THE INFORMATION WE COLLECT
In providing Kashmir-N, we collect, store and use the following Information relating to you:
“Information” is Personal Information and Non-Personal Information;
“Personal Information” is any information or combination of information that relates to you or a Connected Person, and can be used to identify you or a Connected Person. We set out examples of Personal Information (and how we collect such Personal Information) in the “How we collect Information via Kashmir-N” section below.
“Location Data” is information that we collect regarding your location (when you use a location-enabled service), including:
- the location of your device when you use Kashmir-N, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device;
- the IP address of the device or internet service you use to access Kashmir-N; and
- other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located, and Shared Information that you or others post which indicates your location (for example, any geotag information that is embedded in any photos you make available on Kashmir-N or that is made available to us when you use the Kashmir-N “Chat” or “People Nearby” functions).
- technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Kashmir-N, your IP address and your device’s version and identification number;
- information about what you have searched for and looked at while using Kashmir-N, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using Kashmir-N;
- information about communications you have made using Kashmir-N, such as the people you’ve communicated with and the time, data and duration of your communications; and
- metadata, which means information related to items you have made available through Kashmir-N, such as the date, time or location that a shared photograph or video was taken or posted.
“Non-Personal Information” is any information that relates to you but from which it is not reasonably practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.
“Shared Information” is information about you or relating to you that is voluntarily shared on Kashmir-N. Shared Information may include postings that you make on Kashmir-N(including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using Kashmir-N share about you.
HOW WE COLLECT INFORMATION VIA Kashmir-N
We collect Information from you when you use Kashmir-N– for example, when you:
- register to use Kashmir-N;
- log into Kashmir-N with third party platform accounts;
- use Kashmir-N; and
- communicate with us.
Registration and Account Information. You must register for a Kashmir-N account in order to use Kashmir-N. To register, you may need to provide certain Personal Information, such as your name, mobile phone number and password.
Account Verification. If you choose to apply for account verification you may need to provide additional Personal Information, including gender, nationality, date of birth, residential address, copy of residential address proof, copy of personal identification document (for example passport, identification card, home return permit, etc.), personal identification document number, occupation and source of funds
Connected Persons. If you are an Organization you may provide information related to Connected Persons to allow us to administer your Kashmir-N account and comply with laws and regulations applicable to us and our affiliated companies.
Social Connect. When you choose to connect your third party social media account to your Kashmir-N account, we may collect certain Information from your account with that social media platform – for example, to facilitate your login to Kashmir-N with that account.
Using Kashmir-N. We collect Information from and about you through your use of Kashmir-N. For example, we may collect Personal Information from you within Kashmir-N via the following:
- information you make available to us when you open a Kashmir-N account, as set out above;
- any information included in your publicly visible Kashmir-N profile, which may include your profile ID, name and photo;
- information you make available to us via your use of Kashmir-N – for example, via:
- posting Kashmir-N messages and responding to other users’ Kashmir-N messages;
- your sharing of your contact list with Kashmir-N in order to connect with other Kashmir-N users;
- participating in surveys, polls, contests, giveaways and other promotional activities within Kashmir-N ;
- making purchases within Kashmir-N, including your credit card or bank details and information about the purchases that you make;
- information made available by another user about you via their use of Kashmir-N – for example, any Shared Information that others using Kashmir-N make available about you via Kashmir-N and communications they make to you and others using Kashmir-N;
- information we collect in the course of you using Kashmir-N – such as certain Location Data and Log Data; and
- information you provide through your communications with our customer support team.
HOW WE USE YOUR INFORMATION
Use of your Information within Kashmir-N
We may use your Information for any of the following purposes:
- to provide Kashmir-N (and the features and services within Kashmir-N ) to you – for example, to allow you to place VOIP calls within Kashmir-N, to fulfil any purchases you may make within Kashmir-N, and to display content based on your location;
- for communication, verification, security, fraud-detection, archival, backup, informational and operational purposes in connection with the provision of Kashmir-N – including account management, customer service, system maintenance, fulfilment of purchases, notifying contest winners, and other Kashmir-N -related purposes;
- to provide you with advertising and direct marketing that is more relevant to you (as further discussed under the “Direct Marketing” section below);
- to better understand how you access and use Kashmir-N, in order for us to improve Kashmir-N and respond to customer desires and preferences, including for us to provide language and location customisation, personalised help and instructions, or other responses to your and other customers’ usage of Kashmir-N;
- to help us develop our new services and improve our existing services;
- to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with Kashmir-N when your account is subscribed to an official account; and
- to allow you to participate in voluntary surveys about our products and services. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys; we will prohibit them from using your Personal Information for any purpose other than to complete the survey.
