Last Updated: March 10, 2021

We understand that our users care about how their personal information is used and shared. On our way to Inspire Every Corner of the World Through Technology, we work hard to protect your information and take your privacy seriously.

By using our Services, you are agreeing to this Privacy Policy. Please read it carefully.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can review, update, manage, export, and delete your information. Our activities of collecting and processing your data will be done in good faith and be subject to the following principles:

1. purpose: processing done for legitimate, specific and explicit purposes of which the data subject is informed, with no possibility of subsequent processing that is incompatible with these purposes;
2. suitability: compatibility of the processing with the purposes communicated to the data subject, in accordance with the context of the processing;
3. necessity: limitation of the processing to the minimum necessary to achieve its purposes, covering data that are relevant, proportional and non-excessive in relation to the purposes of the data processing;
4. free access: guarantee to the data subjects of facilitated and free of charge consultation about the form and duration of the processing, as well as about the integrity of their personal data;
5. quality of the data: guarantee to the data subjects of the accuracy, clarity, relevancy, and updating of the data, in accordance with the need and for achieving the purpose of the processing;
6. transparency: guarantee to the data subjects of clear, precise and easily accessible information about the carrying out of the processing and the respective processing agents, subject to commercial and industrial secrecy;
7. security: use of technical and administrative measures which are able to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication, or dissemination;
8. prevention: adoption of measures to prevent the occurrence of damage due to the processing of personal data;
9. nondiscrimination: the impossibility of carrying out the processing for unlawful or abusive discriminatory purposes; and
10. accountability: demonstration by the agent of the adoption of measures that are efficient and capable of proving compliance with the rules of personal data protection, including the efficacy of such measures.

This Privacy Policy applies to the Services offered by TubeApp and does not apply to the information practices of other companies and organizations that advertise our Services or Services offered by other companies or individuals, including products or sites that may be linked to our Services.
WHAT INFORMATION DOES TUBEAPP COLLECT?
The information we collect can be generally placed in two categories:

• data on how the users use our Services;
• aggregate data on the content with which the users engage.

We collect information to provide better services to you—from figuring out basic stuff such as which language you speak to more complex things such as which ads you will find most useful or which TubeApp videos you might like. The information we collect and how that information is used depends on how you use our Services and how you manage your privacy controls.

You understand and consent that we may provide and share the information to our partners so that they too can provide you with an optimal experience, but we never disclose information to a partner in the manner that would identify you personally.

When you are not signed in to a valid account, we use the unique identifiers tied to the application or device you are using to collect information. When you are signed in with a third party account, e.g., your Google Account, we use that specific account to collect information.

For greater certainty, whenever you interact with our website or apps, we automatically receive and record information including your IP address, “cookie” information, and the page you requested from your browser on our server logs. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your acceptance of cookies, but this may prevent you from taking advantage of some of our features.

Whenever you interact with TubeApp, we automatically receive and record information on our server logs. The information we collect includes:

1. Services usage data. This may include your age and gender, the languages you use, the terms you search for, the videos you watch, your views and interactions with content and ads, voice and audio information when you use audio features, purchase activity, people with whom you communicate or share content, information regarding the version of our software you are using, the location where you download our software, how often you launch our software, and which features you use.
2. Data on the quality of our Services. This may include the interaction of your devices with our Services, such as IP address, crash reports, system activity, and the date, time, and referrer URL of your request, and your connection between your phone and your computer.
3. Data on user downloads. This may include information regarding which videos you download and your average download speed.
4. Aggregate statistics on content. This may include the number of contacts you have on your phone, how many contacts you have marked as favorites, and the number of apps, songs, videos, or other content you have on your phone. This information is only collected as meta-data, without reference to you or your contacts’ identities.
5. Hardware and software identification. This may include the device type, settings and image resolution, operating system, mobile network information including the carrier name and phone number, the version of the Android operating system, the size of your device’s screen, and internal storage. We support over 500 different Android devices and this helps us prioritize support for different kinds of hardware and software.
6. Location information. We may collect information about your location when you use our Services. Your location might be determined by GPS, IP address, sensor data from your device, and the information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices.

A few features to note:

1. If our software crashed when you were using it, the crash report sent to our server may contain some information about the operating system that you use.
2. If you download content via our desktop software, we store a copy to your computer so that the next time you connect your phone you don’t have to download it again.
3. If you provide us with your name and email address, we will use this information for the purpose of contacting you regarding our Services and products. You may opt-out of such communications at any time by unsubscribing through our Website or contacting us through one of the methods listed at the end of this policy.

