Hita Privacy Policy

Last updated: July 23rd, 2024

Hita is a mobile application for social gathering where people can meet, chat, party and make friends with cool and like-minded people.

This is the Privacy Policy of Blvision HK Limited, with offices at 2-16 Fa Yuen St, Kowloon, Hong Kong, and Hita App (hereinafter collectively referred to as "Hita", "we", "us", or "our") and is incorporated into and is subject to our Terms of Service. In this Privacy Policy (the "Policy"), we refer to our products and services as the "Service".

Hita has always solemnly promised to protect the privacy of users who user our products and service (collectively "user" or "you"). When you use the Service, we or our partners may collect and user personal data. The protection of your personal data is of great importance to us.  The Policy covers how Hita and the third party partners collect and process your personal data (or referred to as "Personal Information") that you share with us when you are accessing to the Service.

Please read the Policy carefully before using the Service to make the appropriate choice. If you do not agree to the Policy, please do not register, visit or use the Service. If you do not wish certain kinds of your personal data to be collected and used by us as pointed out in the Privacy, please note that we may not be able provide you with the corresponding parts of the Service, you may not be able to use some features and functions of the Service, and your experience in Hita may be impacted. By continue using the Service, you agree that we will deal with your personal data in accordance with the Privacy.

If you have any concerns or questions about the Policy or matters related hereto, you can contact us through the feedback channels listed in section "Contact Us" below, and we will get back to you within 7 business days. We appreciate your patience while we process your request.

Directory
1. Personal Data that We May Collect
2. How Will We Use Your Personal Data
3. How Will We Share Your Personal Data
4. How Will We Keep Your Personal Data
5. How Will We Protect Your Personal Data
6. How to Manage Your Personal Data
7. Service Provided by Third Party Partners
8. How Will We Use COOKIES
9. Age Limit
10. Notice and Amendment
11. Contact Us

1. Personal Data that We May Collect

The main purpose of collecting personal data is to enable you and other users to user the Service in a more reliable way. We make sure you and other users have a safe and fun experience while using the Service. To achieve it, we may collect and process information that directly or indirectly related to your personal identity. In both instances, such information may constitute personal data subject to the Policy.

a) Data Not Directly Related to Your Personal Identity
When you use the Service, we may collect and process data not related to your personal identity, such as but not limited to
interaction with the Service - such as page view and click count, to help us analyze the performance. All interaction data are store and processed anonymously.
log - such as crash report, to help us improve our Service. All log file are stored and processed anonymously.

b) Data Directly Related to Your Personal Identity
When you use the Service, we may collect and process data related to your personal identity, such as but not limited to
gender - to provide gender-based service such as gender preference and gender filter.
date of birth - to make sure you meet our minimum age requirement of using the Service.
email - to bind your user id to email in case you forget your login credentials.
facial features - only with your consent, to complete the real person verification.
device information - such as device model, system version, device MAC address, to help fraud protection and risk control.
unique device identifier - such as Android ID, GAID, IDFA, UDID, to help fraud protection and risk control.
location - such as precise latitude and longitude position and approximate WiFi and mobile data position, to provide location-based service such as nearby users.
network - to identify the ip address of network traffic.

Please note that if you upload or post content (known as UGC) in public areas that are visible to other users in the Service and you disclose your personal information in response to information uploaded or posted by other users, such information may be collected and used by other users. When you find that other users improperly collect or use information from you or others, please contact us.

2. How Will We Use Your Personal Data

We may collect and process your personal data through following ways

a) Data Collected with your Consent and Permission, including but not limited to:

• I. Data provided by you when you sign up for an account for the Service or use Hita;
• II. Sharing data provided by you to other uses through the Service, and data saved when you 

b) Data Collected through your Usage of the Service, including but not limited to:

• I. The log data when you use the Service such as the crash report log generated when you encounter a App crash;
• II. The location data when you use the Service such as the GPS position and IP address;
• III. The device data when you use the Service such as device model, operating system, device language.

Please note that if you upload, post or make your information public in a public area visible to other users or in response to other users, such your information may be collected and used by other users. When you find that other users improperly collect or use information from you or others, please report the content in app or contact us as guided below.

c) Data Collected from Third Parties
We may collection data other users provide about you when you use the Service. We may also obtain data from companies owned or operated by us or any other third-party sources and combine that with the data we collect through the Service. The third-party sources are outlined in "Service Provided by Third Party Partners" section.

