Privacy Policy

 

Last updated: December 7st, 2023

 

WHO WE ARE

Ujoy Technology Pte Ltd (collectively referred to as "Company", "we", “us” or "our" in this policy) is the controller responsible for your personal data when you use the App, Funkie.

We value the privacy of users, subscribers, publishers, members, and others who visit and use our Services and want you (collectively or individually, “you” or “users”) to be familiar with how we collect, use, and disclose personal information from and about you. We want you to understand how your personal data will be used and shared. The following policy describes our personal data handling practices.

 

OUR CONTACT INFORMATION

Ujoy Technology Pte.Ltd

30 Pasir Panjang Road #15-31A

Mapletree Business City, Singapore 117440

If you have any questions about how we use your personal data, please contact funkie2022@outlook.com.

 

PRIVACY COMPLIANCE

Funkie makes reasonable efforts to respect the privacy rights of all of its users. For example, we have taken important steps for compliance with the General Data Protection Regulation 2018 (GDPR) for EU users and with the California Consumer Privacy Act (CCPA) for users residing in California.

 

PERSONAL DATA THAT WE COLLECT

We may collect, use, store and transfer different kinds of personal data about you as follows:

Our primary purpose in collecting your personal data is to optimize and enhance your Funkie experience. We use social sign-in to collect certain personal data from the social media platforms you use in order to register you on Funkie. We also collect user generated content such as your chats, posts or other contributions. Please do not share highly sensitive personal data using our Services.

As used in this Privacy Policy, "personal data" is as defined in the GDPR as any information relating to an identified or identifiable natural person ("data subject"). There are a number of ways we collect personal data from you.

 

HOW YOUR PERSONAL DATA IS COLLECTED

 

Direct Collection

Registration: When you register to use our Services, we receive certain information about you through Facebook®, Twitter® or through your direct registration, depending on your method of registration. This information may include your name, your location and language, a profile picture, your email, your phone number and social following. The registration process is optional for Funkie users who only wish to view content, but is required for users who would like to use the Services' more advance options. You can update your profile data at any time.

Funkie Activity: Any user-generated content is collected by Funkie, such as when you enter profile data, create contents, chats, posts, moments, when you gift or fan another user or subscribe to a partner's contents.

Communication from You: When you contact us with questions, concerns or for purposes of customer/technical support, we collect the information contained in your message, which may include your name, contact details and any other personal data you provide.

Consumption: We may collect your device information when you consume on Funkie with respect to our Service. We may collect and retain transaction serial number and transaction historical records at the time you purchase

 

 Automatic Collection

Social Network Data: Your social following, that is, data about your connections, will be collected by Funkie, and if these connections are Funkie users, they will automatically appear as your fans. Keep in mind that we receive information from other users' registrations for our Services, which may include your social username.

Metadata: Information collected behind the scenes by Funkie's servers about your use of Funkie's Services. This includes, but is not limited to, when you last logged in, when you created contents, liked or commented on someone else's sharing, when you created a post, your IP address and other information about your device.

Mobile advertising data: data which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests.

Automated data collection does not lead to profiling that significantly affects Funkie users, but simply gives Funkie a clear picture of its users. which may include your operating system, browser type, brand, model and serial number of your mobile device. For a complete listing of data fields collected and used by Funkie, you may contact us at funkie2022@outlook.com

 

DO NOT PROVIDE SPECIAL CATEGORIES OF PERSONAL DATA:

We ask that you not send us, and you do not disclose, through interaction, "special categories of personal data" as defined in the GDPR (information related to racial or ethnic origin, political opinions, religious or physiological beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership or data concerning data subject's sex life or sexual orientation).

For Funkie users who are EU residents, should you provide "special categories of personal data" using our Services, you understand that you have expressly consented to the collection, use and disclosure of such data in accordance with this Privacy Policy.

 

WHAT'S PUBLIC AND WHAT'S NOT?

Information you voluntarily transmit via our Services is publicly accessible and may be viewed and used by others without any restrictions. We do not control such uses of your personally identifiable information when you share with third parties using our Services. By using our Services, you assume the risk and acknowledge that the personal data provided by you may be viewed and used by third parties and by us for any number of purposes.

