"SKOO"Privacy Policy
Welcome to the esteemed SKOO APP, hereinafter referred to as "we." We acknowledge the utmost importance of safeguarding your personal information and are fully committed to ensuring its safety and security. Our unwavering dedication to maintaining your trust compels us to adhere to the following principles: Consistency of Authority and Responsibility, Clarity of Purpose, Opt-in Consent, Minimum Access, Security, Subject Participation, Transparency, and more. By adhering to these principles, we aim to uphold your trust and protect your personal information. We pledge to implement robust security measures aligned with industry best practices to safeguard your personal information. To this end, we have formulated the SKOO Privacy Policy, hereinafter referred to as the "Policy" or "Privacy Policy," which applies to all SKOO products and services. This Policy also extends to products and services provided by our affiliates that utilize SKOO products/services and do not have their own distinct privacy policy. However, please note that this Policy does not cover services provided by third-party entities or SKOO products and services governed by separate privacy policies. Prior to using any SKOO products or services, we strongly encourage you to carefully read and understand this Policy. Proceed with the relevant products or services only after ensuring your full understanding and acceptance of its terms. By using SKOO products or services, you acknowledge your full understanding and agreement with this Policy. If you have any inquiries, comments, or suggestions regarding the contents of this Policy, please feel free to contact us through the various communication channels provided by SKOO. This paragraph remains unchanged, and the intended meaning of the sentences remains unchanged.
1. How we collect and use your personal information
Personal information encompasses any data, whether electronically recorded or otherwise, that can identify a specific natural person or reflect their activities, either alone or in combination with other information. We collect and utilize your personal information for the following purposes outlined in this policy:
(i) Facilitating User Registration:
To facilitate account creation and provide services, you may choose to sign in with an Apple account. The information provided during registration will be continuously licensed to us for the duration of your service usage. Upon voluntary account cancellation, we will anonymize or delete your personal information as soon as possible in accordance with applicable laws and regulations. Additionally, quick login registration generates a unique ID for you, which you are obligated to protect, with sale or transfer prohibited.
(ii) Product or Service Display and Promotion:
To enhance our offerings, we personalize information search and transaction services based on your browsing and search history, as well as device information. We may display and push relevant information using browsing and search history, device details, and indirect crowd profiling. You may opt-out of receiving commercial advertisements at any time.
During service usage, we collect and analyze information to streamline page displays and search results, understand product fit, and detect account irregularities. This includes device information obtained with user consent during software installation and use. Our website and clients automatically record service usage details as web logs. Device information and log data do not individually identify individuals. If non-personal data is combined with other data to identify individuals or used with personal information, it is considered personal information during combined use. Unless authorized or required by law, we anonymize and de-identify such information.
Communication and call logs, along with provided information, may be stored for issue resolution and record-keeping purposes when you reach out to us.
(iii) Other Uses:
We seek prior consent for using information for purposes not stated in this policy or for using collected information for different purposes.
(IV) Exceptions to Authorized Consent
According to relevant laws and regulations, the collection of your personal information in the following cases does not require your authorized consent:
1.In connection with crime investigation, prosecution, trial and judgment execution, etc;
2.For the purpose of maintaining the subject of personal information or other individuals' life, property and other important legal rights and interests but it is difficult to get your personal consent;
3.The collected personal information is disclosed to the public by yourself;
4.the personal information collected from legitimate public disclosure of information, such as legitimate news reports, government information disclosure and other channels;
5.Necessary for signing a contract according to your request;
6. necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of product or service failures;
7.Necessary for legitimate news reporting;
8.Necessary for academic research institutions to carry out statistical or academic research in the public interest, and to de-identify the personal information contained in the results when providing the results of academic research or descriptions to the outside world;
9.Other cases stipulated by laws and regulations.
If we cease to operate SKOO products or services, we will promptly cease activities to continue to collect your personal information, notify you of the cessation of operation in the form of one-by-one delivery or announcement, and delete or anonymize the personal information in our possession.