We Will Collect and Use Your Information for the Following Purposes

a) Help you to Complete the Sign-up and Login Process

In order for us to provide the Service for you, you need to provide basic sign-up or login information, such as nickname, gender, date of birth, and profile picture etc., used to create an account.

You can also log in or sign up Hita using our supported third-party platform accounts, and in such cases we will obtain the relevant information about you (such as your nickname, profile picture) under the third- party account according to your authorization.

Your above personal data provided by you or obtained by us from your third-party platform account under your authorization, is therefore processed for these purposes in order to provide you with and perform the Service based on your engagement with us. Without this personal data, we are not able to provide you with our services, and you will not be able to log in or use Hita.

You may also fill in your additional information (such as your location, height, weight) during sign-up, login or subsequent use, which will help us to provide personalized recommendations and better service experience for you. However, if you do not provide this information, it will not affect your use of the basic functions of our product and the Service.

b) Implement Real Person Verification

In order for us to verify you are a real person, and to guarantee the security of system, service and users' property, you need to provide your real person verification information, in accordance with relevant laws, regulations and regulatory requirements that are applicable.

For example, when you reply to a private message, you may need to provide your profile picture (personal sensitive information) and your personal pictures of specified actions instructed by us (personal sensitive information). We will make the picture comparison to complete the real person verification (hereinafter referred to as "Real Person Verification").

Please note that your profile picture, real person picture belongs to your sensitive personal information. Please be careful to provide them. If you do not agree to provide such information, you may not be able to obtain relevant services, but it does not affect your normal use of other functions and services of Hita.

c) Provide you with Interaction and Information Release Services
When you use Hita to upload, post, share some information (including text, comment, audio, video, picture, or other content), or follow, send gifts to other users, we will collect and display the information published or formed by you in Hita, and have the right to display your nickname and profile picture.

• I. When you upload your profile picture, conduct real person verification, post your audio bio, or publish your moments/status (including upload and share pictures, texts, audios, videos and other content), we will apply for your permission to access to your microphone, camera, photos, storage rights, and collect the voice/audios, video, photos, pictures, texts and other contents provided by you through such microphone and camera. If you do not agree to give us the permission, you may not be able to obtain relevant services, but it does not affect your normal use of other functions and services of Hita. Please note that the audio, photos and videos you upload may contain your sensitive personal information, please be careful to provide them. Further If the information you post involves personal information of others, you shall obtain the consent of others before posting.
• II. When you follow some user accounts that you are interested in, or communicate and interact with such user accounts (such as like, comment, share content), we will collect the user accounts you follow and show you the content published by such accounts. Meantime, we will also collect your interactions, comments, thumb ups, and shared content with other user accounts, and display or push notifications to relevant users in Hita.
• III. When you send virtual gifts purchased in Hita with your coins to other users, we will collect your profile picture, nickname, gift data and show such information to other users.
• IV. In order to recommend nearby users or push personalized content to you, we may request your permission to access to your location information (personal sensitive information). If you agree to give such permission to us, we will collect and show your location information to other users. You can turn off your location function at any time. When you do, we will no longer collect your location information or show it to other users.
• V. In order to enrich the interaction experience, we may access to the vibrator of your device to provide vibration effect.

d) Provide you with Services of Audio Chat
When you use services of audio chat, we will apply for your permission to access to your microphone. If you do not agree to give us such permission, you will not be able to use relevant services, but your normal use of other functions in Hita will not be affected.

e) Provide you with Top up and Inquiry Services
When you top up (to get coins in Hita), we will collect the information of your purchase order and payment account. If you query the remaining value of your virtual property in your user account, we will collect and show the information to you on the relevant page. Please note the information of your top up, purchase order, account and virtual property are your sensitive information, please be careful to provide and use them.

f) Maintain Account Security, Service Operation, and Optimize Service Experience
When you use the Service, in order for us to identify account anomalies, understand product suitability, and maintain the normal operation of basic function, we may automatically collect, store and process the information about services you use and the way you use them, including:

• I. Log Information: when you use the Service, we may automatically collect details of your use of our services and keep them as relevant web logs. The log information we collected including your login account, IP address, type of browser, telecom operator, network environment, language used, visit date and time, and the webpage browsing record that you visit, push open record, stay time, refresh record, publish record, follow and subscribe record, favorite and share record.
• II. Device information: according to your specific permission granted during your installing and use of Hita, we will receive and record the information about the device you use (including the IMEI, MAC, Serial, SIM card IMSI identification number, device type, operating system and its version, version of App, resolution, package name, device setting, list of process and software, the unique device identifier, software and hardware feature information), and the equipment location information (including IP address, GPS location and other information related to , such as WLAN access point, Bluetooth sensor information, base station sensor).

