Privacy Policy

Effective: December 17, 2025

Introduction
This privacy policy ("Privacy Policy") explains how we collect, use, share and otherwise process personal information in connection with the apps, websites, software, and related services (the “Services”), that link to or reference this Privacy Policy.

Data Controller: SPRING (SG) PTE. LTD., with its registered address in Singapore (“we”, “our”, or “us”).

If you have any questions about this Privacy Policy or how we use your personal information, please contact: feedback@dola.com.

What Information We Collect

We collect information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.
Information You Provide

● Account Information. When you register your account, we collect information such as your username, contact details, password, and date of birth. Certain products related to Dola operate using a unified account service, and you can use your account with those products to access the Services.

● User Content. We collect information that you input, upload, generate, or otherwise provide when you interact with the Services. Examples include your text prompts and chat history, and uploaded files, voice recordings, and photos. Please do not disclose personal or sensitive information, such as passwords, credit card numbers, or other confidential information, during chat interactions with the Services.

● Surveys, Research, and Promotions Information. We collect information you provide if you choose to participate in a survey, research, marketing campaign, or event conducted or sponsored by us.

● Communication Information. When you contact or otherwise communicate with us, we collect the information you send us, such as your name and contact details, proof of identity or age, and the contents of your communications.

Automatically Collected Information

● Technical Information. We collect certain device, browser, and network connection information when you access the Services, including your IP address, unique device identifiers, mobile carrier information, and system settings information. We also collect service-related, diagnostic, and performance information, such as crash reports and performance logs.

● Location Information. We derive your approximate location based on information like your device IP address.

● Usage Information. We collect information about how you engage with the Services, including associated metadata. That includes information about the content you view, search for, like, and save; the duration and frequency of your use; your feedback; and your settings.

● Inferred Information. We may infer your likely preferences and other attributes, such as gender, age and hobbies, based on information we have about you.

● Cookies. We use cookies and similar tracking technologies to operate and provide the Services. To learn more about our use of cookies and other tracking technologies, and your cookie-related choices, please see our Web Cookies Policy.

Information From Other Sources

● Third-Party Platform Information. We receive information from third-party platforms to provide you with certain integrations and features. For example, we may receive your username, email address, or access token if you log in to the Services using a third-party platform, or information about your browsing history when you use our browser plug-in.

● Information From Others. We may receive information about you from others, such as our advertising, analytics and measurement partners, government authorities, publicly-available sources, and other users and third parties.

How We Use Your Information
We use your information to operate, provide, develop, and improve the Services, including for the following purposes:

● To provide, tailor, and administer the Services to you and others, such as by enabling you to interact with various chatbots. Our website and certain features are available to both registered users as well as guests.

● To communicate with you about service-related matters and updates, and to respond to your requests.

● To maintain and enhance the Services’ safety, security, and stability, and to prevent and address inappropriate or illegal activity, including by enforcing our Terms of Service and other policies applicable to you, and where permitted by applicable laws, by scanning, analysing, and reviewing User Content and associated metadata for violations.

● To improve and develop the Services, such as by conducting research; analyzing how people are using the Services; developing new features; and training and improving AI models.

● To customise your experience, such as by recommending content, better informing output responses, and providing you with interactive features.

● To promote the Services, including through marketing communications and by use of third-party advertising platforms.

● To comply with our legal obligations, defend our rights and interests, and to protect the Services as well as the rights and safety of our users, affiliates, and third parties.

We may also aggregate or de-identify your information so that it no longer identifies you and use this information for any purpose.

As noted above, we may use information you provide to improve our Services, including to train AI models. Click here to learn how you can opt out.

How We Share Your Information
We share your personal information as follows:

Service Providers and Business and Advertising Partners.
We engage service providers and business and advertising partners that help us provide, support, and develop the Services, including for functions such as customer service, content delivery, sign-up or log-in capabilities, support and safety monitoring, communications, web analytics, AI integrations, and advertising, marketing and measurement services. In general, we share Information You Provide, Automatically Collected Information, and Information From Other Sources with these entities as necessary to enable them to provide their services. These service providers and partners may include, for example:

● Log-in Services. If you log in to the Services using your third-party account details, we will share certain Technical Information to facilitate this.

● Standard Chatbots. When you interact with our chatbots, certain User Content and Automatically Collected Information may be shared with the third-party developers of integrated AI tools, including LLMs, to generate, optimise, and personalise output.

