Updated on October 26, 2023
Presentation Clause
FlowTick APP (hereinafter referred to as the "Product") and its service provider CUE DIGITAL INTERNATIONAL PTE. LTD.. (hereinafter referred to as "We" or "CUE") respect and protect the personal privacy of all users who use this product. In order to provide you with more accurate services and a more secure Internet environment. We have clarified the principles of our collection/use/provision of personal information. It further explains the rights relating to your personal information. This policy is closely related to your use of our products and/or services, and when you use our product and its related services (hereinafter collectively referred to as “our product and/or services"), we will process and protect your personal information in accordance with the provisions of this policy. We try to explain to you the technical terms involved in this policy in a concise manner for your understanding. In this policy, we have used bold font to distinguish the terms that have a significant relationship with your rights and interests, please refer to them. Please carefully read and fully understand this policy before using/continuing to use our products and services, and make appropriate choices in accordance with the rules of this policy when necessary. If you do not agree with contents of this policy, it may cause our products and/or services to not work properly, or cannot achieve the service effect we intend to achieve, you should immediately stop accessing/using our products and/or services. Your use or continued use of the product and/or services provided by us indicates that you fully understand and agree to the entire content of this Privacy Policy (including updated versions).
1. Definition
1.1 Personal Information
Information relating to identified or identifiable natural persons recorded electronically or otherwise does not include information that has been anonymized. Personal information covered in this policy includes:
1.1.1 Personal Information: including personal name, personal telephone number, e-mail address, etc.;
1.1.2 Network Identity Information: including system account, IP address, e-mail address and password, password protection answer, etc. related to the preceding;
1.1.3 Personal Property Information: including transaction records and other virtual property information;
1.1.4 Personal Common Device Information: Include device identifiers (IMEI, IDFA, Android) ID, MAC, OAID, IMSI and other device-related information), application information (application crash information, notification switch status, application installation list and other application-related information), device parameters and system information (device type, device model, operating system and hardware related information), etc.
1.1.5 Personal location Information: including whereabouts and track, precise positioning of individuals, etc.;
1.1.6 Other relevant information that meets the definition of personal information in this Paragraph.
1.2 Sensitive Personal Information
Once leaked or illegally used, it is easy to cause the personal dignity of natural persons to be infringed or the personal and property safety to be jeopardized. Sensitive personal information covered in this Policy includes:
1.2.1 Your property information (including virtual property information such as transaction records);
1.2.2 Network identification information (including account name, account nickname, e-mail address and password related to the foregoing);
1.2.3 Other information (including mobile phone number and rough location information).
1.3 Deletion of Personal Information
The act of removing personal information from systems involved in the performance of routine business functions so that it remains unsearchable or inaccessible.
1.4 Unique Device Identifier
A unique device identifier (sometimes referred to as a universal proprietary ID or UUID) is a string of characters encoded into a device by the device manufacturer that can be used to uniquely identify the corresponding device (e.g., International Mobile Device Identity number IMEI, network device hardware address MAC, advertising identifier IDFA, etc.). Different device identifiers vary in terms of their validity, whether users can reset them, and how they are obtained. The corresponding device may have several different unique device identifiers. Unique device identifiers can be used for a variety of purposes, including security and fraud detection, synchronization services such as a user's e-mail inbox, and more.
1.5 Cookies
A mechanism that allows the server (or scripts) to store and retrieve information on the client, extending Web-based client/server applications by adding simple, persistent client state. When the server returns the HTTP object to the client, it sends a status message, which is saved by the client. The range of urls that are valid in that state is described in the status message. Thereafter, HTTP requests made by the client in this range will return the current value of this status information from the client to the server, which is called a Cookie.
1.6 Device Information
Means include device name, device model, device identifier, operating system and application version, language settings, resolution, Service Provider Network ID (PLMN), MAC, IMEI, AndroidID, OpenUDID, IDFA.
2. Scope of Application of this Policy
2.1 Scope of Application
This Policy only applies to FlowTick[ ] APP and related services.
