Last updated on: December 17, 2021

Welcome to “OLADANCE” (meaning OLADANCE products and mobile applications (APP), collectively, “OLADANCE”)! This Policy is applicable to the personal information processed (including collection, use, sharing, assignment, disclosure, etc.) through OLADANCE (as defined below) by Shenzhen Dancing Technology Co., Ltd., its subsidiaries and affiliates (collectively, “Dancing Technology”, “the Company”, or “We/Us”).

We attach great importance to your privacy. For better protecting your personal information, we recommend that you should read the updated OLADANCE Privacy Policy (“this Policy”) carefully, especially the clauses in bold, to understand that what information we will collect from you and how we will use such information. Please make sure that you have fully understood and agreed to this Agreement before using OLADANCE. By agreeing to this Policy, you are deemed to have agreed that we process your relevant information in accordance with this Policy. You shall not use OLADANCE unless you have read and accepted all clauses of this Policy.

This Policy is applicable to the personal information, including, but not limited to, the personal information that you voluntarily provide when using OLADANCE services or that is generated subject to the needs of products/services. However, this Policy is not applicable to the use of your personal information by a third party, and we encourage you to familiarize yourself with the corresponding privacy policy before providing personal information to such third party.

For any objection to or question about the clauses of this Policy, you can communicate with us through the contact information announced in Article X “Contact Us” below.

This Policy will help you understand:

  1. Relevant Definitions
  2. How We Collect and Use Your Personal Information

III. How We Use SDK Technologies

  1. How We Process Your Personal Information
  2. How We Store Your Personal Information
  3. How We Protect Your Personal Information

VII. How We Manage Your Personal Information

VIII. Protection of Minors

  1. Amendment and Update
  2. Contact Us
  3. Relevant Definitions
  4. Personal information

Personal information shall mean different information related to an identified or identifiable natural person recorded electronically or by other means, excluding anonymized information.

Sensitive personal information shall mean the personal information that once leaked or illegally used, may easily lead to the infringement of the personal dignity of a natural person or may endanger his personal safety or property. Sensitive personal information under this Policy includes personal biometric information (e.g. voiceprints, static or dynamic facial features, etc.), precise positioning information, personal information of children under the age of 14 (inclusive), etc.

  1. Anonymization

Anonymization shall mean an irreversible technical process that makes personal information subjects unidentifiable or unassociated.

  1. De-identification

De-identification shall mean the technical process that makes personal information subjects unidentifiable without the help of additional information.

  1. How We Collect and Use Your Personal Information

We process the personal information that you voluntarily provide when using OLADANCE services or is generated subject to the needs of products/services in accordance with laws and regulations and on the principles of legitimacy, legality, necessity, openness, transparency and “minimum”, and inform you of the purpose for and scope of using the relevant personal information. If we intend to use your personal information for other purposes not specified herein, or use the collected information for other purposes based on a specific purpose, we will inform you in a timely and reasonable manner, and obtain your consent again before use.

Two types of your personal information we collect and use:

  1. Information necessary for basic business functions: Such information is necessary for the normal operation of products/services, and you are required to authorize us to collect such information. If you refuse to provide such information, you will not be able to use our products/services normally.
  2. Information that may need to be collected for expanding business functions: Such information is required for non-basic business functions, and you can choose whether to authorize us to collect such information. If you refuse to provide such information, the additional functions will not be realized or the effect we intend to achieve will not be achieved, but your normal use of the basic business functions will not be affected.

In addition, you understand and agree that we desire to provide you with perfect products and services, so we will continue to improve our products and services, including technologies. This means that we may launch new business functions frequently, and may collect new personal information or change the purpose for or way of using personal information. If a certain function or product/service that needs to collect your personal information is not described herein, we will explain to you the purpose, contents, use method and scope of the information collection separately by updating this Policy, E-mail, SMS, APP pop-up window, APP notification bar message push, etc., provide you with a way to freely give your consent/dissent, and collect your personnel information after obtaining your explicit consent. For any question about related matters during such process, you can communicate with us through the contact information announced in Article X “Contact Us” below, and we will give you a reply as soon as possible.

We process the following types of your personal information for the following purposes:

  1. User registration and login

When creating an account with OLADANCE, you are required to provide (1) a mobile phone number or E-mail address and create (2) a user name, in order to become our member so that we can provide you with membership services.

