Privacy Policy

Important Notice:

This Privacy Policy is entered into by and between you (“user” or “you”) and CUGNOSPHERE PTE. LTD. and its affiliated companies (“CUGNOSPHERE” or “us”), and this Privacy Policy has contractual effect.
Welcome to use the services provided by CUGNOSPHERE (“CUGNOSPHERE services” or “services”). To protect your privacy while using CUGNOSPHERE services, CUGNOSPHERE has established this Privacy Policy to explain how we collect, use, store, and share your personal information, as well as the ways we provide you with access, updates, control, and protection of this information.
This Privacy Policy applies to the CUGNOSPHERE services we provide to you. When you use our services, we will process and protect your personal information in accordance with the provisions of this Privacy Policy.
By using our services, you indicate that you trust our handling of your information. We are deeply aware of the significant responsibility this entails and are committed to protecting your information and giving you control over it.

1. Introduction

Although the information might be collected to improve application and service quality, we take your privacy seriously. To better protect your privacy we provide this privacy policy notice describing the way your personal information is collected, processed, stored, and used.

2. Revision Strategy

We reserve the right to modify, amend or update this policy at any time. The current version will always be posted on our Privacy Policy page.
You should periodically visit this webpage and use the “Refresh” button on your browser to check for any modifications to this policy. If you click the “Refresh” button in your browser and the “Last Updated” date remains the same, you can assume that there is no change to this policy.
A change in the “Last Updated” date indicates that the policy has been updated or edited, and the updated or edited version replaces any previous version immediately after it is released.
Browsers, Internet Service Providers (ISPs), CDNs, and other organizations or individuals may cache our pages for bandwidth savings or other reasons, in which case you should refresh the cache yourself to check for the latest privacy policy. If the content of the page caused by the cache does not match the actual content, it should be based on what we provide.

3. Interpretation and Definitions

Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

Definitions

• Account means a unique account created for You to access our Service or parts of our Service.
• We (also referred to as either “Us” or “Our” in this policy) refers to the owner of the provided Services. For the purpose of the GDPR, “We” are the Data Controller.
• Cookies are a small piece of data that the server sends to the user’s browser and is stored at the user-side locally. It may contain an anonymous unique identifier that is carried and sent to the server the next time the browser re-initiates a request to the same server. Usually, it is used to tell the server whether different requests are from the same browser/user, such as keeping the user’s login status.
• Customers (also referred to as either “You” or “Your” in this policy) are those who utilize the services. Under GDPR (General Data Protection Regulation), You can be referred to as the “Data Subject” or as the “User” as you are the individual using the Service.
• Data Controller for the purposes of the GDPR (General Data Protection Regulation), refers to “We” as the legal person which alone or jointly with others determines the purposes and means of the processing of the Personal Information.
• End-Users are who interact with our Service through the websites of our Integrators.
• Integrators are those who incorporate our Service into their website or service.
• Personal Information (also referred to as “Personal Data” in this policy), is any information recorded in an electric form or other forms that can identify an individual itself or when it is associated with other information. If the subject of several acts can be identified as the same person by a single piece of information (with or without simple assistance), then the information will be considered as Personal Information, and vice versa.
• Personal Identifiable Information is one type of Personal Information. If it is possible to directly identify, contact or accurately locate the corresponding single specific natural person through a single piece of information (without any assistance), then the information will be considered as Personal Identifiable Information, and vice versa. Personal Identifiable Information includes, without limitation, the individual’s name, date of birth, identification card number or SSN, biometric identifier (e.g. photographs, fingerprints, palm prints, iris, etc.), address, telephone number, precise coordinates, etc. Your IP address will be desensitized and obscured during the process of de-identified, anonymized, desensitized and aggregated, thus we treat it as personal information rather than personal identifiable information.
• Non-personal Information is any information recorded but cannot be directly linked to any particular individual by itself. Usually, this kind of information will be aggregated into categories, thus it is almost impossible to use this information to restore any personally relevant data about a particular individual. Notes that the use of Non-personal Information in combination with Personal Information will be treated as the use of Personal Information.
• Service (also referred to as “The Services We Provided” in this policy) include, without limitation, websites, online services, interactive applications, and email.
• Unique Identifier, (sometimes called a unique ID or UUID) is a string of characters that is incorporated into a device by the manufacturer or server and can be used to uniquely identify the device or user.
• Usage Data (also referred to as “Analytics Information” in this policy) refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). Typically we treat the information as Personal Information.

