Privacy Policy

Effective date: July 2024

ACCORDING TO THE DATA PROTECTION LAWS, WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM USERS UNDER THE AGE OF 14 FOR ANY PURPOSE. IF YOU BELIEVE THAT WE HAVE COLLECT SUCH INFORMATION OF USERS UNDER THE AGE OF 14 WITHOUT PARENTAL OR GUARDIAN CONSENT, OR IF YOU ARE THE PARENT OR GUARDIAN OF THE USER AND WISH TO WITHDRAW THE CONSENT, PLEASE SUBMIT YOUR REQUEST AT【inspaze.src@hellospace.group】 AND WE WILL DELETE SUCH INFORMATION.

Welcome to inSpaze (the “Platform”). This Platform is provided and controlled by HELLOSPACE TECHNOLOGY PTE.LTD. (“inSpaze”, “we” or “us”). We are committed to protect and respect your privacy.

This Privacy Policy describes how we collect, use, protect and share information about you that we obtain when you access and use our Service.

Please read this Privacy Policy carefully to understand how we will treat your information before you start to use our Service or communicate with us outside the Platform Certain features or functionalities of our Platform may be available via the Platform. This Privacy Policy governs the collection and use of data about you and your use of the Platform. (Although, we may provide additional notice and choice options within the Platform itself.)

YOU SPECIFICALLY ACKNOWLEDGE AND AGREE THAT:

1. [inSpaze] has multi-platform application characteristics, including XR\VR and common mobile devices. Based on the different functions and features of these devices, your bio-information and factual reactions, actions, and statements may form public to some of your privacy, if you do not want these contents to be disseminated through our apps, you should consult with the sales consultant or retailer of your device for ways and assistance to turn off the relevant functions.

2. [inSpaze] is a social app and an online community, and for the most part, our apps are used as a public space rather than a private, enclosed space, unless you are using one of our specific features. Therefore, you need to use our application in good faith and reasonably, take the initiative to protect your own privacy and respect the rights of others to use this public space.

By accessing or using our Platform, you are accepting and consenting to the practices described in this Privacy Policy, which may be updated and amended from time to time. If you do not agree to the terms of this Privacy Policy, you may not access or use the Platform.

1.What information do we collect?

2. How we use your information

3. How we share your information

4. Your Choices

5. Security

6.Data Retention

7.Interpretation

8.Changes

9. Contact

1.What information do we collect?

We collect information when you create an account and use the Platform, such as your contact details and content you create . We may also collect information you share with us from third-party social network providers, and technical and behavioral information about your use of the Platform.

1.1 Information you choose to provide

For certain activities, such as when you log on, upload content to the Platform, or contact us directly, you may provide some or all of the following information:

● Registration information, when you sign up for an account on inSpaze, you are asked to enter your Apple account details and you are asked to enter your nickname,avatar.If you are a visionpro user, we may display your Persona image after obtaining your Persona authorization. If you are a mobile user, you may choose to take a photo with a real person's avatar, and we will obtain your facial features through post-processing technology to generate an exclusive virtual image for you. Real avatar and facial features information is sensitive information, after the virtual image is generated, we will delete your real avatar photo and facial features information, and will not use it for any other purpose. If you have an iOS device with a front-facing TrueDepth camera, we may use TrueDepth APIs to detect the angle of the shot when taking the avatar to improve the quality of the shot and achieve better visual effects. We use information from TrueDepth cameras in real time and do not store this information on our servers or share it with third parties.You may fill in your information you disclose in your user profile during subsequent use,such as biography,decoration,background music,social media,region;

● User Content information, we collect the pictures, videos, audio messages you send on inSpaze with your photos’s permissions, camera's permissions, microphone permissions;In the party function, if you are a mobile user, it is used to drive the avatar to show the character's action expression in real time through your authorized camera privileges. We respect your right to choose, if you want to turn off the function of driving expression, you can withdraw the authorization of the camera through the operating system of the device itself. If you refuse to authorize, it will not affect your normal use of other functions. The camera privileges enabled in the Party function will only be used to drive expressions and will not be used for any other purpose, nor will any content be stored.

● Information as your communication/call history and contents or the contact information you send to us when you are contacting us.