● Advertising, Marketing, and Measurement Partners. These partners may receive certain of your Automatically Collected Information in order to help us provide and promote the Services, including through advertising displayed on other platforms. These partners may also help us and our partners measure the effectiveness of our advertising campaigns.

In some cases, when you choose to use an integrated third-party service certain Information You Provide and Automatically Collected Information may be shared with the third party. By using such integrations, you are agreeing that any information shared may be treated in accordance with that third party’s privacy policy and terms of use. For example, user-generated (independent) chatbots offered through the Services do not operate on behalf of, or at the direction of, Dola. If you choose to interact with a user-generated chatbot that deploys third-party plugins and APIs, information sent to the third-party developers of those plugins/APIs will be subject to such developers’ policies and terms. Certain of the Services also rely on integration with YouTube’s API services, and by using the Services, you agree to be bound by the YouTube Terms of Service (http://www.youtube.com/t/terms). For further information regarding Google’s privacy practices, please visit http://www.google.com/policies/privacy.

Our Corporate Group. We share the information described in “What Information We Collect” with members of our Corporate Group. Our Corporate Group may use your information in a manner consistent with this Privacy Policy, including for functions like: storage, content delivery, security, research, analytics, customer and technical support, product and technology improvement and development, including AI model training, and content moderation. Subject to applicable laws, AI models improved using personal information may be utilised by entities within our Corporate Group.

Other Users. Depending on your settings, certain information, such as your profile details, may be visible to other registered users.

Corporate Transactions. We may also share your information in connection with, or during negotiations of, a corporate transaction, such as a merger, consolidation, sale of assets or shares, reorganization, financing, or acquisition of all or a part of our business, or in the unlikely event of bankruptcy.

Legal Obligations and Rights. We may share the information described in “What Information We Collect” with certain competent law enforcement, regulatory or government agencies, courts, or other third parties if we have a good faith belief that it is necessary to:

● Comply with a legal obligation;

● Lawfully protect and defend the rights, property, safety, and security of the Services, our users, copyright holders, and others;

● Investigate potential violations of and enforce our Terms of Service and other policies; or

● Detect, investigate, and prevent against fraud, technical issues, copyright infringement, or other misleading or illegal activities.

With Your Consent. We may share your information for other purposes with your consent or at your direction.

Your Rights and Choices
You may have rights and choices when it comes to your information.

Your Rights. Depending on where you live, your rights under applicable laws may include the right to access, delete, transfer, or correct your personal information; to be informed of the ways in which we process your personal information; to object to, and withdraw your consent for, certain processing activities; to file complaints with authorities; and more. Some of your rights apply generally, while others will only apply in certain circumstances. And, depending on the scenario, these rights may be subject to some limitations by law.

For detailed information about the specific rights and choices available to you in your country or region, please see the relevant subsection under Supplemental Information.

To exercise your personal information rights, or if you have related questions or complaints, please contact us using the details set forth in the Contact Us section. Before we can respond to your request, you may be asked to verify your identity or account details, or provide additional information so that we can properly understand your request.

Your Choices. You may directly access and update certain personal information, as well as opt out of certain features and uses, including enhanced personalisation and model training, through your account settings.

Data Security

Security of your information is important to us. We maintain appropriate technical, administrative, and organisational measures designed to protect your information from unauthorized access, theft, disclosure, modification, or loss.

Data Retention
We retain information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Policy. Actual retention periods vary depending on factors such as the type of information and its processing purpose(s); your information-related rights and choices; compliance with our contractual and legal obligations; and our legitimate business interests, such as safety and security reasons. Beyond such period, we will delete or anonymize your personal data, unless otherwise required or permitted by applicable laws or regulations.

International Data Transfers

Your personal information may be stored on a secure server located outside of the country where you live. We may also transfer your personal information internationally for one or more of the purposes described in this Privacy Policy. Any international transfer of, or access to, your personal information is conducted according to the requirements of applicable data protection laws. Further information about international data transfers may be found under “Supplemental Information”.

Minimum Age and Younger Users

You must be at least 13 years old to use the Services. Depending on where you live, this minimum age may be higher due to local regulatory requirements and the availability of the Services to users younger than 18 for that country or region. Please review the “Supplemental Information” subsection relevant to your country or region for more information.

To provide users younger than 18 with an age-appropriate experience, additional safeguards have been implemented and certain features are not available.

If you believe that there is a user who is below the minimum age, please contact us using the details set forth in the “Contact Us” section.

