UM3 Privacy Policy

Note: the Chinese version is only applicable to users in China, and the English version is only applicable to users outside China. 

点击切换至中文

Reminder

According to THE DATA PROTECTION LAWS, we do not knowingly collect personal information from MINORS for any purpose. If you believe that we have COLLECTED SUCH information of MINOR without parental or guardian consent, or if you are the parent or guardian of the user and wish to withdraw the consent, please submit your request at support@um3.com and we will delete such information.

List

Welcome to UM3 (the “Platform”). This Platform is provided and controlled by Kong Thought Limited or its affiliates (“UM3”, “we” or “us”). We are committed to protecting and respect your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.

Please read this Privacy Policy carefully to understand how we will treat your information before you start to use our Service or communicate with us outside the Platform certain features or functionalities of our Platform may be available via the Platform. This Privacy Policy governs the collection and use of data about you and your use of the Platform. (Although, we may provide additional notice and choice options within the Platform itself.)

By accessing or using our Platform, you are accepting and consenting to the practices described in this Privacy Policy, which may be updated and amended from time to time. If you do not agree to the terms of this Privacy Policy, you may not access or use the Platform.

1. What information do we collect?

We collect information when you create an account and use the Platform, such as content you create, and your location. Without a doubt, if you do not provide us Gender Identity, Nickname, Date of Birth, mobile phone number (select one option to register), we may not be able to facilitate meaningful connections for you.

Information you choose to provide

For certain activities, such as when you register, upload content to the Platform, or contact us directly, or pay for the subscription services, you may provide some or all of the following information (Should you choose not to provide the above mentioned information, the basic function of this Platform will remain unaffected; however, you will be unable to experience certain functionalities the Platform offers):

● Location data, When you view users in the Plaza, we need to collect your city of residence information to match you with nearby users, including determining your city of residence based on your IP address, or you can choose your city of residence yourself. If this information cannot be collected, the "Plaza feature" cannot be used.

● Registration information, You give us information when you register on the Platform on your option, including profile image, username, date of birth, gender and phone number. We respect your privacy. We do not sell or trade phone numbers collected during Opt-in consent to third parties for marketing. We handle personal data in compliance with data protection laws, ensuring confidentiality and proper use.

● The camera permissions, microphone permissions, album permissions, to take or send pictures, videos, audio messages in the app. If you opt not to share the aforementioned information, it may impair the function to capture or send pictures, videos, audio messages in the app.

● Profile information, including My photos, My Daily Life, My Wishes, My Q&A, My Languages, Company / Industry, Job, School, Education, Height, Hometown, Current City, MBTI and other expanded information, to provide you with better service and experience and provide you with personalized services related to the above information. Should you choose not to share the aforementioned information, it may limit our ability to provide the personalized services.

● User Content and Behavioural Information, We process the content you generate on the Platform, including preferences you set (such as choice of language), photographs, pictures, audio files and videos you upload or create, Profile information you disclose in your user profile, comments, feedback, and reviews. Should you choose not to provide the above mentioned information, you will be unable to experience certain functionalities the Platform offers.

● Information as your communication history and contents or the contact information you send to us when you are contacting us. If you opt not to share the aforementioned information, it may hinder our ability to understand and assist you effectively during your interactions with us.

Information we collect automatically

We automatically collect certain information from you when you use the Platform, including unique device identifiers, browsing history (including content you have viewed in the Platform), Cookies (as defined below), your mobile carrier, time zone setting, and mobile or device information including the model of your device, screen resolution, operating system, app and file names and types, and platform.

Usage Information

Device information

Technical Information

Browsing and search history

Cookies

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for login information in a browser and to opt out of login information for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

We also collect information you share with us from third-party social network providers, and technical and behavioural information about your use of the Platform.

2. How we use your information

We use your information to fulfill and enforce our Terms of Service, to improve and administer the Platform, and to allow you to use its functionalities. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your ad experience.

We generally use the information we collect:

3. How we share your information

We may share your personal data in accordance with the relevant laws and regulations of your country/region, including without limitation:

We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled by or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above (“How We Use Your Personal Data”).

If we have a legal obligation or have a good faith belief that such use is reasonably necessary, we may share your information with law enforcement agencies, public or tax authorities or other organizations:

We may also disclose your information to third parties:

4. Third-Party Providers

You acknowledge and agree that we may process your personal information for the purpose of improving the quality of Services, conducting data and product analysis, planning promotional activities, etc., and may share your personal information to our affiliates and partners or to independent third-party vendors listed below for that purpose.

