Last Update: [Jul 31， 2024]

Welcome to Blopee (the "Platform"). The Platform is operated by Socreate HK Limited, with its registered address at UNIT 2508A 25/F, BANK OF AMERICA TOWER, 12 HARCOURT RD CENTRAL, HONG KONG ("Blopee", "we" or "us").

Blopee offers a personal Artificial Intelligence (AI) chatbot service through a text and voice interface.

We are committed to protecting and respecting your privacy. This Privacy Policy (this “Policy”) explains what personal data we collect from you, or that you provide to us, as well as the practice concerning our use, retention and process of your personal data. Before using the Platform, please read carefully and agree to this Policy, especially those highlighted in bold.

By using relevant features and services provided by the Platform, you confirm that you have read this Policy and that you understand and accept the way we collect, use and process your personal data and that you understand your rights to your personal data. If you are a child under 18 years old, please make sure you read the Policy accompanied and instructed by your legal guardian, and your use of the Services shall be deemed that you have got the prior consent of your parent or legal guardian.

Please note that the features and services of the Platform as described in this Policy may vary depending on certain factors, such as the laws and regulations or regulatory requirements in the country or region where you are located, the model and system version of your device, and the application version of the Platform, etc. The actual delivery features and services of the Platform shall be subject to your actual use.

If you have any questions about how we process your personal data, please contact us at: [socreate.app@gmail.com].

Personal data we collect and use

We collect and use the following data about you:

Your Profile Information. Personal data you give us when you register your profile on the Platform, including your email address, mobile phone number, date of birth, username, customized Platform ID, password, and other information you disclose in your user profile.

User Content. The content you upload and generate on the Platform, including the preferences you set, the texts and audios you input into the Blopee chatbot and the content the chatbot generates which are elicited or prompted by you, and other content you submit to the Services. We may collect information about the text and audio that are parts of your User Content, such as identifying the nature of the audio, and the text of the words spoken in your User Content. We may use the above data for content review, user type statistics, and other non-person-identifying operations.

Data about Your Behavior. Data about your use of the Platform and problems that you may encounter. We may collect the data aforementioned through the feedback you submit, and surveys you participate in. We also use cookies and other similar technologies to collect such data. For more information on how we use cookies and other similar technologies, please see the "Cookies and other similar technologies" section below.

Technical Information about Your Device that We Collect. We collect certain data about the device that you use to access the Platform, such as your IP address, device manufacturer, device model, device memory, gravity sensor information, battery status, device system and system version, identifiers for advertiser, network type, network operator, device IDs, Android ID, time zone settings, phone language, phone region, screen resolution and brightness settings. Where you log-in the Platform with multiple devices, we will be able to use your profile data to identify your activity across different devices. In addition, we may also access the permissions on your device including microphone, message notifications, and collect and use relevant data. In order to access the aforesaid data stored on your device, we will implement the measures as required by relevant laws.

Your usage information. We collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you and the advertisements you view.

Information from other sources. We may receive the information described in this Privacy Policy from other sources, such as: we may receive information about you from others, including where you are included or mentioned in User Content, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.

We may collect the personal data aforementioned directly from your device or through the use of a third-party software development kit ("SDK"). SDKs are third-party computer codes that we may apply to our mobile applications and other forms of our services. These SDKs enable third parties’ information collection from your device. We use such SDKs and work with the third parties to use the collected data primarily for data statistics, troubleshooting, application log processing, content sharing and functionality supporting, etc. We will conduct strict security tests on third-party SDKs and agree on strict data protection measures with our partners to ensure the safety of your data.

Sensitive Information. The Platform allows you to input information that may be sensitive and subject to special protections under applicable laws. Such sensitive information may stand alone or be part of the information about you, your life, and any voice and text messages that you provide during your conversations with Blopee’s chatbot. This section explains how we use and protect sensitive information.

Sensitive information you provide in your User Content. In your conversations with the Blopee chatbot, you may choose to provide sensitive information about your religious views, political views, health and medical data, racial or ethnic origin, sexual orientation, genetic and biometric data or philosophical beliefs. By providing sensitive information, you consent to our use of it for the purposes set out in this Policy.

We will only use your information to facilitate your conversation with the Blopee chatbot by allowing the chatbot to learn from your interactions to improve your conversations.

We will not use your sensitive information or any content in your Blopee conversations for marketing or advertising.