Your user profile and most of the content you create when using our Services, such as your moments, public chats, posts, as well as your fanning and gifting activity is publicly displayed to other Funkie users. Most of the data that Funkie collects about your Funkie activity ("metadata") is not publicly available. The number of Diamonds you hold is also not made publicly available, but other users may be able to see that you hold some Props.

 

HOW WE USE PERSONAL DATA

Funkie uses personal data responsibly in order to ensure we are meeting your expectations of our Services, responding to you when you contact us and providing a safe space for Funkie users. We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Purposes for which we will use your personal data

 

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact

Device

Your consent

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

Identity

Contact

Transaction

Device

Marketing and Communications

Location

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including receiving and responding to your feedback and notifying you of changes to the App or any Services

Identity

Contact

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Your consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

To prevent activity we determine to be potentially illegal, harmful or not in the public interest

Identity

Contact

Device

Content

Profile

Usage

Location

Necessary for our legitimate interests (for running our business, security and preventing crimes and misuse of our App)

 

 

DISCLOSURE OF PERSONAL DATA

Although Funkie makes every effort to preserve user privacy, we may need to disclose personal data as detailed below. These are also the categories of third parties with whom we have disclosed personal data:

We may need to disclose your personal data in response to a subpoena, regulatory investigation or court order, or to law enforcement authorities or regulators who have demonstrated their lawful authority. We may also disclose personal data for the public interest or in good faith to prevent harm to individuals. Keep in mind we also share personal data with trusted third parties in order to effectively provide our Services to users.

In addition to responding to law enforcement or regulator requests for personal data, Funkie will disclose personal data to report suspected illegal activity. For example, media files may be shared with the National Center for Missing and Exploited Children.

We may also disclose personal data to enforce our policies or respond to claims that any content violates the right of others. In all cases, such information will be disclosed in accordance with applicable laws and regulations.

Funkie may also share your personal data with third parties performing services on our behalf that have agreed to keep such information confidential (for example, secure payment processing).

Funkie will not retain your face recognition video in our servers, such video is merely for verifying. Facial data, such as when you use some features provided by us to create special effects or emojis or pictures that you uploaded on our Services, but such data will only be processed offline to fulfill the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party.

 

INTERNATIONAL TRANSFERS

The personal data we collect may be transferred to, stored at and processed by us and our affiliated third parties outside of the country in which you reside.

When transferring your personal data to our group companies outside of the jurisdiction in which you reside, we ensure your personal data is protected by requiring all our our group companies follow the same rules when processing your personal data.

Whenever we transfer your personal data to external third parties outside of the jurisdiction in which you reside, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

SECURING PERSONAL DATA

Funkie has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful processing of the data we collect. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by our Services reduce the likelihood of a data security breach.

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your account by ensuring no one else uses your computer or mobile device when you are logged in, by logging off from our Services when not in use and by keeping your passwords confidential.

Here are some examples of the data security controls in place at Funkie (this is not an exhaustive list):

 

COOKIES AND OTHER TRACKING MECHANISMS

A cookie will be used here to mean "mobile cookie" placed in the Funkie app's local storage, in order to tailor the environment based on the user's preferences and track the user's behaviour.

Funkie uses the following types of cookies for the purposes set out below.

Essential Cookies: These cookies are essential to provide you with our Services. For example, they allow you to log in to our App and help the content of the pages you request load quickly. We only use these cookies to provide you with those services.

Functionality Cookies: These cookies allow our App to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to parts of our platform that you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit us.

Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Services and how our Services are being used. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors, the websites that referred them and the Funkie pages visited, what time of day they visited, etc. We use this information to help improve our Services, to gather broad demographic information and to monitor the level of activity on the Funkie App. We use Google Analytics and other third party analytics services for this purpose to capture page and screen views.

Social Media Cookies: These cookies are used when you share information using a social media sharing button or "like" button on our App or you link your account or engage with our content on or through a social networking website such as Facebook or Google+. The social network will record that you have done this.

 

NOT FOR CHILDREN UNDER EIGHTEEN

This Service is a general audience Service, which is neither designed nor intended to collect personal data from children who are under the age of eighteen (18). We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that Personal Information of persons under 18 has been collected on or through our Services, we will take appropriate steps to delete this information. If you believe that we have inappropriately collected Personal Information from young user under 18, please contact us at funkie2022@outlook.com.