1.2 Information Generated from Use of the Platform

When you use the Platform, we automatically collect technical information when you access, browse and use our Platform, including information that we automatically receive and record from your browser or mobile platform on our server logs. This technical information helps us operate and provide our Platform to you, and includes standard information about visits and system capabilities, such as:

● Information about the device(s) you use to access our Platform, including MAC address, IP address, browser type and version, your location, time zone setting(We will display the current time by your time zone setting when you enter the space within the platform), browser plug-in types and versions, operating system version, device type, device model, device configuration, device network information, device environment and other characteristic information of software & hardware ,device and application identifiers, operating information, mobile carrier, and cookies;

● Information about your visits to the Platform, including the full URL clickstream to, through, and from the Platform, including dates and times;

● Information we need and use to facilitate your use of our Platform, such as URL requests, destination IP addresses, or device configuration details.

2. How we use your information

You specifically acknowledge and agree that, as an Internet social networking application for online use, the collection of necessary personal information and device information about you that we disclose is a prerequisite for the proper operation of the application and use of features, unless we indicate otherwise. Therefore, when you do not provide, or provide incorrect or false information, the following situations may occur:

1. You cannot register your account normally;

2. You will not be able to run our application properly;

3. Uncertainty about the negative impact on others;

4. the normal use of your account

If you have used the Product in full compliance with our requirements and you still experience any of the above problems, please communicate with us to resolve the problem according to the contact information provided in this document.

We use your information to fulfill and enforce our Terms of Service , to improve and administer the Platform, and to allow you to use its functionalities. We may also use your information to, among other things, show you suggestions, promote the Platform.

We generally use the information we collect, to:

● create and manage your account;

● provide the Platform to you;

● fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback;

● improve and develop our Platform and conduct product development;

● support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform;

● help us detect abuse, fraud, and illegal activity on the Platform;

● comply with laws, regulations, and other legal requirements;

● comply with relevant industry standards and our policies;

● communicate with you, including to notify you about changes in our services;

● enforce our terms, conditions, and policies;

● protect and enforce our rights and the rights of other Users against unlawful activity, including identify theft and fraud, and other violations of our Terms of Use;

● protect the integrity and maintain the security of our Platform, including secured areas of the Platform;

● operate, evaluate and improve our business, including conducting surveys and market research, developing new products, services; performing accounting, auditing, and other internal functions;

● for any other purposes disclosed to you at the time we collect your information or pursuant to your consent;

● combine all the information we collect or receive about you for any of the foregoing purposes.

3. How we share your information

We do not sell, rent, license, or lease your information to third parties. However, we may share it with the following third parties in or outside your country in accordance with the relevant laws and regulations of your country/region:

3.1 Service Providers

such as hosting services, customer support services, payment Providers and analytics services.

Such providers may be local operating partners or technical support partners outside your country. After the cooperation terminated, they will be denied access to all of our information, including the information to which they previously had access. We promise not to provide, sell, rent, share, or trade your personal information to any unrelated Service Providers, unless we have your prior consent.

We do not control the information that these Service Providers collect or how they use that information. We strongly encourage you to check their own Privacy Policies on their official websites and learn more about their data processing practices. Notwithstanding the foregoing, if you discover that any third party collects or processes your personal information illegally or in a manner which worries you, you are encouraged to contact us, and we will make reasonable efforts to help you.

3.2 We may share the Information with the following service providers:
Name of the service provider Device purpose of data collection: Personal information collected: Privacy Policy:
Agora Apple Vision Pro&iPhone voice and video calling Device Information, IP address,camera's permissions, microphone permissions; https://www.agora.io/en/privacy-policy/
AppleID Apple Vision Pro&iPhone sign in identifier https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/
cosmos MMMedia SDK iPhone Media Device Information, Device Identifiers,IP address,camera's permissions https://cosmos.immomo.com/home/copyright
Firebase Apple Vision Pro&iPhone Statistical analysis Device Information, Device Identifiers https://policies.google.com/u/1/privacy
cosmos PhotonIMSDK Apple Vision Pro&iPhone IM Device Information, Device Identifiers https://cosmos.immomo.com/home/copyright
Apple Music Apple Vision Pro&iPhone access music that users are interested in and play identifier,Favorite music, Recently played music etc. https://www.apple.com/legal/privacy/data/en/apple-music/
ilivedata Apple Vision Pro&iPhone translate Device Information, IP address,microphone permissions https://www.ilivedata.com/site/privacy-agreement
ishumei Apple Vision Pro&iPhone Reviewing user-uploaded videos, images or texts Device Information, IP address,User-generated content https://www.ishumei.com/legal/cn/privacy.html
cosmos push SDK iPhone Push Device Information, IP address https://cosmos.immomo.com/home/copyright
3.3 Professional Advisors

such as lawyers and accountants.

