Privacy Policy

Introduction

Welcome to the Privacy Policy of LokShorts, encompassing its various iterations and subsequent versions, inclusive of the LokShorts APP version (collectively referred to herein as "LokShorts", "we", "us", or "our"). This Privacy Policy is an integral part of and governed by our User Terms of Service. Within this Privacy Policy ("Policy"), our products and services are referred to as "Services."

LokShorts is firmly dedicated to safeguarding the privacy of those who utilize our products and services (hereafter known as "users" or "you"). In the course of providing the Services, we may gather and utilize your personal information. Your personal data's security is a top priority for us. Thus, this policy is designed to elucidate how LokShorts, acting as a data controller, gathers and manages personal data (also known as "personal information") that you share or disclose to us. We may also function as a data processor when handling your personal data received or acquired from third parties.

We urge you to peruse this Policy (particularly the parts emphasized in bold or underlined) thoroughly prior to using the Service, so you can make an informed decision. Should you disagree with this Policy, kindly refrain from registering, logging in, accessing, or using the Service, and from sharing your personal data with us. If you prefer that we not utilize specific types of your personal data in line with this Privacy Policy, be aware that we might then be unable to offer you certain portions of our Service, you may lose access to and/or the ability to use particular features of our Service, and your overall customer experience could be impacted. By consenting to all the terms and conditions of this Policy, you are agreeing to our processing of your personal information in accordance with this Policy.

Should you have any inquiries or concerns regarding this "Policy" after reading it, please feel free to reach out to us via the contact methods provided in Section 9, titled "How to contact us," and we will respond at our earliest convenience.

Table of Contents

1.Types of Personal Data We Collect

2.Methods of Collecting and Utilizing Personal Information

3.How We Use Cookies and Similar Technologies

4.How We Store, Preserve, and Protect Information

5.How to Manage Your Information

6.Services Provided by Third Parties

7.Age Limits

8.Announcements and Amendments

9.How to Contact Us

1.Types of Personal Data We Collect

Our primary objective in gathering your personal information is to facilitate a more efficient and enjoyable experience for you and other users when utilizing our products and services. We strive to create a secure and engaging online environment for all users, and the collection of information aids us in achieving this aim. While using the Services, we may gather and process details that could be directly or indirectly linked to your personal identity. In either scenario, such details may be considered personal data under this Policy.

(1) Information not directly tied to your personal identity: For instance, we may collect and process data about the user's source route, access sequence, and other information, such as tracking the source route and browser software of each user.
(2) Information connected to your personal identity: We may collect, process, or request personally identifiable information, such as birth date, gender, hobbies, personal phone number, facial characteristics; online identification details (including system account, IP Address, email address, and password and security question answers); personal financial details (including transaction history, balances, virtual gifts, membership rewards, coupons, and bank card information); communication details; personal online records and log information (including website browsing history, software usage records, click data, and operation logs); device details (including device model, device MAC address, operating system type, and device settings); software list Unique Device Identifier (such as IMEI/androidID/IDFA/OPENUDID/GUID, information describing the basic details of the personal device includes SIM card's IMSI information); location details (including travel information, precise location data, lodging information, and latitude and longitude).

Please be aware that if you share or post information in a public area visible to other users of the Service, and you reveal your personal information in response to information shared or posted by others, such information may be collected and utilized by others. If you discover that other users have improperly collected or used your or others' information, please contact us as directed in Section 9 "How to Contact Us."

2.Methods of Collecting and Utilizing Personal Information

We will gather and obtain your information in the following manners:

(1) Information you provide, such as:

(a) Information you supply when registering for a service account or using LokShorts;
(b) Information you share with other users through the service and the information you save when using the service.

Please note that other users may collect and use your information if you upload, post, or make your information public in an area where other users can see or respond to it. If you find that other users have improperly collected or used your or others' information, please contact us as outlined in Section 9 "How to Contact Us" below.

Information shared by other users about you, or information about you provided by other users when using the service.

Information we obtain about you, such as log information, location information, and device information, which we collect, aggregate, and record when you use the Services.

We collect and use your information for purposes such as:

Assisting you with registration and login: To provide you with our services, you need to supply basic registration or login information, such as mobile phone number (sensitive personal information), verification code matching result (sensitive personal information), nickname, gender, date of birth, and profile picture, to create an account (username and password).

