Introduction
This "Blood on the Clocktower" User Privacy Policy (hereinafter referred
to as the "Policy") applies only to the "Blood on the Clocktower"
application (hereinafter referred to as the "Botc" or "App") and related
services of Nox Limited (hereinafter collectively referred to as "we"),
including the Botc website at https://www.botcapp.com/ and the Botc
mobile application, and does not apply to third-party products or
services that have separate privacy policies and are not covered by this
Policy. This policy describes which personal data is collected, saved,
and used when you use our App. Also, this privacy policy describes the
way your personal data is accessed, updated, managed, and protected. We
hope that you will read this Privacy Policy ("Policy") carefully to
learn more about how we collect and use information so that you can
better understand our services and better match your true intentions
when choosing whether and what services to use. If you choose to use the
services we provide, it means that you agree to be bound by all the
terms and conditions that we have stated in this policy.
We fully aware of the importance of personal information to you and will
do our best to protect the security and reliability of your personal
information, we are committed to maintaining your trust in us and
adhering to the following principles to protect your personal
information: the principle of consistency of rights and
responsibilities, the principle of clear purpose, informed consent, data
minimization, security guaranty, subject participation, openness and
transparency, etc. At the same time, we commit/warrant to take
appropriate security measures to protect your personal information in
accordance with the industry's proven security solutions.", "If you do
not expressly agree to this policy and start using our app, we will not
collect any information from you, which will result in our inability to
provide you with full-functioned products and services. We strive to
express this in easy-to-understand, concise language and use bold type
to draw your attention to the terms of this policy that are material to
your rights. If you have any questions, comments, or suggestions, please
feel free to contact us.
Email: [support@botcapp.com]
This privacy policy will help you understand the following.
1. How we collect and use your personal information
2. How we use cookies, similar technologies, and SDK technologies
3. How we share, transfer, and publicly disclose your personal
information
4. How we protect your personal information
5. How you manage your personal information/your rights
6. How we handle the personal information of minors
7. Where and how long we store the information and how your personal
information is transferred globally
8. How to update this privacy policy
9. How to contact us
10. Advertisements/information we send to you
11. The scope of application
12. Other
To better clarify, the following concepts in this policy refer to.",
"Personal information means, all kinds of information recorded in
electronic or other means that can identify a specific natural person or
reflect the activities of a specific natural person, or in combination
with other information, including personal identification information
(name, date of birth, identification document number, including ID card,
officer's license, passport, driver's license), facial features,
address, contact telephone number, address book, network identification
information (including account name, account nickname, e-mail address,
and the aforementioned password and password protection questions and
answers); property information, transaction information, personal
Internet records (Internet browsing records, click records, etc.),
personal common equipment information (including hardware model, MAC
address of the device, operating system type, software list unique
device identification code and other information describing the basic
situation of personal common terminal equipment) and personal location
information, etc.
Personal commonly used device information: information describing the
basic situation of personal commonly used devices, including hardware
serial number, device MAC address, software list, unique device
identification code (such as IMEI/IDFA/OPENUDID/GUID/OAID, SIM card IMSI
information, etc.), etc.
Personal location information: refers to information including
whereabouts trajectory, precise positioning information, accommodation
information, latitude, and longitude, etc.
Personal sensitive information refers to personal information that, if
leaked, illegally provided, or misused, may endanger personal and
property safety, and is highly likely to lead to damage to personal
reputation, physical and mental health or discriminatory treatment, etc.
The personal sensitive information in this privacy policy includes:
personal identification information (identification document number,
including ID card, officer's license, passport, driver's license),
facial identification features; property information, transaction
information; network identification information (including account name,
account nickname, email address, and password and password protection
questions and answers related to the foregoing); other information
(including address book, personal phone number (including address book,
personal phone number, travel information, and precise positioning
information).
De-identification refers to the process of personal information
technical processing, which indicates that the subject of personal
information cannot be identified without additional information.
Anonymization refers to the process of making the subject of personal
information unidentifiable through technical processing of personal
information, and the information cannot be recovered after processing.
1、How we collect and use your personal information
Personal information is all kinds of information recorded in
electronic or other means that can identify a specific natural person
or reflect the activities of a specific natural person, or in
combination with other information, and we will collect and use your
personal information for the following purposes as described in this
policy.
