LAST UPDATED: March 2023
BoYuan Internet Limited offers a platform, referred to as the "BoYuan Platform" or "Services," that enables end-users to access content and services via their lock screen when unlocking their mobile, tablet, wearable, or any other smart device. This content may include interesting stories, news, events, games, advertisements, or products. Additionally, the BoYuan Platform allows partners to display their content, which may comprise advertising, games, promotional, entertainment or informational content, on the devices of end-users and other related offerings.
- 1. Information We Collect
- 2. How We Use User Information
- 3. How We Disclose User Information
- 4. Your Privacy Choices and Rights Regarding Our Collection, Use, and Disclosure of Your Information.
- 5. Data Security
- 6. Data Retention
- 7. Children
- 8. International Data Transfer
- 9. Regional Privacy Rights
- 11. Contact Us
1. Information We Collect
The User Information we collect includes but is not limited to information about a User's device and operating system, IP address, web pages visited by Users within our Customers' websites, the link that brought Users to a Customer's website, the dates and times a User accesses a Customer's website, event information (such as system crashes), general location information (such as city and state), hashed email addresses (if provided by the User), and gender (if provided by the User).
Additionally, in the BoYuan News suite of tools, we collect in-app User behaviors (such as online status, browsing activity, and clicks) and implicit non-precise device location inferred from search queries (when enabled by the User). We request our Customers to obtain consent on our behalf, where applicable data protection laws require, for us to collect this User Information. We may also obtain Information about you from our data partners.
2. How We Use User Information
We, along with our partners and affiliates, may use the information collected about you or provided by you, for purposes that are collectively referred to as 'Permitted Purposes'.
2.1. Providing our Service
We may use User Information to provide our Services to Users and our Customers.
2.2. Tailoring content
We may use User Information to customize the content and information we send or display to Users. This may include retargeting content to Users through our Services and other platforms. Furthermore, we may personalize your experiences while using our Services.
2.3. Tailoring content across multiple devices
To enhance the experience of our unique users across different browsers and devices, we may utilize their User Information for tailoring content. This includes providing targeted ad campaigns that cater to their preferences. For example, if we identify a user on a web browser, we may offer personalized content on their mobile apps as well. In order to achieve this, we identify unique users across devices and may sync cookies and identifiers with our service providers or customers. This is done to assist our customers in improving their data and data segments or targeting the appropriate audience.
2.4. Fulfil other administrative purposes
We may process your personal information for various administrative purposes, such as pursuing our legitimate interests, including but not limited to direct marketing, research and development (including marketing research), network and information security, and fraud prevention. Additionally, we may use your information to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for such activities. We may also process your information to ensure internal quality control and safety, authenticate and verify individual identities, including requests to exercise your rights under this policy, debug to identify and repair errors with our services, audit interactions, transactions, and other compliance activities, share information with third parties as necessary to provide the services, enforce our policies, and fulfill our legal obligations.
2.5. Providing our Customers with data segments that facilitate the targeting of content and advertisements for topics, products, and services that may be of interest to you.
A data segment refers to a group of users who possess one or more attributes in common (for example, travel enthusiasts). We offer various data segments, both proprietary and from our data partners, to our Customers. This enables them to effectively target users who are more likely to have an interest in their content and advertisements. At BoYuan, we do not intentionally create segments that are based on sensitive information, such as Personal Data that reveals your racial or ethnic origin, religious affiliations, sensitive health information, sex life, sexual orientation, genetic, or biometric data. However, our Customers may use standard health-related segments that are not considered sensitive, such as inferred interests in health and wellness or over-the-counter medications. Additionally, we provide standard political-related segments to our Customers, which may indicate general political sentiment, interest in specific political issues, and political party affiliation.
3. How We Disclose User Information
We may disclose User Information as follows:
3.1. BoYuan Affiliates
3.2. BoYuan service providers
We may disclose User Information to vendors, service providers, agents, contractors, or others who perform functions on our behalf, such as maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, or fraud detection.