FlowTick APP of CUE provides mobile terminal real-time traffic flow statistics tool. Through this product, you can use our real-time traffic flow statistics service on mobile devices.
2.2 Special Notes
This Policy does not apply to the product and services provided by third-parties through CUE, or to product and services referred to by third-parties links on CUE's website. In this case, you are advised to carefully read and understand the Privacy Policy of third-parties. This Privacy Policy is closely related to the product and services we offer. Please read the following Privacy Policy carefully to understand how we collect, use, store and transfer information from or about you and your end users. Services provided to you by third-parties, except as expressly provided by law, we shall not be liable for any third-parties’ use of the information provided by you.
3. Personal Information We Collect and How We Use the Personal Information
3.1 Device Permission Invocation
In providing this product and related services, we may need to invoke the following permissions on your device:
3.1.1 Telephone Rights: Obtain device identification codes to identify data generated by different devices; Obtaining process currently running, used to determine whether the current APP is in the foreground or background.
3.1.2 Location Rights: Before collecting traffic flow statistics, you need to configure the location of the statistics. At this time, we will obtain the location rights of your device and obtain your real-time location to record the location of your traffic flow statistics.
3.1.3 Camera Permission: Our traffic flow statistics service is based on video images, so when traffic flow statistics are collected, you need to authorize the camera permissions of your device to ensure that our product can successfully obtain videos.
3.1.4 Storage Permission: When storing traffic flow statistics records, we will not only store the configuration and statistical results such as statistical location and statistical time, but also store the scene screenshots when you perform traffic flow statistics, which requires you to grant storage permission of your device before starting statistics.
You have the right to refuse authorization, but may not be able to use the services we provide.
3.2 Personal Information Collect and Use
We will collect, with your authorization and consent, the information you proactively provide when using the Service, as well as the information generated when you use the function or accept the Service through automated means in the following ways:
3.2.1 Registration Information: When you register and log in to APP and related services, you can create an account through your mobile phone number, and you can complete relevant network identification information (avatar, user name), which is collected to help you complete registration. You can also choose to complete your personal information according to your own needs, such as personal introduction and other information.
3.2.2 Location Information: Before the start of statistics, if you authorize our product to obtain geographical location information, our product can be repositioned through real-time positioning or manually triggered by user. When you turn on device positioning function and use relevant services provided by us based on location, we will collect location information. So that you do not need to manually enter your own geographical coordinates to access relevant services, while recording and distinguishing the location for traffic statistics. We use a variety of technologies for positioning, including IP addresses, GPS, and other sensors that can provide relevant information (for example, may provide Google with information about nearby devices, WLAN access points, SSID of WiFi, and base stations). You can turn off location function by authorizing the system, and we will not locate the query information based on the technology, but you may not be able to obtain relevant services or features, or may not be able to achieve the effect intended by relevant services.
3.2.3 Device Information: We will receive and record the device information you use (such as device model, operating system version, device configuration, device ID, device network information, device environment and other software and hardware characteristic information) according to specific permissions you grant during software installation and use, in order to provide you with more matched services, understand product compatibility, and identify account anomalies.
3.2.4 Log Information: When you use the product and/or services, we will automatically collect details about your use of our services and save them as relevant network logs. For example, your login account, IP address, statistical location, statistical duration, statistical number, telecom carrier, network environment, language used, date and time of access.
3.3 Personal Information We Collect from You Through Indirect Means
To provide you with better services, jointly provide you with services or to prevent Internet fraud, our affiliates and partners will share your personal information with us in accordance with the law or with your consent.
You fully understand and agree that the information we collect, according to the relevant laws and regulations, do not need to obtain your authorization consent:
3.3.1 Related to national security and national defense security;
3.3.2 Related to public safety, public health and major public interests;
3.3.3 Related to criminal investigation, prosecution, trial and execution of judgments;
3.3.4 In order to protect the life of the subject of personal information or other individuals, important legal interest such as property but difficult to obtain your consent;
3.3.5 The collected personal information is disclosed to the public by you;
3.3.6 Collecting personal information from legally and publicly disclosed information, such as legal news reports, government information disclosure and other channels;
3.3.7 Necessary for a contract at your request;
3.3.8 Necessary to maintain safe and stable operation of the product and/or services provided, such as finding and handling bugs of the product and/or services;
3.3.9 Necessary for legitimate news reporting;
3.3.10 When an academic research institution carries out statistics or academic research in public interests and provides the results of academic research or description to outside world, and the personal information contained in the results is de-identified;
3.3.11 Other circumstances stipulated by laws and regulations.
3.4 Others
If the information you provide contains personal information of other users, you should ensure that you have obtained legal authorization before providing such personal information to us.