You may also use a third-party platform account supported by us to log in to LokShorts; in this case, we will obtain relevant information (such as your nickname, profile photo) from the third-party account as per your authorization.

Thus, the aforementioned personal data provided by you or obtained by us from your third-party platform account with your consent will be used for these purposes to provide and perform services for you in line with our agreement. Without this personal data, we cannot offer our services, and you will not be able to log in or use LokShorts.

Providing Search Services

When utilizing the search function in LokShorts, we collect your search terms, browsing history, browsing duration, and interaction frequency. This information helps us deliver the content you need and services that may interest you more.

Providing Audio Chat, Voice Chat, Video Chat Services

When using services like audio chat, voice chat, video chat, etc., we will request access to your microphone and camera. If you disagree, you will not be able to use these services, but your regular use of other LokShorts functions will not be affected.

Offering Recharge and Inquiry Services

When you recharge (acquire gold coins in LokShorts), we will collect details about your order and payment account. If you check the remaining value of your virtual property in your user account, we will collect and display it on the relevant page. Please note that information about your recharge, order, account, and virtual property is sensitive, so provide and use it with caution.

Ensuring Account Security, Service Operation, and Optimizing Service Experience

When using this service, to help us detect account anomalies, understand product suitability, provide basic services (such as browsing, search), and maintain the smooth operation of basic functions, we may automatically collect, store, and process information about your service usage and how you use it, including:

(1) Log Details: When utilizing this service, we may automatically gather comprehensive information about your usage and save it as relevant network logs. This log information includes your login account, search queries, IP Address, browser type, telecom provider, network environment, language, access date and time, and records such as total page views, push open records, time spent on the page, refresh records, post records, follow and subscribe records, favorites, and sharing.
(2) Device Information: Based on the specific permissions you grant during the installation and use of LokShorts, we will receive and record information about your device (including IMEI, MAC, serial number, SIM card IMSI identification number, device type, operating system and version, APP version, resolution, software package name, device settings, process and software list, Unique Device ID, software and hardware feature information), as well as device location information (including IP Address, GPS location, and related information like WLAN access points, Bluetooth sensor data, base station sensor).

To collect the above personal basic device information, we will request permission to access your device information. We gather this information to offer you our fundamental services and functions. If you decline to grant such permission, you may be unable to use the service.

Please recognize that device information and/or log information alone cannot identify a specific individual, so this information itself is considered non-personal. However, if such non-personal information is combined with other information to identify a specific individual or with other personal information, it will be regarded as personal information during that combination. In such cases, it will be treated as personal information and protected according to this policy. Unless authorized by you or otherwise stipulated by applicable laws and regulations, such personal information will be anonymized and de-identified.

Offering Client Server or User Response Services

When you reach out to us for Client Server or user responses (such as inquiries, feedback, suggestions, complaints, etc.), we may request necessary personal information to match and verify your user identity, ensuring the security of your account and system. We may store details like your communication/call records, conversations, or contact information to reach you or assist in resolving issues, or to record the solutions and outcomes of related problems. Therefore, we process your personal data for these purposes in accordance with our agreement with you. This personal data may also be processed to protect your legitimate interests, namely to obtain relevant information about your services and other related data from LokShorts.

Providing Information Display and Recommendation Services

We may use your information (such as interests, personalized tags, browsing and search history, device information, usage habits, location information, order information, etc.) and combine it to extract your browsing, search preferences, behavior patterns, and location information through recommendation algorithm modeling, programming, advertising models, user behavior analysis, and user profiling. This enables us to offer page displays and personalized content recommendations that better suit your needs.

Sending Notifications to You

We may send you service-related notices when necessary (e.g., when we suspend individual services due to system maintenance). If you wish to stop receiving messages from us, you can request that we cease sending them. However, we may continue to send messages in accordance with applicable laws and regulations.

Ensuring Your Security

We may use your information for Client Server, security prevention, fraud monitoring, archiving, and backup purposes to ensure the security of the services we provide. We may use or integrate the information we collect, and obtain information authorized by you or legally shared with our partners to comprehensively assess your account and transaction risks, conduct real-name authentication, detect and prevent security incidents, and take necessary records, audits, analysis, and disposal actions as required by law.