In order to collect the above basic personal device information, we will apply for permission to access to your device information. We collect such information in order to provide you with our basic services and functions. If you refuse to provide such permission, you may not be able to use the Service.

Please note that it is impossible to identify a particular natural person only depending on the device information and/or log information, so the device information and log information itself is non-personal information. But if such non-personal information is used in combination with other information to identify a particular natural person, or used in combination with other personal information, during the period of such combined use it will be deemed personal information. In case of such combined use, it will be processed as personal information and get protected according to the Policy. Unless authorized by you or otherwise provided by applicable laws and regulations, such personal information will be anonymized and de-identified by us.

g) Provide you with Customer Service or User Response Service

When you contact us for customer service or user response (such as inquiry, feedback, suggestion, complaint, etc.), we may require you to provide necessary personal information to match and verify your user identity, so as to ensure the security of your account and system. We may store information such as your communication/call history and conversation or the contact information you left behind in order to contact you or help you solve problems, or to document the solutions and results of the related issues.

Your personal data is therefore processed for these purposes in order to provide you with and perform the services based on your engagement with us. This personal data may also be processed in order to safeguard your legitimate interests of obtaining pertinent information and other related data regarding your services obtained from Hita.

h) Provide you with Information Display and Recommendation Service
We may use your information (such as your interests and hobbies, personality label, browsing and search records, device information, habits, location information, order information and so on, if any ) and the combination thereof, through the recommendation algorithm modeling, programming, advertising model, user behavior analysis, user portrait, to extract your browsing, search preferences, behavioral habits, location information, in order to provide you with more page display fitting your needs and recommend the personalized content.

i) Push Notifications to you
We may send you notices related to the service when necessary (for example when we suspend a single service, change, or stop providing a single service due to system maintenance).

If you do not wish to continue to receive messages we have pushed, you may request us to stop the push. For example, in the App setting, you may request us stop sending promotional messages or set up on mobile devices to stop receiving messages from us. However, except when we send messages according to the provisions of the applicable laws and regulations.

j) Provide you with Security
In addition to authentication, we may use your information for customer service, security precautions, fraud monitoring, archiving and backup purposes to ensure the security of the services provided by us to you; we may use or integrate your information collected by us, and our partners obtain the information authorized by you or legally shared information to comprehensively determine your account and transaction risk, conduct identity verification, detect and prevent security incidents, and take necessary records, audits, analysis and disposal actions according to the law.

This personal data is therefore processed for these purposes in order to safeguard your legitimate interests of ensuring the security of your connection and your personal data while you are obtaining information and services from Hita.

k) Improve our Services
We may ask you to participate in surveys about the Service to help us improve existing services or design new services; at the same time, we may use your information for software updates. This personal data is therefore processed for these purposes in order to safeguard our legitimate interests of improving our services in this way.

l) Other Use of Anonymous Information
You understand and agree that, in certain instances, upon the collection of your information, we will de-identify and fully anonymize the data through technical means, so that it no longer constitutes personal data directly or indirectly related to an individual, such as you. The de-identified information will not identify you or be related to you. In such case, we have the right use such de-identified information to analyze and commercialize the user database.

If we use your information for other purposes not specified in the Policy, we will ask for your consent in advance through page prompts, interactive processes, website announcements or other means. Once you agree, such additional use of your information will be considered as part of and apply to the Policy.

m) Notice about Permissions for Particular Functions
You understand and agree that, we may apply for certain access rights on your device in order to collect and use information related to particular functions and services. Such as:

• I. Only with your permission, we may access to your storage space, so that you can cache, download and save the content.
• II. Only with your permission, we may access to your device information and make it as the unique identification of your device, so that we can provide you with more content and personalized recommendations that meet your needs, help you understand the suitability of the product and identify abnormal conditions, ensure security of network and operation of the Service.

