PRIVACY POLICY

Last updated and effected: Sep. 30, 2023

You can view our Privacy Policy in the “Settings” of your Smart Device and/or on our website (http://www.coolitaos.com/).

This Privacy Policy includes:

1. Introduction

2. What Information We Collect

3. How We Use Your Personal Information

4. The Legal Bases For Our Processing Of Your Information

5. How We Share Your Information

6. How We Access To And Transfer Your Information

7. How We Retain Your Information

8. How We Protect Your Information

9. What Are Your Rights

10. How We Protect Children

11. Links To Other Websites, Devices, Apps And Features

12. Update To This Privacy Policy

13. Severability

14. Dual Language

15. How To Contact Us

1. INTRODUCTION

Shenzhen COOCAA Network Technology Company Limited, a company established under the laws of People’s Republic of China (“COOCAA”, “we”, “our” or “us”) knows how important privacy and personal information are to our customer (“you” or “your”).

This Privacy Policy applies to personal data or personal information (hereunder used interchangeably) collected and processed by us through our “Services”, which includes: our websites, our products and certain other products or applications utilizing our streaming platform or operating system (“System”), our advertising services, our emails and newsletters, and our accounts on third-party social networking sites. For the purpose of this Privacy Policy, the “Smart Device” means a hardware device which is installed with Coolita to enable the use of the Services and it can be a Smart TV, a projector, or other device.

This Privacy Policy describes the personal information that we may collect and process through our Services, and how we may collect, use, retain and share your personal information. This Privacy Policy also serves as a notice to explain the choices available to you regarding our processing of your personal information, the rights you may have, the steps we take to safeguard your personal information and how you may contact us if you have any questions about our privacy practices.

We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional privacy policy specific to certain features or services. Those notices are to be read in combination with this Privacy Policy.

Using our services, you can stream video, games and other content in applications (“Web Apps”) provided by third-party Service Providers. When you install, access or stream one of these Web Apps, you are also interacting with that Web App directly, and the Web App provider and its analytics and advertising partners may collect information from your Coolita Device, including your device identifier and how you use that Application. This Privacy Policy does not cover the actions of these Web Apps providers and their partners. For more information about how these Web Apps use your data, please see their privacy policies.

Please also keep in observance that the System and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites or platform. We encourage you to be aware when you leave our sites or Web Apps and to read the privacy policies of other sites that may collect your Personal Information.

By clicking “Accept” checkbox, you consent to our processing of your Personal Information in accordance with this Privacy Policy, and you consent to and you agree to be bound by the terms and conditions of this Privacy Policy.

If you do not agree with the terms contained herein, please do not browse or use our Services.

2. WHAT INFORMATION WE COLLECT

Through your use of the Services, we will collect three categories of information: they are Automatically Collected Information, Information You Provide, and Information from Other Sources as described below. These categories of information may be defined as personal information or/and sensitive personal information or legal terms of similar meaning by the applicable laws in the country/region of your residence.

2.1 Automatically Collected Information

Our Services collect some information automatically when you use the Services. We may obtain information by automated means such as browser cookies, pixels, web server logs, web beacons, and other technologies developed by us or our Service Providers. The Automatically Collected Information include the following type of information:

(1) Device identifiers: information that enables us to identify your use of our Services through your Smart Device, specifically including your device ID, IP address and MAC address. Your Device has a fixed unique number that enables us to identify and authenticate the Device when you use the Services, which is called device ID; and

(2) Device descriptive information: your device stores information about itself and its configuration. This includes the type and size of the Smart Device, operating system version of the Smart Device, the panel resolution, device’s chip, device’s model and brand of the Smart Device, the browser name, browser version, country and corresponding language that have been configured in the Smart Device.

(3) Usage information: information about your use of the Services, including click stream data, your interactions with the Services (such as the web page you visit, the name of the channel or program you watched, requests to view content, details of actions taken while viewing, QR code connected with our other Services), advertisements, third-party websites, Web App and features used through the Services, the pages that led or referred you to the Services, dates and times of use of the Services, crash data, performance and other diagnostic data, and other usage data.

(4) Location information: information about your general area. This includes location inferred from the IP address assigned to your Smart device by your Internet Service Provider, and the country/region you choose to tell us by setting your Smart Device.

2.2 Information You Provide

(1) Profile information: includes the information that you provide when you set up your Coolita account, such as your username, password, and the other information you may add to your profile, such as a profile photo.