4. How We Use Your Personal Information
4.1 How We Use Your Personal Information
4.1.1 To provide you with the use of our services and to maintain and improve these services;
4.1.2 We may collect statistics on the use of our services and may share these statistics with the public or third-parties to disclose the overall use of our services, but these statistics do not contain any identifying information about you;
4.1.3 Use your personal information to prevent, detect and investigate, including but not limited to fraud, security hazards, illegal or violations of agreements, policies or rules with us or its affiliates, in order to protect the legitimate rights and interests of you, other users, us or our affiliates;
4.1.4 Other Uses Authorized by You
4.2 Terms for Secure Use of Personal Information
4.2.1 After collecting your personal information, we will de-identify the data through technical means, and the de-identified information will not be used to identify you. Please understand and agree that we have the right to use the de-identified information, and on the premise of not disclosing your personal information, we have the right to analyze and commercialize the user database, which does not belong to the act of external sharing, transfer and public disclosure of personal information. The de-identified information is used without prior notice to you or consent.
4.2.2 After you actively cancel your account, we will stop providing you with products or services and stop using your personal information in accordance with the law. Before you cancel your account, if you have uploaded content on the platform and you do not want the above content to continue to spread and use on the platform, please delete it yourself.
4.2.3 When we display your personal information, we will use methods including content replacement and anonymous processing to desensitize your information to protect your information security.
4.2.4 When we want to use your personal information for other purposes not specified in this Policy, or if the information collected for a specific purpose is used for other purposes, we will seek your consent in advance.
5. How We Share, Transfer and Publicly Disclose Your Personal Information
5.1 Sharing your personal information is an important basis and part of our provision of products and/or services to you
For your personal information, we will only collect and use it for the purpose and scope of this Policy, or according to the requirements of laws and regulations, and will keep your personal information strictly confidential, except in one or more of the following circumstances, we will not share your personal information with third-parties and/or individuals:
5.1.1 Obtain your express consent or authorization in advance or you actively choose to share;
5.1.2 When sharing is necessary to fulfill legal obligations: We may share your personal information in accordance with laws and regulations, litigation dispute resolution needs, or as required by administrative and judicial authorities in accordance with law;
5.1.3 Sharing your personal information with our affiliates. With your consent, we will only share necessary personal information and will be bound by the purposes stated in this Policy. If we share your sensitive personal information or our affiliates change the purpose of using and processing personal information, we will seek your authorization and consent again.
5.1.4 Sharing your personal information with authorized partners. You understand and agree that we may need to share your personal information with authorized partners in order to be necessary/reasonable for the smooth conduct of our business, to meet your needs/requirements, and to fulfill our obligations under the relevant User Agreement or this Policy. However, we will require authorized partners to process such information for us in accordance with our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and authorized partners can only access the information needed to perform their duties, and cannot use this shared personal information for any other purpose. At present, our authorized partners mainly include the following types:
5.1.4.1 Sharing of relevant functions or services with affiliates: When you use the product and/or services and those related to our partners, we will share your de-identified personal information with these affiliates to ensure the consistency of the services you receive between the products provided by us and the affiliates, and to facilitate unified management of your information;
5.1.4.2 Sharing with business partners for specific functions: When a software service provider, smart device provider or system service provider jointly provides services to you with us, for example, when you need to use the geolocation feature, to enable this feature, we may collect your location information and related device information (such as hardware model, operating system version number, International Mobile Equipment Identification Number (IMEI), network equipment hardware address (MAC)), de-identify it and provide it to related provider;
5.1.4.3 In order to ensure the realization of relevant functions and safe and stable operation of APP, the list of third-parties SDK plug-ins we interconnect with is as follows:
Umeng SDK
Purpose: mobile statistics
Collected information: Device information (such as IMEI, MAC, Android ID, IDFA, OpenUDID, GUID, IP address, SIM card IMSI, and device serial number) and device process information
Privacy Policy: https://www.umeng.com/page/policy
AG Application Statistics SDK
Purpose: mobile statistics
Collected information: equipment information (IMEI/MAC/Android ID/OAID IDFA/OpenUDID/GUID/IP address, etc.)
