1.Introduction

Welcome to SalloChat! We attach great importance to your privacy and will only process your personal data with your consent.
This Privacy Policy (hereinafter referred to as "this Policy") explains how TCI ENTERTAINMENT HONGKONG LIMITED (hereinafter referred to as "we") collects, uses, and shares your personal data, the rights you have regarding your personal data, and other important information about how we process your personal data when you browse and use the services of the SalloChat application (hereinafter referred to as "the Product") operated by us.
This Policy applies to the SalloChat Product and the related services provided thereby.
Please note that before accessing the Product and/or using the Product services, you should carefully read this Policy. Your access and/or use of the Product shall constitute your consent to and acceptance of this Policy. If you do not agree to this Policy, please do not access the Product or use the services. You confirm that (a) you have read and understood this Policy; (b) you accept this Policy and agree to the collection, use, sharing, and other processing of your personal data as described herein; and (c) you agree to receive notifications about security incidents sent by us to your email address.
Please note that your use of the Product services is also subject to agreements such as the Terms of Service.
We reserve the right to adjust this Policy and may notify you through Product notifications (if required by law), but we still recommend that you review the content of this Policy from time to time. If you continue to use the services, you agree to and accept the latest version of this Policy.

2.Personal Data We Collect

2.1 Personal Data You Provide
By using the Product services, you may provide us with the following personal data:
a. Account data. Including your name and email address. If you choose to log in using another platform (such as Google), we will receive the service data you use for logging in, as well as (depending on your account settings on platforms such as Google) detailed data about you, including your name, email address, or unique user identifier.
b. Messages and content. Including content containing personal data that you provide in any free-form or unstructured format when using the Product services, such as information involving personal data provided in messages sent to us.
c. Real-name personal information. Including your photos. If you apply to become a Host, you shall provide your real photos for completing facial recognition verification. Please note that this involves your sensitive personal information.
d. Payment and transaction data. When you purchase paid services provided by the Product, the third-party payment platform we cooperate with will provide us with your order number and payment status.
2.2 Personal Data We Automatically Collect
We will automatically record the following data:
a. Device and network data. Including the operating system, manufacturer and model of your computer device, browser, IP address, device and cookie identifiers, language settings, and general location data such as city, state, or geographical region, microphone permissions, and camera permissions.
b. Usage data. Including data about how you use the services, such as the links and buttons you click on, and page access.
We and our service providers use Cookies, scripts, or similar technologies to manage the services and collect information about you and your use of the services. These technologies help us identify you, customize or personalize your experience, provide you with additional products or services, and analyze the use of our services to make them more useful to you. Most internet browsers allow you to delete or manage Cookie functions and adjust your privacy and security preferences. However, please note that disabling our Cookies may mean that you cannot fully utilize our services.

3.How We Use Your Personal Data

3.1 General Principles for the Processing of Personal Data
Pursuant to this Privacy Policy, personal data is processed by TCI ENTERTAINMENT HONGKONG LIMITED as the data controller in accordance with the following basic principles: (i) compliance with the principles of law and good faith; (ii) accuracy and, when necessary, up-to-dateness; (iii) processing for specific, clear, and legitimate purposes; (iv) limitation to what is necessary for the processing purposes and adherence to the principle of data minimization; (v) storage for the period specified by relevant laws and regulations or for the time necessary for the processing purposes.
3.2 Our Use of Your Personal Data
We will use your personal data for the following purposes:
a. Operation and management of services
(i) Legal basis: Necessary for the performance of a contract
(ii) Reasons and methods for us to use your personal data: Provide and maintain the content and functions of the services. Fulfill the obligations arising from the contract signed with you. Create your account and profile. Facilitate payments and transactions, including payments for purchased subscription services. Respond to your inquiries, feedback, or questions and troubleshoot problems. Manage our relationship with you, including sending you information related to our services.
(iii) Categories of personal data: Account information, personal profiles, messages and content, interests and preferences, payment and transaction data, device and network data, usage data.
b. Provision of core functions of the services
(i) Legal basis: Necessary for the performance of a contract
(ii) Reasons and methods for us to use your personal data: Provide you with online interaction functions to enable you to chat online with other users, etc.
(iii) Categories of personal data: Account information, photos, personal profiles, messages and content, interests and preferences, payment and transaction data, device and network data, usage data, IP address, microphone permissions, camera permissions, location information.
c. Monitoring and protection of services
(i) Legal basis: Legitimate interests
(ii) Reasons and methods for us to use your personal data: Prevent fraud, criminal activities, and abuse of our services, and ensure the security of our information technology systems, infrastructure, and networks (including testing, system maintenance, support, etc.).
(iii) Categories of personal data: Account information, personal profiles, messages and content, interests and preferences, payment and transaction data, device and network data, usage data.
d. Analysis of service usage trends
(i) Legal basis: Legitimate interests
(ii) Reasons and methods for us to use your personal data: Aggregate, anonymize, and de-identify personal data. Analyze the usage and effectiveness of our services. Improve and add functions to our services. Develop our business and marketing strategies.
(iii) Categories of personal data: Account information, personal profiles, messages and content, interests and preferences, payment and transaction data, device and network data, usage data.
e. Enforcement of our service contracts and compliance with legal obligations
(i) Legal basis: Legitimate interests; where required by applicable law, consent is required
(ii) Reasons and methods for us to use your personal data: Enforce and comply with our terms and policies. Protect the rights, privacy, security, or property of us and others. Ensure the integrity of our services. Retain transaction records and comply with legal procedures.
(iii) Categories of personal data: Account information, personal profiles, messages and content, interests and preferences, payment and transaction data, device and network data, usage data.