(2) Contact information: includes your email address, telephone number and other contact information you may provide to us.

(3) Purchase information: includes your payment card information or other third-party payment information (such as PayPal) you provide to us where payment is required, also includes your transaction and purchase history.

(4) User content: include the content you create or publish through our Services, such as your comments to the content displayed on the System and the associated metadata (such as when, where, and by who the content was created).

(5) Information in surveys and promotions: include the information you provide when you choose to participate in one of our surveys, promotions, contests, or marketing campaigns or events.

(6) Communication information: include the information we collect or you sent to us when you contact us, such as proof of identity, feedback about your use of our Services, the interactions with our customer supports, and if you call us, your phone number and call recordings.

(7) Subscription and payment information

When you purchase a subscription package using one or more of our payment gateway service providers, or any other online or mobile payment services provider we may use (including through any app stores), the following payment information will be collected: your credit/debit card details or other bank account details along with the date, time and amount of the transaction payment. This payment information is stored by our payment processors and associated with a merchant name/ID and location which our payment processor gives to us, together with a unique customer ID which we share with them but this payment information is never stored or processed by us. Our payment processors use this payment information to process and facilitate the payment of your subscription fee in order that we may provide you with the service you have requested or to enter into a contract with you to access the Platform (in other words to perform the contract). So that we know you have paid your subscription fee our payment processors will send us a unique transaction ID which we associate with your unique customer ID and which we keep for internal accounting purposes because we have a legal obligation to do so.

Our payment processors may use third party fraud detection software or providers which analyze your payment information in order to make automated decisions as to whether or not payment from you will be accepted. You have the right to contest any fraud decision made about you and to be given more information about why any such decision was made by contacting us.

Where you pay a third party for your subscription package (e.g. an app store like Apple App Store) your payment information is directly collected and controlled by that third party. However, we receive invoice receipts from third parties for your subscription purchase and these receipts are stored by us as we have a legitimate business interest to keep them for internal accounting and tax purposes and to comply with our legal obligation as per any applicable laws including any audits, legal proceedings and/or investigations.

Where our payment processors are providing payment processing services to us we put in place appropriate contracts to protect your Personal Information. For the following aspects of the payment processing our payment processor may act as a controller of your payment information (identified and listed above): providing the payment processing services to you at your request,):, monitoring, preventing and detecting fraudulent payment transactions, complying with legal or regulatory obligations which apply to the financial services sector and analyzing, developing and improving their products and services. Our payment processors have their own privacy policies in place and we recommend you read those policies before you provide your payment information.

In order to process any of your customer support queries related to payment processing, our payment processors give us access to the first 6 digits and last 4 digits of your credit/debit card (including any updates) so that we can perform the contract with you and provide you with a quick resolution of your queries. We also use the first 6 digits of your credit/debit card so that, on the basis of our legitimate business interest, we can analyze the most popular card types and issuing banks of our customer base to ensure that we are able to improve our user experience and provide you better service. Our payment processors will also pass us your expiry date after each payment transaction is completed and we will use this to send you an email reminder to update your payment information before your card expires as we believe we have a legitimate interest to make sure your access to the Platform is not interrupted, you can still cancel at any time. However, at no point in time do we have access to or store the full credit/debit card number in our System.

2.3 Information from Other Sources

(1) Information from advertisers, measurement and data partners: Advertisers, measurement and data partners may share information with us such as device identifiers for advertising, hashed email addresses, and event information about the actions you’ve taken on a website or application.

(2) Information from third party platforms: if you choose to access to our Services using a third party platform account, such third party platform will share information such as your email address, user ID, and public profile. If you choose to link, connect or login to our Platform using a social media platform then such the social media platform may send us your profile and social information such as Email ID, Name, etc.

(3) Information from integration partners: when you interact with any third party service (such as third party applications, websites or products) that integrate Coolita tools, we will receive the information necessary to provide you with features like cross-service authentication or cross-posting. For example, this will happen if you log in to another service with your Coolita account or if you use the “share” button on the System to share content from our Services to a third party application.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your information to operate, provide, develop, and improve our Services, including for the following purposes (“Purposes”):

3.1 Providing video content

When you use the System for watching videos, we will use your device descriptive information, device identifiers and country code. We use the above information to determine the video content that can be displayed in your country and are appropriate to your device. If you publish comment to certain video content, we may display your user content on the relevant pages.