Core business functions and personal information collection", "We will
provide the following services to you and collect the information
listed below separately when providing the following services.
1) Business function: Register as a user.
When you sign up for the Botc service, the following information needs
to be collected for to complete the creation of your account: mobile
phone permissions, mobile phone number, nickname, birthday, gender,
blood type, personal avatar. The information collection is to help you
complete the registration, access to Botc and protect the safety of
your Botc account.
The mobile phone number and personal avatar are considered as
sensitive information, and such information is collected not only to
complete the registration of Botc account but also to meet the
requirements of the national laws and regulations for the network
real-name system.
If you do not provide such information, you may not be able to use our
services properly.
The information you provide above will be authorized to us
continuously for the duration of your service use. We will retain your
information until you cancel your account. When you cancel your
account, we will stop using and delete the above information.
The above information shall only be stored within the borders of
People's Republic of China. If you need to transfer it across the
border, we will ask for your authorized consent separately.
2) Business function: Fate match analysis.
We provide the most suitable matching results through accurate
calculation and analysis based on the user's own information,
effectively helping the user to meet potential friends.
There is no information that we require you to provide when you use
the Fate Matching Features.
Personal location information is sensitive information but if you
provide us with this, it will help to provide you with better service
and experience. However, it is worth noting that if you do not provide
this information, it will not affect the use of the basic business
functions of the APP.
The personal location information you provide will be authorized to us
on an ongoing basis for the duration of your use of the Service. We
will keep your information until you remove your account. When you
remove your account, we will stop using and delete the above
information.
The above information shall only be stored within the borders of
People's Republic of China. If you need to transfer it across the
border, we will ask for your authorized consent separately.
3) Business Function: Chat.
There is no information that we require you to provide when you use
the chat features.
If you provide the following additional information, it will help us
to give you better service and experience: photo album access, camera
access, microphone access, push access. However, if you do not provide
this information, it will not affect the use of the basic business
functions.
The information you provide above will be authorized to us
continuously for the duration of your use of the Service. We will keep
your information until you remove your account. When you remove your
account, we will stop using and delete the above information.
The above information shall only be stored within the borders of
People's Republic of China. If you need to transfer it across the
border, we will ask for your authorized consent separately.
4) Business function: Find Friends.
There is no information that we require you to provide when you use
the Find Friends function.
It will help us to give you a better service and experience if you
provide us with Phone Contacts Access Permissions. We are awared that
Phone Contacts Access is sensitive information, then if you do not
provide this information, it will not affect the use of the basic
business functions of the Service.
If another user uploads an address book that contains your contact
information, Botc may also recommend friends or refer you to the
appropriate users based on that information. If you do not want to be
recommended to your friends, you can choose to turn it off in
[Settings] - [Privacy].
The information you provide above will be authorized to us
continuously for the duration of your use of the Service. We will keep
your information until you remove your account. When you remove your
account, we will stop using and delete the above information.
The above information shall only be stored within the borders of
People's Republic of China. If you need to transfer it across the
border, we will ask for your authorized consent separately.
2、How we use cookies, similar technology, and SDK technology
Cookies
Cookies are small data files that we may store on your computer or
mobile device to ensure the proper functioning of our website, to make
your visit easier, and to recommend content that you may be interested
in. Cookies usually contain an identifier, the name of the site, and
some numbers and characters. You can clear the data cookies
accordingly in your browser.
Other technologies
In addition to cookies, we may use other similar technologies on our
website. Notifications we send to you by SMS or Botc customer service,
site notifications may contain link addresses that link to content on
our site. If you click on the link, click-tracking helps us understand
your product or service preferences so that we can proactively improve
our customer service experience. If you do not wish to have your
activity tracked in this way, you may turn it off at any time.
SDK technology
The SDK technology is provided by third parties with whom we work and
we are only aware of the permissions they require to obtain the
authorization. The third-party will need to collect information from
you and we will not have access to your information unless the third
party explicitly discloses to us the sensitive information to be
collected. The permissions required by the third party and the
sensitive information they explicitly disclose to us for collection
are detailed in the SDK Technical Notes.
If you declined to provide information to the third-party
organization, you will only be unable to use the functions carried by
the technology provided by the third-party organization, but it will
not affect your use of other functions of Botc.