4.How We Share Personal Data

4.1 Service Providers
We share your personal data with companies and/or individuals who provide services on our behalf or assist us in operating our services or business (such as hosting, information technology, customer support, email delivery, product analysis services, etc.). Service providers are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we share it with them.
4.2 Professional Advisors
When necessary, we may share aggregated data with professional advisors (such as lawyers, auditors, banks, or insurance companies) to enable the advisors to provide us with professional services.
4.3 Authorities and Other Parties
We may share personal data with relevant authorities in response to legal requirements or requests from law enforcement or regulatory agencies.
4.4 Business Transferees
If we are involved in a strategic transaction, restructuring, bankruptcy, takeover, etc., during the due diligence process, your personal data and other information may be shared with the counterparty to the transaction or other parties assisting with the transaction, and transferred to the successor or affiliate as part of the transaction, along with other assets.
4.5 Affiliates
For the purposes of optimizing operations, developing functional services, etc., we may share your personal data with our affiliates to the extent necessary.

5.Cookie Policy

Cookies, device information identifiers, and similar technologies are commonly used technologies on the Internet. When you access the Product and use the Product services, we may use relevant technologies to send one or more Cookies or anonymous identifiers to your device to collect and identify information about your access to and use of the Product. We undertake not to use Cookies for any purposes other than those described in this Policy. We use Cookies and similar technologies primarily to achieve the following functions or services:
5.1 Ensure the safe and efficient operation of the Product and services
We may set Cookies or anonymous identifiers for authentication and security purposes to enable us to confirm whether you are securely logged into the services or whether you have encountered theft, fraud, or other illegal activities. These technologies will also help us improve service efficiency and enhance login and response speeds.
5.2 Help you obtain a more convenient access experience
The use of such technologies can help you save the steps and processes of repeatedly filling in personal data and entering search content (example: recording searches and form fillings).
5.3 Clearing of Cookies
Most browsers provide users with the function to clear browser cache data. You can perform corresponding data clearing operations in the browser settings. If you perform the clearing, you may not be able to use the services or corresponding functions provided by us that rely on Cookies.

6.Storage and Transmission of Personal Data

Our services are operated in the United States. If you are located in another jurisdiction, please note that the personal data you provide to us may be transmitted to and stored in the United States, and the relevant laws of the United States may not provide the same level of protection as the country or region where you are located. You explicitly agree to and accept such transmission, storage, and/or processing of your personal data outside the region or country where you reside.

7.Retention of Personal Data

We will only retain your personal data for the period necessary to achieve the purposes of processing the personal data. To determine the appropriate retention period for personal data, we will comprehensively consider factors such as the quantity, nature, and sensitivity of the personal data, the potential risk of harm that may result from the unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve these purposes through other means, and applicable legal requirements.