Regarding to permissions of access to photo gallery/camera, microphone, location, when you need to terminate any permissions, most mobile devices will support your needs. Please refer to or contact the service provider or manufacturer of your mobile device for details. When you give us any permissions, you authorize us to collect and use relevant information to provide you with the corresponding services. Once you withdraw any permissions, your authorization terminates, and we will no longer continue to collect and use relevant information, nor will we be able to provide you with corresponding services. However, the previous collection and use of the information made under your authorization will not be affected.

n) Exceptions to Get Authorization
According to relevant laws and regulations, collecting your information under the following circumstances does not need to get your authorization:

• I. related to performance of obligations according to applicable laws and regulations;
• II. related to public safety, public hygiene and material public interests;
• III. related to criminal investigation, prosecution, trial and execution of judgments;
• IV. it is difficult to obtain your own consent for the maintenance of material legal rights and interests such as the life and property of the main body of the information or other individuals;
• V. the  information collected is disclosed by yourself to the public;
• VI. information collected from legally disclosed information, such as the channels including legitimate news reports and governmental information disclosure;
• VII. necessary to sign a contract according to your request;
• VIII. necessary to maintain the safe and stable operation of the Service, for example, discover and deal with the failure of products or services;
• IX. necessary for legitimate news reports;
• X. necessary for academic research institutions to conduct statistical or academic research based on public interest, and when provided outbound results of academic research or description, the information contained in such results will be de-identified;
• XI. other circumstances as stipulated by applicable laws and regulations.

o) Special Notice about the Personal Sensitive Information
Personal sensitive information refers to the personal information that may endanger personal and property safety and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment once disclosed, illegally provided or abused.

For example, ID card number, personal identification information (such as characteristics of face recognition, voice print, etc.), bank accounts, communication records and content, property information (including virtual property, virtual currency, virtual trading), location information, web browsing history, transaction information is your sensitive personal information. Please be careful to your sensitive personal information. You agree that we can process your sensitive personal information in accordance with the Policy.

3. How Will We Share Your Personal Data

In certain circumstances, we may share your personal data with third-party service providers to further improve and optimize the Service for you. Except for the following circumstances, without your consent, we will not share your data with any third party other than Hita:

We May Share Following Data with Other Users:

a) Information about you, such as your nickname and profile picture;

b) Information about how you have interacted with the Service, such as nicknames of users you are friends with and other information that will help users understand your connections with others using the services. For example, because it may not be clear whether a new friend request comes from someone you know, we may share whether you and the requestor have Hita friends in common;

c) Any additional information you have consented for us to share. For example, when you make an audio chat with other users, we may share your audio data with other users so you two can hear and chat to each other.

We May Share Following Data with All Users as well as the General Public:

a) Public information about you, such as your profile pictures that you submit to a group audio chat channel. If the group audio chat channel is open to public, your information may be viewed by the public.

You expressly agree that the data provided when you sign up the service or the content you created when using the service (including text, comment, audio, video, picture, or other content), may be recorded, stored, published and made available to the rest of Hita users. Furthermore, other users may follow you on the App, and your followers can see, for example, the user-generated content you uploaded to the App. Individuals reading this information may use it or disclose it to other individuals or entities without our control and your knowledge. We, therefore, urge you to consider carefully including any specific information you may deem private in the information you provide or the content you create in the App.

We May Share Your Data with Entities within the Hita Family of Companies or our Affiliates.

We May Share Your Data with Third Parties:

a) We may share information about you with service providers who provide services and functionality on our behalf, sellers that provide goods through our services, business advisors that our lawyers, accountants, business consultants, insurers, and auditors, to the extent it is necessary for them to provide us with their services.

b) We may share information about you if we reasonably believe that disclosing the information is need to:

• I. Comply with any valid legal process, government request, or applicable law, rule ,or regulation;
• II. Investigate, remedy, or enforce potential Terms of Service violations;
• III. Protect the rights, property, and safety of us, our users, or others; or detect and resolve any fraud or security concerns.

c) If Hita get involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share information about you with that company before and after the transaction closes.

The Service may also contain third party links or search results, including third party integrations, or be a co-branded or third party-branded service that's being provided jointly with or by another company. By going to those links, using the third party integration, or using a co-branded or third party-branded service, you may be providing data (sensitive personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. To the extent that you use a profile that may be available to others on the Service, you are solely responsible for its content and accuracy at all times. As always, we encourage you to review the privacy policy of every third party on their website, which are outlined below in section "Service Provided by Third Party Partners".

