Update Software Privacy Policy
Last Updated: July 01, 2023
Welcome to Milena Ariadne (the
“Platform”). The Platform is provided or controlled by Milena Ariadne, a
corporation registered in Singapore (“Bytedance”, “we” or “us”). We are
committed to protecting and respecting your privacy.
This policy
sets out the basis on which any personal data we collect from you, or
that you provide to us, will be processed by us. Please read the
following carefully to understand our views and practices regarding your
personal data and how we will treat it. By accessing or using our
website, services, applications, products and content (that include but
are not limited to the Platform) (collectively, the “Services”), you are
accepting and consenting to the practices described in this policy.
The Types of Personal Data We Use
We may collect and use the following information about you:
Information
you give us.You may give us information about you by accessing or using
our Services or by corresponding with us by phone, e-mail or otherwise.
This includes information you provide when you register for and/or use
the Platform, such as your customer profile, information about your
device, your browsing records, the comments you make on our Platform
(including any Virtual Items (as defined in the Terms of Service) you
contribute to any user-generated content), as well as account and
billing details, including but not limited to, your Apple, Google or
Windows account, PayPal or other third-party payment channel account
where required for the purpose of paying or withdrawing cash. The
information you give us may include your name, State ID number, address,
email address, social media login details, telephone number, credit or
debit card information. It also includes information that you give to
us, such as user-generated content and video content that you may choose
to broadcast on our Platform.
Information you choose to share from
your social networks.If you choose to link the Platform to your social
network or public forum account (such as Facebook or WeChat), you may
provide us or allow your social network to provide us with information
from your social network or public forum accounts. This data may include
your use of the Platform on such public forums and/or social networks.
For further information as to how and for what purpose the social
network provider processes your data, please see their privacy policies.
Technical
Information we collect about you.We automatically collect certain data
from you, including IP address or other unique device identifiers such
as Android advertising ID, Cookies (as defined below), mobile carrier,
time zone and locale setting, operating system and platform and
information regarding your use of the Platform. We may also collect
information about linking your contact or subscriber information with
your activity across our Platform or by linking your activity on our
Platform across all your devices using your email or social media log-in
details.
Behavioral information we collect about you.We also collect
information regarding your use of the Services, e.g. your comments on
our Platform or any other user-generated content and video content that
you generate through and broadcast on our Platform. In addition, we link
your contact or subscriber information with your activity on our
Platform across all your devices using your email or social media log-in
details. We collect engagement scores (“likes”, comments, repeated
views) and relate users based on your behavior. Finally, we collect
opt-ins and communication preferences.
Location data.When you use the
Platform on a mobile device, we may process information about your
location, including location information based on your SIM card, IP
address or mobile device location settings, and if activated on your
mobile device, by use of a Global Positioning System (GPS). We may use
such information to provide you with location-based services, such as
advertising and other personalized content. If you do not wish to share
your GPS location with us, you can switch off GPS functionality on your
mobile device.
We collect and process information you provide,
including any personal information, in the context of composing,
sending, or receiving messages (that means the content as well as
information about when the message has been sent, received and/or read
and the participants of the communication) through our Service's
messaging functionality.
When you upload a video to the Platform
(“User Content”), you automatically upload certain metadata that is
connected to the User Content. In essence, metadata describes other data
and provides information about your User Content that will not always
be evident to the viewer. In connection with your video the metadata can
describe how, when and by whom the piece of User Content was collected
and how that content is formatted. It further includes information such
as your account name that enables other users to trace back the video to
your user account. Metadata will further consist of additional data
that you chose to provide with the video, e.g. any hashtags used to mark
keywords to the video or comments.
Information from third parties.We
may receive information if you use any of the other websites we operate
or other Services we provide. We may also receive information from
third parties (such as advertising networks and analytics providers) and
from other sources, including business directories and other
commercially or publicly available sources.
Cookies
We use
cookies and other similar technologies (e.g. web beacons, Flash cookies,
etc.) (“Cookies”) to enhance your experience using the Platform.
Cookies are small files which, when placed on your device, enable us to
provide certain features and functionality.
We use the following Cookies:
Strictly
necessary Cookies.These are Cookies that are required for the operation
of the Platform. They include, for example, Cookies that enable you to
log into secure areas of the Platform.
Analytical/performance
Cookies.They allow us to recognise and count the number of visitors and
to see how visitors move around the Platform when they are using it.
This helps us to improve the way the Platform works, for example, by
ensuring that users are finding what they are looking for easily.
Functionality
Cookies.These are used to recognise you when you return to the
Platform. This enables us to personalise our content for you, greet you
by name and remember your preferences (for example, your choice of
language or region).
