1. What types of Personal Data do we collect and our purposes

The scope of Personal Data we collect depends on the functions of 17Play you use and how you use these functions. The purposes and types of Personal Data we collect are summarized in the below.

1. A. The Personal Data you directly provide to us

   Registration and Login. If you choose to register for a 17Play account by email or mobile phone number or appstore account(if applicable), we may need to collect your basic profile information such as your user nickname, age, avatar, gender, email or mobile phone number. If you refuse to provide such Personal Data, you will not be able to complete the registration process and can only use very limited functions of 17Play as a visitor. After you have logged in, you may also choose to add additional Personal Data to your personal profile page, such as your birthday,relationship status, hometown, personal tags, etc. to show your personalized image. New users of 17Play may also log in through a third-party platform account (please refer to Section 1.C below for more information).

2. B. The Personal Data provided by you or generated during your use of 17Play

   Content Viewing. Any user can view publicly available UGC within 17Play and you do not need to register a 17Play account or login to view such UGC, but it is necessary to login with an account of VR distribution platform when you use 17Play VR. Whether you are viewing after login or as a visitor, we may collect your browsing history so that you can record and further explore the content you have viewed.
   Social Network and Interaction. In order to provide you with a better social network experience and to increase the number of views of your own UGC, we may ask you at login if you provide us with the access to your Contacts on your device so that we can find friends for you within 17Play community; you may decline to provide us with this access and it will not affect your use of other functions of 17Play. We may also recommend users that you may wish to follow based on data analysis, and you may decline or turn off our recommendations. If you wish to add friends manually, you may provide us with the user ID of your friend, your location data (by turning on the location access on your device), or a list of friends from a third-party social platforms (e.g., Facebook, YouTube, Instagram, and Twitter) so that we can find or recommend other users for you. If you use the Creating Rooms function, we may collect the names and tags of the rooms you create. In addition, 17Play also offers other social network features such as Partner Space, Friendship , which enable you to interact with other users and enjoy 17Play in your way.
   Chat and Message. When you use the Room Chat function, we may collect your text chat data and/or voice chat data, depending on the specific method you use. Please do not worry, your chat data is protected by encryption and we process your chat data only for security purpose, such as automatic screening illegal information about pornography, violence, or scams.
   Feedback and Report. When you use the feedback function within 17Play, we need to collect the feedback description . If you do not provide such information, we may not be able to help you resolve the issue or respond to your feedback. In addition, if you wish to make a report (for example, when you discover any illegal content, illegal user activity, or your rights have been violated), we need to collect a description of your report, the type of report, and relevant chat logs (if any) in order to understand the facts and help you resolve the issue.
   Improving User Experience. To improve your user experience (e.g., by making it easier for you to view information about your account, sending you push notifications, and providing you with personalized content and services that may be of interest to you), we may automatically collect information about your language, gender, clicks and actions, program progress (including login status, interaction information/status, achievement information, etc.), application token, operating system, network information (e.g., IP address), device data (e.g., IMEI and other device identifiers), country/region, device model, screen resolution, geographic location, anonymous user identifier, etc., and analyze such data.
   Maintaining Stability and Security. In order to maintain the stability and security of 17Play and your account, we will automatically collect data related to the operation of the mobile application and your online operations, such as data related to your login status, clicks and actions, user device data (e.g., IMEI and other device identifiers), operating system data, network information (e.g., IP address), etc. when you are using 17Play.
   

3. C. The Personal Data provided by third parties

   Third-Party Login. To make it easier to use 17Play applications, you may also choose to register and login within 17Play through your account on a third-party platform (e.g., appstore id), and it is necessary for you to register the account of the 17Play so that you can use it to login 17Play . In such cases, we may collect your nickname, avatar, third-party account email and Open ID, birthday/age, gender, friend list, location, and by logging in through these third-party accounts, you are consenting to the third-party providing us with the Personal Data concerned. We may also use the contact information (e.g., email address) provided by the third-party platforms to conduct user survey or to send marketing communications to you. Where required by applicable laws and regulations, we will obtain your consent before sending you marketing messages. If you are not interested in such information, you may refuse or opt out at any time.
   If you provide us with any Personal Data of any data subjects other than yourself, please bring this Privacy Policy to their attention. You hereby acknowledge that you have obtained their consent or completed other formality as required by other lawful bases for the Personal Data processing in lieu of consent before providing such Personal Data to us. By submitting such information to us, you represent to us that you are entitled to provide and we are entitled to process the relevant Personal Data for the purposes as stated in the Privacy Policy.
   In general, we will use your Personal Data only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect the relevant Personal Data. However, we may also process Personal Data for other purposes that are not incompatible with the purposes that we have disclosed to you if and where it is permitted by applicable laws and regulations. If we do so, we will inform you separately by other means to ensure transparency.