5.1.4.4 Assisting in dispute settlement. If you are a qualified IP complainant and have filed a complaint, information could be disclosed to the respondent at the request of the respondent so that both parties can deal with possible disputes over rights. Sharing your information is the only way to provide the services you need or to handle disputes between you and others;
5.1.4.5 Sharing based on reasonable business practices, such as when we share joint marketing with third-parties and you are the winner/winner, we may share your personal information with third-parties so that you can successfully claim your rewards, which is to protect the legitimate rights and interests of us and our affiliates or users;
5.1.4.6 We may anonymize the collected personal information for big data analysis, such as the formation of heat maps and insight reports that do not contain any personal information. We may disclose and share statistically processed, non-identifiable information with our partners to understand how users use our services or to inform the public about overall usage trends of our services.
Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even sensitive personal information of you or others. Please think more carefully on your decision.
5.2 We will not transfer your personal information to any company, organization or individual, except in the following cases:
5.2.1 Obtain your consent or authorization in advance;
5.2.2 When necessary in accordance with applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;
5.2.3 Provided in accordance with the relevant agreement signed with you (including the online electronic agreement and the corresponding platform rules) or other legal documents;
5.2.4 When involving our merger, acquisition, asset transfer or similar transactions, such as the transfer of personal information, we will inform you of the name and contact information of the recipient, and we will require the new company and organization that holds your personal information to continue to be bound by this policy and other legal obligations. If the receiving party changes the original processing purpose and method, it will obtain your consent again.
5.3 Public disclosure is the act of releasing information to society or to an unspecified group of people
We will only publicly disclose your personal information in the following circumstances and under the premise of adopting industry-standard security measures:
5.3.1 According to your needs, disclose the personal information you specify under the disclosure method you have agreed to;
5.3.2 When it is necessary to provide your personal information according to the requirements of laws, regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information according to the type and disclosure method of personal information requested. Under the premise of complying with laws and regulations, when we receive a request for disclosure of information above, we will require the issuance of corresponding legal documents, such as subpoenas or investigation letters. We strongly believe that we should be as transparent as possible about the information we are asked to provide to the extent permitted by law. All requests are carefully reviewed to ensure they have a legitimate basis and are limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes. Where permitted by laws and regulations, the documents we disclose are protected by encryption keys.
5.4 Exceptions to obtaining prior authorized consent when sharing, transferring or publicly disclosing personal information
In the following cases, the sharing, transfer and public disclosure of your personal information do not require your prior authorization and consent:
5.4.1 Related to national security and national defense security;
5.4.2 Related to public safety, public health and major public interests;
5.4.3 Related to criminal investigation, prosecution, trial and execution of judgments;
5.4.4 In order to protect the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to get the consent of the person;
5.4.5 Personal information that you disclose to the public by yourself;
5.4.6 Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels, but we will still seek your consent if it has a significant impact on your personal rights and interests;
5.4.7 Necessary for signing and performing contracts according to the requirements of the personal data subject;
5.4.8 Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and handling faults of the products or services;
5.4.9 Other circumstances as regulated by laws and regulations.
According to the law, the sharing and transfer of de-identified personal information while ensuring that the data recipient cannot recover and re-identify the subject of personal information, does not belong to the sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not need to notify you and obtain your consent.
If you do not agree that we provide your personal information to third-parties in accordance with the above terms, please stop using our tracking services immediately.