The Company does not knowingly collect or solicit personal information from children under the applicable age in your country or knowingly allow such persons to register unless it is upon the specific and highlighted consent of at least one of the parents or the legal representatives of the child. If you are a child, please do not attempt to register for the Website or send any information about yourself to us without the permission of your parents or legal representatives, including your name, address, telephone number, or email address. No child may provide any personal information to the Company or on the Website without the necessary permission from their parents or legal representatives. We will use commercially reasonable efforts to verify that the consent referred to above was given by the child’s representatives, considering available technologies. When we learn that we have collected personal information from a child without parental consent, we will delete that information as quickly as possible. Children’s personal data may be collected without the consent mentioned above when the collection is necessary to contact the parents or legal representatives, used one single time and not stored, or for their protection, and under no circumstances shall the data be passed on to third parties without consent as provided herein. If you believe that we might have any information from or about a child, please contact us at hello@tubeapp.net.

The data we collect is sent to the Company servers in the USA in aggregate form and added to our system for analysis. Our Services will not collect the following information without your specific consent or satisfying the preconditions required by applicable laws:

• Your, your friends’, your cat’s phone numbers
• Any of the content of your text messages, either sent or received
• Your music, photos, video, or any contents you download via our Services
• Your sensitive personal data concerning racial or ethnic origin, religious belief, political opinion, trade union or religious, philosophical or political organization membership, data concerning health or sex life, genetic or biometric data, when related to a natural person

We will generally retain information for as long as required, allowed or for as long as we believe it useful. Even if the processing of personal data is terminated, we may continue to use and disclose your Personal Information in accordance with this Privacy Policy as amended from time to time to the extent allowed by applicable laws for purposes of

1. compliance with a legal or regulatory obligation by the controller;
2. transfer to third parties; or
3. exclusive use of the controller, with access by third parties being prohibited, and provided the data has been anonymized.

We do not purport to have listed all possible disclosures that we might make. This Privacy Policy is intended to help you understand our general practices. This policy is not a promise that your information will never be disclosed except as described above. For example, third parties may unlawfully intercept or access information transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information, despite a lack of permission. Although we use what we believe to be commercially reasonable practices to protect your privacy, that does not mean, and you should not expect it to mean, that your information or communications will always be private or protected.

WHY DOES TUBEAPP COLLECT INFORMATION?
To Be the Visionary in the Field of Content Discovery and Entertainment Evolution, we do our best to execute our core values: Kaizen and Create Value for Our Users. The information we collect from all our Services is for the purposes of providing better services to you.

• Provide, Maintain, Improve and Develop our Services. We use your information to deliver our Services, and to ensure our Services are working faster, better, and more stably. We also use the information we collect in existing Services to help us develop new ones to better suit our users’ needs.
• Provide Personalized Services. We use the information we collect to customize our Services for you, including providing recommendations and personalized content. We don’t show you personalized ads based on sensitive categories, such as racial or ethnic origin, religious belief, political opinion, trade union or religious, philosophical or political organization membership, data concerning health or sex life, genetic or biometric data, when related to a natural person. Also, we don’t share or use information that can personally identify you.
• Measure Performance. We use data for analytics and measurement to understand how our Services are used, which will help us to know the pros and cons of particular features and the performance of advertisers’ ad campaigns as well. The ability to measure our performance is an essential part of Kaizen.
• Interact with You. We may use the information we collect to contact you, which enables us to make sure the services we provide are safe and without interruption, e.g. when there is any abnormal action of your account or any important event that you need to know. It also enables us to respond to your request as soon as possible if there is a need.
• Protect Public Policy. We use the information to help improve the safety and reliability of our Services. We may carry out processing of personal data under the following circumstances: a) for compliance with a legal or regulatory obligation by the controller; b) by the public administration, for the processing and shared used of data which are necessary for the execution of public policies provided in laws or regulations, or based on contracts, agreements or similar instruments, subject to the provisions of Chapter IV of Brazilian General Data Protection Law, the Law No. 13,709, of August 14, 2018; c) when necessary for the execution of a contract or preliminary procedures related to a contract of which the data subject is a party, at the request of the data subject; d)for regular exercise of rights in judicial, administrative or arbitration procedures; e) for the protection of life of physical safety of the data subject or a third party; f) to protect health, in a procedure carried out by health professionals or by health entities; g) when necessary to fulfill the legitimate interests of the controller or a third party, except when the data subject’s fundamental rights and liberties which require personal data protection prevail; or h) for the protection of credit, including as provided in the pertinent legislation.

When the processing of personal data is a precondition for the provision of our Services or for the exercise of a right, you may exercise your rights as listed in this Privacy Policy. We use different technologies to process your information for these purposes, such as automated systems that analyze your content to provide you with things like customized search results, personalized ads, or other features. And we analyze your content to help us detect abuse such as spam, malware, and illegal content. We also use algorithms to recognize patterns in data.