Such third-party providers may be local operating partners or technical support partners outside your country. After the cooperation terminated, they will be denied access to all of our information, including the information to which they previously had access. We promise not to provide, sell, rent, share, or trade your personal information to any unrelated third party, unless we have your prior consent.

Besides, to provide you with social features, diversify or otherwise improve our Services, we may also provide third-party features or contents in our Services. Some of third-party services being linked to or embedded in Service (such as Social Media Platforms, third-party payment platforms, Fraud-Detection Service Provider, Anti-Crack and Anti-Cheat Service Provider, Social sharing Tools Provider, Customer Support Partner, etc.) may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you according to their own Privacy Policy, and we do not control the information that these third parties collect or how they use that information. We strongly encourage you to check their own Privacy Policies on their official websites and learn more about their data processing practices. Notwithstanding the foregoing, if you discover that any third party collects or processes your personal information illegally or in a manner which worries you, you are encouraged to contact us, and we will make reasonable efforts to help you. Main third-party vendors linked to our Services which may collect your Personal Information and links to their Privacy Policy are as follows (the specific list of Third-party vendors linked with each of our Service may vary):

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic.

Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

• Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245

For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sites

• AliyunOSS

Their Privacy Policy can be viewed at https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud201902141711_54837.html

• Umeng

Their Privacy Policy can be viewed at https://www.umeng.com/page/policy?spm=a213m0.21031926.0.0.456d677aqLVqXt

5. Your Rights

Under applicable data protection laws (including GDPR, CCPA, and personal information protection regulations in your country of residency), you have a number of rights in relation to your personal data.

We respect and honour these rights and will help you to exercise them insofar as we are able.

Your specific rights can be found in our Supplemental Terms-Jurisdiction-Specific.

Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with.

Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond as soon as we can after verify your identity in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject. You understand and agree that in accordance with applicable laws, we may have the right to charge you for a certain amount of fee depending on the complexity of your requests to cover our operational expenditure.

You may submit a request to access or delete the information we have collected about you by sending your request to us at the email provided in the Contact section at the bottom of this policy. We will respond to your request consistent with applicable law and subject to proper verification. You can exercise your rights by contacting us at support@um3.com.

6. Data Storage and Transmission

Your personal information we collected above may be stored on servers located outside the country where you live.

Due to the nature of Our Service, you are aware and agree that your personal information may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or our partners, located in third countries/outside the country where you live or work. Because data protection laws vary among countries and may not offer the same level of protection for your personal information as those in your home or work country, in which case, we will take steps according to applicable laws and regulations in your country to ensure adequate safeguards are in place and that your personal information is adequately protected within the data process location. For example, we will give you a special reminder and obtain your prior consent, or make sure to anonymize or de-identify your personal information before transferring, and also we may implement special contractual arrangements.

7. Security

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform are no risk，this is why we need you to strictly adhere to the agreements and guidelines in documents such as our privacy policy, and we will work together to keep your personal information as secure as possible.

We have put in place appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates.

If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. Data Retention

We retain your data for as long as necessary to provide you with the service. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

9. Minor

Please understand that the platform is not intended for minors. Minors are generally defined as users under the age of 18. Given the legal regulations in various regions, the definition of minors may vary. We have listed the minimum age at which users from relevant regions can use our services in the table below:

We do not knowingly collect personal information from minors under these ages for any purpose. If you believe that we have personal information of a minor under these ages without parental or guardian consent, or if you are the parent or guardian of the user and wish to withdraw the consent, please submit your request at support@um3.com and we will delete such information.

10. Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. If major updates are involved, we will notify you in advance.

11. Contact

Questions, comments and requests regarding this policy should be addressed to:

We normally provide feedback within 15 days.

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of this policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Algeria

By using the Platform, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (such as local cloud providers to back up your data as described in the Privacy Policy) where it is manually and electronically treated.

Argentina

If you are using our services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Your rights and options: According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ('AAIP'), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. You can exercise your rights by sending your request to support@um3.com free of charge.

If you are not satisfied with how we have responded to any of your rights requests, we encourage you to contact us.

You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos.

