iCareFone Transfer App Privacy Policy

Last updated: July 14, 2023

This product is provided by TENORSHARE (HONGKONG) LIMITED (hereinafter referred to as "Tenorshare," "we," or "the Company"). The registered address of the Company is RM B3, 19/F TUNG LEE COMM BLDG 91-97 JERVOIS ST SHEUNG WAN HONG KONG. The contact information for our data protection officer is [email protected]. We attach great importance to protecting the privacy of users (referred to as "you" hereinafter) and are committed to respecting and protecting the personal information we collect. The data controller is TENORSHARE (HONGKONG) LIMITED and its affiliated companies (including but not limited to HITPAW CO., LIMITED, AFIRSTSOFT CO., Ltd).

Tenorshare has appointed an EU representative in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of Personal Data (the “GDPR”). You can contact the designated EU representative of Tenorshare by reaching [email protected]. This Privacy Policy explains how we collect, use, store, share, and otherwise process your personal information when you use our products. This Privacy Policy will help you understand the following:

Ⅰ. How we collect your information, how we use it, and what information we collect from you

Ⅱ. How we store, protect, and transmit your personal information

Ⅲ. How we share, transfer, and disclose your personal information

Ⅳ. How you shall manage your personal information

Ⅴ. How do we handle the personal information of minors

Ⅵ. Permissions of users in different regions for their personal information

Ⅶ. How the Policy will be updated

Ⅷ. How to contact us

Ⅰ. How we collect and handle your information, and what information we collect from you

1. The personal information we may need to collect and use about you regarding your use of our product includes the following two circumstances:

a. In order to provide you with the basic features of our product, we may need your permission to collect and use the necessary information. In the event that you refuse to provide the corresponding information, you will not be able to have proper access to or use our product.

b. In order to provide you with additional features of our product, you may have the option of accepting or refusing to provide us with certain information about yourself, and the type and scope of personal information collected for the basic features and additional features may differ. If you refuse to provide us with such information, you will not be able to use the additional features or reach the desired results, but this will not prevent you from using the basic features.

2. The specific scenarios in which we collect and use your information for functional purposes:

a. Using our products

When you use our products/services, depending on the different types of products, we may request different permissions and collect different data. In general, if you use our products, we will collect your basic information and device information. We may use this collected information to match corresponding features, modify the appearance or functionality of the product, or develop new features based on the analysis of this data.

• Basic Information: We will collect information about your activities on our product, such as login dates and times, frequently used features, frequently clicked content, pages visited and duration of stay, operational activities, registration information, etc.
• Device Information: We collect information about your device, including device model and configuration information, operating system, and version.

Please understand that when you switch the software product to run in the background, due to device models and system reasons, the information collection activities related to the product features you previously used may not stop immediately, resulting in brief background information collection activities.

b. Creating your account

When you access or use our products, you may have the option to create an account or choose to log in/register through a third-party account (such as a Google account, Apple account, Facebook account, or WeChat account) to fully utilize all the features of the product. When creating a new account, you may need to provide all or some of the following information: your username, E-mail address, phone number, social media accounts, country/region, etc. When registering or sharing through a third-party account, you may provide us with the following partial or complete information: publicly available personal information from the third-party account (nickname, profile picture, etc.), username, email address, etc. This information is used for account creation and user self-presentation. Additionally, in the event of account loss or other account-related issues, this information will assist you in conveniently recovering your account.

c. Customer service and dispute handling

When you contact us or submit requests regarding sales, after-sales, or dispute resolution, in order to ensure the security of your account and the system, we may require you to provide the necessary personal information to verify your identity. To facilitate communication with you, assist in resolving your issues promptly, and document the handling process and outcomes, we may retain records of our communication, correspondence, and related content with you (including account information, address, email, other contact details, and any additional information you provide to substantiate relevant facts). Additionally, in order to provide customer service and improve its quality, we may utilize other information provided by you, including relevant information you provide during customer service interactions and questionnaire responses you submit to us during surveys.

d. Transactions and payments

When you make purchases of our products through our website or within the product, we collect the billing information you provide, including your name and email address, country/region, postal code, the first six and last four digits of your credit card, credit card expiration date, billing address, the type of product you purchased, the amount paid in your currency, subscription ID, and URLs related to the subscription (such as purchase confirmation page URL, subscription cancellation URL, invoice PDF URL).

We will use the transaction and payment information to complete billing, renewal, and subsequent refund services for your orders, and the relevant information will be used for our internal financial records.

We do not collect or process data regarding your payment instruments, such as credit card numbers, bank account numbers, or PayPal accounts. These pieces of information are collected, processed, and stored by qualified payment processors.

e. Use of product features

We may require access to your device's android.permission.WRITE_EXTERNAL_STORAGE and android.permission.READ_EXTERNAL_STORAGE (storage access) permissions. We obtain this permission to read and write application data on the SD card, allowing users to access WhatsApp data, parse it, and perform end-to-end transmission. We may also need access to your device's android.permission.ACCESS_COARSE_LOCATION (coarse location access) and android.permission.ACCESS_FINE_LOCATION for obtaining device location information, enabling users to send location information and establish device connections.

f. Other content

You may provide reviews of our products in the software store's comment section or other public platforms. We will use the review information to improve our products, and we may use your posted reviews (along with your relevant information) for marketing purposes to provide information about our products to consumers and potential customers, enabling others to better understand and use our products.