4. Information We Collect

We collect information from individuals who interact with our Sites and Services, including Integrators, Customers, and End-Users.
We collect the following categories of information:

Personal Information

We collect from our current and prospective Integrators and Customers when they give it directly to us (for example, by filling in a form when signing up for an account, or applying to receive email notifications from us). We may also verify the identity of our Integrators and Customers by comparing personal information against third-party databases or official legal documents.

Analytics Information

Information collected automatically as a result of an Integrator’s or Customer’s use of the Sites or the Services. Some Analytics Information is collected on our behalf by third parties we engage for that purpose, and some Analytics Information is collected through a variety of tracking technologies, including cookies:

• The referrer, frequency, date and the time of your accessing, the clickstream data, the time you spent, the browser you use
• Device brand, vendor, model, factor, screen size and operating systems
• Network operator and location in country and/or province level
• Application or website startup and loading speed, critical operation timing
• Performance data of different content delivery network service providers in your network environment
• Application or website critical errors and related error information that doesn’t include any personal information

According to the definition of “Personal Information” and “Non-personal Information”, this information will not be considered as Personal Information.
If we need certain files for investigating some specific application errors, we will contact you. Files won’t be uploaded automatically unless you permitted.
Besides that, like most Internet services, we also automatically collect certain information, such as your IP address and HTTP request headers. Usually, we use this information to protect our services from being infringed. For example, we will use this information in our Web Application Firewall. Usually, this kind of information will be stored log files and will be deleted within the certain time limit.

Personal Identifiable Information

We do not knowingly, actively and proactively and collect any Personal Identifiable Information through the Service we provide.

Customer Service Information

When you seek our technical and/or customer service support and/or exercise any legal rights as a data subject, we may collect information you provide when communicating with our support team.

Other Information as Per Special Notice

In addition to the information mentioned above, we may collect additional information for some websites, applications, or services we provide. When you use a specific service, we will send you a personal privacy notice to inform you of how we handle your personal information. For personal information processed by such individual services, the personal privacy notice shall prevail.
When you use third-party services related to our services, such as third-party social media plug-ins, sharing buttons, and/or login mechanisms, or interact with them, the scope of this privacy policy will not extend to such functions (whether now or in the future), and these functions should comply with the relevant third-party privacy policies.
In special circumstances, we may collect personal information beyond what is described in this privacy policy with your consent or based on other legal grounds. In such cases, we will further explain how we collect or process the information and the purposes for which it will be used, which may differ from the content of this privacy policy or may not be mentioned in this privacy policy.

5. Why Do We Collect and Process Your Personal Data

We collect and process your personal data mentioned above for the following purposes, including:

• help you create an Account and enable you to manage your Account and maintain your personal profile;
• to facilitate your use of various CUGNOSPHERE Services with your HoYoverse account;
• allow you to access or restrict your access to the CUGNOSPHERE Services;
• provide you the services required by you and perform our contractual obligations towards you;
• analyze and manage CUGNOSPHERE Services for system administration, user service, security, fraud-detection, check the authenticity of an account owner, archival and/or backup purposes;
• correct bugs or errors, improve our services and respond to customer desires and preferences,
• verify and confirm payment;
• keep you up to date on the latest product announcements, notify special events and offer other data pertaining to our services;
• fulfill our obligations under applicable laws and regulations, respond to requests of government authorities;
• establish, exercise or defend legal claims;
• analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience;
• protect the integrity, information safety, and financial security of our services or our users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of the CUGNOSPHERE Services;
• track your process across our websites and applications to verify that you are not a bot and to optimize our services.

For the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with terms in this Privacy Policy. Affiliate in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with CUGNOSPHERE hereto.

6. How we collect your information

The services we provided might use Cookies and other technologies such as pixel tags, web beacons, HTML5 fingerprint, TLS Handshake fingerprint, etc.
We use those technologies to help us better understand the behavior of our users, distinguish between natural persons and automated software, to tell us which parts of our website are being viewed.

Cookies or Browser Cookies

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. If you would prefer to block cookies or other tracking technologies, most browsers and mobile devices all you to change your settings so as to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to disable or delete existing cookies or to automatically reject future cookies. You may also use third-party tools, including browser plug-ins and extensions, to control your cookie preferences. Note, however, that if you disable all cookies, some portions of our Sites may not function properly. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

Flash Cookies

Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service.

