PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT.

This Privacy Policy (“Policy”) may change from time to time. Please check the Policy
periodically for updates.

Yumi Limited, a limited liability company organized in Hong Kong (“Yumi,” “Company,” “We,” “Us,” or “our”) wants you to be familiar with how we collect, use and disclose information.

This Policy describes our practices in connection with information that We collect through

• Software application(s) made available by Us for use on or through computers and mobile devices (the “App”);
• Website(s) operated by us from which you are accessing this Policy (the “Website”);
• Our social media pages and apps (collectively, our “Social Media Pages”); and
• Email messages, text messages or other communications with you.

Collectively, we refer to the App, Website, Social Media Pages, and communications as the “Services.”

The App enables people (each, a “User” and, collectively, the “Users”) who live close to one another to connect and meet, all while ensuring that users remain 100% anonymous to one another. Some User Content is available to all Users, and other User Content is available only to Members.

Capitalized terms not defined herein are defined in our Terms and Conditions.

This Policy does not apply to information collected by:

• us offline or through unrelated websites, applications or services; or
• any third party (including any of our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the App. We encourage you to be aware when leaving the App and to read the privacy statements of any other site or application that collects personally identifiable information.

We and our service providers collect different types of information from and about users of our Services, including information that identifies you as an individual or relates to an identifiable individual (“Personal Information”). Such Personal Information can be categorized as follows

• Essential Information: Information that enables you to use the App, such as your gender, photo, date of birth, sexual preferences and location. This information is necessary for the basic functionality of the App;
• Optional Information: Information that is not required for you to use the App but may enhance your experience, improve the selection process and matching process or personalize recommendations, such as voice recording, height, ethnicity, body type, relationship status, occupation, and answers to profile questions.

We do not collect information that directly identifies you, such as name, postal address, e-mail address, telephone number, other contact information, or credit card information, unless you choose to disclose such information through your use of the Services, such as by including it in messages, profile content or other User-submitted materials. However, information that identifies you may be inferred or revealed if, for example, you include identifying details such as your name in your photo or voice recording, or you are photographed in front of your house showing your address, which we do not recommend.

• Generally speaking, when you purchase a membership through Google Play or the Apple App Store, we do not receive any identifying information about you from that transaction. All identifying information relating to that transaction is handled between you and Google Play or the Apple App Store, as the case may be, and is governed by their respective privacy policies. On the “Account” page in the App, you have the option to “Link Your Account.” If you select this option, you may link your Google Play or Apple App store account with your account within the App.

(a) Information You Provide to Us. The information We collect on or through the Services may include:

• Information that you provide by filling in forms on our App. This includes information provided at the time of, for example, creating your profile or making any inquiries or requests to us.
• Records and copies of your correspondence (including email addresses) such as support requests, if you contact us.
• Your responses to surveys that We might ask you to complete for research purposes.

(b) Information and Persistent Identifiers We Collect Through Automatic Data Collection Technologies.  As you navigate through and interact with our App, We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• details of your visits to our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the App; and
• information about your computer and internet connection, including your IP address, operating system, and browser type.

The information We collect automatically may include personal information which We may maintain or associate with personal information We collect in other ways or receive from third parties. It helps us to improve our App and to deliver a better and more personalized service, including by enabling us to:

• estimate our audience size and usage patterns; and
• recognize you when you return to our App.

The technologies We use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or on your mobile device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App.
• Flash Cookies. Certain features of our App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our App. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the section titled Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our App and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

(c) Our use of UUIDs.  Instead of using your personal information to link your account, We use a randomly generated Universally Unique Identifiers (each, a “UUID”). A UUID is assigned to your device and helps us identify your account within the App. Your UUID may change if you:

• factory reset your device;
• use the App on a different/new device; or
• reinstall the operating system of your device.

When your UUID changes, we may collect your information again, which could result in multiple accounts being created for you. To avoid this, we recommend that you delete your existing account before performing any of the above actions, so that only one account remains associated with you.

Due to the unique nature of the App, your profile includes the Essential Information and, if you choose to provide it, the Optional Information as well, none of which directly identifies you, unless, for example, your photo or audio recording contains details such as your name or other visible identifiers).

We use that information to better understand our user base and enhance our services.

You understand that by providing Essential Information and, if applicable, Optional Information, it will be made available to other Users.

We use information that We collect about you other than that provided in your profile, including any Personal Information:

• to present our App and its contents to you;
• to provide you with information, products, or services that you request from us;
• to fulfill any other purpose for which you provide such information;
• to provide you with notices about your account;
• to carry out our obligations and enforce our rights arising from any use of our App, including for billing, collection and payment;
• to notify you about changes to our App or any products or services We offer or provide through it;
• to prevent fraud;
• for testing, research, analysis and product development, which enables us to improve and enhance the safety and security of our services, develop new features and products;
• to improve the App and any products;
• in any other way We may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, notify us at [email protected]. For more information, see the section titled Choices About How We Use and Disclose Your Information. We may use the information We have collected from you to enable us to display advertisements to our advertisers’ target audiences.