5.5 Careful assessment and responsibility constraints on third-parties sharing personal information
5.5.1 With your consent, we will only share information with third-parties that is necessary to achieve our purpose. If third-parties need to use personal information beyond the scope of the authorization due to business needs, the third-parties will need to seek your consent again.
5.5.2 For third-parties with whom we share your personal information, those third-parties will enter into confidentiality agreements with us. At the same time, we will evaluate their data security capabilities and environment, and require third parties to handle such information with no less confidentiality and security measures than required by this Privacy Policy.
6. How We Use Cookies, Beacons, and Similar Technologies
6.1 Make Your Access Experience Easier
When you visit our related websites or use services provided by our platform, we may identify you by small data files, which may be cookies, flash cookies, or other local storage provided by your browser or associated applications (collectively, "cookies"). This saves you from having to re-enter your registration information and helps you determine your login status and the security of your account or data.
6.2 Cookies Support Services
Please understand that some of our services are only available through the use of "cookies". If your browser or additional browser services allow, you may modify your acceptance of cookies or decline our cookies, but this action may affect our ability to provide you with the best service experience in some cases.
6.3 Use of Beacon
Web pages often contain electronic images (called "single pixel "GIF files or" web "beacons). Web beacons can be used to help websites count users who visit web pages or access certain cookies. We collect information about your web browsing activity through web beacons. For example, the address of the page you visited, the address of the referenced page you previously visited, the time you stayed on the page, your browsing environment, and display Settings.
6.4 We do not use Cookies for any purpose other than those described in this Policy
You can set up your browser to reject or manage Cookies or web beacons. However, please note that if Cookies or web beacons are disabled, you may not enjoy the best service experience and some services may not work properly.
7. How do we store your Personal Information
7.1 Location of Information Storage
Your information may be stored on servers located outside the country where you live. We maintain major servers around the world to bring you our services globally and continuously.
7.2 Information Storage Period
We will only retain your personal information for the period necessary to achieve the purpose stated in this Policy, except when you delete or cancel your account on your own initiative or as otherwise provided by laws and regulations; After your personal information has exceeded the retention period, we will delete your personal information or anonymize it as required by applicable law.
8. How We Manage and Protect Your Personal Information
8.1 Your Rights to Your Personal Information
8.1.1 Query/access to your Personal Information: You have the right to query/access your personal information, except for the exceptions provided by laws and regulations. If you want to exercise your data access rights, you can do so yourself in the following ways:
Account information: You can access and correct your personal data and account information in your account (except identity authentication information) and account binding information, by accessing the Settings in APP to perform such operations.
If you are unable to manage your personal information as described above, you may contact us at any time using the contact details provided in this Privacy Policy. We will respond to your request within 15 working days.
8.1.2 Correction or supplement of your personal information: When you find that there is an error in your personal information processed by us, you have the right to ask us to make a correction or supplement.
8.1.3 Deleting your personal information. You can delete some of your personal information through the FlowTick APP. In the following cases, you can make a request to us to delete personal information:
8.1.3.1 You will no longer use our product and/or services and will actively close your account;
8.1.3.2 We will no longer provide you with the product and/or services:
If your request for deletion is accepted by us, we will, when processing your request for deletion, notify third-parties with your personal information from us as far as possible, and ask them to delete it in a timely manner (unless third-parties has obtained your separate authorization or otherwise provided by laws and regulations);
We may not be able to delete the relevant information immediately due to security technical problems or otherwise stipulated by laws and regulations. We will store your personal information securely until it can be anonymized or deleted in accordance with relevant laws and regulations;
8.1.3.3 Change or withdraw the scope of your consent. Each business function requires some basic personal information in order to complete, in addition to the collection and use of additional personal information, you can contact the customer service staff to give or change or withdraw your consent. After you withdraw your consent, we will no longer process the relevant personal information and will no longer be able to provide you with the product and/or services corresponding to the above withdrawn consent. However, your decision to withdraw your authorized consent will not affect the processing of personal information previously conducted based on your authorized consent;
8.1.3.4 Canceling an account. You can contact us to submit a cancellation request, we will verify the identity of your cancellation within 15 days. After you actively cancel your account, we will stop providing you with the product and/or services, delete your personal information or anonymize it according to the requirements of relevant laws and regulations. Please understand that once you cancel your account, you will not be able to use the product and/or services provided by us, and you will be deemed to have automatically abandoned your existing rights and interests;
8.1.3.5 If you are unable to achieve the above functions, you can contact our business personnel at any time, but for the sake of information security, you may need to make a written request to us, or prove your identity in other reasonable ways, and we will respond to your request within 15 working days after verifying your identity (if necessary).