3.3. Unaffiliated third parties
We may disclose User Information to other unaffiliated third parties, including our data partners for the purpose of connecting you with relevant content through targeted advertising, and our programmatic demand and supply partners for tailored advertising purposes.
We may disclose User Information to Customers when necessary for the Service we provide, such as providing publishers with information about viewing and click-through patterns of their content and providing advertisers with information about conversion rates for analytical purposes.
4. Your Privacy Choices and Rights Regarding Our Collection, Use, and Disclosure of Your Information.
At BoYuan, we understand the importance of protecting your privacy and giving you control over your personal information. We offer a variety of mechanisms to enable you to manage how we collect, use, and disclose your information. This section outlines the choices you have in this regard, and how to exercise those choices.
If you wish to limit the ways in which we collect, use, or share your information, you may choose to uninstall or unsubscribe from the BoYuan Platform. This will allow you to stop receiving communications from us and remove your data from our system.
4.1. Interest-based advertising
To opt out of receiving specific targeted advertisements, please visit the websites of third-party advertisers. However, please be aware that these links may not reach all of our advertising partners, and certain advertisements may still be displayed to you. For complete assurance that no interest-based advertisements will be sent to you, please access the "Settings" page of your smart device, select Google, click on "Ads," and then choose "Opt out of interest-based ads" on your Android device or use any other opt-out mechanisms provided on your Device. Please note that even if you opt-out of interest-based advertising, you may still receive generic ads from BoYuan.
If you choose to participate in one of our surveys, we will provide clear opt-out instructions, including the option to skip the survey. If you elect to skip the survey, we will not include your device in that particular survey. However, please note that opting out of one survey does not mean that you will not receive other survey requests from us.
4.3. Email Communications
4.4. Text Messages
To opt-out of receiving text messages from us, you can follow the instructions provided in the message you received from us, or contact us directly for assistance.
4.5. Push Notifications
We may send you push notifications. If you prefer not to receive these notifications, you can adjust the settings on your mobile device accordingly.
4.6. “Do Not Track”
We understand that some users may choose to activate the "Do Not Track" ("DNT") feature in their web browsers as a privacy preference. However, it's important to note that we do not currently respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
4.7. Tracking Technologies
If you choose not to be tracked, you can select the "do not allow to be tracked" option on your smart device when prompted. However, please be aware that disabling tracking technologies may render some parts of the BoYuan Platform inaccessible or may cause them to function improperly. In addition, if you wish to opt-out of personalized advertisements on mobile applications, you can follow the instructions provided for Android and other platforms. To further protect your privacy, the online advertising industry offers websites that enable you to opt-out of receiving targeted ads from data partners and other advertising partners who participate in self-regulatory programs. To learn more about targeted advertising, consumer choice, and privacy, you can visit the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. However, please note that you must opt-out separately in each application and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
You may have the right to access your Personal Information in accordance with applicable law, which includes confirming whether we are processing your personal information and obtaining access to or a copy of your Personal Information.
If your Personal Information is inaccurate, incomplete, or outdated, you may request correction of your Personal Information. We may provide self-service tools to enable you to update your Personal Information.
You may also request deletion, anonymization, or blocking of your Personal Information when processing is based on your consent or when processing is unnecessary, excessive, or noncompliant.
You have the right to request restrictions on or object to our processing of your personal information.
You may withdraw your consent to our processing of your personal information. However, this will only apply to future processing, and some features of our Service may not be available.
You may request the portability of personal information that you have provided to us.
You have the right to be informed about third parties with whom our application has shared your personal information that was collected by our application.
You may request a review of decisions that were exclusively based on automated processing, and which may affect your data subject rights.
To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will process your requests in accordance with applicable laws.
5. Data Security
6. Data Retention
We collect User Information directly for the purpose of serving ads. We retain this information for a maximum of thirteen (13) months from the User's last interaction with our Services, and sometimes for a shorter period of time. After this time, we remove unique identifiers or aggregate the data to de-identify it.