During your use of the product, we may display advertisements for Tenorshare products and services that we believe may be of interest to you. If you wish to opt out of such purposes, you can contact us through customer service or the form on our website for relevant actions.

From time to time, we may contact our customers directly by mail, email, or telephone to inform you about upgrades, new products, promotions, or special offers that you have expressed interest in receiving. If you want to cancel the aforementioned purpose, you can contact us through customer service or the form on our website for relevant actions.

During your use of our products, you may provide us with your information through data collection forms or other means. We will legally and compliantly use the provided information in accordance with the agreed terms and will not use it for other purposes.

We obtain the aforementioned permissions and information from you in order to provide specific services. If you refuse to grant the corresponding permissions or disagree with us collecting such information, you will be unable to use the corresponding functionalities but can still use our other services without any impact.

Ⅱ. How we store, protect, and transmit your personal information

Unless otherwise required or permitted by applicable laws for longer retention periods, we will determine different retention periods for different types of information based on the nature of the information, the purposes for which we use the information, and the duration necessary to achieve the purposes described in this policy. For example, when processing your information to provide you with services, we will retain your account information, billing information, and similar content for as long as you have an account with us.

We employ reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. Please use complex passwords to assist us in ensuring the security of your account and personal information. Please be aware that the systems and communication networks you use when accessing our products may be subject to security vulnerabilities beyond our control. Understand that in the internet industry, due to technological limitations, rapid advancements, and potential malicious attacks, despite our best efforts to strengthen security measures, it is not possible to guarantee 100% security of information at all times.

Given the global nature of our business operations, we may transfer the data we collect about you to secure servers or data centers located in countries/regions outside the country where the data was initially collected (including the United States, the European Economic Area ("EEA"), or Japan) for storage and/or processing, in order to continue providing our services globally. When transferring your data to countries/regions outside the country where the data was initially collected, we will protect the data in accordance with the instructions in this privacy policy and comply with applicable legal requirements to provide adequate protection for such data.

Ⅲ. How we share, transfer, and disclose your personal information

In order to ensure the implementation of our product-related features and the safe and stable performance of our apps, and because some features of our products cannot be executed by us alone, we may share or entrust some of your personal information with third parties such as our partners in order to ensure the smooth implementation of our product features. You agree that we may share your personal information with affiliates that support our features, and with third parties that we integrate or access, for the purpose of providing the services to you. The support provided by these third parties includes providing us with payment processing, data analysis, and data storage. Our affiliates of our features are not authorized to use your personal information for purposes other than those set forth in this Privacy Policy and the purposes set forth herein. They shall obtain your authorized consent separately if they wish to change the purposes for which personal information is processed.

We may share your data with our affiliated companies, and in the event of a merger, division, acquisition, or bankruptcy liquidation, your data may be transferred as part of such transaction. We will ensure the confidentiality of such information during the transfer, inform you of the name and contact information of the recipient, and require the new entity holding your personal information to continue abiding by this personal information protection policy. Otherwise, we will request the recipient to seek your authorization and consent again. If we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.

We may disclose all the information we collect about you for subsequent reasons: in response to subpoenas, court orders, legal proceedings, law enforcement requests, legal claims, or government investigations, to protect and defend the rights, interests, and safety of the platform, our affiliated companies, users, or the public.

Ⅳ. How you shall manage your personal information

You have the right to access, correct, and delete the information we collect about you. If you are unable to do so, or have any questions about Personal Information we have collected and/or shared about you, or would like to withdraw your consent for our processing (i.e. entirely delete your account) please contact us at: [email protected].

We will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.

Ⅴ. How do we handle the personal information of minors

If you are a minor, you shall use our services with obtaining prior consent of your parent or legal guardian (collectively, "guardian"). We recommend that the guardians of minors shall read this Policy carefully, and we also recommend minors obtain guardians’ prior consent and guidance before submitting personal information in their use of our services. If you are the legal guardian of a minor, please ensure that the minor in your custody is using our products or services with your authorized consent. If you have questions about the personal information of a minor in your custody, please contact us through the means set forth in this Privacy Policy.

We are not directed to children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected the Personal Information of a child under the age of 13, we will take reasonable steps to delete such information from our files as soon as is practicable, unless we have a legal obligation to retain it. Please contact us if you believe we have any information from or about a child under the age of 13: [email protected].