3.4 Business Transaction Recipients

including counterparties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, asset sale, or similar transaction involving our business.

3.5 Safety

to protect inSpaze’s, users’, or other third parties’ rights and safety.

3.6 Member or Affiliate of our group

includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled by or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country.

We do not permit these third parties to use any Information we share for any purpose other than (i) as described in this Privacy Policy, and (ii) to comply with their own legal requirements.

3.7 Legal

government authorities or regulators or other third parties where required by law or legal process.

4. Your Choices

● You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for login information in a browser and to opt out of login information for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

● If you want to view, modify, or delete your data, please check the personal page to edit.

● Delete – you can request that we delete the information we have about you by contacting us at [inspaze.src@hellospace.group] or feedback service, but this right is not absolute. We may need to keep certain information to comply with our legal requirements(For example, some issuing regions or countries have special regulations on cybersecurity laws and consumer protection laws.); If you want to delete your account, you can apply in Settings,this is permanent.When you delete your account,you won’t be able to retrieve the content or information you’ve shared on us.All of your messages will also be deleted.;

● Correct – you can ask that we fix any errors or inaccuracies in the information we hold about you;

● Stop processing – you can tell us to stop processing your information;

● Object – you can object to how we process your information; and you can always withdraw your consent,for example by turning off notification permission information functionality in your mobile device settings if you do not wish to accept our information.

The accuracy of the information we have about you is very important, you can exercise your rights by contacting us at [inspaze.src@hellospace.group] or feedback service. We will respond to your request consistent with applicable law and subject to proper verification.

5. Security

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform are no risk,this is why we need you to strictly adhere to the agreements and guidelines in documents such as our privacy policy, and we will work together to keep your personal information as secure as possible.

You are responsible for protecting your username and password(s) and for the security of information that you transmit to us over the internet.

We have put in place 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.

If you have reason to believe that your interaction with the Platform is no longer secure (for example, if you feel that the security of your username or password has been compromised), you must immediately notify us of the problem by contacting us.

6.Data Retention

The personal data we collect from you is stored and encrypted in our servers located in East Virginia, United States of America (“USA”).

In the future, we may have major servers around the world to provide you with continuous global services.

And you are aware and agree that your personal data may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or partners, located in third countries/outside the country where you live or work. We will take steps according to applicable laws and regulations in your country to ensure that your personal data is adequately protected within the data process location.We retain your information for as long as it is necessary, for example, to comply with our contractual relationship or to provide you with our service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, as may be allowed by applicable laws. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

7.Interpretation

Your use of our Platform may be governed by our Terms of Service located within the Platform, the supplemental terms that govern certain of the features, functionality, tools, content and promotions available on or through the Platform (the "Supplemental Terms"), and any and all policies and rules referenced herein or therein, posted on the Platform, or otherwise communicated to our Users (the "Platform Rules"). In the event that the provisions of any such agreement differ from or conflict with the provisions of this Privacy Policy, the terms specific to that feature, functionality, etc. will apply.

8.Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Effective date ” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.

9. Contact

Questions, comments and requests regarding this policy should be addressed to:

● Email Address: inspaze.src@hellospace.group

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Argentina

If you are using our services in Argentina, 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 Policy, the following terms shall prevail.

Your rights and options: According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. You can exercise your rights by sending your request to inspaze.src@hellospace.group free of charge.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos .

Australia

We take reasonable steps to ensure that third party recipients of your Personal Information located outside Australia handle your Personal Information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

If you are dissatisfied with our response to your request for access to, or correction of, your Personal Information or your privacy complaint in respect of your Personal Information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

Brazil

If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

I. confirmation of whether your data are being processed;

II. access to your data;

III. correction of incomplete, inaccurate or outdated data;

IV. anonymization, blocking or erasure of data;

V. portability of personal data to a third party;

VI. object to the processing of personal data;

VII. information of public and private entities with which we shared data;

VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. withdrawal of your consent.

