Privacy Policy

Your privacy and data security are extremely important to us. We are committed to the responsible management, protection, and use of your personal information.

This Privacy Policy (the “Policy”) serves to explain what information One Manager and its affiliates and subsidiaries (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.

1. What Information Do We Collect?

We may have to collect your personal data to provide you with the better weapons and the most up-to-date security. We do not take your trust for granted. We conform our data use to the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), with effect from 7 May 2020. Therefore, in our Privacy Policy, we explain what we do, how we do it, your choices, and how we may need your cooperation to help you stay safe.

i. Device information

We collect your device and network connection information in order to provide you better experience when you use our app. This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:

l android_id

l device_id

l model, brand

l screen resolution, screen density, screen width and height

l network status

l application version number, version name

l gaid

l system version number, version name

l ad_id

l country

l list of installed applications

l storage card

l wifi status

l installed package usage

l collect notification bar, etc.

ii. Data about your use of the Services

Number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, number of the app opened and some viewed pages, permissions status, whether the function is running normally, such as whether a virus is detected, package name, first open time stamp, app brand, app net status, app model, and system language.

"Log Data" is technical information that is automatically collected by us when you use Application, whether through the use of cookies, web beacons, log files, scripts and e-tags or otherwise, including: Technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Application, your IP address and your device's version and identification number.

Information about what you have searched for and looked at while using Application, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using Application.

These data will only be passed to the certified third-party statistical platform and our self-built data statistics system. The above information is only used to improve the product experience and will not be sold to any third parties. We will not use this information for purposes other than improving the product experience and ad performance.

iii. Android Ad ID

We use your Android advertising identifier to present you with a personalized advertising experience. It is just used for advertising and analytic. Please keep in mind that the advertising identifier contains no user-sensitive information that may be used to identify you or your device. It is not linked to any personally identifiable information or any persistent device identification.

iv. Designated Countries

For all information listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

v. Non-Personal Information

Non-Personal Information is any information that relates to you but from which it is not practicable to directly or indirectly identify you, which may include the information about your devices (such as Your hardware model, operating system version, unique device identifiers, and mobile network information), the list of installed apps on your devices, and technical information about users means of connection to our apps, such as the versions of phone model and other similar information.

vi. The Antivirus engine is powered by Trustlook SDK. Trustlook SDK provides security service and it will record certain information that included user's installed applications. Because it will analyze the app collection, app static & behavior analysis to give the app risk report.

2. How Do We Use the Information?

2.1 We may use your Information for any purpose as below:

l Provide Application and Services (and the features within Application) to you, such as to show to other users in One Manager such as your connected friends or other users on the platform;

l Provide you with advertising and direct marketing that is more relevant to you;

l Better understand how you access and use Application, in order for us to improve Application and respond to customer desires and preferences, including for us to provide language and location customization, personalized help and instructions, or other responses to your and other customers' usage of Application;

l Help develop our service and provide, maintain, improve and modify the Applications, Services and the Site and develop new services;

l Assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with Application.

2.2 The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use. The data we collect may include SDK/API/JS/APP code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, GAID, AD_ID, device model, device model, terminal manufacturer, terminal device operating system version, storage card, screen resolution, screen density, screen width and height, session start/stop time, language location, time zone and network status (WiFi, etc.), hard disk, CPU and battery usage, installed application list, notification bar collection, etc.

2.3 To improve our product and provide you better service, we also share personal data with vendors or agents working on our behalf for the purposes described in this privacy policy. For example, companies we've hired to provide data analytical services may need collect and access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements.

2.4 We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.

2.5 Our business may require us to transfer your Personal Data to countries outside of the European Economic Area ("EEA"). We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Help Center.

2.6 Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.

Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Requests should be submitted by contacting us through [[email protected]].

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

3. What Information Do We Share?

As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including publishers, and data tracking companies. These business partners may use your personal information to measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.