8.How We Protect Your Personal Data

We attach great importance to the security of your personal data and will strive to take reasonable security measures (including technical and management measures) to protect your personal data from improper use or unauthorized access, public disclosure, use, modification, damage, loss, or leakage. For example, we use static encryption to ensure the security of all user data (including database files and backups) and use security keys for data management. We use transmission encryption to protect data streams from user devices to servers and from servers to servers in public network environments. We will also ensure the effective implementation of these technical measures through code review mechanisms. In addition, we regularly test applications and systems for vulnerabilities and security issues and take access control measures (such as access tokens and two-factor authentication) to ensure data security.
Please note and understand that we cannot ensure an absolutely secure Internet environment. If you discover that your personal data has been leaked, please contact us immediately so that we can take corresponding measures.
If any accident, force majeure event, or other situation leading to the leakage of your personal data occurs, we will make every effort to minimize the loss and promptly inform you of the relevant situation, the security measures we have taken and that you can take, and other relevant personal data. If a security incident related to personal data occurs, we will report such incident to the competent authorities in accordance with the requirements of applicable laws and regulations, promptly investigate the problem, and take emergency measures.

9.Your Rights

9.1 You have the right to access a copy of the personal data we have collected about you. Where appropriate, we will provide the personal data in a portable, machine-readable, and easy-to-use format.
9.2 You have the right to request us to correct your personal data, that is, you can ask us to correct inaccurate personal data. If necessary, you can also supplement your personal data.
9.3 You have the right to request us to delete your personal data, including your SalloChat account and related personal data. If you want to delete your account, you can contact us by sending an email to contact@sallochat.com. Please note that after you submit a request to delete your account, you will no longer be able to use SalloChat, so please consider carefully. In addition, when the purpose of use agreed in this Policy no longer exists or the personal data retention period expires, we will also take the initiative to delete your personal data.
9.4 Withdrawal of consent. You can withdraw your consent to our processing of your personal data at any time by sending an email to contact@sallochat.com, and the withdrawal of consent will not affect the legality of our processing of your personal data before the withdrawal. After receiving your withdrawal request, we will process it promptly and will no longer process your personal data unless required by law.
9.5 Other rights, such as the right to object to and request us to restrict the use of your personal data.
If you make the above requests, please contact us in accordance with the method provided in Article 14 "Contact Us" below. To protect the security of your personal data, before responding to your right request, we may need to verify your identity, for example, by asking you to provide certain supporting information related to your identity. We will respond to your right request in a timely manner in accordance with the requirements of relevant laws and regulations.

10.Privacy Policy for Minors

Our products and services are not directed at minors under the age of 18, and we will not intentionally collect personal data of minors under the age of 18. If we discover that a minor under the age of 18 has registered a SalloChat account and/or provided us with personal data, we will delete the relevant personal data in a timely manner as required by law.

11.Third-Party Links

The Product services may contain links to other third-party products or applications, or may direct users to other third-party products or applications not operated by us. This Policy does not apply to these products or applications. The inclusion of third-party links in this service does not mean that we endorse or have reviewed these products or applications. We cannot control or ensure that the personal data processing practices of these products or applications comply with legal requirements. We recommend that you directly and promptly review the privacy policy content of these products or applications.

12.Changes to the Privacy Policy

Our products and services may change from time to time. Therefore, we need to adjust this Policy. We reserve the right to update or modify this Policy at any time and may notify you through Product notifications (if required by law), but we still recommend that you review the content of this Policy from time to time. If you continue to use the services, you agree to and accept the latest version of this Policy.

13.Regional Data Rights

If you are located in one of the following U.S. states: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, or Virginia, in addition to the above agreements, you have the right to request us to:
a. Prohibit the sale of your personal data. Please note that we will not sell your personal data;
b. If our Product involves user profiling and targeted advertising, you can request to object to user profiling and targeted advertising. You need to submit a verifiable request to opt out of each of the above behaviors. Please note that these measures may have a negative impact on your customer experience when using our products and third-party services.
You can exercise the above rights in accordance with the method agreed in Article 14 "Contact Us" of this Policy. Please note that data privacy laws vary by state. If you are located in the United States, please consult a certified local legal advisor for more detailed regulatory information.

14.Contact Us

If you have any questions, concerns, or complaints about this Policy or the processing of personal data, you can contact us by sending an email to contact@sallochat.com.