Targeting Cookies.These Cookies record your
visit to the Platform, the pages you have visited and the links you have
followed. We will use this information to make the Platform and the
advertising displayed on it more relevant to your interests. We may also
share this information with third parties for this purpose.
If for
any reason you wish to not take advantage of Cookies, you may disable
Cookies by changing the settings on your browser. However, if you do so,
this will affect your enjoyment of the Platform and we will no longer
be able to offer to you personalised content. Unless you opt out of
Cookies, we will assume you consent to the use of Cookies.
"Do
not track" signals are preferences that users can set on their web
browser to limit how their activity is tracked across third-party
websites or online services. The Platform does not respond to "do not
track" signals in your web browser.
Analytics information
On
our Platform, we use third-party analytics tools to help us measure
traffic and usage trends for the Services. Traffic refers to the
different data flows surrounding activities of the users on the
Services. These tools, for example, collect information sent by your
device or our Services, including the pages you visit, add-ons, and
other information that assists us in improving the Service. The
information will be used to report and evaluate your activities and
patterns as a user of the Platform to provide services in accordance
with these activities.
Our third-party analytics tools include
Google Analytics provided by Google, Inc (1600 Amphitheatre Parkway
Mountain View, CA 94043, USA). Google Analytics uses Cookies, small text
files containing a string of alphanumeric characters and which are
stored on your computer. Google will use this information including your
truncated IP address to assemble statistics on the use of our Service
or to provide other related services as described above. For further
information on how Google Analytics collects and processes information
about you and information on how to opt out from Google's collection of
information from you, please click here. You can also find further
information in the Google Analytics Terms of Service & Privacy.
We
also use "Facebook Pixel" of Facebook Inc., 1 Hacker Way, Menlo Park,
CA 94025, USA ("Facebook"). This tool is used for advertising purposes
in order to reveal if you have seen our advertisement on Facebook. If
you do not want Facebook to collect the described information about you,
you can opt-out of Facebook's use of cookies and Facebook Pixels here.
How We Use Your Personal Data
We will use the information we collect about you in the following ways:
to
administer the Platform (i.e. to provide our Services to you) and for
internal operations, including troubleshooting, data analysis, testing,
research, statistical and survey purposes (i.e. to guarantee the
Platform’s stability and security) and to solicit your feedback;
to allow you to participate in interactive features of the Platform, when you choose to do so;
to personalize the content you receive and provide you with tailored content that will be of interest to you;
to improve and develop our Platform and conduct product development;
to measure and understand the effectiveness of the advertising we serve to you and others;
to
provide you with services based on the country settings you have
chosen, such as advertising and other content that is related to the
country settings;
to make suggestions and recommendations to you and
other users of the Platform about goods or services that will interest
you or them;
to allow other users to identify you via the "Find other
friends" function as a user of the Service, to allow you to find other
users and to connect with them on the Platform, and to support the
socializing function of the Services;
to provide you with your
profile information to send to anyone you choose and to enable you to
participate on the Platform and interact with other users;
to make
your information available to other users in accordance with the privacy
settings you chose for the respective information;
to show you
content that is similar to content you liked or interacted with (by
commenting and/or watching the content), content from your region as
well as content from users you follow;
to show you advertisements that are relevant to you;
to
promote the Services and use information that you give to us, such as
User Content and video content that you can choose to broadcast on our
Platform, as part of our advertising and marketing campaigns to promote
the Platform;
to enable our messenger service to function;
to help us detect abuse, fraud, and illegal activity on the Platform;
to notify you about changes to our Services;
to communicate with you.
to provide you with user support;
to enforce our terms, conditions and policies;
to
receive payments from you and/or make payments to you in accordance
with the Diamond and Flame provisions set out in the Terms of Service.
It
is in our legitimate interests to promote the Platform, and we may use
information that you give to us, such as user-generated content and
video content that you may choose to broadcast on our Platform, as part
of our advertising and marketing campaigns to promote the Platform.
How We Share Your Personal Data
We may share your personal data with selected third parties in or outside your country, including:
our business partners so that we can make you special offers via the Platform;
with
respect to on-screen ads, advertisers and advertising networks that
require the data to select and serve advertisements to you and others.
We will not share your contact details with our business parties so they
will not contact you directly, but we will share other information so
that they can make you offers tailored to your requirements;
cloud
storage providers to store the information you provide and for disaster
recovery services, as well as for the performance of any contract we
entered into with you;
analytics and search engine providers that assist us in the improvement and optimisation of the Platform.
IT service providers;
Our data center and the servers of our host providers.