8.2 How We Protect Your Personal Information
8.2.1 In order to ensure the security of your information, we strive to take a variety of reasonable physical, electronic and management security measures to protect your information, so that your information will not be leaked, damaged or lost, including but not limited to MD5, encrypted information storage, data center access control. We also take strict management of employees or outsourcing personnel who may have access to your information, including but not limited to taking different permission control according to different positions, signing confidentiality agreements with them, monitoring their operations and other measures. We will provide appropriate security measures according to existing technology to protect your information by providing reasonable security, we will do our best to ensure that your information is not leaked, damaged or lost.
8.2.2 Your account has security protection function, please keep your account and password information properly. We will restore backup to other servers, encrypt user passwords and other security measures to ensure that your information is not lost, not abused and altered. Despite the aforementioned security measures, please understand that there is no such thing as "perfect security measures" on the information network.
8.2.3 Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information has been compromised, especially your account and password, please contact us immediately so that we can take appropriate measures.
8.2.4 Please use a complex password to help us keep your account secure. We will do our best to ensure the security of any information you send us.
9. How We Handle Minors' Personal Information
9.1 We take the protection of minors' personal information very seriously. Our product and/or services are primarily aimed at adults, and minors should not create their own user accounts without the consent of a parent or guardian. In the case of the collection of minor user information with the consent of parents or guardians, we will only store, use or publicly disclose this information as permitted by law, with the express consent of parents or guardians or as necessary to protect minors, otherwise we will try to delete the relevant data as soon as possible.
9.2 Due to the limitations of existing technology and business model, it is difficult for us to proactively identify the personal information of minors. If you find that we have collected the personal information of minors without your knowledge or without prior consent of a verifiable guardian, you can contact us in a timely manner and we will try to delete it in a timely manner after finding out. If we ourselves become aware of the foregoing, we will also delete it in a timely manner, unless we are required by law to retain it.
10. Revision and Update of This Policy
10.1 We may update and revise this Policy as appropriate, and such revisions form part of this Policy
We will post any changes we make to this Policy on this page or in any other way we deem significant, including by sending you an e-mail, in-platform notice, or even by providing you with pop-up alerts. By continuing to use our products and/or services, you agree to be bound by this revised Policy. We encourage you to review our Privacy Policy each time you use our product and/or services.
10.2 For significant changes, we will also provide e-mail notification. The foregoing material changes include, but are not limited to:
10.2.1 Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
10.2.2 We have made significant changes in areas such as management. Such as the change of owners caused by mergers and acquisitions;
10.2.3 The main object of personal information sharing, transfer or public disclosure has changed;
10.2.4 Your rights to participate in the processing of personal information and the way they are exercised have changed significantly;
10.2.5 When the department responsible for handling personal information security, contact methods and complaint channels change;
10.2.6 When the personal Information security impact assessment report indicates a high risk.
11. How to Contact Us
If you have any questions, comments or suggestions about this Policy, or any questions about our processing of your personal information, please contact us through the following channels, we will review the issue as soon as possible, and reply within 15 working days after verifying your user identity:
Address:140 Robinson Road, Tahir Building, Level 15, Singapore 068907
Public e-mail: flowtick_support@cue.group
If you are not satisfied with our response, especially if you believe that our user information processing behavior has harmed your legitimate rights and interests, you can also seek a solution through the following external channels: file a lawsuit with the court with jurisdiction in the place where CUE DIGITAL INTERNATIONAL PTE. LTD.. resides.
Effective date: October 26, 2023
CUE DIGITAL INTERNATIONAL PTE. LTD.