4. What Are the Important Permissions We Request?

Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we ask are listed below:

l Storage: to read the contents of your storage, and to modify or delete the contents of your storage.

l Wi-Fi connection information: to view Wi-Fi connections.

l Other: receive data from the Internet, full network access, measure app storage, install shortcuts to this app, delete shortcuts to this app, view network connections, reorder running apps, view installed apps, draw on top of other apps, notification bar permanent display, connect and disconnect from Wi-Fi, start foreground services, expand and collapse, status bar, and get coarse network-based location.

5. Legal Basis of Your Personal Data

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers.

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our app.

6. How We Process and Protect Your Data?

We make every effort to disconnect or erase all direct identifiers from the Personal Data we collect and use. We are committed to doing everything possible to keep your data secure. We have put in place methods and practices to prevent unauthorized access or disclosure of your data, such as varied degrees of encryption.

We also ensure that any third parties with whom we work maintain all personal data processed on our behalf secure.

7. How Long We Store Your Data?

We shall keep your personal information on our systems for the following time periods:

For Product Data, we will retain information for no more than 36 months to ensure that our services are functioning properly and to evaluate ways to improve our services.

8. Your Rights

We provide you with the rights described below when you use our Services. Please contact us at [email protected] if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

l Where denial of access is required or authorized by law;

l When granting access would have a negative impact on other's privacy;

l To protect our rights and properties; and Where the request is frivolous or burdensome.

i. Right to withdraw consent

If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

ii. Right of access and rectification

If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.

iii. Right to erasure (the “Right to be Forgotten”)

You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

iv. Right to restriction

You have the right to restrict our processing your personal information where one of the following applies:

l You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;

l The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;

l We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or

l You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

v. Right to object to processing

You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

vi. Right to data portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

vii. Notification to third-parties

If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

viii. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

ix. Right to lodge a complaint

If you believe we have infringed or violated your privacy rights, please contact us at [email protected] so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

9. California Residents’ Privacy Rights

We prepare this separate Privacy Notice for California Consumers to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. This notice is designed to supplement the information described in our <Privacy Policy> and applies solely to users who reside in the State of California (“consumers” or “you”).

IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS POLICY DOES NOT APPLY TO YOU. PLEASE REFER TO OUR MAIN PRIVACY NOTICE HERE INSTEAD.

i. Your right to request for information

As required by CCPA, you (or your authorized agent) have the right to request us to disclose information to you about how we collect, use and share your personal information over the past 12 months. These information include: the categories of personal information we collected; the categories of sources for personal information we collected; our business purpose for collecting that personal information; the categories of third parties with whom we share that personal information.

ii. Your Right to Delete Information

Under the CCPA, You (or your authorized agent) have the right to opt out of having your information sold or shared. You (or your agent) have the right to request that we delete your specific personal information that we collected from you and retained, except in the following cases. Such cases include:

l We need your information to detect security incidents, protect against malicious, or illegal activity;

l We need your information to identify and repair application errors that impair existing intended functionality;

l We need your information to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

l We need your information to conduct internal uses that are reasonably aligned with your expectations based on your relationship with us;

l and other cases provided by CCPA and other California laws.

iii. How You Exercise Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by [email protected].

Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for request for information twice within a 12-month period. A verifiable consumer request must:

l Provide sufficient information that allows us to reasonably verify you identity and make us confirm we collected personal information about you;

l Describe your request with sufficient details that allows us to understand and respond to it.

We cannot respond to your request accurately if we cannot verify your identity.

iv. How We Respond Your Request

We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period by email, telephone or other electronic means.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

v. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Such discrimination include: denying you our services; charging you different prices or rates for our services; providing you a different level or quality of our services; suggesting that you may receive a different price or rate for services or a different level or quality of services.

vi. Data collection instructions for minors

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions. For users aged 13~16, they have the right to opt in, and if you are the parent or guardian of users who are aged 13~16, you can also contact us.

10. Children's Privacy

11. Changes to the Policy

Any information that is collected is subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.

12. Contact Us

If you have any questions or concerns about the Policy, you may contact us at email: [email protected].