Enhancing Our Services

We may invite you to participate in service-related surveys to help us improve existing services or design new ones; simultaneously, we may use your information for software updates. Therefore, to maintain our legitimate interest in enhancing our services, we will process this personal data for this purpose.

Other Uses of Anonymous Information

You understand and agree that in certain cases, after collecting your information, we will de-identify and fully anonymize the data through technical means, so it no longer constitutes personal data directly or indirectly related to you or others. The de-identified information does not identify or relate to you. In this case, we reserve the right to use such de-identified information for analysis and monetization of the user database.

If we intend to use your information for purposes not outlined in this Policy, we will seek your prior consent through page prompts, interactive processes, website announcements, or other means. Once you agree, such additional use of your information will be considered part of and subject to this Policy.

Exceptions to Authorization

According to relevant laws and regulations, your authorization is not required to collect your information in the following situations:

(1) Related to the fulfillment of obligations under applicable laws and regulations;
(2) Pertaining to public safety, public health, and significant public interests;
(3) Related to criminal investigation, prosecution, trial, and execution of judgments;
(4) When it is challenging to obtain your consent to protect the life, property, and other major legitimate rights and interests of you or other individuals;
(5) When the information collected is publicly disclosed by you;
(6) Information collected from legally disclosed sources, such as legal news, government information disclosure, and other channels;
(7) Necessary for signing a contract as per your request;
(8) Required to maintain the safe and stable operation of the service, such as detecting and handling product or service failures;
(9) Necessary for lawful news reporting;
(10) If an academic research institution uses the information for statistical or academic research in the public interest and de-identifies the information contained in the results;
(11) Other circumstances prescribed by laws and regulations.

Special Notice on Personal Sensitive Information

Personal sensitive information refers to information that, if leaked, illegally provided, or misused, may endanger personal property safety and easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment.

For example, ID card numbers, personally identifiable information (such as facial recognition, voiceprints, etc.), bank accounts, contact list information, communication records and content, property information (including virtual property, virtual currency, virtual transactions), location information, total page browsing history, health physiological information, transaction information are all considered sensitive data. Please handle your sensitive data with care. You agree that we may process your sensitive data in accordance with this policy.

3.How We Use Cookies and Similar Technologies

We or our third-party partners may obtain and use your information through COOKIES and WEB BEACON and save this information as log information.

By using COOKIES, we offer users a personalized web experience that is simple and user-friendly. COOKIES are small data files sent from a web server to your browser and stored on your computer's hard drive. We use COOKIES to benefit users, such as speeding up the login process for the LokShorts virtual community. COOKIES help us determine your connection to web pages and content, the time spent on certain services, and the services you select.

You should have control over whether and how your browser accepts cookies. Please consult your browser's documentation for more information.

We may share, transfer, or disclose information.

(1) Sharing

We will not share your information with any third party outside of LokShorts without your consent, except in the following situations:

To provide you with our services. We may share your information with our partners and third parties to achieve essential functions or provide the services you need, such as payment services, data services.

To maintain and enhance our services. We may share your information with our partners and third parties to help us offer you more targeted and improved services.

To achieve the purposes described in Section 2 "How we collect and use personal information."

To fulfill our obligations and exercise our rights under this Policy or other agreements between you and us.

Sharing with third parties, including partners who entrust us with marketing, but we will only provide information related to the reach and effectiveness of the promotion and will not provide any information that can identify you.

To comply with applicable laws and regulations, protect us and our affiliates or partners, you, other users, or public interests, property, or safety from harm, such as preventing fraud and other illegal activities and reducing credit risk.

To assist you in resolving disputes or conflicts with others as per your legal requirements.

To provide your information at your and/or your guardian's lawful request.

To provide your information based on academic research.

To provide your information in compliance with social and public interests as per applicable laws and regulations.

We will only share your information for lawful, legitimate, necessary, specific, and clear purposes. For companies, organizations, and individuals with whom we share information, we will sign strict Non-Disclosure Agreements and require them to handle information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.

(2) Transfer

As our business continues to evolve, we may engage in mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. We will require new companies and organizations that hold your information to continue to be bound by this Policy, or else we will request that the company and organization seek your authorization again.