3、How we share, transfer, and publicly disclose your personal
information
Sharing
We will not share your personal information with companies,
organizations and individuals other than the service providers of
Botc, except for the following cases.
1) Sharing with explicit consent: We will share your personal
information with other parties after obtaining your explicit consent.
2) Sharing under statutory circumstances: we may share your personal
information with external parties in accordance with the provisions of
laws and regulations, the need for litigation dispute resolution, or
as required by administrative or judicial authorities in accordance
with the law.
3) Sharing with affiliated companies: Your personal information may be
shared with our affiliated companies in order to facilitate our joint
provision of services to you based on affiliated accounts, to
recommend information that may be of interest to you, or to protect
the personal and property safety of Botc affiliates or other users or
the public from infringement. We will only share necessary personal
information (e.g. we will share your necessary account information
with our affiliates to facilitate your use of our affiliates' products
or services through your Botc account), and we will seek your
authorized consent again if we share your sensitive personal
information or if our affiliates change the purpose of using and
processing personal information.
4) Sharing with Authorized Partners: For the sole purpose of achieving
the purposes stated in this Privacy Policy, certain of our services
will be jointly provided by us and authorized partners. We may share
certain of your personal information with our partners to provide
better customer service and user experience. Examples include
arranging for partners to provide services. We will only share your
personal information for lawful, legitimate, necessary, specific, and
explicit purposes, and only as much personal information as is
necessary to provide the service. Our partners do not have the right
to use the personal information shared for any other purpose unrelated
to the product or service.
We send information to vendors, service providers, and other partners
who support our business by providing technical infrastructure
services, analyzing how our services are used, measuring the
effectiveness of advertising and services, providing customer service,
facilitating payments, or conducting academic research and surveys.
For companies, organizations, and individuals with whom we share
personal information, we enter into strict data protection agreements
that require them to handle personal information in accordance with
our instructions, this Privacy Policy and any other relevant
confidentiality and security measures.
Transfers
1) Transfer with expressly consent: we will transfer your personal
information to other parties after obtaining your express consent.
2) In cases involving mergers, acquisitions or bankruptcy liquidation
situations, or other situations involving mergers, acquisitions or
bankruptcy liquidation involving the transfer of personal information,
we will require the new company or organization holding your personal
information to continue to be bound by this policy, or we will require
the company, organization and individual to seek your authorized
consent again.
Public Disclosure
We will only disclose your personal information publicly Only in the
following situation.
1) With your express consent or based on your unsolicited choice, we
may disclose your personal information publicly.
2) If we determine that you have violated laws and regulations or
seriously violated the rules of the relevant Botc agreement, or to
protect the personal and property safety of users of Botc and its
affiliates or the public from infringement, we may disclose personal
information about you with your consent in accordance with laws and
regulations or the rules of the relevant Botc agreement, including the
relevant violations and the measures Botc has taken against you.
Exceptions to prior authorized consent for sharing, transferring, and
public disclosure of personal information.
In the following cases, prior authorized consent is not required for
sharing, transferring, or publicly disclosing your personal
information.
1) Related to national security or national defense security.
2)
Related to public safety, public health, and significant public
interest
3) Related to crime investigation, prosecution,
trial and execution of judgments, etc.
4) For the purpose
of safeguarding your or other individuals' life, property and other
significant legitimate rights and interests but where it is difficult
to obtain your consent.
5) Personal information that you
disclose to the public on your own.
6) Personal information
collected from legitimate public disclosures, such as legitimate news
reports, government information disclosure and other channels.
According to the law, sharing or transferring personal information
that has been de-identified and ensuring that the recipient of the
data cannot recover and re-identify the subject of the personal
information is not an act of sharing, transferring or publicly
disclosing personal information to the public, and there will be no
need to separately notify you and obtain your consent for the
preservation and processing of such data.
4、How we protect your personal information
In order to protect the security of your information, we will strictly
comply with the technical measures and operational procedures required
by laws and regulations and other regulatory documents to protect the
secrecy of your information, while.
1) We have taken reasonable and feasible security measures to protect
the security of personal information provided by you in line with
common industry solutions to prevent unauthorized access, public
disclosure, use, modification, damage or loss of personal information.