Privacy Policy Updates
We may update this Privacy Policy from time to time. When we do so, we will revise the “Last Updated” date at the top of the new Privacy Policy, or provide alternative notice pursuant to applicable laws. We recommend that you regularly review this page to stay informed of our privacy practices.

Contact Us
Questions, comments and requests regarding this Privacy Policy should be addressed to:

SPRING (SG) PTE. LTD.

Email: privacy@dola.com

Address: 77 Robinson Road, #06-03, Robinson 77, Singapore (068896)

Supplemental Information
If you access or use the Services in any of the countries or regions listed below, the Supplemental Information relevant to that jurisdiction will apply. In the event of a conflict between those jurisdiction-specific provisions and the main body of this Privacy Policy, the relevant jurisdiction’s Supplemental Information will supersede and control.

Australia

Certain entities in our Corporate Group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the "How We Share Your Information" section.

Brazil

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”):

● Confirmation of whether your personal data is being processed;

● Access to your personal data;

● Correction of incomplete, inaccurate or outdated personal data;

● Anonymization, blocking or erasure of personal data;

● Portability of personal data to a third party;

● Objection to the processing of personal data;

● Access to information about public and private entities with which we share personal data;

● Request additional details, where applicable, regarding international data transfers, and the mechanisms (such as the Standard Contractual Clauses) used to carry out such transfers;

● Access to information about the possibility of refusing to provide your personal data and the respective consequences, where applicable;

● Withdrawal of your consent; and

● Request a review, where applicable, 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.

We encourage you to contact us using the details set forth in the “Contact Us” section, if you are not satisfied with how we have responded to any of your rights requests. 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, we may request specific information and/or documents from you in order to verify your identity, before we can properly respond to a request received concerning your personal 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, such as when 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.

In case of doubt about your privacy, your rights or how to exercise them, please contact us. If you have any questions about the processing of your personal data, we would like to clarify them.

International Transfers of Data. International data transfers are necessary for us to provide and administer the Services to our users. We conduct such international data transfers to both internal and external recipients for the purposes described in the “How We Share Your Information” section of this Privacy Policy. For example:

● We may store your personal data on secure servers located in Indonesia, Malaysia, Singapore, and the United States.

● We share your personal data globally within our Corporate Group.

● We may subcontract the processing of your personal data to our service providers or share your personal data with our third-party business partners.

● We may share your personal data with competent government or judicial authorities for legal reasons.

We are committed to ensuring that all personal data we process is protected, regardless of its location, and that international data transfers are carried out securely and in compliance with applicable data protection laws, throughout the entire processing period. Accordingly, we adopt legally valid mechanisms for carrying out international data transfers (such as the Standard Contractual Clauses issued by the ANPD, which are available for consultation here), as well as technical and administrative security measures, such as:

● Internal policies and procedures focused on privacy and the protection of personal data;

● Mandatory training to our employees and implementation of internal rules focused on privacy and information security;

● Access controls, with restrictions based on necessity and specific roles;

● Encryption to protect data both at rest and in transit; and

● Log records for activity monitoring and auditing purposes.

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

DPO. You may contact the Data Protection Officer by emailing: dpobrasil@bytedance.com.

Language. This Privacy Policy may have been prepared in both the English and Portuguese languages. If you are a user located in Brazil, please refer to the Portuguese version which shall prevail.

European Economic Area (“EEA”), Switzerland, and United Kingdom (“UK”)

Legal Bases For Processing. We use your personal data when we have a “legal basis” to do so. Our legal bases for processing your personal data described in this Privacy Policy are set forth in the table below.

International Data Transfers. In some cases, the personal data that we collect about you may be transferred to, processed, and/or stored in countries outside of the EEA, the UK, or Switzerland (for instance, to our service providers and partners).

To support our global operations:

● We may store the personal data described in the “What Information We Collect” section on secure servers located in Indonesia, Malaysia, Singapore, and the United States.

● Certain entities in our corporate group, which are located outside of the country where the data was collected, may be given limited remote access to your personal data so they can provide certain functions, as described in the “Our Corporate Group” subsection of “How We Share Your Information”.

● We may share “What Information We Collect” with service providers and other third-party entities located outside your country or region of residence, as described in “How We Share Your Information”.

When we transfer your personal data outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on adequacy decisions or standard contractual clauses. Further detail is provided below:

● Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or their approved equivalent for the UK and Switzerland) where they recognise that a country offers an adequate level of data protection.

● Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA, including to countries without an adequacy decision. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses.

If you wish to enquire further about these safeguards, please contact us using the details set forth in the “Contact Us” section and below.

Your Rights.

You have the following rights:

● The right to request confirmation of whether we process your personal data and access to a copy of the personal data retained by us.

● The right to request to update or request deletion of your personal data or restrict processing of your personal data.

● Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible.

● Where the processing of your personal data is based on your consent, the right to withdraw your consent at any time. Withdrawing your consent will not impact the lawfulness of any processing activities that have taken place before such withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

● The right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorised by European Union or local law, or this is necessary for the performance of a contract.

● The right to object to processing of your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

● You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

● The right to opt out of marketing communications at any time. If you choose to opt out of marketing communications, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.

● The right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority at the contact details here (for the EEA) and here (for the UK). Certain supervisory authorities will require that you exhaust our own internal complaints process before looking into your complaint.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

To exercise any of your rights, contact us at: privacy@dola.com.

Cookies. We will, unless exempt, obtain your consent to the use of cookies. For more information about cookies, please visit our Web Cookies Policy.

Data Controller. The data controller of your personal data is: SPRING (SG) PTE. LTD.

GDPR Representatives.

If you are based in the United Kingdom, our designated GDPR representative is:

Cosmo Technology Private Limited

Kaleidoscope,

4 Lindsey Street,

London,

United Kingdom,

EC1A 9HP

If you are based in the EEA or Switzerland, our designated GDPR representative is:

Mikros Information Technology Ireland Limited

Mespil Business Centre

Mespil House

Sussex Road

Dublin 4

Ireland

Egypt

Age and Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13, and that you have read and acknowledged this Privacy Policy and Terms of Services and agree to the use by such user of the Services, including registration for an account where applicable.

Indonesia

Age and Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 18 years of age. If you are below 18 years old and you are not married or under guardianship:

• you must obtain approval from your parent(s) or legal guardian(s); and
• your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Services; (ii) your compliance with this policy; and (iii) ensuring that your access to and use of the Services will not, in any event, result in any violation of 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) is not willing to open the account under their name, you must cease accessing and/or using the Services.

Your Choices. Upon your request, we will display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. You may withdraw such consent to our disclosure of personal data to third parties.

You may also request that we: (i) disclose to you the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, or by withdrawing your consent to the disclosure and/or collection of your personal data, you may not be able to use some of Products name's features and functionality.

To exercise any of your rights, please contact us using the details set forth in the “Contact Us” section.

Notification. In the event of any breach affecting your personal data, we will notify you and provide you with information regarding such breach.

Data Retention. We retain your information for as long as it is necessary to provide you with the Services. Where we do not need your information in order to provide the Services to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this 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 have terminated your use of the Services and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

Latin America

If you are using our services in Spanish-speaking Latin America, the following additional terms apply and shall prevail in the event of any conflict with the main body of this Privacy Policy.

How We Use Your Personal Data. Most purposes of processing described in the “How We Use Your Information” section of this Privacy Policy are necessary purposes. The following is a secondary purpose for which we hereby request your consent as required by applicable laws:

● To promote the Services by use of third-party advertising platforms that deliver advertising for the Services.

● To review, improve, and develop the Services, such as by conducting voluntary surveys and research; and improving and training our AI models.

● To personalise and customise your experience on the Services, such as by recommending content, better informing output responses, and providing interactive features.

The above purpose allows us to provide you with a better experience. By using our Services, you consent to the processing of your personal data for these purposes. As required under applicable laws, we offer you the possibility to make decisions regarding how we use your personal data and to exercise your rights, as stipulated under “Your Rights” below. We also offer you choices regarding how we use and disclose your personal data, and you can limit certain processing by using the tools available in your account settings and/or by clicking the “unsubscribe” link or mechanism noted in any marketing or advertising emails we may send.

Providing wrong or inaccurate data can affect the efficiency, purpose, objective or any other aspect of the Services. In some cases, if you refuse to provide your data, you may be restricted from the use of certain features.

How We Share Your Personal Data. We may share your personal data with a third party for purposes other than processing on our behalf. Your personal data may also be transferred/transmitted to servers or data centers outside the country where you live, such as in Indonesia, Malaysia, Singapore, and the United States, for storage and/or processing.

