JOWO Privacy Policy
Last Updated: November 1, 2024
We understand the importance of personal information to you, and we are committed to protecting your personal information.
The JOWO Privacy Policy (hereinafter referred to as “the Policy”) aims to explain the rules for collecting, using, storing, processing, and protecting your personal information, and how you can exercise your right as the subject of your personal information when you use JOWO and other related applications, websites, and services (hereinafter referred to as “JOWO Services” or “the Services”) provided by CREST DIGITAL MEDIA PTE. LTD. (a company registered and validly existing under the laws of Singapore, registered address: 331 NORTH BRIDGE ROAD #22, ODEON TOWERS, SINGAPORE 188720).
If you have any questions about the Policy, you can contact us at any time.
Table of Contents
I. How We Collect and Use Your Personal Information
II. How We Share and Disclose Your Personal Information
III. How We Store and Protect Your Personal Information
IV. Your Rights and Choices
V. Protection of Minors
VI. About The Policy
VII. Contact Us
VIII. Dispute Resolution
I. How We Collect and Use Your Personal Information
A. Collection of Personal Information
When you use the Services, we will collect and use some of your personal information. The types of information we collect and how we use this information depend on how you use the Services, and we may collect your personal information through different channels.
Information You Provide to Us
(1) Account Information
We will collect the personal information you provide when registering/logging in, including your phone number or email, password, and birthday. You can also fill in your gender, nickname, avatar, etc., during registration or subsequent use. You should ensure the accuracy of such information. We collect this information to provide you with account registration and login services, ensure your account security, and improve your online profile.
(2) Information Provided When Contacting Us
When you contact us, to ensure your account and system security, we may need you to provide relevant personal information for identity verification. Upon successful verification, we will provide customer service based on your contact method (phone number/email/other contact methods you provide), your communication with us (including text/pictures/audio and video), and other necessary information related to your needs. During this process, we will collect the above personal information you provide to resolve your issues.
Information We Collect Automatically
(1) Device Information
We collect automatically the information about your device when you access the Services, including your IP address, device type, device model, device name, advertising device identifier, device ID, browser type and settings, operating system, language settings, mobile network information (including carrier name and phone number), application version information, storage information, and other technical information. We collect this information to achieve the basic functions of our products, ensure your account and system security, and provide you with consistent and stable services.
(2) Usage Information
When you use JOWO Services, we automatically collect information about the videos you watch, search terms, the frequency and interaction with videos and ads, the time and frequency of your use of the Services, your purchase activity information, information you collect/share, and other interaction information with our website. We collect this information to provide you with the content you need. To better understand users, we use this information to analyze your video viewing preferences to recommend videos and ads that may interest you.
(3) Your Location Information
We collect your location information when you use the Services to provide practical functions such as recommending better videos and ads in your area. We infer your approximate location through your IP address.
(4) Log Information
We automatically collect log information when you use JOWO Services, which may be obtained through cookies, web beacons, log files, scripts, electronic tags, or other means.
Information from Third Parties
(1) Third-Party Account Information
If you log in to the Services using a third-party platform account (such as Facebook/Google/Apple ID/Google ID), we will obtain your account information from the third-party platform (including name, avatar, phone number, email, etc., as authorized by you) to create or log in to your JOWO account, provide login user services, and ensure your account security and prevent security risks.
(2) Third-Party Payment Information
If you purchase our VIP services or other paid content, third-party payment service providers that we work with (such as Apple Pay, Google Pay, MasterCard, etc.) will provide us with your payment information or payment updates to verify your payment status and provide you with the purchased services. Please note that we only collect your purchased product information, payment transaction number, and channel ID, and do not collect any of your bank card account numbers, payment passwords, or other payment information.
(3) Information from Publicly Available Sources
Such as government public data, publicly available data on social media platforms, etc.