2. How do we use cookies and similar technologies

Like many online services, we use cookies and similar technologies to operate and provide our Services and to improve user experience. Cookies are usually small text files that are stored on your device's browser directory or program data subfolders when you use 17Play. Cookies allow 17Play to access or store information from your application about you, your settings or your device. They are mainly used to ensure 17Play's expected functionality. As a rule, cookies do not contain any information that could identify you directly. They do, however, make it possible to offer you a more personalized user experience. If you do not accept these cookies, you may not be able to use all functions of 17Play. For example, we use first-party cookies to save your login information for future logins to our service. Such cookies are strictly necessary for the normal operation of 17Play.

3. How do we process minors' Personal Data

17Play is not directed to any minors under the age of 13. If we become aware that any Personal Data has been collected by 17Play from a user under the age of 13, we will delete such Personal Data and terminate the user's account. If you believe that we have collected Personal Data from a minor under the age of 13, please contact us by using the contact details provided in the "How to contact us" section below.
If you are a parent or legal guardian of a minor, please ensure that you have read this Privacy Policy and are responsible for your child's activities before allowing your child to create his or her own 17Play account and use the application. You are suggested to pay close attention to your child's use of 17Play and to ensure that your child only uses age-appropriate functions.
We recognize that we have a special obligation to protect minors with respect to the collection and processing of Personal Data. We also strongly recommend that parents and guardians educate their children to never disclose or provide any Personal Data about them without your prior permission when using our services. If you have questions on how we process minors' Personal Data, please contact us using the contact details provided in "How to contact us".

4. How do we share and entrust the processing of your Personal Data

In order to provide you with better services, we may engage third parties (such as those who assist us in providing services related to 17Play, e.g., cloud service providers) to process your Personal Data on our behalf. We will enter into strict confidentiality contractual terms with such third parties and require them to process Personal Data in accordance with our requirements, this Privacy Policy, and the confidentiality and security measures required by applicable laws and regulations.
We may share your Personal Data with third parties in the following circumstances:

1. （1）To provide you with a better user experience, we may share your Personal Data to our cooperation partners, such as sharing your behavioral data and profiling data to online advertising service providers. We may also use Google Analytics and Facebook Analytics to collect information about the use of our services. Google Analytics and Facebook Analytics collect information such as how often users visit the services, what activities do they do when they visit the services, and what are the locations when they login the services. We may collect aggregate information through Google Analytics and Facebook Analytics and share with them such information, for the purpose of copyright royalty calculation, marketing event implementation, and tailored service provision for users in specific territory. This is necessary for our cooperation with music licensors to provide high quality music services to our users.

   （2）To detect, prevent or otherwise address security or fraud issues, we may provide your registration information (i.e. your email, cell phone number or the social media token you used to log in the app), your country/region as selected, and the IP address you last login to the applicable third-party payment service providers during such transactions and payments. 

   （3）In the event we use information such as user-generated content and video content on our Platform as part of our advertising and marketing campaigns to promote the Platform, your personal data contained in such information may be disclosed to the recipients of such advertising or marketing content.

   （4）In the event of any change, merger, acquisition, reorganization, or liquidation involving the transfer of Personal Data, we will ask the new company or organization handling your Personal Data to continue to process your Personal Data in accordance with this Privacy Policy. If the new company or organization handling your Personal Data needs to use your Personal Data for purposes not stated in this Privacy Policy, the new company or organization will obtain your consent, unless otherwise provided by the applicable laws and regulations.

   （5）To relevant competent law enforcement body, regulatory, government agency, court or other third parties where we believe that such disclosure is to (1) comply with an applicable law or regulation; (2) exercise, establish or defend our legal rights; or (3) protect your vital interests or those of any other persons.