Web Beacons

Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.

First-Party Analytics and Tracking Technologies

We use miHuYo Analysis to collect and analyze how our website is used, monitoring how our services are used. We only collect necessary information, all information is anonymized, and your personal information will not be collected. For more information, please see CUGNOSPHERE Analysis Agreement.

Third-Party Analytics and Tracking Technologies

As discussed above, we (and our third-party vendors) collect Analytics Information in part through the use of cookies, web beacons, and other tracking technologies. In some instances, we work with third-party vendors to employ cookies for the purposes of collecting Analytics Information.

• We use Cloudflare to collect debugging data when a user experiences an error.
• We use Cloudflare to optimize our web traffic and protect us from online attack.
• We use Google Analytics to track and report website traffic, and monitor the use of our Service. This data might be shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• For information on how Google uses the collected data, please see Cloudflare’s Privacy Policy.

7. How We Transmit, Process, Store and Protect Information Collected

The online services we provided use encryption technologies such as Transport Layer Security (TLS) to protect collected information during transmission so that it won’t be theft by the Man-in-the-Middle.
The information we collected will be aggregated into categories. Any information that is not required for those purpose described in the policy will be deleted, de-identified, anonymized, or desensitized during the aggregation process.
Analytical information will be stored in computer systems with limited, authorization-required access rights that are protected by mathematical algorithmic encryption and/or physical security measures that cannot be cracked in modern computer systems in a short period of time. Among the facilities. We store the data in encrypted form, as we use third-party storage services.
You acknowledge and agree that your data will be processed on our servers which may not be located in your country/region of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws and regulations.
In the case you request to remove or delete your personal data, we will retain your data as long as necessary for applicable laws and regulations, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.
Where required by law, we will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or where the applicable laws and regulations provide for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by and in accordance with applicable laws and regulations.
Regarding your use of our services, we have taken reasonable measures to prevent unauthorized access or misuse of your personal information, such as organizational controls, technical safeguards, and other protective measures.
Unfortunately, no security measures are 100% foolproof, and as such no network or system (including ours) can be guaranteed to be 100% secure against destruction, loss, alteration, unauthorized disclosure of, or access to the information we collect and store.
Therefore, we strongly advise you to take all possible preventive measures to protect your personal information when using our services, including but not limited to regularly changing your password, using a combination of letters and numbers when setting a password, using a secure browser, and/or taking other possible security measures.
If you believe your information may not be secure for any reason, please contact us immediately at: [email protected].
Please be aware that websites linked to our website and/or websites linked to through our services may collect personal information related to you. This privacy policy does not apply to such third-party services, and we do not control the activities of such other advertisers or websites. We strongly recommend that you read the privacy policy of such third-party websites you may click on before providing any personal information.

8. How We Use Information

We generally use this information for internal purposes such as auditing, data analysis, research, etc.; to protect our services from intrusion; to administer the website; to understand user behavior on the website; to understand and analyze trends; to gather information about the overall audience characteristics of our user base; to create, develop and improve the services we provide. Specifically:

• To administer Integrator and Customer accounts and provide the Service. We use Personal Information in order to associate specific accounts with Integrators and Customers and provide them the Service, respond to requests or inquiries, provide support or technical assistance, and facilitate payments.
• To improve to Site and the Service. We use Analytics Information to improve our existing and develop new services and offerings and to customize existing and future product offerings.
• To derive market insights. We use Analytics Information to analyze the market and conduct business analyses related to the Site and our Services, and for other research purposes.
• To secure our services and systems. We use Analytics Information to secure our systems by identifying potential threats and vulnerabilities and to otherwise protect the information we collect.
• For any legitimate business purpose.

Before such information is used for this purpose, it will be deleted,de-identified, anonymized, desensitized, categorized, and aggregated in ways described above that it cannot be reasonably tied to any individual.
We do not use the information we collect for content and advertising.

9. Who May Access Your Personal Data

In addition to CUGNOSPHERE and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen the occurrence of such disclosure when you provide your personal data.

Competent Authorities

We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose a certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
In addition to be required by applicable laws and regulations, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if you are violating any agreements between us, such as the Terms of Service and this Privacy Policy or otherwise damage us; you are infringing third parties’ rights and interests (including but not limited to intellectual property rights); and/or we believe that it is necessary to prevent fraud or other illegal activities.
Before complying with such requests, we will exhaust our legal remedies to minimize the information we are compelled to share.