2.How we share, transfer, and publicly disclose your personal information
Sharing
We do not share your personal information with companies, organizations, and individuals outside of SKOO's service providers, except in the following circumstances:
(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties;
(2) Sharing under legal circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, the needs of litigation dispute resolution, or at the request of administrative or judicial authorities in accordance with the law;
(3)Sharing with Affiliated Companies: To enable the collaborative delivery of services to you through our affiliated accounts and to safeguard the personal and property safety of SKOO's affiliated companies, other users, or the public from infringement, we may share your personal information with them. We will only share essential personal information. For example, we may share your account information with our affiliates to assist you in using their products or services through your SKOO account. We will obtain your authorization again if we share sensitive information about you or if our affiliates alter the purposes for which they will use or process your personal data.
(4) Sharing Information with Authorized Partners: We may provide certain services in conjunction with authorized partners. This information sharing is limited to the purposes stated in our Privacy Policy. For the purpose of improving customer service and user experience, we may share some of your personal information with these partners. An example of such sharing could be to arrange for a partner to provide a service. We will only share your personal information for lawful, legitimate, necessary, and specific purposes that have been clearly identified. We will only disclose personal information that is required to provide the service. Our partners are not permitted to use the personal information they share for purposes that are unrelated to their products or services.
We share information with vendors, service providers, and other partners who support our business by providing technical infrastructure services, analyzing service usage, measuring advertisement and service effectiveness, providing customer service, facilitating payments, or conducting academic research and surveys.
Companies, organizations and individuals with whom we share personal information are subject to strict data protection agreements requiring them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.
Transfers
We will refrain from transferring your personal information to any companies, organizations, or individuals, except in the following circumstances:
(1) Transfer with Explicit Consent:
Your personal information will only be transferred to other parties with your explicit consent.
(2) Mergers, Acquisitions, Bankruptcy Liquidation, or Similar Scenarios:
In instances of mergers, acquisitions, bankruptcy liquidation, or similar scenarios where personal information may be transferred, the new organization holding your personal information must adhere to this policy. If they are unable to comply, we will require the company, organization, or individual to seek authorization from you again for consent.
Public disclosure
We will only publicly disclose your personal information in the following circumstances:
(1) We may publicly disclose your personal information with your express consent or based on your active choice;
(2) If we find that you have broken laws, regulations, or important SKOO agreements, or if disclosing your personal information is necessary to protect the safety of SKOO users, affiliates, or the public, we reserve the right to disclose your information to law enforcement agencies in accordance with applicable laws and regulations and the relevant SKOO agreements. You will be informed of the specific violation(s) and any measures taken by SKOO.
Exceptions to obtaining prior authorized consent to share, transfer, or publicly disclose personal information
In the following cases, sharing, transferring, or publicly disclosing your personal information does not require your prior authorized consent:
(1) Related to national security and national defense security;
(2)Relating to public safety, public health, and significant public interests;
(3)Relating to crime investigation, prosecution, trial and judgment execution, etc;
(4) For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to get my consent;
(5) Personal information that you disclose to the public on your own;
(6) Personal information collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other channels.
Sharing or transferring personal information processed and de-identified such that the recipient cannot re-identify the subject is not considered an act of sharing, transferring, or publicly disclosing personal information externally under the law. Additionally, such data preservation and processing will occur without further notification or approval of the subject.
3、How we protect your personal information
To ensure the security of your information, we will rigorously adhere to laws, regulations, and other regulatory documents requiring technical measures and operational procedures to protect the confidentiality of your information. Concurrently:
(1) We have implemented robust security measures based on industry standards to safeguard the personal information you provide, aiming to prevent unauthorized access, disclosure, manipulation, or loss of such information. Utilizing encryption technology and trusted protection mechanisms, we fortify the security of personal information and ward off malicious attacks. Furthermore, we have established a stringent internal control system and comprehensive management processes. Access control mechanisms are in place to restrict access to personal information to authorized personnel only. Additionally, we conduct security and privacy protection training courses to heighten employee awareness of the importance of safeguarding personal information.
(2) Our advanced data security management system focuses on data and encompasses the entire data lifecycle. We continuously enhance system security across various dimensions, including organizational construction, system design, personnel management, and product technology.
(3) We undertake reasonable and practical measures to minimize the collection of irrelevant personal information. Your personal information will only be retained for as long as necessary to fulfill the purposes outlined in this policy, unless mandated by law or requiring an extension.