Ⅵ. Permissions of users in different regions for their personal information

The GDPR，Law Concerning Protection of Personal Data of Japan, and other applicable data protection laws provide certain rights for data subjects. Broadly speaking you have, or may have, the right (as more fully provided in applicable data protection laws):

• The right to be informed: The User has the right to be provided with clear, transparent, and easily understandable information about how Tenorshare collects and uses personal data and its rights. This is the reason why Tenorshare is providing the User with the information in this privacy policy.
• The right of access: The User has the right to obtain access to its Personal Data (if Tenorshare is processing it), and other certain information (similar to that provided in this privacy policy).
• The right to rectification: The User is entitled to have its personal data corrected if it’s inaccurate or incomplete.
• The right to erasure: This ‘the right to be forgotten’ enables the User to request the deletion or removal of its personal data where there’s no compelling reason for Tenorshare to keep using it.
• The right to withdraw consent: The User has the right to withdraw a previously provided consent to processing of your personal information.
• The right to object to processing: The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its personal data .
• The right to restrict processing: Under certain circumstances, the User has the rights to ‘block’ or suppress further use of its personal data
• The right to data portability: to receive its Personal Data provided to Tenorshare in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller.
• The right to lodge a complaint: to complain about our processing of your personal information to a local supervisory authority.

It is important to be aware that these rights may not be absolute. For example, if you withdraw your consent to our processing of your personal information, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

In the event of a data leak, we will inform the regulatory authorities and users of the leaked information in a timely manner, If you have any questions about the matters covered by this policy, please contact our Data Protection Officer at [email protected].

Exercise the above rights, you can send an email to customer service email: [email protected], or fill out our request form here. 

Rights regarding personal information for California residents.

Pursuant to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents receive certain rights with respect to their personal information, as described below. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA.California residents have the right not to receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA.

California residents have the right to obtain access to their Personal Data (if Tenorshare is processing it), and other certain information (similar to that provided in this privacy policy).

California residents have the right to request that businesses stop selling or sharing their personal information (“opt-out”), including via a user-enabled global privacy control. Businesses cannot sell or share your personal information after they receive your opt-out request unless you later authorize them to do so again.

Each California resident has the right to request, subject to certain exceptions described in the CCPA, that we disclose to that resident: 

• The categories of personal information we have collected about them;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting or selling the personal information;
• The categories of third parties with whom we have shared personal information;
• The specific pieces of personal information we have collected about them (collectively, a “Request to Know”).

California residents have the right to restrict our use of Sensitive Personal Information collected about them.

In the past twelve months, we have collected, and in the future, we will continue to collect, the categories of personal information cited in the section entitled “The personal information we collect” above. This includes the following categories of personal information set out in the CCPA: identifiers, personal information described in Section 1798.80 of the California Civil Code, characteristics of protected classifications under California or federal law, Internet or other electronic network activity information, geolocation data, professional or employment-related information, and sensitive personal information. We collect and use this information from the sources described in the section entitled “How we collect your information, how we use it, and what information we collect from you” above, and share this information with third parties as described in the section entitled “How we share, transfer, and disclose your personal information” above.

We do not sell your personal information as defined under the CCPA or share your personal information for cross-contextual behavioral advertising purposes and we do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes other than those permitted purposes specifically identified in the CCPA and its implementing regulations.

Right to request deletion of personal information.

Each California resident has the right to request the deletion of the personal information that we collect or maintain (a “Request to Delete”), subject to certain exceptions set forth in the CCPA. 

Process for verifying requests of California residents.

Each California resident has the right to request the correction of any inaccurate personal information that we maintain (a “Request to Correct”), subject to certain exceptions set forth in the CCPA. 

To make the aforementioned Request, you can send an email to customer service email: [email protected], or fill out our request form here.  

Process for verifying requests of California residents.

In order to protect your privacy and security, prior to completing any Request to Know, Request to Delete, or Request to Correct that you may submit, we must verify your identity.  We will verify your identity by asking you to provide certain data that we have already collected from you to confirm that they match our records.  In certain instances, additional verification steps may be required.

Authorized agents.

California residents have the right to designate an authorized agent to make a request under the CCPA on their behalf.  Prior to completing a request made by such an authorized agent, we require that you provide your authorized agent with written permission to submit such a request and require that you or your authorized agent provide us with a copy of such written permission.  Additionally, we require that you verify your identity pursuant to the procedure described above.

Keeping personal information.

Your personal information will be retained in accordance with our Data Privacy Policy.

We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose. For example, information about individuals who have applied for employment with us will be retained for a shorter period than information about individuals who have actually worked for us.

The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period. We also consider the limitation periods for taking legal action and good practice in the legal industry.

If you have any questions on the matters covered in this policy, you can send an email to customer service email: [email protected].

Changes to our privacy policy.

We regularly review this Privacy Policy and may make changes as our services or privacy practices change, or as required by applicable laws or regulations.  Future versions of our Privacy Policy will be available on our website.  We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

Ⅶ. How the Policy will be updated

We may periodically update this Privacy Policy. When we make updates, we will notify you by updating the "Last Updated" date at the top of the revised Privacy Policy, posting the revised Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you use our products to stay informed of any changes. If you disagree with the updated terms and conditions, you should cease accessing or using our products as of the effective date of the changes. The updated terms and conditions will not apply to you if you stop accessing or using our products. If you continue to access or use our products after the effective date of the changes, it will be deemed as your acceptance of the updated terms and conditions.