We disclose information that We collect about you or that you provide to us, including any Personal Information:

• To our affiliates for the purposes described in this Policy
• To our third party service providers, to facilitate services they provide to us
  • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits, email delivery, auditing, and other services.
• By using the Services, you may elect to disclose Personal Information
  • You share data with other members when you voluntarily disclose information in your profile or via messages in the App.
  • If a User submits a report involving you (such as a claim you violated our Terms and Conditions), we may let the reporting User know what actions we took, if any, as a result of their report. The same applies if you submit a report involving another User.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations
  • This may include laws outside your country of residence
• To cooperate with public and government authorities
  • To respond to a request or to provide information we believe is necessary or appropriate.
  • These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  • We may disclose your data to: (i) comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) assist in the prevention or detection of crime; (iii) protect the safety of any person; and (iv) establish, exercise or defend legal claims.
• For other legal reasons.
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the App may be inaccessible or not function properly.
• Promotional Offers from Us. If you do not wish to receive promotional offers from Us or for third parties’ products or services, you can opt-out by sending us an email stating your request to [email protected]. If We have sent you a promotional email, you may send us a return email asking to be excluded from future email distributions.  This opt-out feature does not apply to information provided to the Company in connection with your registration, a service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose to not have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

You may edit your profile information directly through the App. You can also delete your account at any time via the App’s settings and, if you choose, create a new profile thereafter. You can also review and change your personal information by notifying Us at [email protected].

If you uninstall the App from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

We seek to use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. The safety and security of your information also depends on you. Where We have given you (or where you have created) an account for access to certain parts of our App, you are responsible for keeping this account confidential. We ask you not to share your account with anyone.

No data transmissions over the Internet, cell-phone connections or Wi-Fi can be guaranteed to be 100% secure. We cannot guarantee the security of any information communicated by or to other Users.  Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Information” section below.

If We learn of a security breach, We may attempt to notify you electronically so that you can take appropriate protective steps. By using the App or providing personal information to us, you agree that We can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the App. We may post a notice on the App if a security breach occurs, and/or if you have provided an email address to us, we may also send an email to you.

We will keep information you store with us for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to jurisdictions and countries outside of your country of residence, including Hong Kong, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Our Services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our Services. If you suspect that a User is under the age of 18, please contact us via your profile or the chat option within the App or email [email protected].

It is our policy to post any changes We make to our Privacy Policy on this page. If We make material changes to how We treat our users’ personal information, We will notify you through a notice on the App home page, an email or other such means as we determine reasonable to bring the changes to your attention. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring We have an up-to-date active and deliverable email address for you, and for periodically visiting our App and this Policy to check for any changes.  Any changes will become effective when we post the revised Policy on the Services.

To ask questions or comment about this Policy and our privacy practices, contact us at Yumi Limited by emailing us [email protected].

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights regarding our collection, use and sharing of Personal Information. “Personal Information” is information that identifies, relates to, describes, or could reasonably be associated or linked with a particular California resident or household.

As mentioned above, we generally do not collect information that directly identifies you, unless you choose to disclose such information through your use of the Services.

We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information, as listed in the CCPA:

• Identifiers, such as name, contact information (email address), an IP address that can reasonably be linked or associated with a particular consumer or household;
• Personal information as defined in the California customer records law, such as name and contact information;
• Characteristics of protected classifications under California or federal law, such as gender, sexual orientation, and age;
• Commercial information, such as records of products or services purchased;
• Internet or network activity information, such as interactions with our online properties;
• Geolocation information, such as device location and approximate location derived from IP address;
• Audio, electronic, visual, and similar information, such as photographs and voice recordings;
• Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics; and
• Contents of your messages.

Some of the information we collect may constitute “Sensitive Personal Information” under the CCPA, including information that reveals your racial or ethnic origin, sex life or sexual orientation, and contents of your messages. We do not use or disclose Sensitive Personal Information for purposes other than providing and improving our services to you and protecting our services and our community.

We collect Personal Information from you and our third-party service providers.

We use Personal Information as set forth above to operate, manage, and improve our business and Services and to accomplish our business purposes and objectives, including to, for example: provide, personalize, and improve our products and services; process transactions; perform user verification; conduct research, analytics, and product development; deliver advertising and marketing; maintain and secure our infrastructure and IT systems; detect and prevent fraud; support safety and legal compliance; perform internal operations such as audits and accounting; maintain records; and exercise or defend legal claims.

We share Personal Information with the following categories of third parties:

• Service Providers. We share with our service providers, to facilitate the services they provide to us, such as website hosting, marketing services, data analysis, payment processing, order fulfilment, infrastructure provision, auditing, IT services, customer service, and email delivery.
• Legal Authorities. We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.

In the preceding 12 months, we disclosed for our operational business purposes the following categories of Personal Information to the following categories of third parties:

We do not “sell” your Personal Information, and we do not knowingly collect or sell the Personal Information of minors under 16.

If you are a resident of California, you have the right to:

• Request to know what Personal Information we have collected about you and to access a copy of that information
• Request deletion of your Personal Information, subject to certain exceptions under the CCPA
• Request that we correct inaccurate information we hold about you
• Limit the use of disclosure of Sensitive Personal Information, if applicable

You may exercise these rights by emailing us at [email protected]. We may take steps to verify your identity before fulfilling your request. You may designate an authorized agent to make a request on your behalf, provided you give the agent written permission and we are able to verify your identity.

We will not discriminate against you for exercising your rights under the CCPA.

Separate from the CCPA, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

We do not currently respond to browser do-not-track signals.