1.Introduction
As a digital content service company, CATCH INTERNET PTY. LIMITED ("the Company" or "we") collects personal information, referred to as "Personal Data," while providing our products, applications, services, and websites (collectively referred to as "the Services"). Protecting Personal Data is a crucial aspect of our management. We commit to adhering to the applicable laws and regulations of the countries and regions where we operate and to protecting Personal Data in accordance with this Privacy Policy ("the Policy"). This Policy clarifies how we will collect, use, and handle your Personal Data and guides you on managing your own Personal Data. Our Services include not only those provided by our company but also those offered to information providers, advertisers, advertisement distributors, other partners, and customers.
2. Scope of this Policy
This Policy applies to all Personal Data collected by us, regardless of the country or region
2.1. Applicable Scope
This Policy covers all Personal Data we collect. For specific services, we may implement individual privacy policies or additional provisions (collectively referred to as "Individual Policies"). These Individual Policies will detail the types of Personal Data collected for specific services, how we will use and provide such Personal Data, and other applicable policies. If there is any inconsistency between the Individual Policies and this Policy, the Individual Policies will prevail. Within the scope of this Policy, our company is the controller of the Personal Data.
2.2. Applicable Policies
We will process Personal Data in compliance with applicable laws and regulations as per this Policy.
3.Personal Data to be Collected
We will collect the following Personal Data in a lawful and fair manner:
· Personal Data provided to us by you.
· Personal Data related to your use of our Services.
· In addition, we will lawfully collect other Personal Data, including information from third parties.
· If you do not provide certain types of information necessary for using our Services, you may not be able to fully or partially utilize them.
Below are examples of the Personal Data we may collect.
3.1. Examples of Personal Data Provided by You
· You may be asked to provide personal data by operating your device, entering information, or through documents and other mediums.
· This includes, but is not limited to:
o Phone numbers and email addresses required for account creation.
o Responses provided in our surveys.
o Identity verification documents.
o Your profile information (like images, display names, status messages, user IDs, etc.), which will be public unless set as private.
· The contact list on your device. For instance, using features like "Auto Add Friends," we access phone numbers in your contact list only when enabled for auto-adding friends, recommending potential acquaintances, and preventing unauthorized use.
3.2. Examples of Personal Data Related to Your Use of the Service
We collect information related to your activities when using the service and your device usage, such as:
· The status of your service usage, including dates and lengths of usage, search activities and results, purchased service items, and the content and advertisements you view or click.
· When using communication apps like MeTime, the content you post and texts, images, videos, and audio sent through our servers. This also includes external information like recipient data, format, posting time and place.
· In principle, we do not use transmitted content for any purpose other than transmission, but in some specific countries or regions, with your additional consent, we may use some of this information for service provision, development, unauthorized use prevention, and optimized content delivery, including advertisements.
3.2.1. Location Information
· We may collect your device's location information for providing content based on your location, sharing location information with friends in the service, or to provide optimized search results.
· Even if you choose not to share your location, we may estimate your approximate location using your IP address.
3.2.2. Information on Apps, Browsers, Devices, and Networks
We collect information related to the device, browser, and apps you use, including ad identifiers, cookie IDs, device type, operating system, language/time zone settings, browser type, app version, etc., as well as network information like the telecom operator's name and IP address.
3.3. Examples of Personal Data Collected from Third Parties
3.3.1. Personal Data Collected from Partners: We may acquire your personal data from partners who operate independent services or services associated with ours, like MeTime official accounts or MeTime login. Additionally, we might collect your identifiers (such as internal or advertising identifiers), one-way encrypted (hashed) email addresses and phone numbers, IP addresses, certain device information (like the operating system), your attribute information, and activity records (including shopping, browsing, search history, and location information). These data are used for purposes stated in Section 4, like disseminating messages from partner official accounts, advertising, measuring ad effectiveness, generating statistics, and other objectives.
3.3.2. Personal Data Uploaded by Other Users: Other users of our services might upload content containing personal data of third parties, such as photos with other individuals, which we then collect.