We retain deidentified or aggregated data for as long as commercially necessary, which cannot identify any individual or device. This data is used for reporting and analysis purposes.
To ensure that we honor your opt-out requests, we keep opt-out information for a longer period than the retention period mentioned above.
At our company, we are committed to protecting the privacy of children under the age of sixteen (16). Therefore, we do not knowingly collect any personal information or target advertisements on websites that are directed towards children under 16. If you are a parent or legal guardian of a child under 16 and have concerns about the data we collect, please contact us at email@example.com. We take all concerns regarding children's privacy seriously and will work to address them promptly.
8. International Data Transfer
We may transfer, process, and store any information that we handle to any location worldwide, including but not restricted to the United States or other countries that may have different data protection regulations than those of your place of residence. Our priority is to protect your information in line with the applicable laws' requirements.
9. Regional Privacy Rights
9.1. Notice to Individuals in the State of California
9.1.1. Your Rights to Your Personal Information
As a California resident, you have the right to request BoYuan to (i) provide you access to your Personal Information that we have on record, (ii) correct your Personal Information, (iii) delete your Personal Information, (iv) cease or limit the sharing, disclosure, or sale of your Personal Information to third parties, and (v) opt out of cross-context behavioral advertising. We, at BoYuan, are committed to upholding and respecting your rights and will not discriminate against you for exercising any of these rights.
To opt out of BoYuan's disclosure, sharing, and sale of your Personal Information, as well as cross-context behavioral advertising, you can follow the process described in BoYuan's California Consumer Rights Portal. It's important to note that at present, this feature is only accessible to residents of California state.
9.1.2. Categories of Data that BoYuan Holds about You
9.1.3. Why BoYuan Collects your Personal Information
BoYuan collects and processes your Personal Information for the purpose of delivering tailored content and advertisements to enhance your user experience.
9.1.4. Where BoYuan Collects Your Personal Information
BoYuan collects Information in two ways: directly from you as you use our Sites and Services, and from third parties who collect this Information independently. We may also combine the Information that we collect from these different sources to enhance the quality and accuracy of the data we have about you.
9.1.5. How BoYuan Shares Your Personal Information
BoYuan may share your pseudonymous Personal Information with our trusted partners, who are contractually obligated to use this data only for BoYuan’s business purposes. These disclosures to service providers are allowed under the CCPA and do not count as a “sale”, even if you have exercised your right to limit disclosures or sales of your Personal Information to third parties. If we do not have a service provider agreement with a third party, we will honor your request to stop sharing or selling your Personal Information.
9.2. Notice to Individuals in Thailand
9.2.1. Data Controller
If you are a resident of Thailand and use our Services, BoYuan (Thailand) Limited will act as the controller of your Personal Data that is provided to us, collected by us, or processed by us.
9.2.2. Legal Basis for Processing Personal Data
For customers, site visitors, and users located in Thailand, the legal basis for the collection and use of Personal Data will vary depending on the specific context and nature of the Personal Data involved.
However, in general, we will only collect your Personal Data if (i) we have obtained your consent, (ii) we require the Personal Data to fulfill a contract with you, or (iii) we have a legitimate interest in processing the information that is not outweighed by your data protection interests or fundamental rights and freedoms. In some cases, we may also be legally obligated to collect your Personal Data, or we may need to do so to protect your vital interests or those of another individual.
When we require Personal Data from you to meet a legal obligation or fulfill a contractual agreement, we will inform you at the appropriate time and indicate whether providing your Personal Data is compulsory or optional. We will also inform you of the potential consequences if you choose not to share your Personal Data.
In the event that we gather and utilize your Personal Data based on our or a third party's legitimate interests, we will clearly communicate with you at the relevant time about what those interests entail.