Cookies and other similar technologies. We use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) ("Cookies") to automatically collect information for the measurement and analysis of how you use the Platform, enhancing your user experience, improving our services, identifying information that is most interesting to you, tracking trends, measuring the effectiveness of advertising, or storing information you may want to retrieve on a regular basis. A cookie is a text file that is stored on your access device by a web server, which enables the Platform to provide certain features and functionalities.

We may also allow certain third parties to collect information about your online activities through cookies and other similar technologies when you use the Platform. These third parties include (a) our advertisers, who collect information when you view or interact with one of their advertisements through the Platform, and (b) third-party measurement companies, who collect information to show how many and which users of the Platform have viewed or clicked on an advertisement.

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 functionalities of the Platform may no longer be available to you.

We do not collect any financial information from you.

Purposes that we use your personal data for

We will use the data we collect about you for the following purposes:

 to notify you about changes to our service;

 to provide you with user support;

 to measure and understand the effectiveness of the advertisements and other content we serve to you and others, and to deliver advertising to you on the Platform.

 to provide you with our chatbot services to allow you to have individualised and safe conversations and interactions with the Blopee chatbot;

 to communicate with you;

 to help us detect and combat abuse, harmful activity, fraud, data spam and illegal activity on the Platform and ensure the security of user accounts;

 to ensure your safety and security, including reviewing User Content, messages and associated metadata for breach of our content policies and other inappropriate content;

 to ensure that content is presented to you and your device in the most effective manner;

 to improve, promote and develop the Platform;

 to conduct data analysis and testing of the Platform to ensure the stability and security of the Platform;

 to allow you to participate in the interactive functions of the Platform;

 to ensure that you meet the minimum age standard to use our Platform (as required by law);

 to train our algorithms;

 to implement our Terms of Service and other agreements, statements and standards; and

 to manage the Platform, including troubleshooting.

Further, as the purposes for which we may/will use, disclose and/or otherwise process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the laws and regulations or regulatory requirements in the country or region where you are located.

Use of sensitive information. If you choose to provide sensitive information in your Blopee conversations, we will use that information only to facilitate your conversation with the Blopee chatbot and as described in the “Sensitive Information” section above. If you do not want us to process your sensitive information for these purposes, please do not provide it.

How do we disclose your personal data

We provide your personal data with the following specific third parties:

Service Providers: we will provide your personal data (including User Content) to service providers that support our business, such as cloud storage providers, SMS service providers, AI technology service providers, content review service providers, data analyzers, software performance analyzers, messaging service providers, CDN service providers, location-based services providers, etc., for the purpose of providing our services to you and ensuring that the Platform is a safe and enjoyable site.

Advertisers and third-party measurement companies. We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. If you follow a link to any site, or use any of the applications and widgets displayed by our advertisers on the Platform, please note that advertisers and/or third party platforms powering the said applications and widgets have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please read and agree with these policies and terms and conditions before you submit any personal data to these platforms.

Further to the above, you acknowledge and agree that (i) our advertisers and/or any linked sites, applications and widgets on the Platform are not owned by us, operated by us or affiliated to us, (ii) we do not have control over such advertisers and/or any linked sites, applications and widgets on the Platform and the manner in which and purposes for which your personal data will be collected by them, (iii) we are not a party to any contractual terms between you and such advertisers and/or any third party platform providing the applications and widgets on the Platform, and (iv) to the maximum extent permissible by law, we shall not be liable for any liabilities, losses or damages that may be incurred by you as a result of your use of any services provided by our advertiser and/or any social media platform providing the applications and widgets on the Platform, or the collection, use, disclosure and/or processing of your personal data by them.

Law Enforcement Agencies: we will share your data with law enforcement agencies, public authorities or other organizations when required to do so by law and if such share is reasonable and necessary, such as

 to comply with a legal obligation, process or request;

 to implement our Terms of Service and other agreements, statements and standards, including investigating any possible violations;

 to detect, prevent or otherwise address security, fraud or technical issues; or

 to protect the rights, property or safety of us, our users, third parties or the public as required or permitted by law (including exchanging data with other companies and organizations for the purposes of fraud prevention and credit risk mitigation).

Third Parties: If we receive verified complaints from third parties that the content that you post or upload to our Platform constitutes as a violation of the third parties' legal rights, including their intellectual property rights, we may disclose your personal data to the third party for their further action.

Sale or Merger: we will also disclose your data to third parties in the following circumstances:

 If we sell or purchase any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to potential sellers or buyers of such business or assets; or

 If we sell, purchase, merge, are acquired by or partner with another company or business, or sell some or all of our assets. In such a transaction, user data may be included in the transferred assets.