(4) The internet poses security risks and it is advisable not to share any personal information through unapproved modes of communication. DRUG recommends using our services to connect and interact with others. When using our services to communicate, make transactions, or share information, you have the option to select a third party as the recipient. This third party will have access to your transaction details, contact information, communication details, shared content, and related information.
If you suspect that your personal information, particularly your account or password, has been compromised, please promptly contact DRUG customer service. We will take appropriate measures in line with your request.
Please note that by utilizing our services, you may voluntarily share or publicly disclose personal and sensitive information, such as uploading photos containing personal details in dynamic or public forums like group chats or circles. We advise exercising caution before sharing any relevant information on our platform.
For enhanced account security, please utilize strong passwords. Rest assured, we maintain the confidentiality of any information you provide.
We will periodically release and publish reports on security risks and personal data security assessments.
While we endeavor to ensure the security of your information, it's important to recognize that the internet environment is not entirely secure. In the event of damage to our physical, technical, or administrative protection facilities leading to unauthorized access, public disclosure, alteration, or destruction of information, resulting in harm to your lawful rights and interests, we will assume corresponding legal liability.
Following a personal information security incident, we will promptly inform you of the incident's basic details and potential impact, the measures taken or to be taken, suggestions for independently mitigating risks, and remedial measures. We will notify you of relevant developments through push notifications and effective announcements.
Additionally, we will proactively report the handling of personal information security incidents to regulatory authorities as required.
4、How you manage your personal information/your rights
(1) Access and edit your personal information
Account Information - To access or edit personal information, set privacy and permissions, or close your account, log in to your account and go to "My" - "Settings".
Personal Information - To edit the personal information in your profile, log in to your account and click on "My" Personal ID or "Edit".
If you can not access this information through the given path, please contact SKOO Customer Service. We guarantee a response to your request within 15 days.
For any additional personal information generated during your use of our products or services, we will provide it to you in accordance with the relevant arrangements.
2) Correction of your personal information
When you find that there is an error in the personal information we process about you, you have the right to ask us to make corrections or additions. You may make a request for correction or supplementation in the manner set forth in this Article "Accessing and Editing Your Personal Information".
(3) Deletion of your personal information
You may delete some of your personal information in the ways listed in this section "Accessing and Editing Your Personal Information".
In the following cases, you may request us to delete your personal information:
a. If our handling of personal information violates laws and regulations;
b. If we collect or use your personal information without your explicit consent;
c, If our behavior of handling personal information seriously violates the agreement with you;
d, If you no longer use our products or services, or you voluntarily cancel the account;
e. If we no longer provide products or services to you.
If your deletion request is accepted, we will notify any individuals who received your personal information from us. We will request that they promptly delete it, unless required by law or regulation, or if you have independently authorized it.
When information is deleted from our services, it may not be immediately removed from our backup system. However, we will delete this information when the backup is updated to ensure complete removal.
4) Managing the scope of your authorization
For each business function to be completed, basic personal information is required. You are authorized to give or withdraw your consent for the collection and use of additional personal information at any time.
Certain business functions and services require your personal information for fulfillment. If you withdraw your consent, we can not continue to provide these functions and services and will cease processing your corresponding personal information. However, your decision to withdraw consent will not impact our prior processing of personal information based on your consent.
5)User account cancellation
You can log in to SKOO by yourself (SKOO→click "My" icon→click the gear icon in the upper-right corner-system settings interface→"Account and Security"-click "Account Cancellation (Delete Account)" to apply for account cancellation). )", you can apply for account deletion. Please note that your account will be canceled instantly without any manual review after you have submitted a successful account cancellation application in accordance with the aforementioned process steps.
After you take the initiative to cancel your account, we will stop providing you with products or services, delete your personal information in accordance with the requirements of the corresponding laws, or make it anonymized.
(6) Constraints on automatic decision-making by information systems
In some business operations, we use automated decision-making mechanisms that rely solely on information systems and algorithms. If such decisions have a significant impact on your lawful rights and interests, you may request an explanation, and we will offer a channel for appeal that does not violate SKOO's trade secrets, other users' rights and interests, or the public interest.