Third-Party Contractors

CUGNOSPHERE may work with a number of (if any) third parties on or through our services to help us provide services and functionalities to you. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties under the following necessary circumstances, and such third-parties thereof are prevented from processing (including but not limited to accessing, storing, using, or disclosing) your personal data except for achieving the purpose of their cooperation with us:

• Social networking portals who provide login and/or content-sharing service to and in our services;
• Providers of the underlying infrastructure for our website and/or services, such as data storage, hosting, and analytics;
• Integrators that provide security checks for our website and/or services to determine the fraud risk of specific requests or IP addresses.
• Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;
• Other contractors if any for the purpose of providing our services to you.

Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you. For example, users purchasing and/or subscribing products or services will be required to provide additional data to third-party payment contractors, such as a valid credit card number, expiration date. Such third-party payment contractors may collect, process and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries.
When specific third parties are involved in collecting data and information, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.

Other Situations

We may also disclose your information in the following circumstances.

• To protect your, our, or others’ rights, privacy, security, or property, other demands made to public and private entities.
• For any legitimate business purpose, sharing with others is allowed, provided that the information is deleted, de-identified, anonymized, desensitized, categorized, and aggregated, making it impossible to reasonably link it to any individual.

We will not share any information with third parties for any marketing or advertising purposes.

10. Your Rights and Choices

Subject to the applicable laws and regulations, you may have the following data protection rights as a user of our services. You also have the right to complain to the local authorities.
To exercise any applicable rights below or to exercise any other statutory data subject rights you may enjoy under applicable laws and regulations, you may contact us using the contact details under the “Contact and Complaint” heading below.
To protect the security of your Account and your personal data, we may ask you to provide certain additional information to verify your identity before we respond to your requests. Under some circumstances, we may refuse to comply with your request as permitted by applicable laws and regulations. We may also charge a reasonable fee for complying with your request in accordance with applicable law, e.g. if your request is clearly repetitive or excessive.

Right to Know about Personal Data Collected or Disclosed

You have the right to access the personal information we hold about you, namely, information about whether we collect or disclose your personal information; the categories of your personal information that we collect or disclose; the categories of sources from which we collect your personal information; the business or commercial purposes for collecting or disclosing your personal information (if any); and you have the right to request a copy of your personal information being processed, but you need to submit a verifiable request to us through the contact information listed below.

Right to Rectify

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to request for rectification of your inaccurate personal data according to applicable laws and regulations and you can modify the information through your personal page on the HoYoverse Account website or the privacy setting of the services (if available).

Right to Request Deletion of Personal Data

You may have the right to request the deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore or if there is another legal ground for its deletion, subject to submitting a verifiable request to the contact details under the “Contact and Complaint” below.
You acknowledge and agree that as a result of deleting your Account, you will lose access to game related services, including the Account information, subscriptions and game-related information linked to such Account and lose the possibility to access other services through the Account.

Right to Complain

You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Right to Withdraw Your Consent

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. In many circumstances, we need to use your personal data in order for us to provide you with our services which you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require.

11. Warranty Disclaimers

To the fullest extent permitted by law, the Site and the Service (and any other associated services, information, data, features, and other content or materials) are provided on an “as-is” and “as-available” basis. To the fullest extent permitted by law, IMI excludes all warranties, including but not limited to the implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

12. Data Retention

We store your Personal Data securely throughout the life of your account with us. We will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or resolving disputes. The criteria we use to determine storage periods include the applicable contractual provisions that are in force, legal statutory limitation periods, applicable regulatory requirements, and industry standards.
While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your Personal Information are described below.
Contact information for marketing purposes is retained on an ongoing basis until you un-subscribe. Thereafter we will add your details to our suppression list indefinitely. Email information collected from Accessibility Users will never be used for marketing purposes.
Records of communications with you (e.g. support tickets opened via email or Twitter) may be kept indefinitely.
Information collected via technical means such as Cookies, webpage counters and other analytics tools is discarded as soon as practical, but may be kept for a limited period of up to one year from expiry of the cookie, typically in a de-identified, anonymized, desensitized, categorized and aggregated form unless we detect potential abuse of our service.
If we detect potential abuse of our service, we will retain that information to aid us in preventing future abuse. We are unable to link this information to you, your household, an IP address, or any personal information based on the information stored.