Australia

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

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

Brazil

If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

I. Confirmation of whether your data are being processed;

II. Access to your data;

III. Correction of incomplete, inaccurate or outdated data;

IV. Anonymization, blocking or erasure of data;

V. Portability of personal data to a third party;

VI. Object to the processing of personal data;

VII. Information of public and private entities with which we shared data;

VIII. Information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. Withdrawal of your consent;

X. Request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality.

If you are not satisfied with how we have responded to any of your rights requests, we encourage you to contact us.

You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us at: [support@um3.com]. If you have any questions about the processing of your personal data, we would like to clarify them.

Data Protection Officer (DPO): If you wish to reach the Data Protection Officer, contact us at: [support@um3.com].

Access Logs: We keep your application access logs, under confidentiality, in a controlled and safe environment, for at least 6 months, in order to comply with legal obligations.

International Transfers: International data transfers are necessary for us to provide our services. If you are located in Brazil, we will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.

California

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

The CCPA provides California residents with certain legal rights such as access, deletion, disclosure, or 'do not sell. These rights are not absolute and are subject to certain exceptions.

The purpose and specific information for which we collect your personal information is set out in Section 1 of our Privacy Policy.

Your phone number, identity information, and content that we collect in the Privacy Policy belong to your personal sensitive information.

Your device information, log information and your communication with us are collected by us automatically; other information is provided by you; camera permissions, album permissions, microphone permissions and your phone contact permissions are actively enabled by you.

Your Rights under the CCPA are set out in Section 5 of the Privacy Policy.

We will not 'sell' the personal information of California residents within the meaning of 'sold' in the CCPA.

The purposes and entities to which we share or disclose your Personal Information are set out in Section 3 and Section 4 of the Privacy Policy.

You are free from unlawful discrimination for exercising your rights, including being provided with a different level or quality of services or being denied goods or services when you exercise your rights under the CCPA.

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

You can contact us at support@um3.com.

Canada

If you are using the Platform in Canada, the following additional terms apply.

Your Rights: Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request or that they are authorized to act on behalf of another individual in such matters.

Your Choices: For more information about managing your account and privacy settings, please visit 'Privacy Settings' in 'Settings'.

Internal Policies and Access Controls: We implement and maintain internal policies and technical measures to restrict access to your personal information within our organization. Access to personal information within our organization is limited to employees who need the information to perform their job functions. For example, our customer support team may have access to certain types of information during our interactions with you, such as responding to complaints and inquiries. Similarly, our content moderators may access certain information in order to enforce our Terms of Service, Community Guidelines, and other conditions and policies.

Data Retention Practices: We have procedures in place to limit the retention periods as set out in the 'How Long We Keep Your Information' section above. When personal information is no longer needed for these purposes or is no longer required to be retained by law, we take appropriate steps to dispose of it securely in accordance with our internal procedures.

Transfer Outside Your Jurisdiction: We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec). For information about how we or our service providers (including service providers outside Canada) process personal information, please contact us using the contact information set out below. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.

Contact: If you are a resident of Canada, you can contact us at support@um3.com.

EU/UK

If you are an EU or UK resident, you have the right:

Any request from you for access to or a copy of your personal data must be in writing. We will endeavour to respond as soon as we can after verifying your identity, in compliance with our legal obligations under data protection legislation.

For EU and UK residents, we shall provide information on the action taken on a request under GDPR Articles 15 to 22 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. If for legitimate reasons we cannot provide you with the information you need, we shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action.

By law, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for 6 tax years plus the current tax year after they cease being customers, for tax purposes.

When your information is transferred outside of your country of residence, our partners will use adequate safeguards, which may include EU-approved Standard Contractual Clauses, available on the EU Commission website.

(https://commission.europa.eu/law/law-topic/data-protection_fr).

Information about our Data Protection Officer (DPO) is as follows. If you are unsatisfied with how your request is being handled, or need any information concerning our processing of your Personal Information, please contact our DPO:

EU:

Email: support@um3.com

If you have any concerns about our use of your information, you may also have the right to make a complaint to the Data Protection Authority in your country, according to applicable laws. You can refer to this page for more information: https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en

Egypt

This privacy policy is provided in Arabic for users located in Egypt.

By clicking the button to proceed or by proceeding with the sign-up process, you acknowledge that you have read, understood, and consented to this privacy policy. If you do not consent to this privacy policy, you must not use the Platform.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross-border transfer may be to any country in which we have databases or affiliates.