YOUR RIGHTS OF YOUR PERSONAL INFORMATION

All natural persons are assured ownership of their personal data, with the fundamental rights of freedom, intimacy and privacy being guaranteed.

You have the right to obtain the following from the controller, namely the Company, regarding your information being processed by the controller, at any time and by means of an express request of you or your legally constituted representative to the processing agent, to the extent allowed by applicable laws:

• Confirmation of the existence of the processing. You may at any time confirm the processing of data by reviewing the terms and policies of the Company, emailing us or any other means provided by us.
• Access to the data. When you are signed in, you can review and manage your basic personal data as well as data regarding your use of the applications. When you are signed out, you can also manage your information associated with your browser or device.
• Correction of incomplete, inaccurate or out-of-date data. If you find out there is any incomplete, inaccurate or out-of-date information about you, you can contact us at any time regarding these issues and we will correct the information in accordance with what you reasonably provide.
• Anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of applicable laws. You can at any time expressly request us to anonymize, block or delete certain information which you believe is unnecessary or excessive for data processing and is not in compliance with applicable laws through email.
• Portability of the data to another service or product provider. By means of an express request and subject to commercial and industrial secrecy, you can export a copy of content in your Account if you want to back it up or use it with a service outside of TubeApp by emailing us, pursuant to the regulation of the controlling agency. This does not include data that has already been anonymized by the controller.
• Deletion of personal data processed with the consent of the data subject. You can choose to delete your personal information by emailing us unless the use and/or disclosure of the information is for the purposes of a) compliance with a legal or regulatory obligation by the controller; b) transfer to third parties; or c) exclusive use of the controller, with access by third parties being prohibited, and the provided data being anonymized.
• Information about public and private entities with which the controller has shared data. During the collection and processing of your information, we may share or disclose your personal data to third parties. The processor shall carry out the processing according to the instructions provided by the controller, which shall verify the obedience of the own instructions and of the rules governing the subject. You are entitled to know information about either public or private entities with which we have shared data by emailing us.
• Information about the possibility of denying consent and the consequences of such denial. You can choose to give or deny your consent to the processing of your information. As listed in this Privacy Policy, we collect and process certain information for certain purposes. The denial of consent will lead to the failure of such purposes such as providing certain services to you or improving our products. If you have any questions about the denying of consent such as the possibility of denying consent and the consequences of such denial, please contact us at any time as you wish.
• Revocation of consent. You can at any time revoke your consent, by express manifestation, through a facilitated and free of charge procedure to the processing of your information to the extent allowed by applicable laws. We provide various means for such revocation, e.g. through emails or privacy settings in the applications or your devices.

SHARING YOUR INFORMATION
When you manifestly make your information public, your consent is deemed to be made through your action and we no longer need further consent from you to the extent allowed by applicable laws.

We may only share your information with companies, organizations, individuals or other third parties outside TubeApp with your consent. We reserve the rights to provide information to our affiliates and other trusted partners to process it for us, under our instructions and in compliance with this Privacy Policy and any other applicable laws. We will also share your data outside TubeApp if we have abovementioned needs to Protect Public Policy.

To provide better and personalized services for you, you understand and agree that we may share necessary information through SDK or other insertion tools with certain third parties, including without limitation, Vungle and Pangle. The third parties may access, collect, store or share your information. You can check their privacy policies as listed at the end of this Privacy Policy.

INTERNATIONAL TRANSFER OF INFORMATION
Your information may be processed on servers located outside of the country where you live. Though the data protection laws vary among countries, we try our best to comply with all applicable laws. Regardless of where your information is processed, we apply the same protections described in this policy as well as comply with all applicable laws, including without limitation, the Brazilian Data Protection Law.

SECURITY MEASURES
TubeApp is built with reliable security features that continuously protect your information. We keep detecting and automatically blocking security threats from ever reaching you.

We work hard to protect you from unauthorized access, alteration, disclosure, or destruction of information we hold, including:

• We use encryption to keep your data private while in transit;
• We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
• We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
• We try to ensure that our Services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems.

CHANGES TO THIS POLICY
We regularly review this Privacy Policy and update it if it is necessary to make sure that we process your information in ways that comply with it as well as applicable laws. We will not reduce your rights under this Privacy Policy without your explicit consent. The date when the latest version was published will always be clearly identified. If changes are significant, we will provide a more prominent notice, including, for certain services, email notification of Privacy Policy changes.
CONTACT US
E-mail us at hello@tubeapp.net

EXTERNAL LINKS
Pangle: https://www.pangleglobal.com/zh/privacy/enduser-en
Vungle: https://vungle.com/privacy/

updated by yaohan on Mar 11, 2021