3.2 Providing web Apps

When you access and use web Apps from the Coolita APP Store, we will use your device descriptive information, device identifiers and country code. We use the above information to provide you with web Apps that can be displayed, accessed and used in your country.

3.3 Providing games

When you play games in the Services, we will use your country code to provide games that can be displayed and accessed in your country.

3.4 Assisting payments

When you purchase services, contents, and goods through our Services, we will use your device identifier and purchase information to process, facilitate the purchase and transactions.

3.5 Providing weather & forecast information

When you choose to receive current weather and upcoming forecast information for your location, we will use your IP address to provide weather information.

3.6 Providing Personalized Service

After receiving the explicit consent from you, we will use your device identifiers, device descriptive information, usage information and location information to promote advertisements and other content that we think will be of interest to you (“Personalized Service”). For example, we may use what you’ve previously searched for, viewed and used in the Services to recommend advertisements and other content that are most relevant to you.

For more detailed information about the Personalized Service, please refer to the Personalized Service Privacy Notice. You may disable the Personalized Service following the steps as instructed in the Personalized Service Privacy Notice.

Our internal departments or operation teams may have the necessities to access your personal information in order to implement our procedures, management, and internal communication. Nevertheless, we have limited the access and implement technological measure to secure your personal information, in order to prevent any attack or unauthorized access to our computer or electronic system. When disclosing your personal information for a third party to process your personal information or to information processors, please be assured that we will supervise such person to proceed in accordance with our order.

3.7 Assisting remote control

When you use smart Home App from your mobile phone to control the Smart Device, we will use your QR code. We use the above information to link the Smart Device with your mobile phone and turn it into a device controller, so that you can easily control your Smart Device with your mobile phone.

When you search content on the System by giving voice command via remote control, we will use your voice information to assist you to interact with the contents displayed on your Smart Device.

3.8 Interacting with other apps

When you integrate your Coolita account with a third party app, we may share your profile information, your user content with third party partners at your request.

3.9 Communicating with you

We may use your email address, phone number you provide to us to respond to communications, reach out to you for troubleshooting, market the Services, improve the Service, provide other relevant information, or request information or feedback.

To limit the communications you receive from us, or submit a request, please see What Are Your Rights and How to Contact Us sections below.

From time to time, we may use your device identifiers to send important notices on your Smart Device, such as communications about changes to our terms, conditions, and policies. Because this information is important to your interaction with us, you may not opt-out of receiving these important notices sent to your Smart Device.

3.10 Maintaining and improving the Services

We may use your device identifiers, device descriptive information and usage information to maintain and improve the Services, which may include software updates, failure troubleshooting, services maintenance and internal purposes such as auditing or data analysis.

3.11 Security and preventing fraud

We will use your device identifiers, device descriptive information and usage information to protect individuals, employees, and our legitimate interest and for loss prevention and to prevent fraud, including to protect individuals, employees, and us for the benefit of all our users.

3.12 Complying with applicable laws

We may use your personal data in compliance with applicable laws, such as to satisfy tax or reporting obligations, or to comply with a lawful governmental request.

4. THE LEGAL BASES FOR OUR PROCESSING OF YOUR INFORMATION

We only process your information when there is a legal basis to do so, and we rely on different legal bases depending on the specific purposes of processing your information. These legal bases involve contractual necessity, legitimate interests, your consent, compliance with a legal obligation and performing a task in the public interest.

4.1 Contractual Necessity

For the purpose of performing the contract you enter into (i.e., our Terms of Use) when you sign up, access, or use our Services, we will use your information to:

(1) provide you with our Services. We use your information to provide you with our Services. This includes using your information so you can watch the content and play the games on the System. It also includes using your information to provide you with third party content and services you purchase through the Services.

(2) enforce our Terms of Use and policies. We use your information to enforce our Terms of use and other policies. This may include suspending or banning your Coolita account if we determine that you are violating our Terms of Use.

(3) administer our Services. We also use the information we have to administer our Services, such as communicate with you on service related matters and respond to your queries.

4.2 Legitimate Interests

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use your information to:

(1)Provide all users with non-personalized advertisements. We display non-personalized advertisements to all users, including those who have chosen not to receive Personalized Service.

Legitimate interest relied upon: We provide non-personalized advertisements to keep our Services free of charge. We process limited categories of your information to make sure our advertising service is useful to our advertisers (for example, to serve ads to users in a particular country or to users who speak the same language).

(2)Measure the effectiveness of advertising. We measure the effectiveness of the advertisements you see in our Services.

