Welcome to Helo (the “Platform”). The Platform is provided or controlled by Bytedance Inc., a company registered in the State of Delaware, 1013 Centre Road, Suite 403-B, Wilmington, DE 19805 in the County of New Castle (“we” or “us”). We respect and are committed to protecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you are accepting and consenting to the practices described in this policy.
We may collect and use the following information about you:
• Information you give us. You may give us information about you by accessing or using our Services or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register for and/or use the Platform, such as your customer profile, information about your device, your browsing records, the comments you make on our Platform, as well as account and billing details, including but not limited to, your Apple, Google or Windows account, PayPal or other third-party payment channel account where required for the purpose of paying or withdrawing cash. The information you give us may include your name, State ID number, address, email address, social media login details, telephone number, credit or debit card information. It also includes information that you give to us, such as a picture, video or other filetype that you may choose to post on our Platform.
• Information you choose to share from your social networks. If you choose to link the Platform to your social network or public forum account (such as Facebook or WeChat), you may provide us or allow your social network to provide us with information from your social network or public forum accounts. This data may include your use of the Platform on such public forums and/or social networks. For further information as to how and for what purpose the social network provider processes your data, please see their privacy policies.
• Information we collect about you. We automatically collect certain data from you, including IP address or other unique device identifiers, Cookies (as defined below), mobile carrier, time zone and locale setting, mobile or device model, operating system and platform and information regarding your use of the Platform. We may also collect information about linking your contact or subscriber information with your activity across our Platform or by linking your activity on our Platform across all your devices using your email or social media log-in details.
• Behavioral information we collect about you. We also collect information regarding your use of the Services, e.g. profiles and your presumed interests, alongside marketing information such as opt-ins and communication preferences. We collect engagement scores (“likes”, comments, repeated views) and relate users based on your behavior. Finally, we collect opt-ins and communication preferences.
• Location data. When you use the Platform on a mobile device, we may process information about your location, including location information based on your SIM card, IP address or mobile device location settings, and if activated on your mobile device, by use of a Global Positioning System (GPS). We may use such information to provide you with location-based services, such as advertising and other personalized content. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device.
• Metadata. When you upload a picture, video or other filetype to the Platform (“User Content”), you automatically upload certain metadata that is connected to the User Content. In essence, metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your file the metadata can describe how, when and by whom the piece of User Content was collected and how that content is formatted. It further includes information such as your account name that enables other users to trace back the file to your user account. Metadata will further consist of additional data that you chose to provide with the User Content, e.g. any hashtags used to mark keywords to the post or comments.
• Information from third parties. We may receive information if you use any of the other websites we operate or other Services we provide.
We use the following Cookies:
• Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.
• Analytical/performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
“Do-not-track” signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to “do-not-track” signals in your web browser.
We will use the information we collect about you in the following ways:
It is in our legitimate interests to promote the Platform, and by agreeing to comply with this policy you agree that we may use information that you give to us, such as User Content that you may choose to post on our Platform, as part of our advertising and marketing campaigns to promote the Platform.
We may share your personal data with selected third parties in or outside your country, including:
We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above (“How We Use Your Personal Data”).
We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
We may also disclose your information to third parties:
We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.
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. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.
We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.
We use the following criteria to determine the period for which we will keep your information:
We will not retain sensitive personal data or information for longer than is required for the purposes for which such information may be lawfully used or is otherwise required under any law for the time being in force.
After you have terminated your use of our Services, we can store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we can also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.
The Platform is not directed at children under the age of 13. Users under the age of 13 are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 13, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a child under the age of 13, please contact us at email@example.com.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.
We will use commercially reasonable efforts to generally notify all users of any material changes to this policy, such as through a notice on our Platform, however, you should look at this policy regularly to check for such changes. Your continued access to or use of the Services 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 Services.
Questions, comments and requests regarding this policy are welcomed and should be addressed to Bytedance Inc. at email address of email@example.com.