We use encryption technology to enhance the security of personal
information; we use trusted protection mechanisms to prevent malicious
attacks on personal information; we establish a strict internal
control system and a sound and adequate management process; we deploy
access control mechanisms and make every effort to ensure that only
authorized personnel has access to personal information, and we hold
security and privacy protection training courses to enhance employees'
awareness of the importance of We will hold security and privacy
training courses to enhance employees' awareness of the importance of
protecting personal information.
2) We have an industry-advanced data security management system that
focuses on the data lifecycle and enhances the security of the entire
system in multiple dimensions, such as organizational construction,
system design, personnel management, and product technology.
3) We will take reasonable and feasible measures to avoid collecting
irrelevant personal information to the best of our ability. We will
only retain your personal information for as long as necessary to
achieve the purposes described in this policy unless the retention
period needs to be extended or is permitted by law.
4) The Internet is not an absolutely secure environment, and we
strongly recommend that you do not send personal information using
communication methods other than those recommended by Botc. You may
establish connection and share with each other through our Services.
When you create communication, transaction, or sharing through our
services, you can independently choose the person to whom you
communicate, trade, or share as a third party who can see your
transaction content, contact information, communication information,
or sharing content and other related information.
If you find that your personal information, especially your account or
password, has been leaked, please contact Botc Customer Service
immediately so that we can take appropriate measures according to your
application.
From time to time, we will update and disclose
the contents of our security risk and personal information security
impact assessment reports.
The Internet environment is not 100% secure and we will do our best to
ensure or warrant the security of any information you send to us. If
our physical, technical, or administrative safeguards are breached,
resulting in unauthorized access, public disclosure, tampering, or
destruction of information, resulting in damage to your legal rights
and interests, we will be liable.
After the unfortunate occurrence of personal information security
events, we will, in accordance with the requirements of laws and
regulations, promptly inform you of: the basic situation of the
security event and the possible impact, the disposal measures we have
taken or will take, the suggestions you can independently prevent and
reduce the risk, the remedial measures for you, etc. We will promptly
inform you of the event-related situation by way of push notifications
and take reasonable and effective ways to send announcements.
At the same time, we will also take the initiative to report the
disposition of personal information security incidents in accordance
with the requirements of the regulatory authorities.
5、How you manage your personal information / your rights
In accordance with the relevant laws, regulations, and national
standards of the People's Republic of China, as well as common
industry practices, we protect your right to exercise the following
rights to your personal information.
1) Access, edit your personal information
Account information - If you wish to access or edit your personal
information in your account, set privacy and permissions, set message
alerts and chat, change your bound cell phone number and password,
close your account, etc., you can do so by logging into your account
via "My Card "-"Settings" to perform such operations.
2）Correction of your personal information
When you find that there is an error in the personal information we
have processed about you, you have the right to ask us to make
corrections or additions. You can make a request for corrections or
additions in the manner specified in this Article"Accessing and
editing your personal information".
3) Deletion of your personal information
You may delete some of your personal information in the manner set
forth in this Article "Accessing and Editing Your Personal
Information".
You may request deletion of your personal information from us in the
following cases.
a. If our handling of personal information violates laws and
regulations.
b. If we collect or use your personal
information without your explicit consent.
c. If our
handling of personal information is in serious breach of our agreement
with you.
d. If you no longer use our products or services,
or if you voluntarily cancel your account.
e. If we no
longer provide products or services to you.
If we decide to respond to your request for deletion, we will also, to
the extent possible, simultaneously notify the subjects who have
obtained your personal information from us and request them delete it
promptly, unless otherwise required by law or regulation, or unless
such subjects have your independent authorization.
When you delete information from our service, we may not immediately
delete the corresponding information from our backup system but will
delete it when the backup is updated.
4) Managing the scope of your authorization
Each business function requires basic personal information to be able
to complete. You may give or withdraw your authorized consent at any
time for the collection and use of additional collected personal
information.
You can do this on your own in the following
ways.
You can change the scope of your authorization for features and
services by deleting information, turning off device features, as well
as setting "Settings" - "Account & Security, Notification Alerts,
Privacy" in the APP.