X. request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us at: [inspaze.src@hellospace.group]. If you have any questions about the processing of your personal data, we would like to clarify them.

dpo: If you wish to reach the Data Protection Officer, contact us at: inspaze.src@hellospace.group

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 6 months, in order to comply with legal obligations.

International Transfers. International data transfers are necessary for us to provide our services. If you are located in Brazil, we will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.

If you are under the age of 18, you should not use inSpaze for any purpose without first obtaining parental/guardian agreement to the Privacy Policy (both for themselves and on your behalf).Please contact us at inspaze.src@hellospace.group if you believe we have any Personal Information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").

The CCPA provides California residents with certain legal rights such as access, deletion, disclosure, or "do not sell." These rights are not absolute and are subject to certain exceptions.

The purpose and specific information for which we collect your personal information is set out in Section 1 of our Privacy Policy.

Your phone number, Momo account password, third-party account information, identity information, transaction record information, Alipay information, payment card information, communication/call history and content that we collect in the privacy policy belong to your personal sensitive information.

Your device information, log information and your communication with us are collected by us automatically, other information are provided by you;

Your Rights under the CCPA is set out in Section 45 of the Privacy Policy.we will not sell the personal information of California residents within the meaning of "sold" in the CCPA.

The purpose and entities we share or disclose your Personal Information is set out in Section 3 and Section 4 of the Privacy Policy.

You are free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

You can contact us at inspaze.src@hellospace.group.

Canada

If you are using the Platform in Canada, the following additional terms apply.

Information Relating to Children and Teens. Please note that if you are a resident of the Province of Quebec, you are only permitted to use the Platform if you are at least 14 years old.

Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request or that they are authorized to act on behalf of another individual in such matters.

Your Choices. For more information about managing your account and privacy settings, please visit PSettings page.rivacy Settings in Settings.

Internal Policies and Access Controls. We implement and maintain internal policies and technical measures to restrict access to your personal information within our organization. Access to personal information within our organization is limited to employees who need the information to perform their job functions. For example, our customer support team may have access to certain types of information during our interactions with you, such as responding to complaints and inquiries. Similarly, our content moderators may access certain information in order to enforce our Terms of Service, Community Guidelines, and other conditions and policies.

Data Retention Practices. We have procedures in place to limit the retention periods as set out in the “Data Retention” section above. When personal information is no longer needed for these purposes or is no longer required to be retained by law, we take appropriate steps to dispose of it securely in accordance with our internal procedures.

Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec). For information about how we or our service providers (including service providers outside Canada) process personal information, please contact us using the contact information set out below. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.Contact. If you are a resident of Canada, you can contact us at inspaze.src@hellospace.group.

EU/UK

IF YOU ARE EU or UK RESIDENTS, you have the right:

● To request access to or a copy of any personal data which we hold about you;

● To rectification of your personal data, if you consider that the information we are holding is inaccurate;

● To ask us to delete your personal data, if you consider that we do not have the right to hold it;

● To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);

● To ask us to stop or start sending you marketing messages as described below in the marketing section;

● To restrict processing of your personal data;

● To data portability (moving some of your personal data elsewhere) in certain circumstances;

● To object to your personal data being processed in certain circumstances; and

● To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond as soon as we can after verify your identity in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

For EU, UK residents, we shall provide information on action taken on a request under GDPR Articles 15 to 22 to the you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. If for legitimate reasons, we cannot provide you with the information you need, we shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for 6 tax years plus current tax year after they cease being customers for tax purposes.

When your information is transferred outside of your country of residence, our partners will use adequate safeguards, which may amongst others include EU-approved standard contractual clauses, which are available on the EU Commission website. (https://commission.europa.eu/law/law-topic/data-protection_fr).

If you are unsatisfied with how your request is being handled. To get in touch with him or her for any information concerning our processing of Personal Information, please contact us:

Email: inspaze.src@hellospace.group

If you have any concerns about our use of your information, you may also have the right to make a complaint to the Data Protection Authority in your country according to applicable laws. You can refer to this page for more information: https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en

Egypt

This privacy policy is provided in Arabic for users located in Egypt.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 14 and that you have read and acknowledged the Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

By clicking the button to proceed or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this privacy policy. If you do not consent to this privacy policy, you must not use the Platform.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates.

