Finovel Privacy Policy

We(Finovel) recognizes that your privacy is very important, and we take it seriously. Your privacy and trust are very important to us, and it is our commitment to being transparent about the use of collected information. This Guideline will explain how Finovel collects, uses and stores your personal information, along with the rights you are entitled to. We will use this Guideline to explain the relevant details, including the following:

i. We will describe the types of personal information we collect and their corresponding use in order for you to understand how we collect specific types of personal information for a particular function, the reasons for its use and the methods of such collection.

ii. At present, Finovel will not actively share or transfer your personal information to any third parties outside of Finovel. Where the sharing or transferring of your personal information arises in some other situation or you require us to share or transfer your personal information to a third party outside of Finovel, we will directly obtain, or verify the third party has obtained your prior express consent to such share or transfer of your personal information. Also, we will evaluate the risks of such sharing or transferring.

iii. At present, Finovel will not actively obtain your personal information from a third party outside of Finovel. If there is a requirement to obtain your personal information indirectly from a third party for future business development purposes, we will clarify with you the source, type and scope of such personal information. For example, if the processing of personal information for a specific development is beyond the scope of what you originally agreed to provide to a third party, we will obtain your prior express consent before processing your personal information, and we will strictly abide by the relevant laws and regulations and require that the third party guarantees the legitimacy of the information provided.

1.The Information We Collect

The information we collect depends on how you use our services and the choices you make.

In the process of using Finovel service, Finovel will, in accordance with the following ways, collect information provided by you during the use of the service or information generated by the use of the service, in order to provide such services to you, to optimize our services and protect your account security:

1.1 If you access or use our services as a registered user (or by authorizing with a third-party account like Google or Facebook), we will collect certain information associated with your account that you provide to us (usually your username, nickname, age, email address, password, and profile picture).

1.2 When you edit your profile image, Finovel will display a pop-up window that collects and stores your uploaded profil image, letting you know that we will be displaying the reviewer's profile in the Book Reviews module. We will only allow you to upload an image if you click the "Agree" button. You can choose to decline. If you decline, we will use the default profile for the reviewer and it will not interfere with other features.

1.3 When you use Finovel’s service, in order to ensure the normal use of our services, to maintain the normal operation of our services, and to optimize and improve our services and protect the safety of your account, we will collect information about your device model, operating system, unique device identifier, login IP address, Finovel version number, access network mode , type and status, the quality of your network, equipment accelerators (such as gravity sensing equipment), operation logs, service logs (such as the information you browse on Finovel, or the information about service failure, referrer URLs etc.) and other log information. Such information is required to provide you with Finovel’s service and are basic information which must be collected.

1.4 Cookies

To ensure the normal operation of this platform, we will store small data files called cookies on your mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, we can store your preferences and usage habits. We will not use cookies for any purpose other than those described in this policy. You can delete cookies by clicking on "Clear Cache" in the settings page within the app.

1.5 Adjoe SDK Terms of Usage

Consent to the Processing of Personal Data for the Use of Playtime

When using Playtime for the first time, you first have to accept our terms and conditions of use (GTC) during the registration and agree to the processing of your personal data by Playtime. For this purpose, you have to confirm the following declaration of consent by clicking on the “ACCEPT” button underneath (if you do not want to give consent, please click on “REJECT”; the use of Playtime will then not be possible):

I hereby consent to adjoe GmbH using the following personal data within the framework of the use of Playtime:

Installed apps (including the use duration and use history)

Playtime usage data (history of clicks in Playtime and starts of the Playtime partner app)

Device ID (so-called GAID oder IDFA) and other technical specifications of the end device

The data will be connected to your end device via the device ID (so-called GAID or IDFA) and sent, encrypted, to our servers.

The processing of the above data is necessary to be able to recommend, via system messages, the installation of apps available in Playtime that match my interests, and calculate the bonuses acquired as a result of my use of the corresponding apps.

I am aware that a profile of interests will be generated using the above data, and depending on the types of app I use, this may contain particularly sensitive personal data (e.g. health-related data or data about my sexual orientation, and any other data in special categories pursuant to Art. 9[1] GDPR).