Specific business functions and services will require your personal
information to complete. After you withdraw your consent, we will not
be able to provide you with the functions and services for which you
have withdrawn your consent, and we will no longer process your
personal information. However, your decision to withdraw your consent
will not affect our previous processing of personal information based
on your consent.
5) User account cancellation
You can log in Botc APP (Botc APP → click "My Card" icon → click the
gear icon in the upper right corner - system settings interface → -
click "Account cancellation (delete account)", you can apply for
account cancellation.
After you voluntarily cancel your account, we will stop providing
products or services to you, delete your personal information or make
it anonymous for processing in accordance with the requirements of the
corresponding law.
6) Restraint on automatic decision-making by information systems
In some business functions, we may make decisions based solely on
non-manual automated decision-making mechanisms, including information
systems and algorithms. If these decisions significantly affect your
legitimate rights and interests, you have the right to ask us to
provide an explanation, and we will also provide a method of appeal on
the premise that it does not infringe on Botc the trade secrets or
other user rights and interests of the public interest.
7) Respond to your request above
For security purposes, you may need to provide a written request or
otherwise prove your identity. We may ask you to verify your identity
first before processing your request.
We will respond within 15 days. If you are not satisfied with our
response, you may also initiate a complaint through Botc Customer
Service.
For your reasonable requests, we will try to fulfill your requests. We
may reject requests that are unwarrantedly repetitive, require
excessive technical means (for example, requiring the development of
new systems or fundamental changes to current practices), pose a risk
to the legal rights of others, or are highly impractical.
Related restrictions
In the following cases, we will not be able to respond to your request
in accordance with the requirements of laws and regulations.
a. Related to national security and national defense security.
b.
Related to public safety, public health, and significant public
interests.
c. Related to crime investigation, prosecution,
trial and execution of judgment, etc.
d. Where there is
sufficient evidence of subjective malice or abuse of rights by the
subject of personal information
e. Responding to your
request will lead to serious damage to the legitimate rights and
interests of you or other individuals or organizations
f.
Where commercial secrets are involved.
6、How we handle the personal information of minors
Our products are mainly for adults, we expect parents or guardians to
guide minors to use our services, if you are a minor under the age of
18, before using our products, you should read and agree to this
policy together under the supervision and guidance of your parents or
other guardians. Children (under the age of 14) are not allowed to
create their own user accounts without the consent of their parents or
guardians.
We protect the personal information of minors in accordance with the
relevant national laws and regulations, and in the case of personal
information collected from minors with parental consent, we will only
use, share or publicly disclose this information as permitted by law,
with the express consent of the parent or guardian, or as necessary to
protect the minor.
If we find that we have collected personal information from minors
without prior verifiable parental consent, we will seek to delete the
relevant data as soon as possible.
7. Where and for how long the information is stored, and how your
personal information is transferred globally.
The geographical area where personal information is stored.
We store the personal information collected and generated within the
territory of the user in China in strict accordance with the laws and
regulations.
In the case that personal information leaves the country, we will not
transfer the above information outside the country. If some products
involve cross-border business and we need to transfer the relevant
personal information collected in the country to overseas
institutions, we will follow the relevant national regulations and at
the same time evaluate the information security of the information
leaving the country, and obtain your explicit authorization, and
implement it in accordance with the laws and regulations and the
regulations of the relevant regulatory authorities, We will require
the overseas institutions to keep your personal information
confidential through effective measures such as signing agreements and
on-site verification, except for your personal initiative such as
cross-border posting through the internet.
In the above cases, we will ensure that your personal information is
totally protected in accordance with this privacy policy.
Duration of storage of information
In general, we will only retain your personal information for the
shortest period of time necessary to achieve our purposes, and we will
delete or anonymize your personal information beyond the corresponding
period. However, we may change the period of storage of personal
information due to the need to comply with legal requirements in the
following cases.
1) In order to comply with the relevant provisions of applicable laws,
regulations or policies, and other regulatory documents.
2) To comply with the provisions of decisions, etc. of administrative
organs or similar authorized organizations, judgments or rulings of
judicial organs, awards of arbitration organs, or other legal
proceedings.
3) In order to comply with the relevant provisions of laws,
regulations, etc., which we are reasonably certain are required.