With your affirmative consent, we will transfer your information to other parties.

(3) Disclosure

We will only disclose your information in the following circumstances, complying with industry-standard security measures:

Disclose your designated information with your affirmative consent according to your needs;

In cases where it is necessary to provide your information in accordance with applicable laws and regulations, mandatory administrative enforcement, or judicial requirements, we may disclose your information according to the type of information requested and the manner of disclosure. We will require the recipient to produce corresponding legal documents, such as subpoenas or investigation letters, and ensure that the information requested is as transparent as possible, legally valid, and limited to data obtained by law enforcement agencies for specific legal purposes.

(4) Exceptions to Authorization

In accordance with applicable laws and regulations, your authorization is not required for the collection, sharing, transfer, and disclosure of your information in the following cases:

(1) Directly related to public safety, public health, or major public interests;
(2) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(3) When it is difficult to obtain your consent to safeguard the life, property, and other major legitimate rights and interests of you or other individuals;
(4) The collected information is disclosed to the public by you;
(5) Information collected from legally disclosed sources, such as legal coverage, government information disclosure, and other channels;
(6) Fulfilling obligations stipulated by applicable laws and regulations;
(7) Other circumstances prescribed by laws and regulations.

Sharing, transferring, and publicly disclosing de-identified personal information where the recipient cannot re-identify the natural person will not be considered as sharing, transferring, and publicly disclosing personal information. We may store and process such data without prior notice or your consent.

4.How We Store, Preserve, and Protect Information

We retain your information only for the period required for the purposes described in this Policy and as required by applicable laws and regulations. If we terminate the service, we will stop collecting your personal information in compliance with applicable laws and regulations. After the service is terminated, we will delete or anonymize your personal information unless otherwise stipulated by laws or regulatory agencies.

The information we collect and generate in the Services is stored in Singapore. You agree to authorize us to store and transfer your personal information/data across borders through this Policy. We ensure that your personal information is adequately protected in accordance with this Policy and relevant applicable laws and regulations. We will take measures to protect your information, including:

(1) Technical Measures for Data Security: We will adopt security protection measures in line with industry standards, including establishing reasonable system specifications and security technologies to prevent unauthorized access, modification, and loss or damage to your information.
(2) Other Security Measures: We manage and standardize the storage and use of information by establishing data security rules and conducting comprehensive data security control and awareness through monitoring and audit mechanisms.
(3) Employee and Partner Access: We only allow employees and partners who need to know your information to access it, and we have set up strict access control and monitoring mechanisms for this purpose.
(4) Reasonable Precautions: We will take all reasonably practicable steps to ensure that irrelevant information is not collected.
(5) Internet Environment: We will do our best to ensure the security of any information you send to us, but please be aware that the Internet environment is not 100% secure.
(6) Handling of Security Incidents: We have formulated systems to clarify the classification and grading standards of security incidents and the corresponding procedures, and we have established a special security incident emergency response team.
(7) Your Responsibilities: Please take care to protect the security of your information, especially your account, password, and other identity elements.

5.How to Manage Your Information

You have the right to access, correct, update, object, and delete your information. You can manage your information through the Services or ask us to make relevant amendments. We may require you to perform real-name authentication when accessing or managing your data.

You can also publish, share, cancel, change the scope of your consent, and handle sensitive information as described in this Policy.

We may make exceptions to your requests in accordance with applicable laws and regulations.

6.Services Provided by Third Parties

The Service may link to social media or other services provided by third parties. You agree that third parties may directly collect and process your information if you use such services. We will evaluate the legality and necessity of such third parties to collect information and require them to take protective measures for your information.

7.Age Limits

The LokShorts service is provided to adults only. Minors may not create their own user accounts and/or use our service. We will protect the information of minors in accordance with applicable laws and regulations.

8.Announcements and Amendments

We may modify the terms of this Policy at our discretion. Major changes will be notified prominently, and your continued use of the Service implies agreement with the revised Policy.

9.How to Contact Us

If you have any questions or concerns about this Policy or LokShorts's privacy practices, please contact us by email at lokshorts-support@imyfone.com. You also have the right to lodge a complaint with the competent data protection authority if you have any questions or concerns about LokShorts's processing of your personal data.