TouchPal Privacy Policy
Effective Date: August 13, 2018
Update Date: August 16, 2019
1. What
Information We Collect
2. How
We Use Your Information
3. How
We Share Your Information
5. International Transfer of Personal Data
6. Security
7. Advertising and Analytics Services Provided
by Others
9. Changes
to This Privacy Policy
10. Your
Choices
We
take your privacy and data security seriously. This privacy policy ("Privacy
Policy”) is meant to help you understand what information Shanghai ChuLe
(CooTek) Information Technology Co., Ltd. and its affiliates and subsidiaries
(collectively, “CooTek”, “we”, “us” or “our”) collect, how we use such
information, and the recipients with whom we share such information.
This
Privacy Policy applies to your access and use of the website at http://www.touchpal.com/
(the “Website”), the mobile applications made available in the U.S. versions of
the Apple App Store and the Google Play Store (the “Apps”), the TouchPal
Keyboard made available in the U.S. versions of the Apple App Store and the
Google Play Store, along with any revisions, updates and/or modifications thereto
(collectively, “TouchPal Keyboard”) and any data, products, services and
associated materials or media supplied with the TouchPal Keyboard (together
with the Website, Apps, TouchPal Keyboard, the “Services”) which are made
available in the United States. This U.S. Privacy Policy only applies to access
and use of the Services within the United States, and does not apply to any
other data gathered or used by us, including through websites and mobile
applications not listed above or to the information practices from other
countries.
This
Privacy Policy is incorporated into and made a part of the End User License
Agreement. Please review our End User License Agreement because
it governs your use of the Services and limits our liability to you. By using
our Services, you agree that we may treat your information in the ways we
describe in this Privacy Policy. If you do not agree with any term of this
Privacy Policy or the End User License Agreement, you may not use our Services.
This Privacy Policy contains the following sections:
1.
What
Information We Collect
Information
You Provide to Us
We collect information you provide directly to us.
For example, we collect information when you register for an account, sign up
for a subscription, participate in any interactive features of the Services,
subscribe to a newsletter or email list, participate in a survey, contest,
promotion or event or otherwise communicate with us.
The types of information we may
collect from you include:
(a)
Account Information: We may collect information relating to your
account, such as your name, email address, password, postal address, phone
number, subscription and any other information you choose to provide.
(b)
Transaction Information: We may collect information relating to any
products and services you purchase from us. We may also collect and store
limited payment information from you, such as payment card type; however, we do
not collect or store full payment card numbers and all transactions are
processed by our third party payment processor.
(c) Input
Information: We will ask you to install
and enable our TouchPal Keyboard on your mobile device. The TouchPal Keyboard
runs in the background, logging your keystrokes on your mobile device. We will
collect information that you input using the TouchPal Keyboard, such as the
text you enter into any textbox, content of voice recognition, and other content you enter when
using any other applications on your mobile device. For optimizing the user experience and to
turn on and off exactly when you need to use or close our TouchPal Keyboard, we
will collect the usage statistics of the other applications that need to open
TouchPal Keyboard when they are in use.
(d) Other Information You Provide or Automatically
Collected by Us, such as information you provide when you participate in a survey,
contest, promotion or interactive area of the Services or when you request
technical or customer support, and for providing; and the installed application
name list on your device for better delivering advertising and content targeted
to your interests.
Information We
Collect Automatically
When you
access or use the Services, the types of information we may automatically
collect about you include:
(a)
Log Information: When you visit the Services, our servers
automatically record certain log file information, such as your Internet
Protocol (“IP”) address, GPS data, operating
system, browser type and language, referring URLs, access times, pages viewed,
links clicked and other information about your activities on the Services.
(b)
Mobile Device Information: We collect information about the mobile device you
use to access or use the Services, including the hardware model, operating
system and version, unique device identifiers, GAID, MAC address, Android ID, mobile
network information and information about your use of the Services. With your
consent, we may also collect
information about the location of your device and access and collect
information from certain native applications on your device (such as your
device’s camera, photo album and phonebook applications) to facilitate your use
of certain features of the Services. For more information about how you can
control the collection of location information and/or our access to other
applications on your device, please see “Your Choices” below.