(4) Information from Other Sources
You acknowledge that we cannot and will not obtain your personal information collected by third parties without authorization. If we need to indirectly collect your personal information from third parties due to business cooperation, we will ensure the legal collection and use of information through multiple layers and channels: (1) We will take measures, including but not limited to contractual agreements, to ensure that the third party has obtained your consent or collected your personal information within the scope permitted by relevant laws and regulations; (2) We (or the third party) will clearly inform you of the source, type, purpose, method, and business function of your personal information before collection, and obtain your authorization and consent again if the use method and scope exceed your original authorization; (3) We will require the third party to commit to the legality of the personal information source through agreements, and if the third party violates, we will clearly require them to bear corresponding legal responsibilities; (4) Our professional security team will strengthen the security of personal information. We will protect indirectly obtained personal information with protection measures no less than those for our users' personal information.
B. Use of Personal Information
We may use the information collected in JOWO Services for the following purposes based on different types of information.
(a) To fulfill and perform our contract with you and execute our agreement with you;
(b) To provide, process, maintain, develop, and improve JOWO Services (including video content, advertisements, paid services, etc.);
(c) To provide personalized recommendation services (including video content, advertisements);
(d) To evaluate your application (if applicable), respond to your questions/inquiries/feedback/disputes;
(e) To process your registration, login requests, verify and execute transactions related to your online payments;
(f) To communicate with you, including sending you commercial marketing information, operational activity notifications, agreement text updates, etc. We may use one or more contact methods (such as email, phone, SMS, contact address) you provide during the use of the Services to contact you, send you security verification messages, product and service updates, activity information, offers, user experience surveys, etc. You can unsubscribe through the method provided in Section IV (5) of this Policy;
(g) To monitor, prevent, or investigate any fraud, abuse, security risks, and technical issues that harm JOWO, you, or the public, protect your account and system security, and improve the security and reliability of JOWO Services;
(h) To conduct market research and trend analysis, comprehensive statistics, data analysis, processing, and investigation related to JOWO Services;
(i) For other purposes disclosed to you when collecting your information or with your consent.
C. Cookie Terms
Cookies are small files containing strings of characters that are sent to and stored on your computer, mobile device, or other devices when you log in and use websites or other online content (usually encrypted). Cookie-like technologies are other technologies that can be used for similar purposes as cookies, such as Web Beacons, Proxy, embedded scripts, etc. In this Policy, we collectively refer to all such technologies as “Cookies.” Generally, we use Cookies to collect your personal information when you register, log in, and use our Services, such as your website visit habits, browsing information, login information, etc.
We use Cookies mainly to simplify operational steps (such as keeping the login status), protect your account information and our product security, measure and analyze the pages you click and how you use the platform, record your preference settings, recommend content you need and may be more interested in, improve website performance, monitor our website's visitor traffic and operations, measure, analyze and optimize our platform's advertising performance to enhance user product experience and improve our Services.
You can manage or delete Cookies stored on your computer, mobile device, or other devices through the relevant functions of your browser or device. Some of our Services can only be realized through the use of Cookies. If you refuse to use or delete them, you may not be able to use our related Services normally or obtain the best service experience through our Services, which may also affect your information protection and account security.
II How We Share and Disclose Your Personal Information
A. Sharing of Personal Information
1. Information You Share Yourself
You can share your personal information or other information with third parties (including unspecified objects) based on JOWO Services, such as using the sharing function in our Services. You can choose to share relevant information through email, SMS, social applications (such as Facebook), or other applications. Information you share in third-party applications is controlled and processed by the third party and is subject to their terms of service and privacy policies. We are not responsible for any information leakage or misuse caused by your sharing behavior, and you need to bear the corresponding legal responsibilities yourself.
