Ⅰ. How we collect and handle your information, and what information we collect from you
1. When you use our products, there are two situations in which we may need to collect and use your personal information:
a. To provide you with the basic functionalities of our products, we may require your authorization to collect and use necessary information. If you refuse to provide the relevant information, you will not be able to access or use our products properly.
b. To provide you with additional functionalities of our products, you may choose to either consent or decline to provide certain information to us. The types and scope of personal information collected and used for basic functionalities and additional functionalities may vary. If you refuse to provide such information, you will not be able to use the corresponding additional functionalities or achieve the intended effects of those functionalities. However, it will not affect your normal use of our basic functionalities.
2. The Specific Scenarios for Collecting and Using Your Information：
a. Using Our iCareFone Transfer LINE App
When you use our products/services, based on the different types of products, we may request different permissions and collect various data. Generally, when you use our products, we will collect your basic information and device information. We may use this information to match corresponding functionalities, make changes to the appearance of the product, modify functionalities, or develop new features based on the analysis of this data.
- Basic Information: We collect information about your activities on our products, such as login dates and times, frequently used functions, content frequently clicked on, pages visited and the duration of visits, operational activities, registration information, and more.
- Device Information: We collect information about your device, including device model and configuration, 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 related to your previous use of product functionalities may not immediately stop, resulting in temporary background information collection.
We process Product Usage Data and Product Installation Data so that we can facilitate, evaluate, and verify your use of our products and services. We will also use the Product Usage Data for our own internal statistical and analytical purposes, and to evaluate and enhance users' experience of the Products by identifying customer preferences and analyzing crash data. If you want to cancel the aforementioned purpose, you can contact us for relevant inquiries or actions through our customer service or the form available on our website.
b. Creating Your Account
When you visit or use our products, you may have the option to create an account or choose to log in and register through third-party accounts (such as Google account, Apple account, Facebook account, WeChat account) to access the full range of product features. When creating an account, you may provide the following partial or complete information: for example, username, email, phone number, social media accounts, country or region, and other details. When registering through third-party accounts or sharing via third-party accounts, you may provide the following partial or complete information: publicly available personal information from the third-party account (such as nickname, profile picture), username, email address, etc. These details are used for account creation and user self-presentation. Moreover, if you encounter account-related issues, such as account retrieval, this information will facilitate a more convenient account recovery process.
c. Customer Service and Dispute Handling
When you contact us or submit inquiries related to pre-sale, after-sale, or dispute resolution, in order to safeguard the security of your account and the system, we may require necessary personal information from you to verify your identity. For the purpose of contacting you, promptly assisting you with problem resolution, or documenting the handling process and outcomes, we may retain records of our communication, correspondence, or call logs, along with relevant content (including account information, address, email, other contact information, and any other information you provide to substantiate relevant facts). To provide customer service and improve the quality of our support, we may also utilize other information you provide, including relevant details shared during customer service interactions or responses to questionnaires sent by you during surveys.
d. Transaction and Payment
When you make transactions and payments for our products through our website or within the product, we will collect the billing information you provide, including your name, 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 related URLs (such as purchase confirmation page URL, subscription cancellation URL, invoice PDF URL).
We will use transaction and payment information to complete billing, renewal, and subsequent refund services for your orders, and such information will be used for internal financial record-keeping.
We do not collect or process data related to your payment instruments, such as credit card numbers, bank account numbers, or PayPal accounts. Such information is collected, processed, and stored by qualified payment processors.
e. Use of Product Features
We may require android.permission.MANAGE_EXTERNAL_STORAGE permission (all file access) for your device. We obtain this permission to read and write data to the SD card, allowing users to read line attachments from the SD card and back them up to the specified directory. We may also need android.permission.READ_EXTERNAL_STORAGE (storage access) and android.permission.WRITE_EXTERNAL_STORAGE permissions for your device to read and write application data on the SD card. This allows users to read line data, parse it, and perform end-to-end transmission.
f. Other Content
You may provide reviews for our products in the software store's comment section or other public platforms. We will use this review information to improve our products, and we may use your published reviews (with your relevant information) for marketing purposes. This enables us to provide information about our products to consumers and potential consumers, allowing others to better understand and use our products.
While using our products, 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 these purposes, you can contact us through our customer service or the form available 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 told us you were interested in receiving . If you want to cancel the aforementioned purpose, you can contact us for relevant inquiries or actions through our customer service or the form available on our website.