(c)
Information Collected by Cookies and Other
Tracking Technologies: We and our
service providers use various tracking technologies, including cookies and web
beacons, to collect information about you when you interact with our Services,
including information about your browsing and purchasing behavior. Cookies are
small data files stored on your hard drive or in device memory that help us
improve the Services and your experience, see which areas and features of the Services
are popular, and count visits. Web beacons are electronic images that may be
used in the Services or emails and help deliver cookies, count visits and
understand usage and campaign effectiveness. For more information about
cookies, and how to disable them, please see “Your Choices” below.
Information
We Collect From Other Sources
We may
also obtain information about you from other sources and combine that with
information we collect directly. For example, we may collect information about
you when you post content to our pages or feeds on third party social media
sites, or if you use credentials (e.g.,
username and password) from a third party site to create or log into your
CooTek account.
All your
user information we collect will be stored safely in the United States and will
not be transferred to other regions or countries.
We may
use information about you for various purposes, including to:
(a)
Provide,
maintain and improve the Services;
(b)
Manage your
account and send you related information, including confirmations, updates,
technical notices, security alerts and support and administrative messages;
(c)
Respond to your
comments, questions and requests and provide customer service;
(d)
Communicate with
you about the Services, offers, surveys, events and other news and information
we think may be of interest to you;
(e)
Monitor and
analyze trends, usage and activities in connection with the Services;
(f)
Detect,
investigate and prevent fraudulent transactions and other illegal activities
and protect our and others’ rights and property;
(g)
Personalize and
improve the Services and provide advertisements, content and features that
match your profile or interests;
(h)
Facilitate
contests, sweepstakes and promotions and process and deliver entries and
rewards;
(i)
Link or combine
with information we get from others to help understand your needs and provide
you with a better experience; and
(j)
Carry out any
other purpose for which the information was collected.
We may
share information about you as follows or as otherwise described in this
Privacy Policy:
(a)
With vendors,
consultants and other service providers who need access to such information to
carry out work or perform services on our behalf;
(b)
When you
participate in the interactive areas of the Services or interact with us on
third party social media sites, certain information that you provide may be
displayed publicly, such as your name, photos and other information you choose
to provide;
(c)
We may share
your information with third parties and service providers that
provide products or services to us, that help us market or advertise to you
(including co-branded marketing and advertising), or that provide products or
services to you.
(d)
We also provide
information and content to research partners and academics to conduct
research that advances scholarship and innovation that support our business or
mission, and enhances discovery and innovation on topics of general social
welfare, technological advancement, public interest, health, and well-being;
(e)
In response to a
request for information if we believe disclosure is in accordance with, or
required by, any applicable law, rule, regulation or legal process;
(f)
If we believe
your actions are inconsistent with our End User License Agreement or other
policies, or to protect the rights, property or safety of CooTek or others;
(g)
In connection
with, or during negotiations of, any merger, acquisition, sale of assets or any
business, other change of control transaction or financing;
(h)
Between and
among CooTek and any current or future parent, subsidiary and/or affiliated
company; and
(i)
With your
consent or at your direction.
We also
may share aggregated or de-identified information, which cannot reasonably be
used to identify you.
4.
Social
Sharing Features
The
Services may offer social sharing features and other integrated tools, such as
the Facebook and Twitter buttons (e.g.,
“Like” or “Tweet”), which let you share actions you take on the Services with
other media. Your use of such features enables the sharing of information with
your friends or the public, depending on the settings you establish with the
entity that provides the social sharing feature. For more information about the
purpose and scope of data collection and processing in connection with social
sharing features, please visit the privacy policies of the entities that
provide these features.
5.
International
Transfer of Personal Data
The
security of your information is important to us. We implement and maintain
reasonable security measures intended to protect against unauthorized use,
disclosure, alteration or destruction of the information we collect and
maintain. However, please be aware that, despite our efforts, no data security
measures, no method of transmission over the Internet, and no means of
electronic or physical storage, is absolutely secure. As such, you acknowledge
and accept that we cannot guarantee the absolute security of your information transmitted
to, through, or on the Services or via the Internet and that, any such
transmission is at your own risk.