When using OLADANCE, you are required to choose to fill in and/or complete the necessary information for the services, which may include your E-mail address, mobile phone number, nickname, etc., in order to maintain your general information and improve your service experience. If you do not provide such information, your use of OLADANCE basic business functions will not be affected.

  1. Audio play function

When you use OLADANCE for audio play, we may need to collect your browsing and play history, favorites, etc. generated during your use.

  1. Message notification

During our operation, we may send you different types of notifications through your E-mail, SMS, APP pop-up window, APP notification bar message push, etc. for user message notification, identity verification, security verification, user experience survey and other purposes. Furthermore, we may also send you commercial information e.g. services, functions or events that may be of interest to you. If you do not want to accept such information, you can communicate with us through the contact information announced in Article X “Contact Us” below.

  1. Improvement of our services

For better understanding your opinions and suggestions on OLADANCE products/services and improving the quality of our products/services, we may, with your consent, send/provide questionnaires to you or conduct interviews with you, etc. through E-mail, SMS, APP pop-up window, APP notification bar message push or other third-party tools (Survey Monkey). During the process of filling in the questionnaires/accepting interviews, you are required to provide different types of your personal, depending on the type of questionnaire/interview. If you do not want to provide the above personal information, you may refuse to complete the questionnaire/accept the interview.

When you use our services, we may directly or indirectly collect, store and associate information about the services you use and how you use them, including log information and device information, in order to identify abnormal account status, understand product suitability, provide you with basic services such as browsing, ensure the normal operation of services, and optimize service experience. For collecting the above personal device information, we will apply for permission to access your device information.

When you interact with OLADANCE platform, we may collect the relevant information, including your IP address, APP operation records, mobile phone and headset device information, in order to conduct data analysis and research and improve the products/services we provide to you.

  1. OLADANCE APP permission invoking

Certain functions provided by OLADANCE may require you to enable the operating system permissions, in order to provide you with the services you choose to use, or to ensure the quality and experience of services. If you disagree to authorize OLADANCE APP to obtain the relevant operating system permissions, your use of the basic business functions (except for the necessary operating system permissions that basic business functions depend on) provided by us will not be affected, but you may not be able to obtain the user experience that extended business services give you.

1). Bluetooth permissions (Android, iOS version): We need you to authorize us to access your Bluetooth permissions for pairing and connecting OLADANCE products with other devices (e.g. your mobile phone).

2). Camera permissions (Android, iOS version): If you want to use OLADANCE to provide the function of taking pictures and sending, we need you to authorize us to access your mobile phone camera permissions.

3). Album permissions (iOS version): We need you to authorize us to access your album permissions for sending or selecting photos.

4). Microphone permissions (Android, iOS version): We need you to authorize us to access your phone’s microphone permissions, and may collect the sound of your voice interaction information. When OLADANCE executes the relevant instructions, it will obtain your voice data, and transmit the data back to your selected third-party account service, as well as forward the information you request. We also need you to authorize us to access your phone’s microphone permissions for better providing walkie-talkie services.

5). Permissions to read and write external storage space (SD Card) (Android version): We need you to authorize us to access your permissions to read and write external storage space, which is used for uploading and storing pictures and for storing device firmware files and temporary data.

6). Location permissions (Android version): We need you to authorize us to access your location permissions to search for nearby Bluetooth devices. Android 6 and higher requires location services to be enabled in order to search for Bluetooth devices.

7). Call permissions (Android version): We need you to authorize us to access your call permissions for generating device ID locally on the client side.

Please note that if by enabling any permission, you are deemed to have authorized us to collect and use the relevant personal information to provide you with corresponding services. Once disabling any permission, you are deemed to have cancelled the authorization, and we will no longer continue to collect and use the relevant personal information based on the corresponding permissions, and we will not be able to provide you with services corresponding to such permissions. However, your decision to disable the permissions will not affect the previous collection and use of information based on your authorization, and your cancellation of authorization will not affect the use of other functions, unless you cancel the authorization of personal information necessary for basic business functions.