Legitimate interest relied upon: to enable the advertisers to view and understand the performance of their advertisements and make informed decisions (such as what kinds of ad campaigns they may want to run and the type of audience they want to reach). This helps keep the advertisements on our Services relevant and keeps our Services free for all users.

(3)Ensure the security and stability of our Services. We use your information to carry out testing and analysis to ensure the stability and security of our Services, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

Legitimate interest relied upon: to ensure the ongoing stability and security of our Services and to ensure they are continuously available and functioning.

(4) Review, improve and develop our Services. We use the information to understand how people are using our Services to improve and develop our Services.

Legitimate interest relied upon: to improve, promote, and develop our Services in an informed way.

(5) Share your information with third parties to provide additional features. We share your information with third parties providing additional features when you choose to use these features. For example, when you link your Coolita account to a third party service, the third party will be able to obtain your basic profile information and other information you choose to provide depending on the permissions you give.

Legitimate interest relied upon: to enable those third party service providers to better authenticate users and optimize the user experience.

(6) Marketing communications. We may send promotions, contests, or marketing campaigns or events to you on your Smart Device. We will obtain your consent to send you messages where required by law.

Legitimate interest relied upon: To promote new developments and features of our Services and/or third party products and services.

4.3 Your Consent

By clicking “Accept” / ticking in the box provided at the end of this Privacy Policy, you consent to the processing of your personal data in accordance with this Privacy Policy. Should we process your personal data outside the Purposes, we will request for your additional consent to access or use your information for specific purposes. If we process your information based on your consent, you can withdraw your consent at any time, unless such withdrawal is restricted by the law or by contract. However, your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent.

Please note that if you withdraw your consent, you may not be able to utilize the Services.

4.4 Compliance with a legal obligation

We may use your information where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts.

4.5 To perform a task in the public interest

We may use your information where it is necessary to perform a task in the public interest as required by laws or respond to lawful requests and legal process.

5. HOW WE SHARE YOUR INFORMATION

5.1 Service Providers

To help us provide you with our Services, we may, where necessary, share your personal information with our third-party Service Providers. These third parties may process your personal data on our behalf or for one or more of the purposes of this Privacy Policy. We restrict the Service Providers from using or disclosing the information except for the above-mentioned Purposes or to comply with legal requirements.

Those carefully selected Service Providers provide services for or on behalf of us, including the Service Provider providing technology services (such as web browsers, IoT solutions) and content services (such as GeoIP information bases, content portfolio consisting of Web Apps, video and game resources, and weather and forecasting information), and advertising. We require these Service Providers to protect your information according to applicable laws and this Privacy Policy.

We share Automatically Collected Information, Information You Provide, and Information from Others with these Service Providers as necessary to enable them to provide their services.

5.2 Third Party Platforms

We partner with third party platforms to offer you a seamless log-in and content sharing experiences. We share information with these third party platforms when you want to use these features. For example, if you choose to:

(1) log-in to a third party platform using your Coolita account, we will share your basic profile information and any other information you permit to provide; or

(2) sign-up or log-in to the our Services using your account details from a third party platform, we will share certain device information to facilitate this.

5.3 Integration Partners

When you choose to access third party services from our Services, we may share your device identifiers and device descriptive information with third party partners to help them integrate with our System and to provide you with a seamless experience.

5.4 Advertising Partners

(1)Advertisers: We provide advertisers with aggregate information about how their advertisements have performed to help them measure the effectiveness of their advertising campaigns.

We create this aggregate information by using device information and usage information relating to how you engage with advertisements on our Services, and Information from Other Sources. We share your information directly with advertisers where you give us your permission.

(2) Measurement and data partners: We also share device information and usage information with third party measurement providers who help us measure advertisements on our Services and help our advertisers determine how effective their advertisements have been.

5.5 Our Affiliates

Our affiliates around the world provide various supports for our Services. We may share Information You Provide, Automatically Collected Information, and Information from Other Sources with our affiliates as necessary to enable them to provide important functions such as research and development, security, analytics, payments, customer support, and technical support.

5.6 Others

Under limited circumstances described below, we may share your information with others:

(1) Corporate transactions: Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.

(2) Legal obligations and rights: We may access, preserve, and share the information described in “What Information We Collect” with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

(a) comply with applicable law, legal process or government requests, as consistent with internationally recognized standards;

(b) protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm.