You also acknowledge your consent to receiving marketing messages from us.As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

Hong Kong SAR

If you choose not to provide your Personal Information, you may not be able to use inSpaze properly.

As a Hong Kong SAR data subject you have legal rights in relation to the Personal Information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request (to receive a copy of the data we process about you). You can also exercise your right to data correction as well as your right to stop to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

"Sensitive Personal Information" means passwords, financial information (such as bank account or credit card or debit card or other payment instrument details), biometric data, data relating to physical or mental health, sex life or sexual orientation, and/or medical records or history, and similar information, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

In the circumstances enumerated in the Privacy Policy, where we permit any third parties to collect and use your Sensitive Personal Information, we shall (i) ensure that such third parties maintain the same security standards that are adhered to by us for the protection of your Sensitive Personal Information and (ii) take reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information.

If you believe we hold any other Personal Information about you or your children, and that information is inaccurate, or you have queries regarding the processing, transfer or end-use of your Personal Information, please contact us at inspaze.src@hellospace.group.

You do not have the right to retrospectively retract consent or request for deletion of records required for statutory purposes but can withdraw consent to any further processing of your or your children's Personal Information.

In accordance with applicable data privacy laws and regulations in India, we shall take appropriate, reasonable technical and organisational measures to prevent the loss of, damage to or unauthorised access to or processing of your Sensitive Personal Information.

Macau SAR

You have the right not to provide your Personal Information. However, as a result, we may not be able to provide inSpaze to you. As a Macau SAR data subject you have legal rights in relation to your Personal Information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your Personal Information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In the event you are agreeing to the Privacy Policy in order for a minor (a person under the age of 18) to access and use inSpaze, you hereby consent to the provision of Personal Information of the minor to be processed in accordance with the Privacy Policy and you personally accept and agree to be bound by the terms in the Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with the Privacy Policy.

In relation to users in Malaysia, our servers are located outside of Malaysia and you consent to the transfer of your data outside of your country.

Right of access: You have the right to request access to and obtain a copy of the Personal Information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your Personal Information in the amounts permitted by law.

When handling a data access request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

We will comply with data access requests within the time periods as stipulated under Malaysian data protection laws.

Right of correction: You may request for the correction of your Personal Information. When handling a data correction request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your Personal Information: You may request limiting the processing of your Personal Information by using the contact details provided in the Privacy Policy. However this may affect our provision of inSpaze to you.

To protect your Personal Information and handle complaints relating to your Personal Information, we have appointed a data protection officer, responsible for the management and safety of your Personal Information, who can be contacted at:inspaze.src@hellospace.group.

Mexico

If you are using our services in Mexico, 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 policy, the following terms shall prevail.

How we use your personal data. Almost all purposes of processing stated in this section of the main Privacy Policy are necessary purposes.

How we share your personal data. We may share your personal data to a third party for purposes other than processing on behalf of us. We will obtain your consent for such sharing as required by applicable laws.

By providing us with your personal data and using our Platform you agree to the transfers that require your consent. You can always revoke your consent and exercise your rights, as stated below.

Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, opposition, consent withdrawal, limitation to the use and disclosure of your data. You can exercise your rights by sending your request to inSpaze.src@hellospace.group. To know more about the applicable requirements and procedure to exercise your rights, contact us to the mentioned email address. If you are under 18 years, you may exercise your rights through a parent or guardian. Your rights requests will be resolved as soon as possible according to the nature of your request.

Philippines

If you are using our services in the Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

If you are under the age of 18, you undertake that you have obtained your parent or legal guardian's consent to register an account on and use inSpaze.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Singapore

By clicking "accept", you consent to the collection, use and disclosure of your Personal Information, for the purposes set out in the section "How we use your information" in the Privacy Policy, and which we will process as an "organisation" as defined under the Personal Data Protection Act 2012.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at inspaze.src@hellospace.group.

You have the right to access your Personal Information, how we use it, and who we share it with. You can access the Personal Information you have made available as part of your account by logging into your account. If you believe we hold any other Personal Information about you, please contact us at inspaze.src@hellospace.group.