Please be aware that we, in accordance with the provisions of laws and regulations, may not obtain your prior authorization and consent for the collection and use of your personal information under certain circumstances, more fully described in Section 4 “Exceptions to authorization and consent” in Article IV hereof.

III. How We Use SDK Technologies

Our APP will embed the SDK of third-party partners or other similar APPs for ensuring the stable operation and function realization of our mobile client, and enabling you to enjoy and use more services and functions.

We will conduct strict security testing on application programming interfaces (APIs) and software development kits (SDKs) used by third-party partners to obtain the relevant information, and agree on strict personal information protection measures with authorized partners, making them to process personal information by following this Policy and taking any other relevant confidentiality and security measures. Please check the Description of Collecting and Using Information by Third-party SDKs attached at the bottom o this Agreement.

  1. How We Process Your Personal Information
  2. Joint processing and entrusted processing

You are fully aware and agree that when providing you with products or services, we will jointly process and entrust the processing of your personal information under the following circumstances, and we will separately seek your authorization and consent through the notification method announced in Article IX below beyond the following circumstances:

  1. Joint processing: Upon obtaining your separate consent or subject to Section 4 “Exceptions to authorization and consent” in Article IV hereof, we may jointly process your information with third-party partners who help us operate, analyze, improve, customize, support and market.
  2. Entrusted processing: Certain specific modules and functions in OLADANCE business functions are provided by external suppliers. The third-party partners we entrust to process personal information can only have access to the information they need to perform their duties, and we will supervise their entrusted processing activities.

E.g. in order to understand your feedback on our products, we will use the third-party Survey Monkey questionnaire platform in your survey, and the relevant contents you fill in the questionnaire will be stored on the corresponding platform server.

We will only entrust and jointly process your information for the legal, legitimate, necessary, specific and explicit purposes as stated herein. We will conduct a reasonable review of the personal information security environment of third-party partners, and sign strict personal information processing agreements with them to ensure that they can only access the information they need to perform their duties, and require them to take adequate protection measures for your information, and to strictly abide by applicable laws, regulations and regulatory requirements.

If the agreement between us and the third-party partner on the processing purpose and processing method changes and substantially affects the original processing purpose and processing method, we will obtain your authorization and consent again. If you choose to cancel the authorization, we will stop the services corresponding to the authorization.

  1. Assignment

We may assign your personal information to other companies, organizations or individuals upon obtaining your separate consent or in accordance with Section 4 “Exceptions to authorization and consent” in Article IV hereof. In the event of a merger, acquisition or bankruptcy liquidation, the assignment of personal information may be involved. In this case, we will require new companies or organizations that hold your personal information to continue to be bound by this Policy. In case of any change in the personal information collection and processing methods as agreed herein, the companies or organizations will seek your authorization and consent again.

  1. Disclosure

We may disclose personal information on the premise of taking industry-standard security protection measures when obtaining your separate consent or in accordance with Section 4 “Exceptions to authorization and consent” in Article IV hereof. For your disclosed personal information, we will carefully review its legitimacy, rationality and legality as soon as we receive the application for disclosure, and take the measures described in Article VI hereof to protect your personal information when and after such disclosure.

  1. Exceptions to authorization and consent

Please be aware that we, in accordance with the provisions of laws and regulations, may not obtain your prior authorization and consent for the collection and use of your personal information under the following circumstances:

  1. Directly relevant to national security or national defense;
  2. In response to public health emergencies;
  3. Directly relevant to criminal investigations, prosecutions, trials or execution of court decisions, etc.; or in accordance with the requirements of laws and regulations, the requirements of administrative organs or public security organs, procuratorial organs, people’s courts and other competent authorities;
  4. Necessary to protect the life, health and property safety of natural persons in emergencies, e.g. to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain your consent;
  5. Personal information is disclosed to the public by you or collected from legal channels (e.g. legal news reports, government information disclosure, etc.);
  6. Necessary in accordance with the signing and performance of the relevant agreements or other written documents with you; or
  7. Necessary to perform legal duties or legal obligations.
  8. How We Store Your Personal Information
  9. Storage location

We are a global company and operate on a global scale. In principle, we will store in the People’s Republic of China the personal information collected and generated during our operations in the People’s Republic of China. Since we provide products/services through resources and servers located all over the world, this means that, after your separate consent is obtained, your personal information may be transferred to jurisdictions outside the country/region where you use the products/services, or subject to access from these jurisdictions. Such jurisdictions may have different personal information protection laws, and in such cases, we will endeavor to ensure that your personal information is adequately and equally protected in the People’s Republic of China. E.g. we will obtain your consent for cross-border transfer of your personal information, or implement security measures such as de-identification of your personal information before cross-border personal information transfer.