We Will Collect and Use Your Information for the Following Purposes:

a) Provide you with our services. We may share your information with our partners and other third parties in order to achieve the core functions you need or to provide the services you need, such as payment service, data service.

b) Maintain and improve our services. We may share your information with our partners and other third parties to help us provide you with more targeted and improved services, such as communication service providers that push notifications on our behalf;

c) Achieve the purposes described in section "Personal Data that We May Collect" and "How Will We Use Your Personal Data”;

d) Perform our obligations under this Policy or other agreements entered into between you and us and exercise our rights;

e) Share with third parties including the partners who entrusts us to promote, but we will only provide such third parties with the information relating to the coverage and effectiveness of the promotion, not any information which will identify you, such as name (if any), telephone number (if any) or email address (if any); or we will summarize the information so that it will not identify you personally. For example, we can notify such third parties how many people viewed their promotional information or purchased their goods after viewing such information, or provide them with statistical information that could not identify personal identity and help them understand their audiences or customers.

f) To the extent permitted by applicable laws and regulations, in order to comply with such law and regulations, protect us and our affiliates or partners, you, other users, or the public interest, property or safety from harm, such as to prevent fraud and other illegal activities and reduce credit risk, we may exchange information with other companies and organizations. However, this does not include information sold, rented, shared, or otherwise disclosed for profit making in violation of the commitments made in this Policy;

g) Help you deal with your disputes or controversy with others upon your legitimate request;

h) Provide your information in response to the legitimate requests of you and/or your guardian;

i) Provide your information according to the individual service agreement signed with you (including the online signed electronic agreement and the corresponding platform rules) or other legal documents;

j) Provide your information based on academic research;

k) Provide your information based on the social and public interests that are in conformity with applicable laws and regulations.

We will only share your data for legitimate, justifiable, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share the information, we will sign strict confidentiality agreements with them and ask them to process information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

Your data may also be stored and processed in any country we provide service to due to server facilities and third party service providers. By using the Service, you consent to any such transfer of information outside your country.

Exceptions to Get Authorization

According to relevant laws and regulations that are applicable, collecting sharing, transferring and disclosing your information under the following circumstances does not need to get your authorization:
a) Directly related to public safety/security, public health and material public interests;
b) Directly related to criminal investigation, prosecution, trial and execution of judgment;
c) It is difficult to obtain your own consent for the maintenance of material legal rights and interests such as the life and property of the main body of the information or other individuals;
d) Information collected is disclosed by yourself to the public;
e) Information collected from legally disclosed information, such as the channels including legitimate news reports and governmental information disclosure;
f) Performance of obligations under applicable laws and regulations;
g) Other circumstances as stipulated by applicable laws and regulations.

According to applicable laws and regulations, it will not be deemed as sharing, transferring and publicly disclosing personal information to share, transfer, publicly disclose de-identified personal information by which the data receiver can not re-identify natural person subject. We may save and process such data without prior notice or your consent.

4. How Will We Keep Your Personal Data

We retain your information only during the period required by the purposes described in the Policy and within the time limit required by applicable laws and regulations. If we terminate the Service, we will promptly cease activities of collecting your personal information according to relevant laws and regulations that are applicable. After the termination of the Service, we will delete or anonymize your personal information, unless otherwise stipulated by applicable laws, regulations or regulatory authorities.

The information we collect and generate within the Service is stored in Singapore. You agree to authorize us to store and transfer your personal information/data across borders through the Policy. 

5. How Will We Protect Your Personal Data

We ensure that your personal information is adequately protected in accordance with the Policy and relevant applicable laws and regulations. We will take the following measures to protect your information:

a) Data Security Technology Measures
We will adopt industry-standard security protection measures, including the establishment of reasonable system specifications and security technologies to prevent unauthorized access and modification to your information, avoid the damage or loss of your data. For example, in some services, we will use encryption technology (such as SSL) to store and protect your information, and isolate it via isolation technology. In the use of information (such as information display, information-related computing), we will use a variety of data desensitization technologies to enhance the security, and use strict data access control and multiple identity authentication technologies to protect the date from being used illegally.

b) Other Security Measures Adopted by Us to Protect the Information
We manage and regulate the storage and use of information by establishing a data classification hierarchy, data security management rules, and data security development regulations. We conduct comprehensive data security control through information access confidentiality agreements, monitoring and auditing mechanisms. We also strengthen the security awareness. For example, we hold security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting information.