3.4. Other Circumstances of Collecting Personal Data
In addition to the scenarios mentioned earlier, we may also collect personal data in the following situations, but not limited to:
3.4.1. Personal Data Collected Directly from Third-Party Services: We might collect login records from third-party websites and applications that have plugin features like "Send via MeTime." These records are linked to your account to help us understand how you use our services and to maintain, improve, and secure our services.
3.4.2. Personal Data Collected from Public Information: We gather public information, such as details published on corporate websites, for use in services like search. If this public information contains personal data, it might be utilized to display search result.
4.Purposes of Using Personal Data
· We use the collected personal data (including data collected while you use our services and from third parties) for the following purposes:
o To provide and maintain our services;
o To develop and improve our services;
o To enhance security and prevent unauthorized use;
o To offer optimized services to you.
· Our use of personal data aims to deliver our services, for research and development to provide safer and higher-quality services, and to offer services (including advertisements) more aligned with user needs.
· This involves managing and using identifiers assigned to users, partners, advertising IDs (like IDFA and Google Ad IDs), and other identifiers and one-way encrypted email addresses and phone numbers.
· Additionally, we may combine information collected from partners with our data for purposes mentioned in this section, such as disseminating partner information, advertising, measuring ad effectiveness, and generating statistics.
· We notify or announce the purposes of data collection to users within the scope required by applicable laws.
· We won't use personal data beyond the scope of these purposes unless we have your consent or as permitted by law. We take measures to ensure that data is not used for any other purposes.
· Notwithstanding the above, when collecting personal data from third parties, if such data has other purposes, we will use it within legally permissible limits based on the provided purposes.
Examples of data usage include:
4.1. Providing and Maintaining Services
· To provide and maintain our services, respond to inquiries, conduct marketing activities, and issue service-related and partner announcements, we use the necessary information.
· This includes verifying your identity when you log in, during identity verification, and while addressing user inquiries. It also involves sending and publishing messages and content, processing invoices and payments for purchased goods or paid services, monitoring service usage to respond to customer service inquiries, and dispatching prizes or products obtained from marketing activities.
4.2. Developing and Improving Services
· To provide superior services, products, and content, we utilize personal data for development and improvement.
· This involves analyzing user attributes, service usage, and advertisement click rates through surveys to develop and enhance our services. We also collect statistical data and build models for service improvement, understand page usage frequency for better page design, and conduct surveys about current or potential future services.
4.3. Security and Prevention of Unauthorized Use
· To ensure uninterrupted service provision and user peace of mind, our company implements necessary security measures, using personal data to prevent unauthorized use.
· For instance, we utilize personal data to ensure safety in scenarios such as verifying user compliance with terms of use, addressing illegal posts, and examining inappropriate behaviour.
4.4. Offering Optimized Services
· We use personal data to recommend content to users, including advertisements. This might involve providing recommendations and ads based on users' locations, purchase histories, and user behaviour and characteristic data, like search keywords or joined MeTime official accounts.
· Additionally, we combine information from partners (like identifiers and hashed phone numbers and email addresses) with the personal data we hold to execute and measure the effectiveness of our advertising campaigns.
4.5. Your Personal Data Related to MeTime
As a principle, we obtain your consent before processing personal data related to MeTime. However, within the limits allowed by applicable regulations, we may process your personal data based on legal grounds such as:
· Fulfilling contracts with you or taking necessary steps at your request;
· Complying with legal obligations, like adhering to government mandates for information disclosure;
· Protecting significant interests of you or a third party;
· Investigating or preventing illegal activities;
· Processing personal data to protect legitimate interests of our company or a third party;
· For public interest, historical archiving, research, or statistical purposes.
5. Provision of Personal Data
· We will not provide, disclose, or share your personal data with third parties unless with your consent or as permitted by applicable laws.
· Situations where we might provide personal data to third parties include:
o but are not limited to, subcontractors and partners outside your country or region.
o Our data centres are located in the USA, China, and Singapore. We take necessary measures, like encryption, to protect personal data, even in countries with different data protection laws than Australia.