2. Information We Share
We generally do not share your personal information with third parties. If one or more of the following situations exist, we will share your information with the following third parties in compliance with the legal requirements of your jurisdiction:
2.1 You actively request or consent to share;
2.2 Sharing with Business Partners
You understand and acknowledge that some of our Services will be provided by business partners or jointly provided by us and business partners. Therefore, you agree that we may share your necessary personal information with the following partners for the purposes stated in this Policy:
a. Service providers, such as marketing agencies providing marketing services, payment institutions providing payment services, logistics service providers, and other partners providing service function support, such as Apple Pay, Google Pay, Salesforce, etc.;
b. Data processors (including data processors providing online advertising data monitoring, data statistics, data analysis, etc.). To analyze/maintain/improve our Services and provide better content, we may share your relevant information (such as video playback records, ad display records, terminal models, your city, etc.) in aggregated form with designated partners providing such services (such as Comscore, Google). The aforementioned information does not involve your personal identity information. Please rest assured that unless we obtain your consent, we will not share your personal identity information with them;
c. Advertising partners, such as Google, Smaato, OpenX, etc., during our cooperation in advertising business, we will share device ID, advertising device identifier, user age and gender tags, IP address, etc., to help them make advertising or decision recommendations, improve ad reach effectiveness, and better understand user needs. We promise not to share personally identifiable information without your consent;
d. Operational activity service partners. We may be sharing information of winners in joint marketing activities with third parties (such as your name and other information) to timely issue prizes/gifts to you;
e. Third-party SDK service providers. Our products may include third-party SDKs or similar applications. If you use such services provided by third parties on our platform, you agree that they will directly collect and process your information (such as embedded code, plugins). The collection and processing of information by such service providers are subject to their privacy policies and not this Policy. However, we will review the business qualifications of such third parties and strive to ensure their legal compliance and security. To maximize the protection of your information security, we strongly recommend that you review their privacy policies before using any third-party SDK services. To protect your legal rights, if you find that such SDKs or similar applications pose risks, we recommend that you immediately stop related operations and contact us promptly.
f. Other business partners, such as Astro, Singtel, etc., with whom we have commercial cooperation.
When sharing your information, we will take various measures to protect your personal information security, including but not limited to: (1) If your authorization is required again, we will inform you of the purpose, type, and recipient of the information and obtain your authorization and consent before sharing; (2) We will strictly stipulate the personal information protection obligations and legal responsibilities of the information recipient through agreements; (3) Our security team will conduct security assessments and processing of the information's output form, flow, and use, and anonymize personal information as much as possible; (4) If your information is transferred to other countries/regions due to the above sharing matters, whether transferred to our affiliates or third-party business partners, we will ensure that all such data cross-border transfers meet the requirements of applicable data protection laws.
2.3 Sharing Your Information As Per Legal or Regulatory Requirements
(1) In certain circumstances, we may share your personal information with third parties (such as judicial authorities, law enforcement agencies, government agencies, or other similar third parties) to comply with legal requirements, regulatory requirements, so as to protect your, our legitimate rights and interests, or public interests, property, or safety from harm;
(2) In certain circumstances, only by sharing your personal information can we achieve the functions of our services or provide the services you need, or handle disputes or conflicts related to you;
(3) Sharing your personal information in accordance with the relevant agreements (such as online agreements, platform rules) or legal documents signed with you;
(4) The information we share is de-identified. The third party receiving the information cannot re-identify the information subject, or the personal information publicly disclosed by you, or the information we collected from legally public channels.
(5) Other situations required by laws and regulations or regulatory authorities.
2.4 Third Parties Related to Certain Transactions
If we undergo mergers, acquisitions, reorganizations, splits, bankruptcies, asset transfers, or similar transactions, your personal information may be transferred as part of such transactions. We will notify you and require the new holder to continue to comply with and perform all the contents of this “JOWO Privacy Policy” (including usage purposes, usage rules, security protection measures, etc.).
B. Disclosure of Personal Information
Except for necessary disclosures to punish violating accounts, fraudulent behaviors, etc., announce winner lists, comply with court judgments or other legal procedures, relevant government agencies or legally authorized organizations' requirements, and other reasonable reasons for legal requirements, we will not publicly disclose your personal information. If there are reasonable reasons for public disclosure, we will inform you of the purpose, type of information to be disclosed, and obtain your authorization or consent before public disclosure.
Please note that even with your authorization or consent, we will only publicly disclose your personal information for legal, fair, necessary, specific, and clear purposes and anonymize the personal information in the disclosure content as much as possible.
III How We Store and Protect Your Personal Information
A. Storage of Personal Information
a. Storage Location: Currently, JOWO runs data centers in Japan. You understand and agree that under the conditions and terms stated in this Policy, we may transfer and store your personal information in the aforementioned data centers, although the data protection standards in these data centers may differ from those in your jurisdiction. We will strive to protect your personal information according to strict standards and minimize the risk of personal information leakage.