5. How do we protect your Personal Data

To provide you with a privacy-friendly environment, 17Play offers a variety of privacy protection features to limit the Personal Data that other users can see. We use appropriate technical and organizational measures to protect your Personal Data that we collect and process. The measures that we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. For example, we adopt encryption at rest to secure all user data (including database files and backups) and use security keys for data management. We adopt encryption in transit through TLS 1.2 protocols to protect data flow in the public network environment from user devices to servers and from servers to servers. We will also ensure the effective implementation of these technical measures through code review mechanisms. In addition, we periodically test the applications and systems for vulnerabilities and security issues, and take access control measures such as access tokens and multi-factor authentication to ensure information security.

Please be aware and understand that we cannot ensure an absolutely secure Internet. If you find that your Personal Data is breached, please contact us using the contact details provided in "How to contact us" immediately so that we can take the corresponding measures.In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Data, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take and other relevant information. In the event of a security incident related to Personal Data, we will report such incident to the competent authorities in accordance with the requirements of applicable laws and regulations, promptly investigate the problem, and take the emergency measures.

7. Your rights

We value the protection of your Personal Data. If you want to access, correct, or delete your Personal Data, or if you want to refuse marketing messages, file a complaint, withdraw consent, or exercise other rights under applicable laws and regulations, please do so as described below or contact us using the contact details provided in "How to contact us".

1. A. Access your Personal Data

   You have the right to access the Personal Data that we collect about you. For Personal Data such as nickname, avatar, birthday, occupation, personal tags and other information that you voluntarily provide to us, you can view them in your personal profile (Setting page) within 17Play; for Personal Data that you provide and generate while using 17Play (e.g., chat messages, UGC, etc.) as well as Personal Data that third parties provide to us (e.g., third-party platform account information, payment information, etc.), you can access them within the corresponding functions of 17Play. You also have the right to request a copy of your Personal Data from us, by contacting us using the contact details provided in the "How to contact us" section below.

2. B. Correct your Personal Data

   We will endeavor to ensure that your Personal Data is accurate and up-to-date by implementing appropriate measures. If your Personal Data is inaccurate or incomplete, you have the right to correct such Personal Data. For Personal Data such as nickname, avatar, birthday, occupation, personal tags and other information that you voluntarily provide to us, you can correct them within your personal profile (Setting page) within 17Play; for Personal Data that you provide and generate while using 17Play (e.g., chat messages etc.) and Personal Data that third parties provide to us (e.g., third-party platform account information, payment information, etc.), if you think such Personal Data needs to be corrected, you can contact us using the contact details provided in the "How to contact us" section below. Please note that for Personal Data provided by third parties, we may not be able to keep the information up-to-date and you may need to contact the third-party for correction.

3. C. Delete your Personal Data

   You have the right to request us to delete your Personal Data, including your 17Play account and related Personal Data. You can do this on the Setting page ( Delete Account) within 17Play. Please note that after you submit a request to delete your account, you will no longer be able to use 17Play, so please decide carefully. In addition, we will also voluntarily delete your Personal Data after the expiration of the retention period of the Personal Data when the purposes of processing in the first part of this Privacy Policy no longer exist.
   If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Data after termination of services or operations.

4. D. Right to file a complaint

   You have the right to file a complaint with the data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. Before you file a complaint, we also sincerely hope that you will first provide us with your comments and we will endeavor to answer your questions and protect your rights.

5. E. Right to withdraw consent

   If we process your Personal Data based on your consent, you may withdraw your consent at any time. Please note that withdrawal of your consent will not affect the lawfulness of any processing we have carried out prior to your withdrawal of consent, nor will it affect the lawfulness of our processing of your Personal Data based on a lawful basis other than your consent.

6. F. Other rights under applicable laws and regulations

   If you want to exercise your other statutory data subject rights under applicable laws and regulations, you may contact us using the contact details provided in the "How to contact us" section below.

7. G. Identity verification and responding to your requests

   In order to protect the security of your information, we may need to verify your identity before responding to your requests to exercise your rights, for example, by requiring you to provide certain identity-related supporting information. We will respond to your request to exercise your data subject rights in accordance with the requirements under applicable laws and regulations and in a timely manner.