In response to the above situations, we will explicitly inform you separately (including the purpose of exporting personal information, recipients, use methods and scope, use contents, etc.), and transfer your personal information with your consent or as otherwise permitted by law. We will ensure that the recipients of personal information shall have sufficient personal information protection capabilities to protect your personal information.

  1. Retention period

We keep your personal information for the shortest period necessary to provide you with products and services, e.g. when you use our registration and membership functions, we need to collect your mobile phone number. After you provide the mobile phone and during the period when you use these functions, we need to keep your mobile phone number in order to provide you with these functions normally and ensure the security of your account and system.

We judge the retention period of personal information mainly by referring to the following standards, whichever is longer:

  1. Completing the transaction purpose related to you, maintaining the corresponding transaction and business records, and responding to your possible inquiries or complaints;
  2. Ensuring the safety and quality of the products/services we provide to you;
  3. Whether you agree to a longer retention period;
  4. Whether there are other special provisions on the retention period; and
  5. The necessary period stipulated by law (E.g. the Electronic Commerce Law stipulates that the retention period of commodity and service information and transaction information shall not be less than three (3) years from the date of completing the transaction).

After the above retention period has expired, we will delete or anonymize your personal information, unless it meets the circumstances specified in Section 4 “Exceptions to authorization and consent” in Article IV hereof.

  1. How We Protect Your Personal Information

We have taken industry-standard security protection measures to protect the personal information you provide against unauthorized access, public disclosure, use, modification, damage or loss. We will take any and all reasonable and practicable measures to protect your personal information.

After a personal information security incident unfortunately occurs, we will, in accordance with the requirements of laws and regulations, inform you in a timely manner the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions that you can independently prevent and reduce risks, the remedial measures for you, etc. We will inform you of the incident-related situation by E-mail, SMS, APP pop-up window, APP notification bar message push, etc. If it is difficult to inform the personal information subjects one by one, we will publish an announcement in a reasonable and effective manner. At the same time, we will actively report the processing of personal information security incidents in accordance with the requirements of the regulatory authorities.

VII. How We Manage Your Personal Information

  1. Access and update

We encourage you to update and amend your information to make it more accurate and effective. We will take appropriate operation settings and guidelines or provide contact channels for submitting applications to ensure that you can, as far as possible, access, update and correct your information or other information provided when using OLADANCE.

If you intend to access, update and correct your certain information, you may log in to your personal account and visit your account settings page to view and change your account profile information. You can also contact us for processing through the contact information announced in Article X “Contact Us” below. Unless otherwise provided by laws and regulations, when you correct your personal information, we may not immediately correct or delete the corresponding information from the backup system, but will correct or delete the information when the backup is updated.

  1. Change the scope of your authorization or withdraw your authorization

You can change the scope of your authorization for us to continue collecting personal information or withdraw your authorization by deleting information or disabling device functions, etc. You can withdraw all authorization for us to continue collecting your personal information by canceling your account. Please understand that each business function requires some basic personal information to complete. When you withdraw your consent or authorization, we cannot continue providing you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your personal information. However, your decision to withdraw your consent or authorization will not affect the previous collection, processing and use of information based on your authorization.

  1. Cancellation and deletion

We provide you with the cancellation and deletion functions of your registered account. You can log in to your personal account, visit your account settings page, and delete your account by yourself if you meet the conditions as agreed in the service agreement and the applicable Chinese laws and regulations. When your account is logged in, the path to cannel your account: Me - Personal Information - Delete Account. You can also delete your account by submitting a request to our customer service E-mail at support@oladance.com.

You may request us to delete your personal information in the following circumstances:

  1. If our processing of your personal information violates laws and regulations;
  2. If we collect and use your personal information without your consent;
  3. If our processing of your personal information violates our agreement with you;
  4. If you no longer use our products/services, or you cancel your account; or
  5. If we no longer provide you with products/services.