We
may share your information with any member or affiliate of our group,
which includes our subsidiaries, our ultimate holding company and its
subsidiaries, and companies that we control, are controlled or under
common control, and our service providers and strategic business
partners, and their respective subsidiaries, in each case in or outside
your country, for the purposes set out above (“How We Use Your Personal
Data”).
We may share your information with law enforcement
agencies, public or tax authorities or other organisations if legally
required to do so, or if we have a good faith belief that such use is
reasonably necessary to:
comply with a legal obligation, process or request (including tax and related reporting requirements);
enforce
our Terms of Service and other agreements, policies, and standards,
including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect
the rights, property or safety of us, our users, a third party or the
public as required or permitted by law (including exchanging information
with other companies and organisations for the purposes of fraud
protection and credit risk reduction).
We may also disclose your information to third parties:
in
the event that we sell or buy any business or assets, in which case we
may disclose your data to the prospective seller or buyer of such
business or assets; or
if we sell, buy, merge or partner with other
companies or businesses, or sell some or all of our assets. In such
transactions, user information may be among the transferred assets.
The Security of Your Personal Data
We
take steps to ensure that your information is treated securely and in
accordance with this policy. Unfortunately, the transmission of
information via the internet is not completely secure. Although we will
do our best to protect your information, for example, by encryption, we
cannot guarantee the security of your information transmitted through
the Platform; any transmission is at your own risk.
We have
appropriate technical and organizational measures to ensure a level of
security appropriate to the risk of varying likelihood and severity for
the rights and freedoms of you and other users. We maintain these
technical and organizational measures and will amend them from time to
time to improve the overall security of our systems.
We will,
from time to time, include links to and from the websites of our partner
networks, advertisers and affiliates. If you follow a link to any of
these websites, please note that these websites have their own privacy
policies and that we do not accept any responsibility or liability for
these policies. Please check these policies before you submit any
information to these websites.
Data Retention
We use the following criteria to determine the period for which we will keep your information:
our contractual obligations and rights in relation to the information involved;
legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time;
statute of limitations under applicable law(s);
our legitimate business purposes; and
disputes or potential disputes.
After
you have terminated your use of our Services, we can store your
information in an aggregated and anonymized format. Notwithstanding the
foregoing, we can also retain any personal information as reasonably
necessary to comply with our legal obligations, allow us to resolve and
litigate disputes, and to enforce our agreements.
Information Relating to Children
The
Platform is not directed at children under the age of 16. Users under
the age of 16 are not allowed to use the Platform or register an account
on the Platform. If we become aware that personal data has been
collected from a person under the age of 16, we will delete this
information and terminate the person’s account. If you believe that we
may have personal data about or collected from a child under the age of
16, please contact us at milenaariadne83@gmail.com.
Complaints
In
the event that you wish to make a complaint about how we process your
personal data, please contact us in the first instance at
milenaariadne83@gmail.com and we will endeavor to deal with your request
as soon as possible. This is without prejudice to your right to launch a
claim with your data protection authority or follow the dispute
resolution process provided in the Terms of Service.
Changes
We
will generally notify all users of any material changes to this Policy
through a notice on our Platform, however, you should look at this
Policy regularly to check for such changes. Your continued access to or
use of the Services after the date of the updated Policy constitutes
your acceptance of the updated Policy. If you do not agree to the
updated Policy, you must stop accessing or using the Services.
Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to:
Milena Ariadne
Address:
mail Address: milenaariadne83@gmail.com
Supplemental Terms - Jurisdiction-Specific
India.
If you are using our Services in India, the following additional terms
apply. In the event of any conflict between the following additional
terms and the provisions of the main body of this Privacy Policy, the
following terms shall prevail.
The security of your personal
data.The personal data shared by you for the purposes of the Services
would be safeguarded in accordance with the policies and systems adopted
by us.
Data retention.We will not retain sensitive personal data or
information for longer than is required for the purposes for which such
information may be lawfully used or is otherwise required under any law
for the time being in force.
Information relating to children.The
Platform is not directed at persons under the age of 18. Users under the
age of 18 are not allowed to use the Platform or register an account on
the Platform. If we become aware that personal data has been collected
from a person under the age of 18, we will delete this information and
terminate the person’s account. If you believe that we may have personal
data about or collected from a person under the age of 18, please
contact us at milenaariadne83@gmail.com.
Your rights
Data
rights.You have the right to access and review personal data we hold
about you, to rectify any personal data held about you that is
inaccurate, to request the deletion of personal data held about you, and
the right to request the suspension of the processing of your personal
data. You can exercise your rights by contacting us at
milenaariadne83@gmail.com.
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