In the process of using our products, you may provide us with your information through data collection forms or other means. We will lawfully and compliantly use the relevant information according to the agreed terms and will not use it for other purposes.
3. We obtain the aforementioned permissions and information from you to provide specific services. If you refuse to grant the corresponding permissions or disagree with the collection of such information, you will be unable to use the corresponding features but it will not affect your normal use of our other services.
Ⅱ. How we store, protect and transfer your information
Unless required or allowed by applicable laws to retain data for a longer period, we will determine different retention periods based on the types of information, the purposes for which we use the information, and the duration necessary to achieve the purposes described in this policy. For instance, when processing your information to provide services, we will retain your account information, billing details, etc., for as long as you have an account.
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. However, please be aware that the systems and communication networks you use while using our products may have security issues beyond our control. We strive to enhance security measures, but due to technological limitations and rapid developments in the internet industry, as well as potential malicious attacks, we cannot guarantee 100% security of information.
Given that our business operates globally, we may transfer the data we collect about you to secure servers or data centers located in countries/regions outside of the country where the data was initially collected (including the United States, European Economic Area ("EEA"), or Japan) to continue providing our services worldwide. When we transfer your data to countries/regions outside of the country where the data was initially collected, we will protect the data according to the instructions in this Privacy Policy and comply with applicable legal requirements to ensure adequate protection of the data.
Ⅲ. How we share, transfer and disclose your personal information
To ensure the realization and secure stable operation of our product's relevant functionalities, and due to some products being developed in collaboration with third-party partners, we may share or entrust certain personal information with these partners to ensure the smooth completion of our products. In order to provide you with services, we will share your personal information with affiliated companies supporting our functionalities and third parties integrated into or accessed by us to provide services. Such third parties may provide support in payment processing, data analysis, and data storage. Our affiliated companies supporting our functionalities have no right to use your personal information for purposes unrelated to those stated in this Privacy Policy. If they need to change the purpose of processing personal information, they will seek your separate authorization and consent.
We will share your data with our affiliated companies. In the event of a merger, division, acquisition, or bankruptcy liquidation, your data may be transferred as part of such transactions. 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 holder of your personal information to continue to be bound by this Privacy Policy. Otherwise, we will request the recipient to seek your authorization and consent anew.
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 from you for the following reasons: in response to subpoenas, court orders, legal proceedings, law enforcement requests, legal claims, or government investigations, to protect and defend the platform, our affiliated companies, users, or the public's rights, interests, and safety.
Ⅳ. How you shall manage your personal information
You have the right to access, rectify, and delete the information we collect about you. If you are unable to do so or have any questions about the personal information we collect and/or share about you, or if you wish to withdraw your consent for our processing (i.e., complete deletion of your account), please contact us through the following email: [email protected].
We will take action on users' requests and provide information free of charge, unless such requests are manifestly unfounded or excessive (especially if they are repetitive). In such cases, we may charge a reasonable fee (considering the administrative costs of providing the information or communication or taking the action requested) or refuse to comply with the request.
Ⅴ. How do we handle the personal information of minors
If you are a minor, you should use our services with the prior consent of your parents or legal guardians (collectively referred to as "guardians"). We recommend that the guardians of minors carefully read this policy, and we also suggest that minors obtain the consent and guidance of their guardians before submitting personal information during the use of our services. If you are the legal guardian of a minor, please ensure that the minor under your guardianship is using our products or services after obtaining your authorized consent. If you have any questions about the personal information of the minors under your guardianship, please contact us through the methods specified in this Privacy Policy.
Our products 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 become aware that we have collected personal information from a child under the age of 13, we will take reasonable steps to promptly delete such information from our records, unless we have a legal obligation to retain it. If you believe that we have any information from or about children under the age of 13, please contact us: [email protected].
Ⅵ. Permission 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 their 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 the 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 you.
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 and from the sources described in the section entitled “How we collect and handle your information, 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 their 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
TWe may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new 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 about any changes. If you do not agree with the changes that have taken effect, you should stop accessing or using our products from the date the changes become effective, and the changes will not apply to you. If you continue to access or use our products after the changes have become effective, it will be deemed that you agree to the changes that have taken effect.
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Ⅷ. How to contact us
If you have any questions, inquiries, opinions, suggestions, or complaints regarding this Privacy Policy or personal information protection, you can contact us through the online customer service.
Additionally, you can reach us through the following ways:
- Send an email to customer service at: [email protected]
- Submit an online form at: https://support.tenorshare.com/#/