When we decide to respond to your deletion request, we will also inform the entity that acquires your personal information from us and ask it to delete your personal information without delay, unless otherwise required by laws and regulations, or the entity has acquired specific authorization from you. After you delete or we assist you in deleting the relevant information, we may not be able to delete the corresponding information from the backup system immediately due to applicable laws, regulations and security technologies. We will store your personal information securely and will not process it further until backups can be cleared or anonymized.

  1. Automatic decision-making in constrained information systems

In certain business functions, we may only make decisions based on non-human automatic decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you reserve the right to request us to make an explanation and we will provide appropriate remedies.

  1. Respond to your above request

We take your every request very seriously. At the same time, you understand and agree that we may not be able to respond to your request in a timely manner under the circumstance as specified in Section 4 “Exceptions to authorization and consent” in Article IV hereof.

VIII. Protection of Minors

OLADANCE products/services are not intended to be used exclusively by minors. Minors shall obtain the consent of their guardians before using our products/services. If you are a minor, you are required to read this Policy under the supervision and guidance of your guardian(s) before using our products/services, and you shall use our products/services and submit your personal information under the explicit consent and guidance of your guardian(s). We protect the personal information of minors in accordance with applicable Chinese laws and regulations, and will only process the personal information of minors when permitted by laws and regulations and with the explicit consent of their guardians.

If you are the guardian of a minor, for any question about the personal information of the minor under your guardianship, you can communicate with us through the contact information announced in Article X “Contact Us” below. If we find that we have collected the personal information of minors without the prior consent of their verifiable guardians, we will delete the relevant personal information as soon as possible.

  1. Amendment and Update

For providing you with better services, we may amend the clauses of this Policy in a timely manner based on the updates of OLADANCE products/services and the relevant requirements of laws and regulations, and announce any amendment to this Policy on this page. Such amendment shall constitute an integral part of the Policy. For material changes, we will also provide more prominent notifications (including E-mail, SMS, APP pop-up window, APP notification bar message push or other methods). Material changes as mentioned herein include, but are not limited to,

  1. Material changes to our service model, e.g. the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;
  2. Material changes in our ownership structure, e.g. the changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
  3. Material changes in the main objects of personal information sharing, assignment or public disclosure;
  4. Material changes in your rights to participate in the processing of personal information and the way they are exercised;
  5. Material changes in our responsible department for handling personal information security, contact information and complaint channels;
  6. When the personal information security impact assessment report indicates a high risk;
  7. Other significant circumstances or circumstances may seriously affect your personal rights and interests.

If you disagree with the changes, you can choose to stop using OLADANCE services; by continuing using OLADANCE services, you are deemed to have fully read, understood and agreed to be bound by the amended policy. We will put your satisfaction first for any of our amendments. We encourage you to check this Policy each time you use OLADANCE services.

We may issue service-related announcements when necessary (e.g. when we suspend, change, or terminate a certain service due to system maintenance). If you do not want to continue to receive our push messages, you can request us to stop push messages. E.g. you request us to stop sending promotional SMS in accordance with the SMS unsubscription guidelines, or set your mobile device to stop receiving our push messages, except when we send messages in accordance with the law or the service agreement.

  1. Contact Us

For any question, inquiry or complaint about the contents of this Policy or matters related to privacy protection when using our services, you can contact us in any of the following ways:

  1. You can submit feedback online on OLADANCE APP function page;
  2. You can contact us by sending an E-mail to our customer service E-mail at support@oladance.com;

We will reply to you as soon as possible within fifteen working days after receiving your feedback and suggestions and verifying your user identity.

Annex I Description of Collecting and Using Information by Third-party SDKs

SDK name: NetEase Yunxin SDK

Purpose:

Walkie-talkie communication

Type of personal information: Voices, texts and pictures uploaded by individuals.

 

SDK name: AndroidUtilCode

Affiliation/developer: Blankj

Category: Basic function

Source: https://github.com/Blankj/AndroidUtilCode

Package name: com.blankj.utilcode

Purpose: Development kits, technical components, used to aid development

Type of information collected: Not involving the collection of personal privacy information

Official website link/privacy policy link: https://github.com/Blankj/AndroidUtilCode