Where
we have given you (or where you have chosen) a password which enables you to
access to a CooTek account, you are responsible for keeping this password
confidential. Please do not to share a password with anyone.
7.
Advertising and Analytics Services Provided by Others
We may
allow others to serve advertisements on our behalf across the Internet and to
provide analytics services. These entities may use cookies, web beacons and
other technologies to collect information about your use of the Services and
other websites, including your IP address, web browser, pages viewed, time
spent on pages, links clicked and conversion information. This information may
be used by us and others to, among other things, analyze and track data,
determine the popularity of certain content, deliver advertising and content
targeted to your interests on the Services and other websites and better
understand your online activity.
If you
want to stop receiving personalized ads, you can go to “Settings” of TouchPal
Keyboard, once you choose not to receive personalized ads, we and our
third-party partners will stop sending personalized ads to you. Please note
that the number of ads you see will not change, but they may be less relevant
to you.
The
Services are not intended for children under the age of 18. Children under the
age of 18 must not use the Services for any purpose without first obtaining legally
valid parental/guardian consent to this Privacy Policy (both for themselves and
on your behalf). We do not knowingly collect personal information from any
children under the age of 18 without such consent. Please contact us if you
believe we have any personal information from any children under the age of 18 without
such parental/guardian consent. We will take reasonable steps to delete it as
soon as possible.
9.
Changes
to This Privacy Policy
We
reserve the right to amend this Privacy Policy at any time. You will know if
the Privacy Policy has changed since the last time you reviewed it by checking
the “Effective Date” included at the beginning of the document. If we make a
material change to the Policy, you will be provided with appropriate notice in
accordance with legal requirements. By continuing to use the Services after
changes have been posted, you are confirming that you have read, understood and
consented to the latest version of this Privacy Policy.
(a)
Account
Information
You may update,
correct or modify information about you at any time by logging into your online
account or by emailing us at privacy@touchpal.com. If you wish to deactivate your account,
please email us at privacy@touchpal.com, but note we may continue to store
information about you as required by law or for legitimate business purposes.
(b)
Location
Information
With your consent, we may collect
information about your actual location when you use our mobile applications.
You may stop the collection of this information at any time by changing the
settings on your mobile device, but note that some features of our mobile
applications may no longer function if you do so.
(c)
Native
Applications on Mobile Device
Some features of our mobile
applications may require access to certain native applications on your mobile
device, such as the camera and photo storage applications (e.g., to take and upload photos) and the phonebook application (e.g., to send invitations to your
contacts to try the Services). If you decide to use these features, we will ask
you for your consent prior to accessing the applications and collecting information.
Note that you can revoke your consent at any time by changing the settings on
your device.
(d) Cookies
Most web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set your browser
to remove or reject browser cookies. Please note that if you choose to remove
or reject cookies, this could affect the availability and functionality of the Services.
(e)
Promotional
Communications
You may opt out of receiving
promotional communications from us by following the instructions in those
communications or by emailing us at privacy@touchpal.com. If you opt out, we may still send you
non-promotional communications, such as those about your account or our ongoing
business relations.
(f)
Push
Notifications
With your consent, we may send
promotional and non-promotional push notifications or alerts to your mobile
device. You can deactivate these messages at any time by changing the
notification settings on your mobile device.
(g)
Your California
Privacy Rights
California law permits residents of
California to request certain details about how their information is shared
with third parties for direct marketing purposes. If you are a California resident, you may request
this information once per calendar year by emailing to us at privacy@touchpal.com.
11. Retention
of Your Personal
Data
We
keep your Personal Data for 10 years. If you continue to use the Services when
such 10-year period expires, the storage period of your Personal Data will
continue for another 10 years. If you no longer use the Services, we will
delete your Personal Data on a timely basis.
If you
have any questions or opinions regarding this Privacy Policy, you may contact
us at: privacy@touchpal.com.