(c) investigate potential violations of and enforce our Terms of Use, any other applicable terms, policies, or standards; or

(d) detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

6. HOW WE ACCESS TO AND TRANSFER YOUR INFORMATION

6.1 Access to your information

Our maintenance operations in China may access to your information stored in India or Germany. As described in the “How We Share Your Information” section, we may also we share your information with our affiliates and other entities in China, Singapore, United States, and other countries which are outside of your country of residence.

For the purposes described in this Privacy Policy, your information may be accessed from the above-mentioned countries or regions in accordance with applicable laws. The jurisdiction in which these global facilities are located may or may not protect personal data to the same standards as in your jurisdiction. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal data. While such information is outside of your country/region of residence, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. We will protect all personal information we obtain in accordance with this Privacy Policy and take reasonable steps to ensure that it is treated lawfully.

6.2 Transfer of your information

We process and back up personal data through a global operating and control infrastructure. Currently, we use cloud services deployed in India for processing personal data of users from Asia and use cloud services deployed in Germany for processing personal data of users from EEA or Switzerland and other regions.

If we need to transfer personal data outside of your jurisdiction, whether to our affiliates or third-parties Service Providers or other partners, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards.

If we change our data deployment plan which will affect the process and storage of your information, we will update and notify you immediately and ask for your consent when it is required under applicable local data protection laws.

In particular,

(1)The personal data we collect and generate in our operations in India is processed and stored in India, except for cross-border transmissions permitted under applicable laws.

(2)The personal data we collect and generate in our operations in some other regions of Asia, including The Philippines, Indonesia, Malaysia, Thailand and Vietnam, is processed and stored in India for now, except for cross-border transmissions permitted under applicable laws.

(3)The personal data we collect and generate in our operations in South Africa is processed and stored in Germany for now, except for cross-border transmissions permitted under applicable laws.

(4)Should we be required to transfer Personal Information to third parties outside of your country or regions of residence, we will ensure that the recipient of the information is subject to a law, binding corporate rules or binding agreement which provide an adequate level of data protection as required by applicable laws and regulations.

7. HOW WE RETAIN YOUR INFORMATION

7.1 Retention criteria

We will take appropriate and reasonable steps to ensure that we retain information about you based on the following criteria:

(1)We retain information for as long as necessary to provide our Services and for the other purposes set out in this Privacy Policy; and

(2)We retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our Services, and enhancing the safety, security and stability of our Services), and for the exercise or defense of legal claims.

7.2 Retention periods

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Service, we keep this device information for as long as the System on your Smart Device is activated. We may also keep your profile information if you for as long as you use your Coolita account.

Your personal data will be deleted or anonymized after the expiration of retention period specifically required or allowed by applicable regulations or laws.

8. HOW WE PROTECT YOUR INFORMATION

Security of your information is important to us. We maintain appropriate technical, administrative, organizational, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. These measures are designed to provide a level of security appropriate to the risks of processing your Personal Information. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us (See “How To Contact Us” below).

Our Service uses commercially reasonable security practices and procedures industry practices and procedures designed to help keep your Personal Information safe and secure. Unfortunately, the transmission of information over the Internet is not completely secure. Although we strive to protect your Personal Information, we cannot guarantee the security of your data while it is being transmitted to our Service; any transmission is at your own risk. We will also ensure, on a commercially reasonable efforts basis, that any agent or third party that we employ complies with the same security standards as we do for the protection of your Personal Information.

Your information may be transferred to or may be maintained on computers, computer systems and computer resources located outside of the country and regions of residence where the privacy laws may be different as those where you live.

9. WHAT ARE YOUR RIGHTS

9.1 Your rights under applicable laws

You have rights and choices to your information under applicable laws. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations.

You may choose to exercise the following rights about your information according to applicable laws, by contacting us as specified in the “How To Contact Us” section below in writing or by other means permitted by applicable laws:

(1)Right of confirmation and access. You can ask us to confirm whether your information has been processed, or request access to your information and receive a copy of personal data we have collected and stored about you.

(2)Right of rectification. You can update, rectify or change your information in the settings of your Smart Device. You can ask us to update, rectify or change your information where that information is not accurate.

(3)Right of erasure. You have right as provided by applicable laws to request us to erase, destroy, or anonymize your personal information. You may request us to cease the supply of personal information to a third party under certain circumstances according to applicable laws.

(4)Right of portability. You have the right to data portability in circumstances where we rely on contractual necessity and consent as our legal basis. This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party.