How will we retain your personal data?

Retention location and international data transfer: to provide you the services, security maintenance and other purposes specified in this Policy, we may store your personal data in the servers in countries/regions (such as Japan, the U.S., Singapore, etc.) other than where you are resided and transfer your personal data to our affiliates, service providers or business partners in such countries/regions. These countries or regions may have different data protection rules than where you reside. When we transfer your personal data to the recipients in such countries/regions, we will take all necessary and appropriate measures to protect your personal data and ensure the security of your personal data in transit in accordance with this Policy and applicable data protection laws. We will also require the recipients of your personal data to provide adequate protection to safeguard the security of your data. For example, we may enter into appropriate data processing agreements with the recipients or complete other formalities as required by applicable data protection laws or regulatory authorities.

Retention period. We will retain your personal data where we have a proper business need or any legitimate commercial purpose to do so, for example, to fulfill our Terms of Service or provide you with our service. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims. After you have terminated your use of our Platform (i.e., deleting your account), we will delete your personal data or process it in an anonymized way.

Your rights

Under applicable data protection laws, you have certain rights to your personal data, which may include the right to access, delete, update or correct your personal data, the right to know how your personal data is processed, the right to have a copy of your personal data, the right to request us to stop the collection, processing and use of your personal data, and other rights as conferred by applicable data protection laws.

If you have any questions on how to use the above tools or are unable to use such tools to exercise certain rights, want to know about what rights you may have or want to exercise them, or have any other requests, inquiries, or complaints, please contact us at: [socreate.app@gmail.com].

We will respond to all requests on the exercise of personal data we receive from the user according to the applicable data protection laws. To protect the security of your account and your personal data, we may verity your identity before we respond to your requests. Under some circumstances, we may refuse to comply with your request as permitted by applicable laws. In such cases, we will explain why we refuse to respond to your request in our reply. In addition, we may charge a reasonable fee for responding to your request in accordance with applicable laws.

The security of your personal data

We take measures to ensure that your data is processed securely and in accordance with this Policy, such as processing under encryption. We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users, including developing internal data protection management programs, granting access on a need-to-know basis, and controlling access to personal data. We maintain these technical and organizational measures and will adjust them from time to time to improve the overall security of our systems.

Although we have taken reasonable and effective measures as described above and comply with the standards required by applicable laws and regulations, since the data transmission through the internet is not completely safe, we still cannot guarantee the security of your personal data transferred through the Platform. Any transmission is at your own risk and you should take active measures to ensure the security of your personal data, such as: regularly changing your account password and not disclosing your account password and other personal data to others. In particular, while we provide a Platform for you to socialise and connect with other users, you should exercise care and caution when communicating with others on the Platform and not disclose sensitive information about yourself.

In the event of a security incident involving personal data, we will report to the competent authorities in accordance with the law, conduct a timely investigation into the incident and initiate contingency plans. At the same time, we will send notifications to relevant users through effective channels to prevent or control any data breach.

Data relating to children

This Platform is not directed at children under the age of 18. In certain cases, this age may be higher due to local regulatory requirements. If you are a child under that age, please do not use this Platform.

By using the services, you confirm that you are over the relevant age specified herein or you have got the prior consent of your parent or legal guardian or you have the legally capacity to sign a binding contract with Blopee in accordance the applicable laws and regulations, and you have legally capacity to provide your personal data to Blopee.

If you believe that we hold personal data about or collected from a child under such specific age, please contact us at [socreate.app@gmail.com] and we will take steps to delete the account and associated personal data under that account.

Complaints

In the event that you wish to make a complaint about how we process your personal data, contact us immediately at: [socreate.app@gmail.com]. We will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with relevant data protection authority.

Update to this Policy

We may update this Policy from time to time for various reasons including to improve our privacy practices, to reflect changes to our Service, and to comply with relevant laws. When we update the Policy, we will notify you by updating the "Last Updated" date at the top of this Policy, and posting the new Policy. When we make any material changes to our Privacy Policy, we will notify you via in-App message, or providing any other notice required by applicable laws. Your continued access to or use of the Platform after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Platform.

Severability

If any court of law, having jurisdiction to decide on this matter, rules that any provision of this Privacy Policy is invalid, then that provision will be removed from this Privacy Policy without affecting the rest of the terms herein, and the remaining provisions of this Privacy Policy will continue to be valid and enforceable.

Contact

If you have questions, comments, or requests regarding this Policy and how we process your personal data, please contact us at: [socreate.app@gmail.com].