You also acknowledge your consent to receiving marketing messages from us.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

Hong Kong SAR

If you choose not to provide your Personal Information, you may not be able to use UM3 properly.

As a Hong Kong SAR data subject, you have legal rights in relation to the Personal Information we hold about you (to the extent permitted under applicable laws and regulations).

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

India

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

In the circumstances specified in this Privacy Policy, when we permit any third party to collect and use your Sensitive Personal Information, we shall: (i) ensure that such third parties maintain the same security standards as we do to protect your Sensitive Personal Information; (ii) take reasonable measures to ensure that the third parties do not further disclose such Sensitive Personal Information.

If you believe we hold any other Personal Information about you or your child that is inaccurate, or if you have questions regarding the processing, transfer, or end-use of your Personal Information, please contact us at: support@um3.com.

You do not have the right to retrospectively retract consent or request the deletion of records required for statutory purposes, but you may withdraw consent to any further processing of your or your child's Personal Information.

In accordance with applicable data privacy laws and regulations in India, we shall take appropriate and reasonable technical and organisational measures to prevent the loss, damage, unauthorised access to, or processing of your Sensitive Personal Information.

Indonesia

If you are using our services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age, or married, or not under guardianship. If you are under 21 years of age, unmarried, or under guardianship:

You must obtain approval from your parent(s) or legal guardian(s); and

Your parent(s) or legal guardian(s) shall be responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this Policy; (iii) ensuring that your use of the Platform does not violate any applicable laws and regulations relating to child protection.

If you do not have consent from your parent(s) or legal guardian(s), and your parent(s) or guardian(s) are not willing to open an account in their name, you must cease accessing the Platform.

Your Choices. You may withdraw your consent to UM3's disclosure of your personal data to third parties. Upon receiving your request, we will cease to display, publish, transmit, disseminate, and/or grant access to your personal data to third parties. Please note that withdrawing your consent to the disclosure and/or collection of your personal data may prevent us from fulfilling your requests, and you may not be able to use some features of UM3.

You may request UM3 to: (i) disclose the history of personal data we have collected; and/or (ii) erase and dispose of your personal data stored on our servers. Please note that requesting the erasure and disposal of your personal data may result in your inability to use some features of UM3.

To exercise any of your rights, contact us at: support@um3.com.

Notification. In the event of any personal data breach, we will notify you and provide relevant information about such breach.

Data Retention. We retain your information for as long as it is necessary to provide you with the service. Where your information is no longer needed to provide the service, we retain it only if we have a legitimate business purpose for doing so. However, we may retain such data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise, or defence of legal claims.

After you terminate your use of the Platform and the five (5) - year retention period expires, we will store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics purposes.

Japan

By clicking 'Accept', you consent to the cross-border transfer of your information to any country where we have databases, affiliates, or service providers located.

Pursuant to the provisions of Japan's Act on the Protection of Personal Information, you may request that we notify you of the following matters regarding your Personal Information stored by us: purpose of use, content of disclosure, any correction, suspension of use or provision, and/or deletion of all your Personal Information. To make such a request, please contact us at: support@um3.com

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), and storage of your personal information as described in this privacy policy.

Kuwait

You represent that you are at least 21 years of age, or at least 18 years of age with parental/guardian consent, and thus legally capable of contracting under the applicable laws and regulations of Kuwait.

By accepting this Privacy Policy, you expressly authorise us to collect, use, store, and process your personal data, and to disclose such data to third parties inside or outside Kuwait, in accordance with the provisions of this Privacy Policy.

Macau SAR

You have the right not to provide your Personal Information. However, this may result in our inability to provide UM3 services to you. As a Macau SAR data subject, you have legal rights in relation to your Personal Information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to obtain a copy of the data we process about you, make a data correction request, and have the right to object to the use of your Personal Information for marketing or any other form of commercial prospecting, or on any grounds of a personal nature. We may charge a fee for complying with a data access request.

Malaysia

For users in Malaysia, our servers are located outside Malaysia, and you consent to the transfer of your data outside your country.

Right of Access: You have the right to request access to and obtain a copy of the Personal Information we have collected and are processing (either by us or on our behalf). We reserve the right to charge a fee for providing access to your Personal Information, in amounts permitted by law.

When handling a data access request, we may require you to provide specific information to verify your identity, ensuring that you are legally entitled to make such a request.

We will comply with data access requests within the timeframes stipulated under Malaysian data protection laws.