The categories of the recipients of your personal data and its purposes are described in the section “How We Share Your Information” of the main body of the Privacy Policy. For information about how we, our business partners, or our service providers (including members, subsidiaries, or affiliates of our corporate group, including those outside the country where you live) may process personal data, please use the “Contact Us” section set out above.

By providing us with your personal data and using our Services, you consent to those data sharing and transfer activities described in the “How We Share Your Information” and "International Data Transfers" sections of this Privacy Policy that require your consent. You can always exercise your rights as outlined below.

Age, Parental and Guardian Consent. If you are a user in Peru, you declare that you are over the age of 14. If you are under the age of 14, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 14, you hereby declare that such user is above the age of 14, and that you have read and acknowledged this Privacy Policy and Terms of Services and agree to the use by such user of the Services, including registration for an account where applicable.

Your Rights. You may have rights and choices when it comes to your personal data. Depending on the jurisdiction in which you reside, your rights under applicable laws may include the following: to know, access, delete, update, or correct/rectify your personal data; to be informed of the ways in which we process your personal data; to limit the use and disclosure of your data; to transfer and data portability; to revoke your consent and to request evidence of your consent; to object to certain processing activities; to not be affected by a decision based solely on automated processing; and to file complaints before the competent data protection authority, where applicable, but especially if we reject your request or do not respond in a timely manner.

Revoking your consent does not affect the lawfulness of our use or processing of your data undertaken prior to such revocation. Some of your rights apply generally, while others will only apply in certain circumstances and jurisdictions, and, depending on the scenario, these rights may be subject to some limitations by law.

You can exercise your rights free of charge, by sending your request to the contact details set forth in the “Contact Us” section. Your rights requests will be resolved as soon as possible according to the nature of your request and within the terms established by applicable laws. We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests.

Nigeria

Legal Bases for Processing. We abide by the relevant principles for the processing of personal data as stipulated under Nigerian law. We collect and use personal data to offer the Services as described in this Privacy Policy. By signing up to and/or using the Services, you agree to the processing and use of your personal data in accordance with this Privacy Policy. We process your personal data on the basis that the processing is necessary for the performance of a contract into which you are entering or have entered. In some circumstances, we may have to process data for other purposes that are not necessary for the performance of a contract. In such cases, the processing may be based upon (i) our legitimate interests; (ii) compliance with our legal obligations; (iii) consent you may have provided to us; (iv) the performance of a task in public interest; and/or (v) protection of vital interests.

International Transfers. International data transfers are necessary for us to provide our services, and your personal data may also be transferred to servers or data centers outside the country where you live, such as in Indonesia, Malaysia, Singapore, and the United States, for storage and/or processing. If you are located in Nigeria, we rely on the performance of contract or where necessary, any other legal bases for international data transfer under applicable data protection laws and regulations.

Age, Parental and Guardian Consent. You declare that you are 18 or over the age of 18.

If you are below 18 years of age:

• you must obtain consent 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 Services; and (ii) your compliance with this Privacy Policy.

If you are not at least 18 years of age and you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) are not willing to open an account under their name(s), you must cease accessing the Services.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, in addition to the rights listed above, you shall have the right to: withdraw your consent at any time where the legal basis of our processing is consent; object to the processing of your personal data; request the restriction of processing in specific circumstances; and data portability.

Processing. We may process your personal data through manual and automated methods. We use your information to enforce our Terms of Services and policies (through a mix of technology including automated means and human moderation). This may include removing content or suspending or banning your account if we determine that you are violating our Terms of Services or other policies. You have the right not to be subject to decisions based solely on automated processing which produces legal or similar significant effect concerning you. However, you may not be entitled to this right, where the decision becomes necessary for the performance of the contract between us, where you have given us your consent, or as authorised by law.

Complaints and Remedies. You may raise complaints, exercise your rights or seek any remedies, or reach our Privacy Team by using the details set forth in the “Contact Us” section. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. You also have the right to lodge a complaint with the Nigeria Data Protection Commission via email at info@ndpc.gov.ng or through platforms available for complaints via its website at https://ndpc.gov.ng/.

Philippines

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the Philippines National Privacy Commission, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

South Africa

Age and Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and the Terms of Services and agree to the use by such user of the Services and registration for an account, where applicable.

