Effective Date: April 24, 2024
● What Information We Collect
● How We Use Your Information
● How We Share Your Information
● Our Legal Bases and How We Process Your Information
● Your Rights and Choices
● Data Security and Retention
● Our Global Operations and Data Transfers
● Younger Users
● Privacy Policy Updates
● Contact Us
This Privacy Policy is designed to ensure compliance with the General Data Protection Regulation (GDPR) in the European Economic Area (EEA), the UK Data Protection Act, and applicable Swiss data protection laws. It governs the personal information collected and processed by NOVAHUB INC, USA. and its affiliates (“Da Memo,” “we,” “our,” and “us”) through our websites and related Da Memo products, collectively referred to as the “Services.”
We've carefully designed this Privacy Policy to prioritize your needs and interests. It's essential for you to comprehend our approach to collecting and using personal information, so you can confidently manage the data you choose to share with us through the Da Memo app. This document details our procedures for collecting, utilizing, sharing, processing, and protecting any personal information you provide. In this policy, "personal information" is defined as data that can be used to identify you, whether it's by that data alone or when combined with other data. We pledge to adhere to the guidelines of this Privacy Policy when it comes to handling your personal information.
We are committed to processing your data lawfully, fairly, and transparently. We only collect personal information where we have a lawful basis to do so, including where you have provided consent, where processing is necessary for the performance of a contract with you, where processing is necessary for compliance with a legal obligation, or where processing is necessary for the purposes of our legitimate interests.
We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.
Information You Provide
When you use the Platform, you may provide some or all of the following information:
● Account and profile information, such as date of birth, gender,weight,height,Step length.
Automatically Collected Information
We automatically collect certain information from you when you use the Platform
● Usage Information.
Third-party platforms and partners
We use Google Firebase to support our collection of your information. The following is the information that firebase will automatically collect.
● Age:The age of the user by bracket: 18-24, 25-34, 35-44, 45-54, 55-64, and 65+.
● App store:The store from which the app was downloaded and installed.
● App version:The versionName (Android) or the Bundle version (iOS).
● Browser:The browser from which user activity originated.
● City:The city from which user activity originated.
● Continent:The continent from which user activity originated.
● Country:The country from which user activity originated.
● Device brand:The brand name of the mobile device (such as Motorola, LG, or Samsung).
● Device category:The category of the mobile device (such as mobile or tablet).
● Device model:The mobile device model name (such as iPhone 5s or SM-J500M).
● Gender:The gender of the user (male or female).
● Interests:The interests of the user (such as Arts & Entertainment, Games, Sports).
● Language:The language setting of the device OS (such as en-us or pt-br).
● New/Established:New: First opened the app within the last 7 days.Established: First opened the app more than 7 days ago.
● Operating system:The operating system used by visitors to your website or mobile app.
● OS version:The operating system version used by visitors to your website or mobile app (such as 9.3.2 or 5.1.1).
● Platform:The platform on which your website or mobile app ran (such as web, iOS, or Android).
● Region:The geographic region from which user activity originated.
● Subcontinent:The subcontinent from which user activity originated.
please refer:https://support.google.com/firebase/answer/9268042
We use your information to operate, provide, develop, and improve the Platform, including for the following purposes.
● Maintain and enhance the safety, security, and stability of the Platform by identifying and addressing technical or security issues or problems (such as technical bugs).
● Review, improve, and develop the Platform, including by monitoring interactions and usage across your devices, analysing how people are using it, and by training and improving our technology
● Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.
Service Providers
We engage service providers(Google Firebase)that help us provide, support, and develop the Platform and understand how it is used. They provide services such as Data Analysis, Data Storage. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.
Within Our Corporate Group
We may share all of the Information We Collect with a parent, subsidiary, or other affiliate of our corporate group.
Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.
Legal Obligations and Rights.
We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:
● comply with applicable law, legal process or government requests, as consistent with internationally recognised standards.
● protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk.
● nvestigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.
We may only use your information when we have a “legal basis” to do so. We use different legal bases depending on why we use your information (in other words, the “purpose” of our processing). These legal bases are contractual necessity, legitimate interests (ours, yours or those of another party), consent, compliance with a legal obligation, performing a task in the public interest, and protection of vital interests.
Here we explain the legal bases we rely on when we process your information. This section also describes why we use your information, how this information is processed, the categories of information involved, and the associated rights (which always includes the right to access your information). For more information on how to exercise any of your rights, please check out the “Your Rights and Choices” section in the Privacy Policy.
Contractual Necessity
We use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you access, or use the Platform. This means we use your information to:
● Provide you with the Platform. We use your information to allow you to access and use the Platform.
● Enforce our Terms, Guidelines, or policies. We use your information to enforce our Terms, Guidelines, and policies. This may include removing content (including through automated means) or suspending or banning your account if we determine that you are violating our Terms or Guidelines.
Your Rights: Whenever we use your information on the basis that it is necessary for the contract we have with you, you have the right to port information you have provided to us.
Legitimate Interests
We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use the information we collect to:
Ensure the security and stability of the Platform.
● We use your information to ensure the stability and security of the Platform, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
● Legitimate Interest relied upon: To ensure the ongoing stability and security of the Platform and to ensure it is continuously available and functioning.
Information used: Information You Provide, Automatically Collected Information.
Review, improve, promote and develop the Platform.
● We use the information we have to understand how people are using the Platform and to develop and improve the Platform, including to train, develop, and improve our technology such as our machine learning models and algorithms.
● Legitimate Interest relied upon: To improve, promote, and develop the Platform in an informed way.
● Information used: Information You Provide, Automatically Collected Information.
Compliance with a legal obligation
We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.
To perform a task in the public interest
We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.
Your rights: When we use your information on the basis that it is necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our usage.
To protect someone's vital interests
We may use your information where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.
You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Da Memo will be responsible for responding to your request within the relevant periods provided by law.
Access your information.
You can ask us, free of charge, to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information.
Delete your information.
You can delete or ask us to delete some or all of your information. When you delete Da Memo, your personal data will be automatically deleted
Rectify your information.
You can change or ask us to change or correct your information where that information is not accurate. You can change it yourself on the app.
Port your information.
You have the right to data portability in circumstances where we rely on contractual necessity or consent as our legal basis. This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party. You can exercise your right of portability by choosing to “Download your data” in your settings.
Object to the processing of your information.
You also have the right to object to the processing of your information in certain circumstances. This right applies when we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.
Restrict the processing of your information.
You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.,
To exercise any of the above rights, please contact us
Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorised access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods. We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.x
To Support our global operations with Google Firebase:
When we transfer your information outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on:
● Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country offers an adequate level of data protection. We transfer your information as described in What Information We Collect to some countries with adequacy decisions; or
● Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in What Information We Collect to certain entities in our Corporate Group (as described here) and third parties in countries without an adequacy decision.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account
We may amend or update this Privacy Policy from time to time. We will notify you of any material changes to this policy by a notice provided through the Platform or by other means. The “Last Updated” date at the top of this policy reflects the effective date of such policy changes.
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
1-6/F, Building 1-6, Qiufen (10A), Taihua Wutong Industrial Park, Sanwei Community, Hangcheng Street, Bao'an District, Shenzhen
Email: support@moyoung.com