Right of Correction: You may request the correction of your Personal Information. When handling a data correction request, we may require you to provide specific information to verify your identity, ensuring that you are legally entitled to make such a request.

Right to Limit Processing: You may request to limit the processing of your Personal Information by using the contact details provided in this Privacy Policy. However, this may affect our ability to provide UM3 services to you.

To protect your Personal Information and handle complaints related to it, we have appointed a Data Protection Officer responsible for the management and security of your Personal Information. You may contact the Data Protection Officer at: support@um3.com.

Mexico

If you are using our services in Mexico, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

How We Use Your Personal Data. Almost all the data processing purposes stated in the main body of this Privacy Policy are necessary purposes.

We process your data using both manual and automated methods.

How We Share Your Personal Data. We may share your personal data with third parties for purposes other than processing on our behalf. We will obtain your consent for such sharing as required by applicable laws.

By providing us with your personal data and using our Platform, you consent to the data transfers that require your authorisation. You may withdraw your consent at any time and exercise the rights described below.

Your Rights: You have the following rights with respect to your personal data: access, correction, deletion, opposition, withdrawal of consent, and limitation of use and disclosure. You may exercise these rights by sending a request to support@um3.com. To learn more about the requirements and procedures for exercising these rights, contact us via the aforementioned email address.

Philippines

If you are using our services in the Philippines, the following additional terms apply pursuant to the relevant laws, rules, regulations, and issuances of the Philippines National Privacy Commission ('NPC') on data privacy.

Your Rights. To the extent that the relevant laws, rules, and regulations on data privacy recognise your rights and freedoms as a data subject, you shall have the right to information, the right to object, the right of access, the right to rectification, the right to erasure or blocking, the right to lodge complaints with the NPC, the right to claim damages, and the right to data portability. Before we can respond to a request to exercise one or more of the aforementioned rights, you may be required to verify your identity or account details.

Singapore

By clicking 'Accept', you consent to the collection, use, and disclosure of your Personal Information for the purposes set out in the 'How We Use Your Information' section of this Privacy Policy. We will process your Personal Information as an 'organisation' as defined under the Personal Data Protection Act 2012.

Our designated Data Protection Officer for compliance with the Personal Data Protection Act 2012 may be contacted at support@um3.com.

You have the right to access your Personal Information, understand how we use it, and know who we share it with. You can view the Personal Information you have provided as part of your account by logging into your account. If you believe we hold any other Personal Information about you, please contact us at support@um3.com.

You have the right to correct any inaccurate Personal Information. You can access the Personal Information we hold about you by logging into your account. If you believe we hold any other inaccurate Personal Information about you, please contact support@um3.com.

South Korea

If you are using our services in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Your Opt-in Choices and Communication Preferences: To provide you with more convenient and personalised information display and push services, we collect your opt-in choices and communication preferences to deliver personalised services. You may turn off the relevant functions at any time within UM3 by going to 'More' -> 'Settings' -> 'Privacy'. If you do not provide this information, it will only affect your use of relevant personalised services and will not impact the basic functions of UM3's products and services.

Data Retention: In principle, personal information will be destroyed immediately after the purpose of collection and use is achieved. However, certain information may need to be retained after the purpose is achieved in accordance with the provisions of relevant laws and regulations. The relevant retention rules are as follows:

1) Display/Advertisement Records: 6 months (The Act on the Consumer Protection in Electronic Commerce)

2) Contract or Subscription Cancellation Records: 5 years (The Act on the Consumer Protection in Electronic Commerce)

3) Payment and Goods Supply Records: 5 years (The Act on the Consumer Protection in Electronic Commerce)

4) Consumer Complaint or Dispute Resolution Records: 3 years (The Act on the Consumer Protection in Electronic Commerce)

5) Website Access Records: 3 months (Protection of Communications Secrets Act) You may contact us at any time via [support@um3.com]. After verifying your identity, we will delete or anonymise your information.

Personal information stored in electronic file format will be anonymised/de-identified using irreversible technologies to ensure it cannot be recovered; paper-based information will be destroyed by shredding or incineration.

You consent to us using user data for research and statistical purposes to improve service quality. In such cases, we will ensure that personal information is desensitised, de-identified, and anonymised (no longer associated with you) and may use such information without further notice to you.

If you opt out of marketing pushes, we may retain necessary information to ensure we do not contact you for marketing purposes.