In order for app providers to finance our app suggestions, they must be sent the device ID for billing purposes.

View Adjoe's full data privacy statement and terms and conditions of use via the link below:

Terms and Conditions of Use: https://adjoe.zone/legal/en/terms_of_use.html

Data Privacy Statement: https://adjoe.zone/legal/en/data_privacy.html

1.6 When you use Finovel with other interoperable software or hardware, providers of such software or hardware can, with your consent, obtain relevant information that you actively disclose or transmit on Finovel. You should fully understand product features and information protection policy of other software or hardware before granting your consent.

In addition, in accordance with relevant laws and regulations and national standards, in the following circumstances, we may collect and process your relevant personal information without asking for your consent:

1) When it is directly related to national interests such as national security and national defense, or it is directly related to major public interests such as public safety, public health, and public knowledge;

2) When it is directly related to a criminal investigation, prosecution, trial or execution of judgments;

3) In order to protect vital legitimate interests of you or of other individuals, such as right of life, property, and reputation, while it’s hardly to obtain the consent of the individual;

4) When the personal information is disclosed to the public by yourself;

5) When the personal information is collected from legally publicly disclosed information, such as legitimate content reports, government information disclosure, etc.;

6) When it is necessary for entering into and/or performance of a contract to which you are the party;

7) When it is necessary for maintenance of the safe and stable operation of the products or services provided, such as discovering malfunctions and/or troubleshooting products or services;

8) When it is necessary for legitimate content reporting;

9) When it is necessary for conducting statistical or academic research which is for public interest, and when the results of academic research or description are provided externally, the personal information contained is de-identified.

10) Other circumstances as stipulated by laws and regulations.

Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not in the above description and your information is collected, we will explain to you the type of information, the scope and the purpose of the information collection by means of page prompts, interactive processes, website announcements or other ways, to obtain your consent.

Please note that at present, Finovel will not actively obtain your personal information from a third party outside of Finovel. In the event that we need to obtain your personal information indirectly from a third party for future business developments, we will inform the source, type and scope of the use of your personal information to you prior to obtaining such information. For example, where Finovel requires to process personal information for a specific development which is beyond the scope of what you originally agreed to provide to a third party, we will obtain your prior express consent before processing your personal information; In addition, we will strictly abide by the relevant laws and regulations, and require that third parties guarantee the legitimacy of the information provided.

2.Storage of Information

2.1 Where Information is Stored

We will act in accordance with laws and regulations and store personal information collected within the territory in local.

2.2 The Duration Storing Information

In general, we will only keep your personal information for the time necessary to achieve a specific purpose, for example:

Mobile phone number: When you use Finovel service, we will need to store your mobile phone number to ensure your normal use of the service; when you delete your Finovel account, we will delete the corresponding information;

3.Information Security

We strive to secure users' information to prevent information leakage, improper use, unauthorized access or disclosure.

We will use a variety of security measures to ensure the security of information within reasonable security standards. For example, we will use encryption technology (for example, SSL), data anonymization and other means to protect your personal information.

We use ever-improving technical means to enhance the security of the software installed on your device to prevent your personal information from leaking. For example, we will perform partial information encryption on your device for secure transmission; to prevent viruses, Trojans or other malicious programs or website, we will collect the information about applications installed on your device or process information regarding the running application.

We have set up specialized management systems, processes and organizations to ensure the security of information. For example, we strictly limit the range of people who may access such information and require them to comply with the confidentiality obligations and conduct audits.

In the case of information leakage or other incidents involving information security, we will initiate contingency plans to prevent the wide spread of security incidents and inform you in the form of push notifications and announcements.

4.How We Use Information

We may use information collected by certain features for our other services. For example, we may use the information we collect when you use one of our features, and provide you with specific content in another service, including, but not limited to ads, information security tips for content you have read, indirect crowd portraits based on feature tags, and providing more accurate and personalized services and content.

In order to ensure the security of our services, and to enable us to better understand the operations of our applications, we may record information such as your frequency of using our applications, crash logs, overall usage, performance data, and the sources that apps are installed from. We will not combine the information stored in the analytics software with any personally identifiable information you provide in the application.