7) Responding to your request above
If necessary, a written request or proof of your identity may be required for security purposes. We may ask you to confirm your identity before proceeding with your request.
We will respond within 15 days. If you are dissatisfied with our response, you can submit a complaint through SKOO Customer Service.
We will do our best to fulfill your reasonable requests. We may deny requests that repeat unnecessary information, demand extensive technical resources (e.g. the creation of a new system or a significant change in current practices), jeopardize the legal rights of others, or are highly impractical.
Limitations
In the following cases, we will not be able to respond to your request in accordance with laws and regulations:
a. Related to national security, national defense security;
b. Related to public safety, public health, and significant public interests;
c. Related to crime investigation, prosecution, trial and execution of judgment, etc;
d. There is sufficient evidence that the subject of personal information has subjective malice or abuse of rights;
e. Responding to your request will lead to serious damage to your legitimate rights and interests or those of other individuals or organizations;
f. Where commercial secrets are involved.
5.How your personal information is transferred globally
We adhere to not transferring this information outside of China. In cases where our products involve cross-border business and necessitate the transfer of personal information collected in China to overseas organizations, we will strictly adhere to relevant national regulations. This involves evaluating the security of outbound information, obtaining your explicit authorization, and complying with laws, regulations, and relevant supervisory authorities' directives.
For transfers to overseas organizations, we will require adherence to measures such as signing agreements, conducting on-site verification, and other effective means. Through these measures, we ensure that overseas organizations maintain the confidentiality of any personal information they obtain. However, it is essential to note that should you voluntarily post news across borders on the internet, it will not fall under this confidentiality requirement.
In such cases, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.
How long we store information
In general, we will only retain your personal information for the shortest period of time necessary to achieve the purpose for which it was collected, beyond which it will be deleted or anonymized. However, we may change the period of storage of personal information in order to comply with legal requirements in the following cases:
(1) To comply with the relevant provisions of applicable laws and regulations or policies and other normative documents;
2) To comply with the provisions of decisions, etc. of administrative organs or similar authorized organizations, judgments and rulings of judicial organs, decisions of arbitration organs, or other legal procedures;
3)We are reasonably sure that it is necessary to comply with laws and regulations and other relevant provisions;
(4) For purposes reasonably necessary for the execution of the relevant service agreement or this policy, for the protection of public interest, for the protection of the safety of the persons and property of third parties, such as our customers, our affiliates, other users or employees, or for other legitimate rights and interests.
When DRUG ceases to operate, we will take the form of push notification, website or in-program announcement to notify you, and delete or anonymize your personal information within a reasonable period of time.
6.How this privacy policy is updated
Our privacy policy may change. We will update our policy if we change our business functions, the purpose of use, or the contact information of the person in charge of personal information protection.
We will not restrict your rights under this Privacy Policy without your explicit consent. We will notify you of any significant changes, including through SKOO Platform postings and customer service notices.
Material changes within the meaning of this Policy include, but are not limited to:
Our Privacy Policy may change. In the event of a change in business functions, a change in the purpose of use, or a change in the contact information of the person responsible for the protection of personal information, we will revise our privacy policy accordingly.
We will not limit your rights under this Privacy Policy without your express consent. We will provide prominent notices of material changes (including notification through SKOO Platform postings, SKOO customer service notices, etc.).
Material changes referred to in this Policy include, but are not limited to:
(1) Significant changes in our service model. For example, the purpose of processing personal information, the type of personal information processed, and the way personal information is used;
2) Changes in the primary recipients of personal information that is shared, transferred or publicly disclosed;
(3) Significant changes in your right to participate in the processing of personal information and the manner in which it is exercised;
(4) When there is a change in the department responsible for handling the security of personal information, contact information and complaint channels;
(5) When the security impact assessment report of personal information indicates that there is a high risk.
If you choose to continue to use our services after being notified, you agree to be bound by the revised policy.
We will also archive the old version of this policy for your review, and you may apply to us for access through the contact information reserved in this policy.
7.Contact Us
This Privacy Policy is copyrighted by us and we have the right to interpret and modify it to the extent permitted by law.
E-mail address: SKOO@hotmail.com.