(5)Right to withdraw consent. You can withdraw consents to the processing of personal data based on your consent, unless such withdrawal is restricted by the law or by contract. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made.

(a)You can withdraw your consent in the settings of your Smart Device, especially your consent to Personalized Service;

(b)If you want to unsubscribe from the electronic communications in the email you received, please click the link for un-subscription in your email.

(6)Right to object or restrict processing. You have the right to object to or restrict our processing of your information in certain circumstances, relying on legitimate interest or public interests on the basis of applicable laws. For example, according to applicable laws, you may require us to cease or not to begin processing their personal data for purposes of direct marketing. You may object to decision-making based solely on automated processing related to your profile, under certain circumstances according to applicable laws.

In submitting an objection or restriction request, you should explain what specific processing activity you are objecting to or should be restricted, and why the processing should be stopped. We will stop the particular processing if we don’t have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

9.2 We will ensure you can exercise your rights in accordance with the applicable laws. Depending on the applicable laws, there may be situations where we may refuse your requests, for example, when refusing is in pursuant to a court order, or exercising your rights would adversely affect the rights and freedom of others.

9.3 When you need to exercise your rights, we may ask you to authenticate your identification, such as through your device ID.

9.4 Normally, you don’t have to pay us when you’re exercising your rights under the applicable laws; however, we reserve the right to charge you a reasonable fee for the processing of any information access, correction request or other scenarios where charge of fee is permitted by applicable laws.

9.5 We will respond to your requests within the time limits provided under applicable laws in the country/regions of your residence.

9.6 If you have any questions regarding this Privacy Policy or about exercising your rights, you may send your request in writing to the email address we provide below in “How to Contact Us”.

9.7 If you are of the opinion that the processing of your personal data by us is not in compliance with this Privacy Policy or applicable laws, you have the right to make a complaint to the competent regulatory authority in your jurisdiction.

10. HOW WE PROTECT CHILDREN

We attach great importance to the protection of children’s personal information. We do not provide Services directly to those we consider to be a child individual under the age of 18 or the equivalent age as specified by law in your jurisdiction, unless with the consent of a guardian. We consider it the responsibility of the guardian to supervise the children’s use of our Services. We will not make profiling, tracking, or monitoring behaviorally or making personalized advertisements on children and other data processing which may cause significant harm to children.

If it can be proved that we have collected personal information of children without the prior consent of a parent or guardian, please contact us via the email address we provide below in How to Contact Us and we will delete children’s personal information after reasonable verification.

11. LINKS TO OTHER WEBSITES, DEVICES, APPS AND FEATURES

This Privacy Policy does not apply to the practices of any third-party that we do not control. The Services may provide the ability to connect to other websites, devices, apps and other features (collectively, “Third Party Accesses”), which may operate independently from us and may have their own privacy notices and policies. Some of these will be provided in the form of links to third parties’ websites, and some will be accessed in the form of SDKs, APIs, etc. We strongly suggest you to review their policies and services to learn more about their privacy practices, which may differ significantly from ours. We are not responsible for the privacy practices, content, policies or actions of the Third Party Accesses. The use of any information you may provide to third parties on Third Party Accesses, or which such parties may otherwise collect on other accesses, is not governed by this Privacy Policy.

12. UPDATE TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes to this Privacy Policy by a notice provided through the Smart Device notification or by other means. We will inform you at the top of the policy when it was most recently updated to reflect changes in our personal data practices with respect to the Services. The up-to-date version of this Privacy Policy can be accessed directly in our Services at all times. We recommend that you familiarize yourself regularly with any changes to this Privacy Policy.

13. SEVERABILITY

If any part of this Privacy Policy is found by any court or other competent authority to be invalid, unlawful or unenforceable then such part shall be severed from the rest of the provisions of this Privacy Policy which shall continue to be valid and enforceable to the fullest extent permitted by law.

14. DUAL LANGUAGE

This Privacy Policy is made in English language and in the language of your residence country (if applicable) and both versions are equally authentic. In case of any discrepancy between these two versions, the English version of this Agreement shall prevail.

15. HOW TO CONTACT US

Please contact us if you have any questions or concerns about your personal data or require assistance in managing your choices.

Address: Shenzhen COOCAA Network Technology Company Limited, E363, Floor 3, Port Building, Marine Center, 59 Linhai Avenue, Nanshan Street, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen, China, 518052.

Email: CustomerCare@coocaa.com