4) For purposes reasonably necessary to enforce the relevant service
agreement or this policy, to safeguard the public interest, and to
protect the personal and property safety or other legitimate rights
and interests of third parties such as our customers, our affiliates,
other users or employees.
When Botc ceases operation, we will notify you in the form of push
notifications, website or in-program announcements, and delete or
anonymize your personal information within a reasonable period of
time.
8. How this privacy policy is updated
Our privacy policy is subject to change. In the event of changes in
business functions, changes in the purpose of use, or changes in the
contact information of the person in charge of personal information
protection, we will revise our privacy policy accordingly.
We will not limit your rights under this Privacy Policy without your
express consent. We will provide prominent notice of material changes
(including notice via a public notice on the Botc platform,
Botccustomer service notice, etc.).
Major changes within the meaning of this policy include, but are not
limited to.
Our privacy policy may change. In the event of a change in business
function, a change in the purpose of use, or a change in the contact
information of the person in charge of personal information
protection, we will revise our privacy policy accordingly.
We will not limit your rights under this Privacy Policy without your
express consent. We will provide prominent notice of Majorchanges
(including notice via a public notice on the Botc platform, Botc
customer service notice, etc.).
Major changes within the meaning of this policy include, but are not
limited to.
1) Significant changes to our service model. Such as the purpose of
handling personal information, the type of personal information
handled, the way personal information is used, etc.
2) Changes in the primary recipients of the sharing, transfer, or
public disclosure of personal information.
3) Significant changes in your rights to participate in the processing
of personal information and the manner in which they are exercised.
4) When there is a change in the department responsible for handling
personal information security, our contact information and complaint
channels.
5）When the personal information security impact assessment report
indicates that there is a high risk.
If you choose to continue to use our services after being notified,
you agree to be bound by the revised policy.
We will also keep an older version of this policy on file for your
review, which you may request from us through the contact information
reserved in this policy.
9、How to contact us.
If you have questions or suggestions about this policy or related
matters, etc., we have established a dedicated line for personal
information protection, and you can contact us through the following
complaint channels.
Report Email: [support@Botcapp.com]
We will properly receive and promptly reply to your complaint within
fifteen days after verifying your user identity.
If you are
not satisfied with our response, especially if you think our personal
information processing behavior has damaged your legitimate rights and
interests, you can also seek a solution by filing a lawsuit to the
court with jurisdiction in the place where the contract was signed.
This agreement was signed in Chaoyang District, Beijing, People's
Republic of China.
10、Advertising/Information we send to you
We may use your relevant information to send you commercial
advertisements on relevant websites, applications, and other channels.
If you do not wish to receive commercial advertisements from us, you
may unsubscribe at any time through the appropriate product
unsubscribe function.
11、Application scope
This privacy policy applies to all services provided by Nox Limited,
including the Botc client, website, etc., but does not apply to
third-party products or services that have separate privacy policies
and are not included in this privacy policy.
12、Others
The headings in this Privacy Policy are for convenience and reading
only, and do not affect the meaning or interpretation of any provision
of this Privacy Policy.
This Privacy Policy is copyrighted by us, and we reserve the right to
interpret and modify it to the extent permitted by law.
| System | Operators | Products |
Purpose of collecting personal information from third parties
|
Types of personal information collected from third parties
|
Ways of collecting personal information from third parties
|
|---|
| Apple/Android | Beijing Baidu.com Technology Co. | Baidu Map SDK |
Help users to post messages and send real-time location location
| Acquisition of personal location information | SDK acquisition |
| Apple/Android | Beijing Baidu.com Technology Co. | Baidu Map SDK |
Help users to post messages and send real-time location location
| Acquisition of personal location information | SDK acquisition |
In order to better experience some of the features, you can choose to
enable or deny the following permissions at your own discretion.
| System | Operators | Products |
Purpose of collecting personal information from third parties
|
Types of personal information collected from third parties
|
Ways of collecting personal information from third parties
|
|---|
| Apple/Android | Beijing Baidu.com Technology Co. | Baidu Map SDK |
Help users to post messages and send real-time location location
| Acquisition of personal location information | SDK acquisition |
| Apple/Android | Beijing Baidu.com Technology Co. | Baidu Map SDK |
Help users to post messages and send real-time location location
| Acquisition of personal location information | SDK acquisition |