South Korea

Data Retention. We retain information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Policy. We will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:

● Act on Consumer Protection in Electronic Commerce:

o Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years

o Records on the handling of consumer complaints or disputes: 3 years

o Records on advertisements and labels: 6 months

● Protection of Communications Secrets Act

o Records on your visits to our website: 3 months

Destruction of Personal Data. We destroy personal data whose purposes of collection as consented to by you have been achieved, or whose periods of use to which you consented, or which were provided in the Privacy Policy, have expired. We destroy your personal data in a manner that renders it unrestorable by the relevant department.

Your Rights. You have the right to access your personal data, to rectify any inaccurate personal data, to request the deletion of your personal data, and to request the suspension of the processing of your personal data. You may also have the right to opt out of international transfers of your personal data, so long as such transfers are not necessary to provide you with the Services. You can exercise your rights by contacting us using the details set forth in the “Contact Us” section.

Data Security. We work hard to protect the Services and our users from unauthorized access to, or unauthorized alteration, disclosure, or destruction of, information we hold. To this end, we have in place technical, managerial, and physical safeguards, including internal policy for data protection, limiting the access to personal data on a need-to-know basis, and controlling access to the facilities where personal data is processed.

Entrustment and/or Overseas Transfer of Personal Data. We entrust your personal data to members of our corporate group, service providers, and other recipients described in the “How We Share Your Information” section of the Privacy Policy, some of whom are located abroad, subject to your consent or notifications to you, if applicable. Where we transfer your personal data outside of South Korea, we do so for the purposes described in this Privacy Policy. The entities receiving and processing your personal data are committed to using and storing such personal data in compliance with domestic and international regulations, including taking appropriate physical and technical measures to protect your personal data.

Age and Parental and Guardian Consent.

• The Services are not directed at children under the age of 14.
• You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 14 and that you have read and acknowledged this Privacy Policy and the Services’ Terms of Services and agree to the use by such user of the SErvices and registration for an account, where applicable.

Türkiye

Legal Bases for Processing Your Personal Data. We rely on the following legal bases while processing your personal data in accordance with Article 5 of the Law on Protection of Personal Data No. 6698 (“Data Protection Law”):

● Processing is explicitly laid down or dictated by laws;

● Processing of your personal data is necessary, provided that it is directly related to the conclusion or fulfillment of the contract between us;

● Processing is mandatory for us to be able to comply with our legal obligations;

● The relevant data is made available to the public by yourself;

● Processing is mandatory for the establishment, exercise or protection of a right;

● Processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms;

● Your explicit consent (please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above).

Your Rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:

● The right to learn whether we process your personal data;

● The right to request information with regard to such processing, if we process your personal data;

● The right to learn the purposes of the processing and whether they are used for such purpose or not;

● The right to know the third parties within or outside the country, to whom we transfer your personal data;

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

● The right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law;

● The right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items;

● The right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means;

● The right to claim indemnification for damages incurred due to illegal processing of your personal data.

If you would like to exercise your rights, please contact us using the details set forth in the “Contact Us” section.

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty (30) days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged in accordance with the Turkish Personal Data Protection Board.

Language. If you are a user located in Türkiye, the Turkish version of this Privacy Policy (where available) shall control.

United Arab Emirates (“UAE”)

How We Share Your Personal Data. By using the Services in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main body of this Privacy Policy.

Governing Law and Dispute Resolution. By using the Services in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:

● Where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and

● For all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Mediation Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within thirty (30) days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Arbitration Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

Vietnam
Age and Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:

• you must obtain approval from your parent(s) or legal guardian(s); and
• your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Services; (ii) your compliance with this Privacy Policy; and (iii) ensuring that any of your participation in the Privacy Policy will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease using the Services.

Methods of Processing Your Personal Data. We may process your personal data by manual or automated methods.

Your Rights and Choices. Subject to certain exceptions, you have statutory rights and obligations under applicable laws. In particular, you have the following statutory rights:

● Right to know;

● Right to consent and withdraw consent;

● Right to access;

● Right to delete data;

● Right to restrict data processing;

● Right to be provided with data;

● Right to object data processing;

● Right to complain, denounce or initiate lawsuits;

● Right to claim for damages; and

● Right to self-protection.

You may exercise these rights by contacting us using the details set forth in the “Contact Us” section, and we will respond to your request regardless of the location in which your personal data is stored.

You have the following statutory obligations:

● Protect your own personal data;

● Request other relevant organizations and individuals to protect your personal data;

● Respect and protect personal data of others;

● Provide complete and accurate personal data upon giving consent to the processing of your personal data; and

● Other obligations under applicable laws.