Last updated: Jan 2023

This VVLive Live Privacy Policy explains how VVLive (“VVLive”, “we”, or”us”) process any personal data we collect from visitors and any applications, services provided in relation to the website (collectively, the “VVLive Services”).

We value the privacy of users, subscribers, publishers, members, and others who visit and use the VVLive Services (collectively or individually, “you” or “users”) and want you to be familiar with how we collect, use, and disclose personal information from and about you.

You may share personal information when using the VVLive Services. One example is when you provide information about yourself as part of the VVLive account creation process. Another is when you take certain actions on the VVLive Services that are public or intended to be public in nature, such as when you broadcast content, post profile information, follow a channel, or subscribe to a broadcast channel. Given the social nature of some of the VVLive Services, that information may be collected, used, or disclosed by others who are part of that social interaction. In addition, some features of the VVLive Services are designed to provide others with information about user activity, such as identifying the user who created a particular Clip or the subscription status of users for a given channel. We encourage you to be mindful of this when considering your activity on the VVLive Services.

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If you have any questions about how we use your personal data, please contact bittlenevils@hotmail.com.

2.Automatically Collected Informationfor Legitimate Interests

• Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier and language;
• Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;
• User-generated contents (“UGC”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use VVLive Services;
• Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on VVLive Services, but such data will only be processed offline to fulfill the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party;
• Payment information, such as bank account number, Paypal or other payment information where required for payment;
• Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services;
• Your social network contacts with your permission, when you activate the “Discover Friends” function and allow us to access your contacts;
• Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;
• Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints; and
• Information you provide when participating in in-app surveys and activities.

• Information you provide from social media when you create a VVLive account by connecting with a third-party social media, such as Facebook, Instagram, Twitter, Google, or if you link a VVLive account with a third-party social media account;

• Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed to, and information regarding your interaction with other users;
• Information from Other Sources: We may obtain additional information from third parties and sources other than the VVLive Services. For example, we may obtain additional information from games or services you use, or social media networks (such as Facebook) for which you have approved our access. When you access the VVLive Services through social media networks or when you connect the VVLive Services to social media networks, you are authorizing VVLive to collect, store, and use such additional information and content in accordance with this Privacy Policy
• Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device,Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address;
• Information regarding your access to and use of other apps;
• Other location information, such as the information based on your SIM card;
• Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests;
• Metadata, associating with the UGC you provided us, which describes other data and provides information about how, when, and by whom the piece of UGC was collected and how that UGC was formatted, such as hashtags used to label the keywords to the video and captions; and

• Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use VVLive Services, enhance your experience using VVLive Services.

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, to calculate the percentage of users accessing a specific website feature, or to calculate ad impressions served or clicked on.

Storage and access to cookies that are set in connection with the VVLive Services are governed by the VVLive Live Cookie Policy.

We will only use your Personal Information when the applicable laws allow us to. In general, we use your Personal Information for the following purposes:

• Provision of services: to present VVLive Services and its contents to you, including any interactive features on VVLive Services, and to provide you with information, products or services that you allow us to; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with promotion activities and sweepstakes;
• Improvement of services: to improve and personalize our services by presenting new services, information, recommendations, and feedback;
• Customer management: to manage a registered user’s account, to provide customer support and notices to the registered user about his account or subscription, and notices about changes to VVLive Services or any other product or service we offer or provide through it;
• Communication: to communicate and interact with you directly, for an example, we may send notifications regarding upcoming changes, promotion activities or improvements on VVLive Services;
• Content review: to review pictures, images and contents posted or generated on VVLive Services to ensure that we comply with any applicable content regulations in any relevant jurisdiction;
• Customization of content: to perform research and analysis about your use of, or interest in contents, products, advertising, or services available on VVLive Services in order to develop and display content tailored to your interests on our Website and App;
• Performance Analysis: to determine whether users of VVLive Services are unique, or whether the same user is using VVLive Services on multiple occasions, and to monitor aggregate metrics such as total number of visitors, number of videos viewed, demographic patterns;
• Functionality and security: to identify users not meeting the age limit, to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
• Compliance: to enforce our terms of use and to comply with our legal obligations;
• Aggregation: to aggregate information we collect about you to which one or more purposes described above.
• Cookie: We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform and improve our services. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.

• Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video or a picture each time you upload a video
• We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to improve, optimize the Platform and to prevent illegal use.
• We may share your Personal Information outside of VVLive Services when we have your consent, either express or implied.
• We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
• We may disclose your Personal Information to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, customization of content, analytics, security, map navigation, data storage and cloud services, supporting our functionality, and other features offered through VVLive Services. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. However, if you connect to a third-party service through VVLive Servicesor otherwise links your VVLive account with a third-party service, you are requesting and authorizing us to share or grant access to information on your behalf with such third party. We may also send information about the content that you watched or your activities on VVLive Services to such third party in order to upgrade your experience on VVLive Services.
• We may disclose or share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred. If such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses information in a manner that is consistent with this privacy policy.
• We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) comply with any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or other third parties; or (e) to maintain and protect the security and integrity of VVLive Services or infrastructure.
• We may disclose aggregated information about our users. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.

By using VVLive Services you consent to the transfer of information that we collect about you, including Personal Information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.

When you click on a link to any other website, mobile application or third-party content through VVLive Services, you will go to another website or other mobile application and another entity may collect information from or about you. We have no control over, do not review, and cannot be responsible for, these third-party websites or mobile applications or their contents. Please be aware that the terms of this privacy policy do not apply to these third-party websites or mobile applications or content, or to any collection of information after you click on links to these third-party websites, mobile applications or content.

We take appropriate administrative, technical and physical security measures to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your Personal Information. You should use caution whenever submitting information through VVLive Services and take special care in deciding which information you provide us with.

You are responsible for maintaining the secrecy of your password and account information at all times.

You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Please note that your choice to disable cookies will be specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

You can at any time request to opt out from allowing us to send you push notifications by adjusting the permissions in your mobile device.

You can switch off GPS location, Microphone, Camera or other similar functions on your mobile device if you do not wish to share them. You can also hide your location, videos uploaded, recent active time and other information by adjusting “Privacy” setting.

You can choose not to provide us with Personal Information, but that may result in you being unable to use certain features of VVLive Services because such information may be required for you to register as a user, purchase Paid Services, participate in a promotion, survey, sweepstakes or make complaints.

You can change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings. For more information on how to change the advertising identifier privacy settings on your device, please visit http://www.networkadvertising.org/mobile-choice or http://youradchoices.com/appchoices.

You can make changes to your information, including accessing your information, correcting or updating your information or deleting your information by editing your profile in the App.

You may submit a request to access, modify or delete the Personal Information we collect about you by (a) using Help or Feedback function on VVLive Services or (b) by sending your request to us via email at bittlenevils@hotmail.com. We will respond to your request consistent with the applicable laws as soon as practicable after proper verification procedures.

If you are a California resident, you may request us to disclose the categories and specific pieces of Personal Information about you that we collect or share to any third party for commercial uses. You will need to send an email to bittlenevils@hotmail.com if you wish to make such request, and format the subject line as Identification of Personal Information+Californian+Your VVLive ID. We may ask you to go through a verification process, such as using your phone number and an instant pin, before we respond to your request. Please note that we will not be able to handle this kind of request if submitted through postal mail, telephone, or facsimile.

If you are a California resident, you may also request us to delete Personal Information that we have collected about you. You will need to send an email to bittlenevils@hotmail.com if you wish to make such request, and format the subject line as Deletion of Personal Information+Californian+Your VVLive ID. You need to describe in your email what Personal Information you wish us to delete, and provide any supplementary information that helps us to locate such piece of Personal Information, such as the date you provided us with such piece of Personal Information and the specific content of such piece of Personal Information. We may ask you to go through a verification process, such as using your phone number and an instant pin, before we respond to your request. Please note that we will not be able to handle this kind of request if submitted through postal mail, telephone, or facsimile or if you fail to provide information in sufficient details to permit us to locate the Personal Information concerned. Further, we do not guarantee complete deletion of the Personal Information concerned given that it may already be shared or reposted by other users or third parties.

Users domiciled in California are encouraged to designate an authorized agent to exercise their rights of privacy on their behalf. To designate an authorized agent, you will need to execute a valid, legally enforceable power of attorney (“POA”) with your agent and submit this POA together with your request to us. We will contact your agent once we confirm that your request and the POA are valid in accordance with this privacy policy and the applicable laws.

We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that Personal Information of persons under 18 has been collected on or through the VVLive Services, we will take appropriate steps to delete this information.

If you believe that we have inappropriately collected Personal Information from a Young User, please contact us at bittlenevils@hotmail.com.

We will retain your Personal Information for as long as reasonably necessary for the purposes described in this privacy policy, while we have a legitimate business need to do so in connection with your account, or as required by laws (for example, for legal, tax, accounting or other purposes), whichever is the longer.

To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we use your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, You should check the latest version regularly, as they are binding on you.

If we change anything in our privacy policy, the date of change will be reflected in the “last updated date”. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.