13. Cookie Policy (How We Use Cookies and Other Technologies)

Type of Cookies We Use

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.
We use both session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

• Type: Session Cookies / Persistent Cookies
• Administered by: us

These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features (E.g. Your Login Status). They help to authenticate users and prevent fraudulent use of your accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Functionality Cookies

• Type: Persistent Cookies
• Administered by: us

These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
We considered the information collected through cookies and other technologies as Non-personal Information, as it is impossible for others to restore any personally relevant data about you through it.
We will not use cookie technology to share any of your personal information to any third-party, or to assist third parties in collecting any of your personal information.

Tracking and Performance Cookies

• Type: Persistent Cookies
• Administered by: Third-Parties Vendors

These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features, or new functionality of the Website to see how our users react to them.
We have taken every possible measure to avoid the usage of cookies for tracking and performance analysis purposes. We also have taken every possible measure to prevent third-party vendors from setting cookies for such purposes on your browser or device.

Your Choices Regarding Cookies

If You prefer to avoid the use of Cookies on the Website, first You must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.
If You do not accept Our Cookies, You may experience some inconvenience in your use of the Website and some features may not function properly.
If You’d like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser.

• For the Chrome web browser, please visit this page from Google。
• For the Internet Explorer web browser, please visit this page from Microsoft。
• For the Firefox web browser, please visit this page from Mozilla。
• For the Safari web browser, please visit this page from Apple。
• For any other web browser, please visit your web browser’s official web pages.

Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available on Adobe’s website.

14. Personal Information from Children

Our Sites and Service 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, although certain third-party vendors that we use, or certain websites that we link to may do so.
These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.
If we learn that we have collected 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 through [email protected] if you believe we have any information from or about a child under the age of 13.
We do not share the personal information of Consumers We actually know are less than 16 years of age, even if We already receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. And consumers may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

15. Cross-Border Data Transfer

Please be aware that your personal data will be transferred to, processed, and stored in Singapore and/or the United States. Data protection laws in Singapore and/or the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to Singapore and/or the U.S. as set forth in this Privacy Policy by visiting our Sites or using our Service.

16. Use Your Personal Information for New Purposes

We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we may notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we may seek your consent for any unrelated purpose and allow you to terminate your use of the service at that time if you object.

17. Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. However, we do not, and will never sell your personal information. So You don’t have to send request to us.

18. Notice to California Residents

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.
For the categories of personal information we have collected from you in the preceding 12 months, please see the sections above. We collect this information for the business and commercial purposes described above. In the preceding 12 months, we have shared the following categories of information with third parties for a business purpose:

We do not “sell” (as this term is defined in the CCPA) the personal information we collect. Please refer to the section above for more information regarding the types of third-party cookies, if any, that we use.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, as well as the right to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. Please note that you must verify your identity and request before further action is taken, such as by providing your government identification. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.

19. Notice to EU Data Subjects

We may process Personal Data (Personal Information) under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us.

20. General

If any provision of this Privacy Policy is wholly or partially invalid or unenforceable for any reason, the remaining provisions of this Privacy Policy shall still be valid and binding and shall have full force and effect.
The headings of all clauses in this Privacy Policy are for reading convenience only and do not have any actual meaning, and cannot be used as a basis for interpreting the meaning of this Privacy Policy and related clauses.
The associated parties of this Privacy Policy refer to entities that directly or indirectly control CUGNOSPHERE, are controlled by it, or are under common control with it.
CUGNOSPHERE can translate this Privacy Policy into other languages. If there are any discrepancies between the Chinese version and other language versions, the Chinese version shall prevail within the scope of applicable laws and regulations.
The failure of CUGNOSPHERE to exercise or delay in exercising or fully exercising any right under this Agreement or according to the provisions of laws and regulations shall not be deemed a waiver of such right, nor shall it affect CUGNOSPHERE’s right to exercise such rights in the future.
CUGNOSPHERE reserves the right to modify, supplement, delete, or update this Privacy Policy.
If this agreement conflicts with the laws and regulations of your country or region, the local laws and regulations shall prevail.

21. Contact

If you have any questions about this Privacy Policy or have any requests for resolving issues arising from or in connection with this Privacy Policy, please contact us in the first instance through the following methods:
Email: [email protected]
We will review the issues involved as soon as possible and process them in a timely manner after verifying your identity, and respond within 15 working days or the time limit stipulated by laws and regulations at the latest.

CUGNOSPHERE PTE. LTD.
Last Updated: May 18, 2024
Effective Date: May 18, 2024