As stated in this Policy, we may share your personal information with third parties, who may be located outside Japan. We will transfer and process your personal information after meeting the applicable laws and regulations for cross-border transfers.
b. Storage Period: Generally, we only store your personal information for the period necessary to provide our services and the shortest period required. After the storage period, we will delete or anonymize your personal information according to relevant laws and regulations. However, in the following situations, we may change the storage period of information to comply with legal requirements:
(1) To comply with applicable laws and regulations;
(2) To comply with court judgments, rulings, or other legal procedures;
(3) To comply with relevant government agencies or legally authorized organizations' requirements;
(4) We have reasons to believe that we need to comply with relevant laws and regulations;
(5) For the execution of relevant service agreements or this Policy, to maintain public interest, protect the personal and property safety or other legitimate rights and interests of us, our affiliates, our partners, other users, or employees.
Specifically, if you are a user in Canada, if we use your personal information to make a decision that directly affects you, we will retain the information for at least one year after use to give you a reasonable access to the information. Even if you change or cancel your consent for us to collect, use, share, or disclose your personal information, we may still retain such information if there are legal reasons.
If our products or services cease to operate, we will notify you through push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period.
B. Protection Measures for Personal Information
We adopt industry-standard security technical measures and supporting organizational structures and management systems to protect your personal information security, minimizing the risk of information leakage, damage, misuse, unauthorized access, unauthorized disclosure, and alteration. Our specific protection measures include:
1. Data Security Technical Measures
We use encryption technologies such as Transport Layer Security (TLS) to prevent the risk of sniffing and interception during transmission; adopt security storage measures such as data classification and grading; strictly control data permission systems, use multi-factor authentication technologies, monitor data processing behaviors to avoid unauthorized access and use; monitor the entire data life cycle to prevent unauthorized access, public disclosure, use, modification, accidental or intentional damage or loss of personal information.
2. Data Security Organizational and Management Measures
We build a dedicated personal information protection responsibility department, formulate business data security usage rules, data cooperation specification management systems, and other related internal control management systems to minimize employee authorization permissions; regularly organize employee training on information security protection, and other feasible security organizational and management measures, such as encrypting personal information storage areas, and restricting employee access to storage areas.
3. Handle Security Incidents
We have a JOWO Security Emergency Response Center, to formulate multiple security management systems and emergency response plans, and clarify security incident reporting processes and emergency response handling processes. In the face of a personal information security incident, we will activate the emergency plan to prevent the expansion of the security incident and notify you through phone, push notifications, announcements, emails, etc.
Please note and understand that the internet is not an absolutely secure environment. Despite the above protection measures, we cannot fully guarantee or ensure the security of our services or any information you provide to us. If your personal information is leaked, it may affect your personal and property safety. Therefore, we strongly recommend that you choose secure access methods, use complex passwords, so as to help us ensure your account security. If you find that your personal information is leaked, please contact us immediately so that we can take corresponding measures to protect your information security.
IV. Your Rights and Choices
You have various rights and choices regarding your personal information in our Services as stipulated by applicable laws and regulations. Your rights and choices may include but are not limited to:
(1) Access Your Personal Information
You have the right to inquire or access your relevant personal information in our Services, including contacting us directly or accessing it within the product. Our products provide information inquiry and access functions, including:
- Inquiry/Access Account Information: You can log in to your personal account at any time through the relevant product page to access your account's personal profile information, including avatar, nickname, birthday, gender, etc.
- Inquiry/Access Usage Information: You can check some of your usage information at any time through the relevant product page, including collection records, viewing history, offline download records, etc.
(2) Correct/Modify Your Personal Information
You have the right to correct/modify some of your personal information in our Services according to the operational guidelines and settings provided on the product function page. You can also contact us directly to correct or modify your relevant personal information.
(3) Delete Your Personal Information
You have the right to delete your relevant personal information in our Services. You can contact us directly to delete your account.
If we violate legal regulations or our agreement with you by collecting, using, or sharing your personal information, you can directly request us to delete your personal information or ask us to notify third parties who have received your information to delete it, except for data that has been anonymized or as otherwise required by laws and regulations.