c) We only allow our employees and partners who need to know the information to access to your information, and set strict access control and monitoring mechanisms for this purpose. We also require that all personnel who may have access to your information perform the corresponding confidentiality obligations. Failure to perform these obligations may result in legal liability or suspension of cooperation with Hita.

d) We will take all reasonably practicable steps to ensure that no unrelated information is collected.

e) The internet is not an absolutely secure environment, and the methods used to communicate with other users, such as e-mail, instant messaging, social software or other service software, cannot be determined to be fully encrypted. We recommend that you use complicated passwords when using such kinds of tools and carefully protect your Information security.

f) The internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protective facilities are destroyed, resulting in unauthorized access to information, public disclosure, alteration, or destruction, and your legitimate rights and interests are damaged, we will assume corresponding legal liabilities.

g) Dealing with Security Incidents
When communicating with third parties through the Service, you will inevitably disclose your information to the counterparty or potential counterparties. Please protect your information and provide it to others only when necessary.

In order to cope with possible risks such as information disclosure, damage and loss, we have formulated a number of systems to clarify the classification and grading standards for security incidents and security vulnerabilities and the corresponding processing procedures. We also set up a specific emergency response team for security incidents. According to the requirements of the security incident handling regulations, we will initiate security preplans for different security incidents, conduct stop loss, analysis, positioning, formulate remedial measures, and trace and crack with relevant departments jointly.

Upon the occurrence of unfortunate information security incidents, we will promptly inform you in accordance with the requirements of applicable laws and regulations: the basic information and possible impact of security incidents, the measures we have taken or will take, and recommendations on your own precautions and risk reduction, remedial measures for you and so on. At the same time, we will promptly inform you of the incident-related situation by push notification, etc. When it is difficult to notify the information subject one by one, we will issue a notice in a reasonable and effective manner. Meanwhile, we will also voluntarily report the disposal of information security incidents in accordance with regulatory requirements.

Please understand that due to technical limitations and risk prevention limits, even if we have strengthened our security measures as much as possible, we cannot always guarantee 100% security of the information. You need to understand that the system and communication network used by you to access to the Service may have problems due to circumstances beyond our control. Please be sure to take good care of your account, password and other identity elements, which are used by us to identify you when you use the Service. It may make you suffer losses for you to disclose the foregoing information. If you find that any of the foregoing information may or have been leaked, please contact us immediately as guided in section "Contact Us" below so that we can take appropriate measures in time to avoid or reduce related losses.

6. How to Manage Your Personal Data

a) Access, Rectify, Update, Object and Delete

We encourage you to rectify, update and modify your information to make it correct, more accurate and effective. You can access to your information and complete such conduct by yourself through the Service, or request us to do relevant modification, supplement or deleting. We will use appropriate technical methods to ensure you can access to, update, correct and delete your own information or other information provided or generated by you when you use the Service as much as possible.

For the purpose of maintaining your information secure, when accessing to, updating, correcting and deleting the above information, we may ask you to do identity verification at first. Upon making a request to access to, update, correct or delete your personal data, we will assess whether there is any rule or exception under the applicable laws that may enable us to object to your request, and inform you of this decision.

For your information collected through COOKIES and WEB BEACON, we also explain the selection mechanism provided to you in section "How Will We Use COOKIES" below. If you desire to search, modify or delete your partial information, please log into Hita account to complete relevant operations. In case you have any question or request to access to, rectify, update, modify and delete your data, you can contact us pursuant to the means explained in section "Contact Us" below.

Unless otherwise stipulated by applicable laws and regulations, when you correct or delete your personal information or apply for deletion of an account, we may not immediately correct or delete the relevant information from the backup system, but we will correct or delete such information when the backup is updated.

b) Publish and Share

The Service allow you to share your information not only with your social network, but also with all users who use Hita, such as information uploaded or posted by you on Hita, your response to the information uploaded or posted by others, your personal information uploaded or published in the public area which is available to non-specific users in the Service, and also the location data and log information related to such information. As long as you do not delete the information you published or shared, such information may remain in the public domain; even if you delete the shared information, such information still may be cached, copied or saved independently by other users or third parties who are not under our control, or be kept in the public domain by other users or such third parties. If you publish or share information through above channels, which results in the disclosure of your information, we will not be liable for it. Therefore, we kindly remind you and request you to carefully consider whether or not to publish or share your information through above channels.

c) Cancellation

Subject to conditions specified in the service agreement in relation to the Service and the provisions of relevant laws and regulations that are applicable, your account for the Service may be cancelled or deleted. After the account is cancelled or deleted, all service information and data related to such account and the Service will be deleted or processed according to the service agreement in relation to Hita.