5.1. User Public Disclosure
· Information and personal profiles set to public by users can be accessed by third parties, including posts and comments on public boards accessible by unspecified or large numbers of users.
· Due to the nature of digital data, this information can be copied, stored, or transmitted by third parties. Carefully consider the content and scope of disclosure when setting personal profiles or posting.
· We may provide your public information to third parties, which may be published on third-party services. We ensure these third parties comply with relevant data protection policies.
5.2. Business Succession
In business transactions like acquisitions, mergers, or changes in business entities involving the business covered by this policy, personal data may be transferred to the successor within the legally permissible scope.
5.3. Provision of Services
Within the legally permissible scope, after removing information that directly identifies users (like names, addresses, detailed location information, or MeTime message content), we might provide your personal data to third parties (including partners) for purposes such as improving service quality, considering new service needs, preventing unauthorized use, or providing data for research purposes.
5.4. Compliance with Regulations and Cooperation with Public Authorities
In response to legal requests (such as subpoenas) or emergencies (like suicide threats), we may disclose personal data to third parties (like police or courts) as per law. For more details, refer to our "Transparency Report" page.
6. Personal Data Security Management
· We have established policies and rigorous organizational, personnel, physical, and technical security measures to ensure proper management of collected personal data.
· We regularly review and improve our internal rules and standards to enhance data protection measures in line with changes in applicable laws and social norms.
6.1. Security Measures
· We implement measures including encryption, strict access control based on the "need to know" principle, round-the-clock security monitoring, external certification assessments of our security measures, and development of new security technologies.
· Please note that no electronic transmission or data storage method is completely infallible.
· Your cooperation is essential for protecting your privacy and data security. Please keep your passwords confidential and inform us of any unauthorized use or security breaches through our contact form.
6.2. Personal Data Storage Location
Personal data of Australian users is stored in data centres located in Australia, Singapore, the USA, and China.
6.3. Personal Data Retention Period
· We collect and store personal data to provide services, achieve policy objectives, or comply with regulations.
· Unless you request account deletion, we retain most of your information. After account deletion, we will keep your data for a period to respond to inquiries, resolve disputes, prevent misuse of services, or comply with laws.
· We set retention periods based on specific purposes and delete data after a reasonable period following purpose achievement. If regulations or other standards specify retention periods, we comply accordingly. After expiry, we may retain data in an anonymized form.
7.Your Choices Regarding Personal Data
· You have rights over the personal data we process, such as access and correction, within the bounds of law.
· We provide features for you to edit your profile and manage the collection, use, and sharing of your personal data.
· You have rights to access, correct, delete, restrict processing, withdraw consent, data portability, and request confirmation of personal data processing.
· Under certain conditions, you can prohibit us from processing your personal data.
· To exercise these rights, notify us through our contact form.
· After identity verification, we will respond to your requests within a reasonable timeframe.
· If you no longer wish to use the service, you may delete your account. This does not affect the legality of prior data processing.
· We may charge fees for exercising your rights as defined by procedures, unless prohibited by law.
8. Other Important Information
We may change this policy; the latest version will be posted on our website. Significant changes will be communicated through reasonable channels.
8.1. Children's Privacy
Our services are for the general public. Minors need legal guardian consent to use the services and provide personal data. In Australia, we take special care of minors' personal data and do not knowingly collect it. If we find such data collected, we will take steps to delete it.
8.2. Requests/Inquiries
If you have questions or comments about this policy or the personal data we process, contact us at info@gometime.com.
8.3. Policy Changes
· We may periodically change this policy; the latest version will be on our website. Significant changes will be notified through the service or other reasonable means.
· If you disagree with any changes or wish to stop using the service, you may deactivate your account. Continued use indicates acceptance of policy changes and the latest version. We will seek your consent as required by law.
CATCH INTERNET PTY. LIMITED
Established: December 28, 2023