You have the right to correct any of your Personal Information that is inaccurate. You can access the Personal Information we hold about you by logging into your account. If you believe we hold any other Personal Information about you and that information is inaccurate, please contact inspaze.src@hellospace.group.

South Korea

If you are using our services in South Korea, 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 policy, the following terms shall prevail.

Children under the age of 14 must not use inSpaze for any purpose. Please contact us if you believe we have any Personal Information from any children under the age of 14 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

● Profile information, including biography,decoration,background music,social media,region and other expanded information, to provide you with better service and experience. You can delete the information at any time by going to “Profile” from within inSpaze. If you do not provide this information, it will only prevent you from using or participating in services related to this, and will not affect the basic functions of using inSpaze products or services.

Data retention. In principle, after the purpose of collecting and using personal information is achieved, the information is destroyed without delay. In addition, it is necessary for us to retain the information even after the purpose of collection and use is achieved in accordance with the provisions of relevant laws and regulations. Relevant laws and regulations to retain the user’s information are as follows:

1)Records on display/advertisement: 6 months (The Act on the Consumer Protection in Electronic Commerce)

2)Records on contract or subscription withdrawal: 5 years (The Act on the Consumer Protection in Electronic Commerce)

3)Records on payment and supply of goods: 5 years (The Act on the Consumer Protection in Electronic Commerce)

4)Records on consumer complaints or dispute settlement: 3 years The Act on the Consumer Protection in Electronic Commerce)

5)Records on website visits: 3 months (Protection of Communications Secrets Act)

You can contact us at any time through 【inspaze.src@hellospace.group】. After verifying your identity, we will delete or anonymize your information. You may also delete your entire account in Settings

● Destruction procedure : Personal Information that needs to be destroyed is destroyed in accordance with the law or regulation under the supervision of our Data Protection Officer.

● Destruction method : For personal information stored in the form of an electronic file, we will delete the information using a technical method such as anonymization/ de-identification that cannot be reversed to make sure that it cannot be reproduced or reused. Printed personal information will be destroyed by shredding or incineration.

You acknowledge and agree that to improve the quality of our services, sometimes we may need your user data for research or statistical purposes , in which case we will make sure your personal information has been desensitized, de-identified and anonymized first (so that it can no longer be associated with you) and we may use this information without further notice to you.

Data rights. You have the right to access 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 inspaze.src@hellospace.group.

Data Security. We work hard to protect inSpaze and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal data on a need-to-know basis and controlling access to the facilities where personal data is processed.

Entrustment and/or Overseas Transfer of Personal Data. We entrust your data to our affiliates, cloud storage providers and IT service providers, some of whom are located abroad, subject to your consents or notifications to you, if applicable. Where appropriate, we ensure that such entities which receive and process your data are subject to contractual obligations to store and use personal data in compliance with applicable domestic and international regulations and take appropriate physical and technical measures to protect personal data. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Service, by contacting us here.

Identity of the overseas recipient Location of the recipient Purpose of use Items Method Deletion contact
ilivedata Singapore Translation service Text to be translated Transmitted from time to time Retained for such time as stated in the privacy policy of the relevant third party service. Please refer to the privacy policy of the relevant third party service for contact information. https://www.ilivedata.com/site/privacy-agreement
ishumei Singapore content moderation service User-generated public content to be reviewed Transmitted from time to time Retained for such time as stated in the privacy policy of the relevant third party service. Please refer to the privacy policy of the relevant third party service for contact information. https://www.ishumei.com/legal/cn/privacy.html

Changes. We may update this Privacy Policy from time to time to accommodate changes in technology, law, our operations, or for any other reason we determine is necessary or appropriate, you agree to review it for the updates on this page frequently. We will indicate the last updated Date at the top of this page. We may also notify you 7 days in advance or 30 days in advance for material changes by placing a clear notice in the Services, on our websites, sending push notifications, or other notification methods that may be appropriate based on the nature of the updates (If the updated content may have a significant impact on your rights). Your continuous use of any of the Services after the effective date will be deemed as your acceptance for the updated Privacy Policy.

These Terms are drafted in the English language and will be translated into other languages. The English language version of these Terms shall prevail if there is any conflict or inconsistency requires clarification.