You understand and agree that after you or we assist you in deleting relevant information from our Services, due to the limitations of applicable laws and security technologies, we may not be able to immediately delete the corresponding information from the backup system. In this case, we will securely store your personal information and isolate it from any further data processing until the backup system is updated to delete or anonymize this information.
(4) Other Rights
If you encounter any problems while exercising the above rights, you can contact us through the contact methods provided in this Policy. We will verify your identity and help you resolve the issue within a reasonable period or within the period stipulated by the laws of your jurisdiction, except as otherwise provided by laws and regulations or this Policy. In addition to the above rights, if the laws of your jurisdiction grant you other personal information rights, we will still strive to ensure the realization of those rights. Specifically, if you are a resident of California, USA, and we are subject to CCPA jurisdiction, we will protect and realize your consumer rights in accordance with CCPA regulations.
V Protection of Minors
You must be at least 18 years old to use JOWO Services.
We attach great importance to the protection of minors' personal information. The age definition and privacy protection rules for minors vary in different jurisdictions. If you are over 18 years old but still considered a minor under the laws of your jurisdiction, you should read this Policy accompanied by and under the guidance of your guardian, and obtain your guardian's consent to this Policy before submitting your relevant personal information. Please note that due to the nature of the internet and the anonymous rights of users, it is difficult for us to verify the authenticity of your guardian's consent. Therefore, if you fall under the aforementioned circumstances, please ensure you have obtained your guardian's consent.
If you believe we have collected personal information from minors without their consent, please contact us through the contact methods provided in this Policy.
VI About This Policy
(1) Scope of This Policy
Our Services may be provided through third-party platforms, use functions operated by third-party platforms, or contain links to websites operated by third parties. The information processing rules of these third parties are determined by them and may differ from ours. Third-party websites, applications, platforms, etc., have independent privacy policies, and this Policy does not apply to them. Therefore, we recommend that you carefully read their privacy policies. For example, when links to third-party websites operated by third parties appear in our App, we will notify you or mark them as “third-party products,” “third-party services,” or similar expressions.
(2) Updates to This Policy
Based on the continuous innovation and development of JOWO's business model and technical functions, we may update the terms of this “JOWO Privacy Policy” from time to time and notify you in accordance with applicable laws and regulations, which may include publishing notices, push messages, pop-ups, emails, or one or more methods, allowing you to review the updated privacy policy before choosing to continue using our Services. If such updates involve us collecting more of your personal information, or changes in the purpose, method, or third-party recipients of using/sharing personal information, we will obtain your authorization and consent again. We recommend that you review this Policy each time you use our Services. To check the last update time of this Policy, please refer to the “Last Updated” date at the top of the page.
VII Contact Us
(1) If you encounter privacy protection-related issues or have any questions about this Policy (including inquiries, complaints, suggestions, etc.) while using our Services, you can submit feedback online, or you can contact us at the following contact information:
Email: joywatch2023@gmail.com
Contact Phone: (65) 98069116
(2) We will respond to your questions after verifying your user identity within the response period stipulated by the laws of your jurisdiction. Generally, we will not charge you for this service.
VIII Dispute Resolution
If any court with jurisdiction rules that any provision of this Policy is invalid, that specific provision will be deleted from this Policy, but such invalidity will not affect the validity of the remaining provisions of this Policy. The remaining provisions of this Policy will continue to be enforced.
Both parties agree that, to the maximum extent permitted by applicable law, this Policy is governed by and interpreted in accordance with the laws of Singapore.
Any disputes arising from or related to this Policy (including but not limited to the enforcement of this Policy) shall be resolved through friendly negotiation. Either party may also submit the dispute to the Singapore International Arbitration Centre (“SIAC”) for arbitration in accordance with the SIAC Rules in effect at the time of submitting the arbitration application. The arbitration shall be conducted in Singapore, and the arbitration tribunal shall consist of one (1) arbitrator. The language of arbitration shall be Chinese. For the avoidance of doubt, friendly negotiation is not a prerequisite for submitting the dispute to SIAC for arbitration. The arbitration award shall be final and binding on both parties.