8. Special notice to California residents

If you are a California resident, this section provides a special notice and applies to you. For California residents, Personal Data in this section is equivalent to "Personal Information" that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

California Shine the Light Law: California residents may request a list of all third parties to which we have disclosed certain Personal Data about you for marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information by contacting us using the contact details provided in the "How to contact us" section below. Please allow up to thirty (30) days for a response.
California Minors: If you are a California resident under the age of 18 and you are unable to remove publicly-available information that you have submitted to 17Play, you may request removal by contacting 17Play using the contact details provided in the "How to contact us" section below. When requesting removal, you must be specific about the information you want to be removed and provide 17Play with specific information, such as the URL for each page where the information is located, so that we can find it. 17Play is not required to remove any information where: (i) federal or state law requires us or a third party to maintain the information; (ii) the information was not posted by you; (iii) the information has been anonymized by 17Play so that you cannot be identified from such information; (iv) you don't follow our instructions for removing or requesting removal; or (v) you received compensation or other consideration for providing the information. Removal of your information from the services does not ensure complete or comprehensive removal of that information from our systems or the systems of our service providers. In addition, materials that you have posted may be republished or reposted by another user or third party. Please note, 17Play is not required to destroy the information; 17Play's obligations under California law are satisfied so long as we anonymize the information or render it invisible to other users and the public.
Do Not Sell My Personal Data:Where applicable, the California Consumer Privacy Act ("CCPA") provides you with the right to opt out of the "sale" of your Personal Data. We generally do not directly sell your Personal Data in the conventional sense (i.e., for monetary or other valuable consideration). Like many social and entertainment mobile applications, however, we use services that help deliver interest-based ads to you and may transfer Personal Data to business partners for their use. Making Personal Data (such as online identifiers or browsing activity) available to these companies may be considered a "sale" under the CCPA. To request that 17Play may not "sell" your Personal Data, please contact us using the contact details provided in the "How to contact us" section below. Please note, some transfers of your Personal Data may not be considered "sales" and certain exemptions may apply under the CCPA, such as sharing aggregated demographic and interest data of users. Your selection does not affect other sharing of your data, as outlined in this Privacy Policy. You may still see some advertising, regardless of your selection.
Do Not Track:At this time, we are not aware of worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Accordingly, our services may be unable to respond to "Do Not Track" requests from browsers. In addition, when you use our services, we and third parties may use tracking technologies to collect your Personal Data about your online activities for a variety of purposes, including serving you advertising and personalized content. If you want to opt out of having your online activity and device data collected by third parties, there are a number of tools and methods that any user may use. For example, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Please note that using these tools to opt out of tracking and targeting does not mean that you will not receive advertising while using 17Play, nor will it prevent the receipt of interest-based advertising from third parties. It will exclude you, however, from interest-based advertising conducted through relevant networks and platforms, as provided by their policies and choice mechanisms.
Additional Information:If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable laws and regulations, we may charge a reasonable fee to comply with your request.

9. How do we update this Privacy Policy

We may update this Privacy Policy from time to time in response to the changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make. You can see when this Privacy Policy came into effect by checking the "Effective Date" displayed at the top of this Privacy Policy. If you continue to use any functions of 17Play, you are deemed to have read and understood the updated version of the Privacy Policy.

10. How to contact us

If you have any questions or concerns about this Privacy Policy or our processing of your Personal Data, especially if you consider that our processing your Personal Data impairs your legitimate interests, please contact us using the contact details below. We will review your question without delay and make a timely reply according to the applicable laws and regulations. Our contact details are as follows:
Company Name: VOH PTE. LTD.
Email: vvking.service@gmail.com

11. Governing law and dispute solution

This Privacy Policy is governed by the internal substantive laws of Singapore, without respect to its conflict of law provisions. Any dispute arising out of or in connection with the Privacy Policy, including any question regarding existence, validity or termination of the Privacy Policy , shall be referred to and finally resolved by arbitration administered by Singapore International Arbitration Centre ("SIAC") in accordance with the Arbitration Rules of SIAC ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be in Singapore. The Tribunal shall consist of three (3) arbitrators. The language of the arbitration shall be English.