Contact. Questions, comments and requests regarding this policy are welcomed and should be addressed to inspaze.src@hellospace.group.

The information of our DPO is as followed. If you are unsatisfied with how your request is being handled, you may also lodge a complaint to our DPO. To get in touch with him or her for any information concerning our processing of Personal Information, please contact our DPO:

name: Yang

email: inspaze.src@hellospace.group.

And for teenager protection in South Korea, the contact information of our Teenager Protection Officer is as followed:

name: Yang

email: inspaze.src@hellospace.group.

Sri Lanka

By clicking "accept", you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your Personal Information.However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use inSpaze.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your Personal Information, we will provide you with our response to the request within 21 working days.

Taiwan,China

In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using inSpaze.

You may exercise the following rights as set forth in Article 3 of the Personal Data Protection Act: (1) access your Personal Information to check and review it; (2) have a copy of your Personal Information; (3) supplement or correct your Personal Information; (4) demand that we cease the collection, processing, or use of your Personal Information; and (5) demand that we delete your Personal Information. To the extent permitted by law, there may be limitations on our ability to comply with your request.

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use inSpaze.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian's consent to register an account on and use inSpaze.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

● withdraw your consent to the processing of your Personal Information (only where the legal basis for our processing is consent); however, please note that where consent is required to process your Personal Information, we may not be able to deliver the expected service without it;

● request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your Personal Information;

● request us to provide you or a third party with your Personal Information which is stored by us in a machine readable format; and/or

● lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us at inspaze.src@hellospace.group.

Türkiye

If you are using our services in Türkiye, the following additional terms apply along with the contents of the foregoing Policy. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Data Controller Representative. You may contact our data controller representative in Türkiye by email or mail to handle questions and complaints in connection with the processing of your personal data if you are in Türkiye.

inspaze.src@hellospace.group

Hürriyet, Dr. Cemil Bengü Cd. NO:4 KOLEKTİF HOUSE MİNT METRO. 302

ODA/KAĞITHANE/İSTANBUL

United Arab Emirates

 If you are using the Platform in the United Arab Emirates (“UAE”), the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail: 

In the case of users located in the United Arab Emirates, the minimum age to be able to legally agree to commercial transactions is 21 (under the Hijri calendar). However, a minor, who is between the ages of 18 and 21 may obtain a court order giving him/her permission to engage in specific commercial transactions.

1. How we share your personal data

In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy. 

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note also that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team ("CERT"). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

2. Governing law

By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE.

Vitenam

If you are using our services in Vietnam, 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 policy, the following terms shall prevail.

By accepting the Privacy Policy, you expressly agree and authorize us to collect, use, store, and process your Personal Information, including, lawfully disclosing and transferring it to third parties, as described in the Privacy Policy.If you are below 16 years old or under guardianship:

● you must obtain approval from your parent(s) or legal guardian(s); and

● your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Platform if you are not at least 16 years of age.

Data subject's rights and obligations. Subject to certain exceptions, you have statutory rights and obligations under applicable laws. In particular, you have the following statutory rights:

Right to know;

Right to consent and withdraw consent;

Right to access;

Right to delete data;

Right to restrict data processing;

Right to be provided with data;

Right to object data processing;

Right to complain, denounce or initiate lawsuits;

Right to claim for damages; and

Right to self-protection.

You may exercise these rights by contacting us through the details in the Contact section, and we will respond to your requests regardless of the location in which your data is stored.

You have the following statutory obligations:

Protect your own personal data;

Request other relevant organizations and individuals to protect your personal data;

Respect and protect personal data of others;

Provide complete and accurate personal data upon giving consent to the processing of your personal data; and

Other obligations under applicable laws.

We maintain international standards and security practices for data protection. When your Personal Information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

Your Personal Information, if required to be disclosed to the competent law enforcement agencies, public authorities or other judicial bodies and organizations, will be disclosed upon receipt of written request from such organizations.

Where required by the law and regulatory requirements of your jurisdiction from time to time, we may retain all or part of your Personal Information for a period longer than described in the Privacy Policy.

You have the right to access, correct, and erase the Personal Information we hold about you. You also have the right to withdraw your consent to collect, store, process, use and disclose your Personal Information and to request us to stop processing or providing your Personal Information to a third party.