Privacy Policy

For providing you with “Tochat”( the “App” or “Software” ) and related services( “Services”), Action First Holding Limited( “we”, “our”, or “us”) needs to collect some private information about you. We understand the importance of protecting your privacy. Therefore, we have established this Privacy Policy to explain how we treat your information and protect your privacy when you use the Software and the rights and options available to you regarding your information.

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Please read this Privacy Policy carefully to understand it. If you use the Software, we consider you to consent to the terms and conditions described in this document.

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE.

1.Information We Process and Purposes of Processing Your Information

Information that you submit to the Software
1)Registration Information
For creating an account (“Account”) through the Software and getting more chances to interact with other users, you may volunteer to provide certain information (“Registration Information”) about you to the Software, such as username; gender identity; date of birth; preference; personal introduction; photos; other detail information.

2)Phone Number
For safety and to ensure you have a better possible user experience, we will need you to verify your Account and ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake accounts being created which can be used for malicious activities and cybercrime. We collect and use your phone number on the basis of our legitimate interests identified above and for the prevention of fraud. You can also use your phone number to log into the Software.

3)Geolocation Information
If you turn geolocation features on, when you use your mobile device, we will collect information about Wi-Fi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the App and make it easier for you to interact with other users.

4)Permission to Access to the Camera, Microphone, Photo Album.
In order to use the features of the video or voice communication in the Software, you may voluntarily grant us permission to access the microphone or camera. In order to use other features, such as set avatars, send pictures to other users, you may voluntarily grant us permission to access the camera or photo album to obtain photos in your mobile device. Only if you confirm the permission, will we gain access to your camera microphone or photo album.

5)Permission to Access to the Storage.
To ensure that you may save photos or cache information normally to your device, you may voluntarily grant us permission to access the storage of your device.

6)Support Related Information.
If you communicate with us via our support section or via email, we may collect your email address voluntarily submitted.

Information that is processed automatically
1)Device Information. We may use Internet protocol to collect information about your device when you use the App, including your configuration and settings of the Software and Services, version of the Software and Services; ISP (Internet Service Provider), Internet protocol (IP) address, Media Access Control (MAC) address, anonymous user identifiers, device configuration and identifiers; language. And we will use ASIdentifierManager to collect Advertising ID.

2)Payment data. We may use the Database to collect certain information about your orders and payment records for purchasing virtual diamonds and other paid services offered by us. such as purchase items, payment time, order status. We do not collect and we are not responsible for the collection or security of payment details. Payment information is processed and stored using third-party companies (such as Apple or Google). These companies can be contacted through their websites. Before entering your personal details, we suggest that you read and become familiar with the privacy policy of these third-party companies.

3)Virtual diamonds and points.
We may use the Database to collect certain information about virtual diamonds and points in your Account, such as the growth/ consumption of your points and virtual diamonds.

4)Consumption information.
When you purchasing virtual diamonds and other paid services offered by us (“in-app purchase”), we will collect the following consumption information from you and share it with Apple upon Apple’s request:
a.Account Tenure: the age of the your Account.
b.App Account Token: the UUID of your Account that completed the consumable in-app purchase transaction.
c.Consumption Status: whether you have consumed the in-app purchase.
d.Delivery Status: whether we delivered the in-app purchase you have purchased and, if not, the reasons for non-delivery.
e.Lifetime Dollars Purchased: the total amount, in USD, of in-app purchases you have made in the App, across all platforms;
f.Lifetime Dollars Refunded: the total amount, in USD, of refunds you have received, in the App, across all platforms;
g.Platform: the platform on which you consumed the in-app purchase;
h.Play Time: the amount of time that you used the App;
i.Sample Content Provided: whether we provided, prior to your purchase, a free sample or trial of the purchased content, or information about its functionality.
j.User Status: the status of your Account within the App.
You can find out more details through the following links:
https://developer.apple.com/documentation/appstoreserverapi/consumptionrequest

5)Photos and videos.
To ensure a safe and healthy App experience for all users, we will collect the photos or videos that you intend to post on your profile or moments and share them with third-party technology provider who will detect and filter any suspected illegal or objectionable content before it is posted on the App. If such photos or videos are deemed suspected illegal or objectionable, you will not be able to post them on your profile or moments.

Use of your information
Our main goal is to ensure your experience on the App is an enjoyable one and you don’t end up getting stung! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:
a. offer you our services and features;
b. personalize the App and the content we deliver to you;
c. resolve disputes between you and other Users; and
d. investigate fraud, protect our legal rights, and enforce our Terms of service.

2.Disclosure of Your Information
We will not disclose your personal information, except in the limited circumstances described here:
1)Your Consent – Where you voluntarily do upload and choose to provide your personal information on your profile when you create an Account, you are explicitly consenting to our processing of your information and making this public to other users. Therefore, we recommend you to think carefully about the information you disclose about yourself.
2)Service Providers - We engage certain trusted third parties to perform functions and provide services to us. We may share your personal information with these third parties, but only for the purposes of performing these functions and providing such services e.g. information technology companies (hardware and software) which provide services to support our products.
3)Required by law- If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the other users, our partners, or the general public).
4)Business Transfers -In the event that we or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal information.
We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Privacy Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

3.User Age Restriction
Although we want as many people as possible to enjoy the Service, you have to be at least 18 years old or reach the statutory minimum age according to the law and regulation in your country, in order to use the App.
We do not knowingly collect any information about or market to children, minors or anyone under the statutory minimum age. If you are less than 18 years old or the statutory minimum age in your country, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the statutory minimum age has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and terminate their Accounts from the App.

4.Modifying Your Registration Information
You may access or modify the Registration Information you provided. When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.
Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

5.Changes to this Privacy Policy
As the App evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information. By continuing to access or use the App after changes to this Privacy Policy become effective, you agree to be bound by the revised Privacy Policy.

6.Security
We pride ourselves on taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:
a. Please make sure you log out of your Account after use as you never know who may stumble onto your Account;
b. Please don’t share your social media password with anyone else!
c. Change your social media password periodically.
If you ever think someone has had access to your social media password, please report it to the relevant social media platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to the App and any transmission is at your own risk.
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

7.Transfer of Data Outside Your Territory
We work in the international space and provide the App to our users around the world. We and third-party that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
Where you are located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where maybe outside of EEA once you use the App and/or Services. You may withdraw your consent at any time.

8.How Long We Use Your Personal Data
We generally retain your personal information for as long as is necessary for the performance of the agreement between you and us and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your Account.
However, some data may still be stored for a certain time period if the information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

9.Your Data Rights
You have the right to delete your Account, or to access, modify, correct or delete any personal data which we may have collected. In order to exercise this right, please contact us by email at [TochatApp@outlook.com]. If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to the processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA. To exercise these rights please contact us by email at: [TochatApp@outlook.com].