Destruction of Personal Data: We destroy personal data in a manner that renders it unrecoverable.

Data Rights: You have the right to access, correct, and delete your personal data, and to request the suspension of processing. You may exercise these rights by contacting us at support@um3.com.

Data Security: We protect UM3 and our users from unauthorised access to, alteration of, disclosure of, or destruction of the information we hold through technical, managerial, and physical safeguards (including internal data protection policies, limiting access to personal data on a need-to-know basis, and controlling access to facilities where personal data is processed).

Entrustment and/or Overseas Transfer of Personal Data: To provide services, we directly collect and process personal data overseas. With your consent or after notifying you (if applicable), we entrust your data to affiliates, cloud storage providers, and IT service providers (some of which are located overseas). We ensure that the recipients comply with domestic and international regulations through contractual obligations and adopt appropriate physical and technical measures to protect the data. Unless the transfer is necessary for service provision, you may opt out of such transfer by contacting us.

Changes: We may update this Privacy Policy from time to time due to technological, legal, or operational reasons, or for any other necessary or appropriate reasons. You agree to regularly review this page for updates. For material changes, we will notify you 7 days or 30 days in advance (if the updated content significantly affects your rights) via in-service announcements, website postings, push notifications, or other appropriate methods. Your continued use of the services after the effective date will be deemed acceptance of the updated Privacy Policy. For significant changes, we may re-obtain your consent via a pop-up window when you log in again.

These terms are drafted in English and translated into other languages. In case of any conflict or inconsistency requiring clarification, the English version shall prevail.

Contact: Questions, comments, and requests regarding this Policy are welcome and should be sent to support@um3.com.

Information about our Data Protection Officer (DPO) is as follows. If you are unsatisfied with how your request is being handled, you may also lodge a complaint with the DPO. To contact the DPO for any inquiries about our processing of Personal Information, please use the following details:

Name: Dean

Email: support@um3.com

Sri Lanka

By clicking 'Accept', you consent to the terms and conditions of this Privacy Policy and permit the collection, use, and disclosure of your Personal Information.

If you request to withdraw consent, refrain from further data processing, erase, rectify, or supplement your Personal Information, we will provide a response to your request within 21 working days.

Taiwan, China

For users located in Taiwan, China, individuals under the age of 20 are required to obtain parental/guardian consent before using UM3.

You may exercise the following rights as set forth in Article 3 of the Personal Data Protection Act: (1) access and review your Personal Information; (2) obtain a copy of your Personal Information; (3) supplement or correct your Personal Information; (4) request that we cease the collection, processing, or use of your Personal Information; (5) request that we delete your Personal Information. To the extent permitted by law, there may be limitations on our ability to fully comply with your request.

Thailand

By clicking 'Accept', you acknowledge that you have read, understood, and agreed to the Privacy Policy. If you do not agree to the Privacy Policy, you must not use UM3.

Users under the age of 20 must obtain consent from their parent or legal guardian before registering and using UM3.

Pursuant to the Thai Personal Data Protection Act (PDPA), you may:

● Withdraw your consent to the processing of your Personal Information (only when consent serves as the legal basis for processing); however, please note that if consent is required for processing, withdrawal may affect the provision of services;

● Request access to, correction of, cessation of automated processing or profiling (if applicable) of, suspension of, restriction on the use/provision of, and/or deletion of your Personal Information;

● Request that we provide the Personal Information we store to you or a third party in a machine-readable format;

and/or

● Lodge a complaint with the competent authority.

To make such requests, please contact us via support@um3.com.

Türkiye

If you are using the services in Türkiye, in addition to the content of the aforementioned Policy, the following additional terms apply. In the event of any conflict between the following additional terms and the main body of this Policy, the following terms shall prevail.

Data Controller Representative: Users in Türkiye may contact our Data Controller Representative in Türkiye via email or mail to address questions and complaints related to the processing of Personal Data.

support@um3.com

Legal Bases for Processing Personal Data: Pursuant to Article 5 of Law No. 6698 on the Protection of Personal Data, we process Personal Data based on the following legal grounds:

● Explicitly permitted or required by law;

● Necessary for the conclusion or performance of a contract;

● Necessary for the performance of legal obligations;

● Data publicly disclosed by you;

● Necessary for the establishment, exercise, or protection of rights;

● Necessary for our legitimate interests (without infringing on your fundamental rights and freedoms);

● Your explicit consent (please note that this basis is only relied on when consent is required for processing; it is not relied on when other legal bases are applicable).