Where we utilize your personal information beyond the scope of our collection statement or a direct or reasonable connection, we will inform you and obtain your prior express consent again before using your personal information in such situations.

5.External Parties

At present, we will not actively share or transfer your personal information to a third party outside of Finovel. If there are other circumstances in which your personal information is to be shared or transferred or where you require us to share or transfer your personal information to a third party outside of Finovel, we will directly obtain or verify the third party has obtained your prior express consent to such share or transfer of your personal information.

We will not publicly disclose personal information collected by us. If we have to disclose such information publicly, we will inform you of the purpose of such disclosure, type of information disclosed and the sensitive information that may be involved, and obtain your prior express consent.

As our business continues to develop, we may engage in mergers, acquisitions, transfers of assets, etc. We will inform you of such circumstances and continue to protect your personal information and require new controllers to continue to protect your personal information in accordance with the laws and regulations and the standards as strict as required by this Guideline.

In addition, in accordance with relevant laws and regulations and national standards, in the following circumstances, we may share, transfer, or publicly disclose personal information without prior consent of the subject of personal information:

1) When it is directly related to national security or national defense;

2) When it is directly related to public safety, public health, or major public interests;

3) When it is directly related to a criminal investigation, prosecution, trial or execution of judgments;

4) When it is for protecting vital legitimate interests of you or of other individuals, such as right of life, property, and reputation, while it’s hardly to obtain the consent of the individual;

5) When the personal information is disclosed to the public by yourself;

6) When the personal information is collected from legally publicly disclosed information, such as legitimate content reports, government information disclosure, etc..

6.Your Rights(About Account Deletion)

During your course of using Finovel, in order to provide you with an easier way to access, change, delete your personal information while ensuring you with the right to withdraw your consent regarding the use of personal information and the right to cancel your account, we have provided you with the applicable function when designing the product

6.1 Access and modify personal information, including region, nickname, avatar, birthday, etc.

1) After entering Finovel, click "Me"

2) Click on the avatar bar

3) Access or modify personal information

6.2 Account Deletion

You have the right to delete your Finovel account at any time. Here are two methods for account deletion:

1) Request deletion via email:

- Send an email to Finovel.help1@gmail.com with the subject line "Account Deletion" and include your account information and deletion request in the body of the email.

- Our customer service team will respond to your request within 7 business days, and assist you with the account deletion process after verifying your identity.

- Once your identity and account information are confirmed, we will freeze your account data (during which time your account will be unusable) to ensure legitimate business interests (such as fraud detection) and compliance with legal obligations (such as tax and legal reporting). Subsequently, all related account data will be permanently deleted after 60 days, and once deleted, this data cannot be recovered.

2) In-app deletion:

- In the Finovel app, follow the steps outlined in Section 6.1 to navigate to the account information page.

- Select the "Delete Account" option and complete the account deletion confirmation process as guided. At this point, we will freeze your data, rendering your account unusable.

- To ensure legitimate business interests (such as fraud detection) and compliance with legal obligations (such as tax and legal reporting), the system will automatically permanently delete all related account data 60 days after completing the account deletion confirmation process, and once deleted, this data cannot be recovered.

If you encounter any problems during the account deletion process or have questions about data processing, please contact us at Finovel.help1@gmail.com

7.Amendments

We may revise this Guideline in due course. In the event where the terms of this Guideline are amended, we will show you amended Guideline by way of push notifications and/or pop-up windows when you log in or when the APP version has been updated. Please note that we will follow the updated Guideline to collect, use and store your personal information only after you have tapped on the consent button in the pop-up window.

8.Protection of minors

We place great importance in the protection of personal information of minors. If you are a minor under the age of 18, according to the relevant laws and regulations, your parents’ or legal guardian's written consent should be obtained prior to you use of Finovel service.

9.Contact us

If you have any other complaints, suggestions, or querries regarding personal information of minors, please contact us at Finovel.help1@gmail.com. We will review your queries as soon as possible and respond within thirty days after verifying your identity.