process your request within a reasonable time after you send it, and will not collect, use, and/or disclose your personal information based on your request thereafter.

If you withdraw your consent, you may no longer be able to access some and/or all of the features of Vskit products and services. Withdrawing your consent or authorization will not affect the validity of our previous processing activities based on your consent.

d. Right to complain

You have the right to make a complaint by contacting us by sending an email to privacy.help@mbox.ng. We will respond promptly after receiving your complaint. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you can also file a complaint or report to the local statutory personal data protection department, or file a lawsuit with the competent court.

e. Right to manage privacy settings

You have the right to control your privacy settings. You can use these privacy settings to restrict us from collecting, using, disclosing or processing your personal information. For example, you can choose to turn on or off the functions and permissions of "File and Media Permissions" and "Camera". You can also obtain more detailed information about the security status of your device in "Settings". If you have previously agreed to turn on the corresponding permissions or agree to our use of your personal information based on the above business scenarios, you can turn it off through "Settings", "Application Management", "Permission Management" or change your decision by contacting us through privacy.help@mbox.ng.

f. The right to cancel services or accounts

You can request to cancel your account by privacy.help@mbox.ng contacting us in this service. Please be cautious in canceling your account. You know and understand that after you cancel your account, we will stop providing products and services based on the account. Unless otherwise required by the laws applicable in your area, we will also delete the corresponding personal data under your account. If you are authorized to log in to this service through a third-party account, please apply to the third party to cancel your account.

g. Rights in certain jurisdictions

Please note that under applicable law in certain jurisdictions, you may have the following data principal rights:

(1) Right to restrict processing. You have the right to request that we restrict the processing of your personal information. We will examine the reasons for your restriction request. If the reasons comply with applicable data protection laws, we will only process your personal information where such laws apply and notify you before lifting the processing restriction.

(2) Automated decision-making rights. You have the right to refuse information processing based on automated decision-making, including performance analysis and other automated processing that may have legal or similar effects on you.

(3) Data portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.

We have the right to refuse to process your request, and we have the right to refuse certain requests from you under applicable exemptions or in accordance with applicable law. For example, some requests are obviously unfounded or obviously exceed the limit, or require disclosure of third-party information.

6. How we handle children's personal information

Vskit's products and services are not provided to children under the age of 14 or the equivalent age specified by law in your jurisdiction (the legal standards for determining the age of children vary in different countries or regions, and we will mainly define children based on the laws and regulations of the specific business country or region). We will not actively collect children's personal data, nor will we use children's personal information for marketing purposes. If you find that relevant children's information has been transmitted to us, please send an email to privacy.help@mbox.ng to contact us, and we will delete the relevant information as soon as possible. If we find that we have collected children's personal information, we will also try to delete the relevant content as soon as possible.

7. Third-party service providers and their services

When you use Vskit products or services (such as payment services, etc.), you may receive website links or content and services provided by third parties outside of us, and some third-party products or services may be provided through SDKs and other means. You can choose whether to access or accept the websites, products and services provided by third parties based on your own judgment. Our Privacy Policy does not apply to any products and services provided by third parties. Because we cannot substantially control third parties, we cannot be responsible for the collection and processing of your personal information by such third parties. When you submit any information to such third parties, please carefully understand their Privacy Policy and pay attention to protecting your personal information.

8. Supplements and updates to this policy

We reserve the right to update or modify this policy from time to time based on changes in our business, technology, applicable laws and operations. If this policy is modified, we will publish the latest policy through APP push, or notify you by APP in-app notification . Please regularly pay attention to this page or the notices we send to you to keep abreast of updates to this Privacy Policy. Although this Privacy Policy may be adjusted, we will not weaken your rights under this Privacy Policy without your express consent.

When we collect additional personal information from you or when we use or disclose your personal information for new purposes, we will seek your affirmative consent again in accordance with applicable law. If you continue to use the products and services on the website, mobile device and/or any other device, you will be bound by the updated Privacy Policy.

The content of Vskit products or services described in this Agreement may vary depending on the type of product you are using, system version, or local laws and regulations.

9. How to contact us

If you have any suggestions, questions or concerns about our Privacy Policy or practices relating to the protection of personal information, please contact us at:

Email: privacy.help@mbox.ng (Note: This email address is only used to receive emails related to our Privacy Policy or our protection of personal information)

We will review your privacy or personal information request as soon as possible and respond to you within 15-30 days after verifying your user identity. If your request itself involves complex or significant issues, we may ask you for more information.

If you are not satisfied with our response, especially when your legal rights have been violated by us, you can seek solutions from the relevant data protection regulatory authorities in your jurisdiction. If you make the above inquiries to us, we will provide information on possible complaint channels that may be applicable to you based on your situation.

Thank you for taking the time to read our Privacy Policy!