Your Rights: Pursuant to Article 11 of the Law on the Protection of Personal Data, you have the following rights with respect to your Personal Data:

● The right to know whether your Personal Data is being processed;

● If processed, the right to request information regarding such processing;

● The right to understand the purpose of processing and whether the data is used in line with that purpose;

● The right to know the third parties (both domestic and foreign) that receive the data;

● The right to request correction of incomplete or inaccurate data;

● The right to request deletion or destruction of data under the conditions specified in Article 7 of the Law on the Protection of Personal Data;

● The right to request that we notify third parties (to whom the data was transferred) of corrections, deletions/destructions made at your request;

● The right to object to negative outcomes resulting solely from the automated analysis of your data;

● The right to claim compensation for damages caused by illegal processing.

You may exercise the above rights via support@um3.com.

Your requests will be processed as soon as possible based on their nature, with a maximum timeframe of 30 days, and free of charge. However, if additional costs are incurred, fees may be charged in accordance with the rates set by the Turkish Personal Data Protection Board.

Amendments: The following sections of the Policy do not apply to users in Türkiye:

If you do not agree to this Policy, please do not use this Platform.

By accessing or using the Platform, you acknowledge that you have read this Policy, understand your rights related to your Personal Data, and understand how we collect and process such data.

United Arab Emirates

If you are using the Platform in the United Arab Emirates ('UAE'), the following additional terms apply. In the event of any conflict between the following additional terms and the main body of the Privacy Policy, the following terms shall prevail:

Users in the UAE must be at least 21 years of age (per the Hijri calendar) to legally consent to commercial transactions. However, minors aged 18 to 21 may obtain a court order to gain permission for specific commercial transactions.

1. How We Share Your Personal Data

In addition to the main body of this Policy, by using the Platform in the UAE, you agree to the terms of this Privacy Policy and consent to our sharing of your Personal Data in accordance with the main body of this Policy.

We may voluntarily report cybersecurity incidents that constitute crimes under UAE law (e.g., the UAE Cybercrime Law) and submit them to relevant authorities for investigation. Please note that voluntary reporting of cybersecurity incidents may also be made to the UAE Computer Emergency Response Team ('CERT'). CERT is a security awareness organization that provides incident logging procedures and advice on known cybersecurity threats.

2. Governing Law

By using the Platform in the UAE, this Privacy Policy shall be governed by and construed in accordance with the laws of the UAE.

Vietnam

This Privacy Policy is provided in Vietnamese for users in Vietnam. In the event of a dispute, the Vietnamese version shall prevail.

Methods of Processing Personal Data: We may process Personal Data through manual or automated methods.

Data Subject's Rights and Obligations: Pursuant to applicable laws, you have statutory rights and obligations.

In particular, you have the following statutory rights:

Right to be informed;

Right to consent and withdraw consent;

Right of access;

Right to data deletion;

Right to restrict processing;

Right to obtain data;

Right to object to processing;

Right to complain, report, or initiate legal proceedings;

Right to claim compensation;

and

Right to self-protection.

You may exercise these rights by contacting us through the details in the 'Contact' section, and we will respond to your requests regardless of where your data is stored.

Your statutory obligations include:

Protecting your own Personal Data;

Requesting other relevant organizations and individuals to protect your Personal Data;

Respecting and protecting the Personal Data of others;

Providing complete and accurate Personal Data when consenting to the processing of your Personal Data;

and

Other obligations specified by applicable laws.

We adhere to international standards and security practices for data protection. When your Personal Information is transferred within or outside your jurisdiction of residence, the receiving entity shall adhere to the same or higher level of security practices and data protection as we do.

When we permit third parties to collect and use your Personal Information, we will take reasonable measures to ensure that such third parties do not further disclose the Personal Information.

Upon receiving a written request from competent law enforcement agencies, public authorities, or other judicial bodies and organizations, we will disclose the required Personal Information.

Pursuant to the laws and regulatory requirements of your jurisdiction from time to time, we may retain all or part of your Personal Information for a period longer than that specified in this Privacy Policy.

You have the right to access, correct, and delete the Personal Information we hold about you. You also have the right to withdraw your consent to the collection, storage, processing, use, and disclosure of your Personal Information, and to request that we cease processing or providing your Personal Information to third parties.