9.2.3 Your Rights to Your Information
As a user of BoYuan services, you have the right to request access to, export, delete, or restrict processing of your Personal Data. To exercise these rights or to learn more about what Personal Data and behavioral information BoYuan holds about you, please visit BoYuan's Data Subject Access Request Portal. Customers may also submit a data subject access request via email at firstname.lastname@example.org. BoYuan will respond with the relevant information.
If you have any questions regarding the collection and use of your Personal Data, please contact us at email@example.com .
9.2.4 Thailand Data Transfers
BoYuan transfers data internationally, including outside of Thailand. To ensure compliance with applicable data protection laws, BoYuan has implemented an Inter Group Data Transfer Agreement based on the standard contractual clauses established by the European Economic Area.
As a global company, BoYuan processes data across various countries, including Thailand, the EEA, the United States, and Hong Kong. Under the Personal Data Protection Act, B.E. 2562, BoYuan is required to use specific legal mechanisms to protect Thailand Data when transferring it outside of Thailand.
When BoYuan transfers data originating from Thailand to other locations, it relies on Standard Contractual Clauses established by the European Commission. These clauses define privacy and security commitments between companies that transfer personal data. BoYuan, Inc. and its Affiliates have implemented Standard Contractual Clauses to guarantee the legality, privacy, and security of the data flows required for the provision, maintenance, and development of our services.
9.3 Notice to Individuals within the People’s Republic of China (“PRC”)
9.3.1 Processing Entity and Designated Office
If you are a resident of the People's Republic of China (PRC), please note that BoYuan Information Technology Shenzhen Co. Ltd. will act as the data controller for your Personal Information that is either provided to, collected by, or processed by BoYuan in relation to our Services.
9.3.2 Legal Basis for Processing Personal Information
For Customers, Site Visitors, or Users from the People's Republic of China (PRC), our legal basis for collecting and using Personal Information will vary depending on the specific context and nature of the information collected.
In general, we only collect Personal Information when (i) we have obtained your consent to do so, (ii) it is necessary for us to fulfill a contractual obligation with you, or (iii) when it is necessary to support news reporting or the public interest. There may be instances where we are required by law to collect your Personal Information or where it is necessary to protect your vital interests or those of another person. If we ask you to provide Personal Information to comply with a legal obligation or fulfill a contract, we will make it clear whether providing such information is mandatory and inform you of any potential consequences if you choose not to provide it.
If you have any questions regarding the legal basis for collecting and using your Personal Information, please contact us at firstname.lastname@example.org.
9.3.3 Your Rights to Your Information
As a valued user of our services, you have the right to be fully informed about how we handle your Personal Information. This includes the right to restrict or refuse the processing of your Personal Information, and to make informed decisions about its use. Additionally, you have the right to access, correct, supplement, transfer, export, delete, or restrict the processing of your Personal Information.
To make use of these rights, please visit BoYuan’s Data Subject Access Request Portal if you are a User, where you can specifically request information about what Personal Information and behavioural information we hold about you, and how you can exercise your rights. Alternatively, Customers may submit a data subject access request by emailing us at email@example.com, and we will respond promptly with the relevant information.
In the unlikely event that you have any concerns about how we handle your Personal Information, you have the right to complain to the relevant department performing duties of Personal Information protection. However, we are committed to protecting your privacy, and encourage you to contact us first at firstname.lastname@example.org with any questions or concerns you may have about our collection and use of your Personal Information.
9.3.4 PRC Data Transfers
To offer BoYuan's Services, we collect personal information of individuals located in the PRC through a server based in Hong Kong. Subsequently, this data flows between Hong Kong, the EEA, the UK, the United States, and Singapore. Please note that BoYuan does not store any Personal Information in the PRC. Instead, we store information of our Customers, Users, and Visitors in data centers located in Singapore, which are governed by their respective data protection regulations.
11. Contact Us
For inquiries regarding the privacy of our Sites or Services, or if you wish to obtain the names and contact information of our Affiliates who may process your Personal Information as data controllers, please reach out to us at email@example.com.