You can finish the cancellation of your Hita account according to the guidance in related operation page in Hita.

If you lost access to your Hita account and would like us to revoke, cancel, or delete your account, you may fill in this form and we will review and process it according to the service agreement.

d) Change the Scope of Your Consent

Some information is required to use the Service, but the provision of most other information is on your decision or consent. Where the processing of personal data is based on your consent, you can always select whether or not to disclose the information. You can change the scope of your consent to us to continue to collect the information or withdraw your consent by means of withdrawing it, deleting information, turning off device functions and so on. You may also withdraw your consent by contacting us pursuant to the means explained in section "Contact Us" below.

After you withdraw your authorization, we are unable to continue to provide you with the service corresponding to such withdrawal, and will not process your corresponding information. However, your decision to withdraw your consent will not affect the information processing previously based on your consent.

e) Tips for Sensitive Information

Certain information may be considered being sensitive information because of its particularity, such as your race, religion, personal health and medical information, as well as identification documents, personal biometric information, property information, traces, information of minors, etc.

Please note the content and information provided, uploaded or posted by you on the Service (such as photos or information about your social activities) may reveal your sensitive information. You need to carefully consider whether or not to use the Service to disclose your sensitive information. When you do so, we will understand that you give your explicit consent to us to process such sensitive information. You agree that your sensitive information will be treated in accordance with the purposes and manner described in the Policy.

f) Constraint Information System Automatic Decision

In some business functions, we may make decisions based solely on non-human automated decision mechanisms such as information systems, algorithms, and so on. If these decisions significantly affect your legitimate rights and interests, you may request us for an explanation and we will provide appropriate remedies.

To respond to your above request and for the security reason, you may need to provide a written request and prove your identity for us to verify. Your reasonable request will not be charged in principle, but the request that is repeated, submitted by many times or beyond the reasonable limit will be charged a certain cost. We may refuse requests that are unnecessarily repetitive, require too much technology (such as the development of a new system or a fundamental change in existing practices), pose a risk to the legitimate interests of others, or are highly impractical (such as those involving backing up information held on tape).

We will not be able to respond to your above request under the following circumstances:

• I. Related to our performance of obligations under relevant laws and regulations that are applicable;
• II. Directly related to public security, public health and major public interests;
• III. Directly related to criminal investigation, prosecution, trial and execution of judgment;
• IV. We have sufficient evidence to show that you have subjective malice or abuse of rights;
• V. For the purpose of protecting the life, property and other important legitimate rights and interest of you or other individuals, but it is difficult to get your consent;
• VI. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
• VII. Involving commercial secrets;
• VIII. Exceptions to other relevant laws and regulations that are applicable.

7. Service Provided by Third Party Partners

The third-party service providers we may access mainly include the following purposes:
a) for the ads-related service, including advertising display, advertising data statistics and monitoring, etc.;
b) for the message push function, including mobile phone manufacturer push, specific event reminder, personalized recommendation, etc.;
c) for the payment related service, including order payment, transaction behavior verification, income settlement, payment information summary statistics, etc.;
d) for the real person verification function;
e) to obtain the device location permission, collect device information and log information, etc. under your consent;
f) for third-party authorization services, including login of third-party accounts and sharing of relevant content to third-party products;
g) to support product function modules, including voice playback, video playback, content storage, etc.;
h) to optimize product performance, including improving hardware distribution network capability, reducing server cost, functional hot repair, etc.;
i) for account security, product reinforcement related services, including network monitoring, domain name resolution (HTTDNS), anti-hijacking, anti-spam and anti-cheating, encryption and decryption services;
j) for anti-garbage filtering service of audio, video and text content;

Some third-party SDKs or similar applications we access may involve the collection of user information, and if you use such services provided by third parties in the Service, you agree that your information will be directly collected and processed by them. We will evaluate the legality, legitimacy and necessity of the information collected by such third parties, require them to take protective measures against your information, and strictly comply with relevant laws, regulations and requirements that are applicable.

These third-party social media and other services are operated by relevant third parties. Your use of the social media services or other services of such third parties (including the provision of your information by you to such third parties) must be subject to their terms of service and information protection statement (but not this Policy) and you must read carefully such terms. This Policy only applies to any information collected by us, but not applies to services provided by third parties or their information use rules, and we are not liable for the use of information provided by you to any third parties.

