Venus Play Technology Limited.
PRIVACY STATEMENT

Last Updated:, 2024 April 12nd

This privacy statement explains our collection, use, and disclosure of personal data. This privacy statement applies to Venus Play Technology Limited. and to our controlled affiliates and subsidiaries (“Venus”). References to our “services” in this statement include our websites, apps, devices, and other products and services. This statement applies to our services that display or reference this statement, but it does not apply to any services that display or reference a different privacy statement.

PERSONAL DATA WE COLLECT

The personal data we collect depends on how you interact with us, the services you use, and the choices you make.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

Information you provide directly. We collect personal data you provide to us. For example:

• Name and contact information. We collect name, username or alias, and contact details such as email address, postal address, and phone number.
• Demographic data. In some cases, such as when you register or participate in surveys, we request that you provide age, gender, and similar demographic details.
• Content and files. We collect the photos, documents, or other files, including voice messages, you upload to our services; and if you send us email messages or other communications, we collect and retain those communications.
• Payment and purchase information. If you make a purchase or other financial transaction, we collect credit card numbers, financial account information, other payment details, and information about the purchases you make within our app and confirmation that payment for those purchases has been made.

Information we collect automatically. When you use our services, we collect some information automatically. For example:

• Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
• Geolocation data. Depending on your device and app settings, we collect precise geolocation data when you use our apps or online services.
• Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.

Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.

Information we obtain from third-party sources. We also obtain any of the categories of information described above from third parties. These third-party sources include, for example:

• Third party partners. Third party applications and services, including social networks you choose to connect with or interact with through our services. We may obtain contact information, identifiers, and photos or files from such third parties. For example, if you link a social media account to the app, we may obtain the name on your profile and profile images.
• Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
• Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
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When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

COOKIES, MOBILE IDs AND SIMILAR TECHNOLOGIES

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

What are cookies and similar technologies?

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables us and our third-party analytics and advertising partners to access these mobile IDs.

How do we and our partners use cookies and similar technologies?

We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use our services, including personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.

Examples of third-party analytics and advertising providers we use on our websites and in our services include, but may not be limited to the following:

To learn about their privacy practices and how to opt-out from their use of cookie data for targeted advertising purposes, click on the links above. You may also use the advertising and cookie controls described below.

What controls are available?

• Advertising controls. Our advertising partners may participate in associations that provide simple ways to opt out of ad targeting, which you can access at:
  • United States: NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/)
  • Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/)
  • Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/)

These choices are specific to the browser you are using. If you access our services from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.

• Browser cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
• Email web beacons. Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
• Do Not Track. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.

OUR USE OF PERSONAL DATA

We use the personal data we collect for purposes described in this privacy statement or otherwise disclosed to you. For example, we use personal data for the following purposes:

We combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.

OUR SHARING OF PERSONAL DATA

We share personal data with your consent or as necessary to complete your transactions or provide the services you have requested or authorized. In addition, we share each of the categories of personal data described above, with the types of third parties described below, for the following business purposes:

• Public information. Some information you provide on our services are publicly displayed, such as your name and/or username. You may select to make certain other information publicly available as well, such as your profile, demographic data, content and files, or geolocation data.
• Service providers. We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions.
• Affiliates. We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our services and operate our business.
• Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
• Legal and law enforcement. We will access, disclose, and preserve personal data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:
  • protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
  • operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
  • protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies also collect personal data through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the Cookies section of this statement. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

Please note that some of our services include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

Finally, we may share de-identified information in accordance with applicable law.

CHOICE AND CONTROL OF PERSONAL DATA

Access, correction, and deletion. If you wish to access, correct, or delete personal data about you that we hold, you may access your account by logging into the Venus services you use.

If you are unable to access certain personal data we have via the means described above, you can request access by contacting us as described at the bottom of this privacy statement. However, to the extent permitted by applicable law, we reserve the right to decline requests that are unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, where deleting data would interfere with a legal or business obligation that requires retention of the data, or where we are unable to authenticate you as the person to whom the data relates.

Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the Contact Us section below. If you receive a sales call from us, you can ask to be placed on our do-not-call list. These choices do not apply to certain informational communications including surveys and mandatory service communications.

Choices for Cookies and Similar Technologies. See the Cookies section for choices about cookies and other analytics and advertising controls.

EUROPEAN DATA PROTECTION RIGHTS

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

•                     You can request access to, and rectification or erasure of, personal data;

•                     If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

•                     If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;

•                     You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and

•                     For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests or contact our Data Protection Officer, please use the contact information at the bottom of this statement. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.

Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by contacting us at AOS_support@elex-tech.com

Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, email us at AOS_support@elex-tech.com

or mail a request to 97 E. Brokaw Road, Suite 310, Room M, San Jose, CA 95112.

Right to Opt-Out. You have a right to opt-out from future “sales” and “sharing” of personal information.

Note that the CCPA defines “sell,” “sharing,” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” or “sharing” under those definitions. In the past 12 months, we have sold the following categories of personal information: Name and Contact Information, Content and Files, Demographic Data, Identifiers and Device Information, Usage Data, Geolocation Data, and Inferences. To opt-out from “sales” of personal information, please visit our “Do Not Sell or Share My Personal Information” page.

We do not knowingly sell the personal information of minors under 16 years of age.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.

Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.

Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.

California Customers may request further information about our compliance with this law by e-mailing AOS_support@elex-tech.com. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated e-mail address.

California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed to AOS_support@elex-tech.com. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

RETENTION OF PERSONAL DATA

We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we delete a user’s personal data two years after their account becomes inactive.

LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use IBM data centers in the United States and Aliyun data centers in China. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this statement is processed and protected according to the provisions of this statement and applicable law wherever the data is located.

Location of Processing European Personal Data. We transfer personal data from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

SECURITY OF PERSONAL DATA

We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction.

To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

CHANGES TO THIS PRIVACY STATEMENT

We will update this privacy statement when necessary to reflect changes in our services, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.

HOW TO CONTACT US

If you have a privacy concern, complaint, or a question for Venus or our data protection officer, please contact us at AOS_support@elex-tech.com.

Our address is 97 E. Brokaw Road, Suite 310, Room M, San Jose, CA 95112.

Our data protection representative for the European Economic Area and Switzerland is Adaptant Solutions AG

Rosenheimer Str. 139

81671 Munich

German

compliance-elex@adaptant.io

The nominated Representative for data protection matters in the United Kingdom is:

Adaptant Services Ltd

Kemp House, 160 City Road

London EC1V 2NX

United Kingdom

compliance-elex@adaptant.io

Inquiries may also be submitted through Adaptant’s contact form at https://www.adaptant.io/contacts-locations/.