 

ACCURACY OF INFORMATION COLLECTED

Funkie wants to keep the personal data we store about you as accurate and complete as possible. We rely on the user to provide accurate information and we also have protocols in place to promote data integrity.

The information that we collect from you is the same information that you have previously provided to Facebook®, Google+® or relevant portions thereof. By updating the information in one of these social media accounts, you may be automatically updating the information in your Funkie account the next time that you log in. You can access and modify your Funkie account information directly by logging into Funkie and clicking the Help function, as well as make any changes to any express consents that you may have given with respect to us contacting you for Funkie news or promotions.

 

RETENTION AND STORAGE OF THE INFORMATION WE COLLECT

We will retain your information as long as you are an active Funkie user, to permit us to use it for the purposes that we have communicated in this Privacy Policy. Funkie has implemented retention schedules to avoid indefinitely storing personal data that has been collected indirectly (for example, about a Funkie user's social connections).

Personal data that is no longer required for administrative or business purposes, and that does not need to be archived by Funkie, will be overwritten or scrambled such that it no longer identifies a Funkie user. We may in some circumstances use such scrambled data (which no longer identifies the Funkie user) indefinitely without further reference to you for research or statistical purposes.  Keep in mind that third parties who store data on our behalf have their own retention rules.

 

YOUR RIGHTS

 

Some jurisdictions’ laws grant specific rights to Funkie users, which are set out in this section. You may have all or some of the following rights set forth below according to applicable laws. We will respond to your request consistent with the applicable laws as soon as practicable, normally within one month, after proper verification procedures. Your exercise of these rights is usually free of charge, unless we deem it is chargeable under the applicable laws.

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Withdraw Consent to processing your personal data, at any time, where the processing is based on your consent. If you do that, we will still process certain information on legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.

Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.

Right to Restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

 

ACCEPTANCE OF THIS PRIVACY POLICY

By using our Services, accessing our App, you are consenting to the practices relating to personal data collection and use that are described in this Privacy Policy.

Please note that our Services are controlled and offered by Funkie from its facilities in Singapore. The laws of other countries may differ regarding how personally identifiable information must be handled by Funkie. Funkie makes no representations that our Services are appropriate or available for use in other locations. Those who access or use the Service from other jurisdictions do so at their own volition, and consent to Funkie's collection, storage and use of their personally identifiable information as set forth in this Privacy Policy.

 

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time in order to better reflect our current data handling practices. Thus, we encourage you to review this Privacy Policy frequently! The "Last Updated" date above indicates when this Policy was last changed.

Any material change to this Privacy Policy will be clearly displayed on App. Personal data collected by us will be dealt with in accordance with the provisions of our Privacy Policy which were in effect at the time of collection. If at any time in the future we plan to share personal data with more third parties, we will maintain GDPR compliance and a high standard of care for your personal data. Your continued use of our Services following the posting of any changes to this Privacy Policy means you accept such changes. Should you not agree, you should no longer use our Services and go to your Privacy Settings to terminate your account.

Privacy Policy last updated: December 7st, 2023

 

FOR USERS IN THE EUROPEAN UNION

If you are in the EU, you have the rights under the GDPR:

If you wish to exercise any of rights herein or under GDPR, contact us at funkie2022@outlook.com or use Help or Feedback function on Funkie.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

 

FOR USERS RESIDING IN CALIFORNIA

You may have the right under the California Consumer Privacy Act to request information about the collection of your personal information by Funkie, or access to or deletion of your personal information. If you wish to request information about the collection of your personal information, please send an email to us via funkie2022@outlook.com. If you wish to delete your personal information, please send an email to funkie2022@outlook.com; or you may request deletion of your account on Delete Your Account page.

Please note that certain information may be exempt from such requests under California law and that, depending on your data choices, certain services may be limited or unavailable.

No sale of personal information. In the twelve months prior to the effective date of this Disclosure, Funkie has not sold any personal information of you, as those terms are defined under the California Consumer Privacy Act. 

No discrimination. Funkie will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.