8. How Will We Use COOKIES

We or our third party partners may obtain and use your information through COOKIES and WEB BEACON and save this information as log information.

By using COOKIES, we provide users with a simple and easy-to-use personalized web experience. A COOKIES is a small amount of data that is sent from a web server to your browser and stored on your computer's or your mobile device's hard drive. We use COOKIES to allow its users to benefit. For example, to make the login process of Hita faster, you can choose to save the username of your last used login method in a COOKIES. This will make it easier and faster to login into the Service next time. COOKIES can help us to determine the webpages and content you are connected to, time you spend on certain service, and the service you have chosen.

COOKIES enables us to serve you better and faster, and to make your experience on the Service more personal. However, you should be able to control whether and how COOKIES is accepted by your browser. Please check the documentation attached to your browser for more information on this.

We or our third party partners may collect and use your information through COOKIES and WEB BEACON, and store such information. We use our own COOKIES and WEB BEACON for the following purposes

a) Remember your identity. For example, COOKIES and WEB BEACON help us identify you as our registered user, or save your preferences or other information provided by you to us.

b) Analyze your use of our services. We can use COOKIES and WEB BEACON to understand for which activities you use the Service, or which services or service is the most popular. We may request your consent prior to using COOKIES and WEB BEACONS for these purposes.

c) Advertising optimization. COOKIES and WEB BEACON help us to provide you with advertisements related to you based on your information instead of general advertising. We may request your consent prior to using COOKIES and WEB BEACONS for these purposes.

While we use COOKIES and WEB BEACON for the foregoing purposes, we may summarize and provide the information collected through COOKIES and WEB BEACON to advertisers and other partners to analyze how you and other users use the Service and for advertising services.

The Service may have COOKIES, WEB BEACON and similar technologies placed by advertisers and other partners. These COOKIES, WEB BEACON and similar technologies may collect information related to you for analyzing how users use such services, sending you advertisements that may be of interest to you, or evaluating the effectiveness of advertising services. The collection and use of such information by these third parties’ COOKIES, WEB BEACON and similar technologies are not governed by this Policy, but are governed by its own personal information protection statement, and we are not responsible for the third party's COOKIES, WEB BEACON or similar technologies.

You can also reject or manage COOKIES or WEB BEACON through the browser (if you access the Service via a browser) or user selection mechanism. However, please note that if you disable COOKIES or WEB BEACON, we may not be able to provide you with the best service experience, and some services may not work properly. At the same time, you will still receive ads, but the relevance of these ads to you will decrease.

9. Age Limit

Hita and the Service is provided to adults only. No minor (meaning natural persons who have not reached the specified age stipulated by applicable laws) is allowed to create his or her own user account and/or use our services. We will protect information about minors in accordance with relevant laws and regulations that are applicable.

We do not knowingly process personal data from any minor without his/her guardian’s consent. If you believe we have any personal data from any minor under your guardianship, please contact us via the contact information set forth in section "Contact Us", we will promptly investigate (and remove, if applicable) such personal information. We will only use or disclose the personal information of minors when permitted by laws and regulations, with the express consent of guardians or when necessary to protect minors.

10. Notice and Amendment

We may revise the terms of the Policy as appropriate and such modifications form part of the Policy. But when we do, we will let you know one way or another. For major changes (meaning significant changes, such as significant changes of our service mode, ownership structure, main objects of personal information sharing, transfer or public disclosure, your right to participate in the processing of personal information and the way to exercise it, our responsible department responsible for dealing with the security of personal information, contact information and complaint channels), we will provide more noticeable notices, and you may choose to stop using the Service. In such case, if you continue to use the Service, you agree to be bound by the Policy as revised.

Any amendment will put your satisfaction in the first place. We encourage you to review our Policy each time you use the Service.

We may publish service-related announcements when necessary (for example, when we suspend certain service due to system maintenance). You may not be able to cancel these announcements that are related to the service and that are not in the nature of promotion.

Finally, you must be obligated to keep your account and password confidential. In any case, please take care of such information safely.

11. Contact Us

For complaints, reports, questions, comments, or suggestions about the Privacy Policy and matters regarding your data, please contact us at support@hita.chat

Address: 2-16 Fa Yuen St, Mong Kok, Kowloon, Hong Kong