In addition, we may need to retain, disclose and use your Information for the following purposes (collectively, the “Retained Information Purposes“):
- to comply with applicable laws and regulations;
- to comply with a court order, subpoena or other legal process, whether binding on us or any of our affiliates in any jurisdiction;
- in response to a request by a government authority, law enforcement agency or similar body made to us or any of our affiliate companies (whether situated in your jurisdiction or elsewhere);
- where we believe it is reasonably necessary to comply with applicable laws or regulations;
- to protect any rights, property or safety of ours, our affiliate companies or other users of Kashmir-N.
We may also anonymise or aggregate any Personal Information collected through Kashmir-N and use such anonymised and aggregate data for any purpose.
Use of Personal Information on our other services
For example, Personal Information collected during your use of Kashmir-N may be used to suggest particular content that can be made available to you on, or be used to present more relevant advertising to you in, another Tencent service. You may also ask us to migrate or export your Personal Information contained in Kashmir-N to another Tencent service, where such migration option is available.
Personal Information within Your Content
We may use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties.
Such products and services (of ours or third parties) include the following:
- our products and services and the products and services of our affiliate and subsidiary companies and joint venture partners, including messaging services, online media services, interactive entertainment services, social networking services, payment services, internet search services, location and mapping services, application software and services, data management software and services, on-line advertising services and other social media, entertainment, e-commerce, information and communications software and services (“Internet Services”); and
- third party providers of Internet Services and products and services relating to dining, food and beverages, sports, music, film, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewellery, cosmetics, personal health and hygiene, electronics, collectibles, housewares, appliances, home decoration and furnishings, pets, automobiles, hotels, transport and travel, banking, insurance and financial services, loyalty and reward programs and other products and services that we think may be relevant to you.
We will honour your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact our Privacy Officer at any time and free of charge.
In addition, you may be able to opt-out of certain direct marketing by following the relevant instructions set out on our marketing communications.
We will not share your Personal Information with advertisers unless we have your permission to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.
When you opt out of direct marketing pursuant to the above, you may continue to see online advertising (that is not direct marketing) within Kashmir-N and/or our advertisements on other websites or applications.
SHARING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES
Sharing for the provision of Kashmir-N
We may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes:
- providing Kashmir-N to you;
- assisting us in carrying out the purposes set out under the “How We Use Your Information” section above;
- helping us understand and improve Kashmir-N .
Sharing for marketing purposes
We may allow third party marketing partners (such as Kashmir-N Official Accounts partners, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use Kashmir-N . If you wish to opt-out of such collection of your Personal Information by our third party marketing partners while you are using Kashmir-N, please contact us at [email protected].
We may also provide your Personal Information to third party marketing partners where you have asked us or consented to us doing so or where it is required in order for us to provide Kashmir-N to you.
Other terms relating to the sharing of your Personal Information Where we or our affiliate companies share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information:
- subject to any other instructions and restrictions as required by us, including any appropriate confidentiality and security measures that we implement.
We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the “Period of use of your Personal Information” section below.
A WORD ABOUT SHARED INFORMATION
Kashmir-N enables Shared Information to be shared publicly with your Kashmir-N contacts, all users of Kashmir-N and/or the public, via features provided by either us or third parties, so that Shared Information can be broadly and instantly transmitted. Shared Information will remain public for as long as you do not delete it; and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.
In addition, we may also provide other Kashmir-N-related features that allow you to share Shared Information in public – for example, publicly accessible blogs and forums, or certain social media features within Kashmir-N – for example, “plug-ins” (which create a direct link between two websites) and “widgets” (which are interactive mini-programs that provide third party services within Kashmir-N). You should be aware that any information you provide within such features may be read, collected and used by third parties who access them.
Please consider carefully what you post and communicate through Kashmir-N. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in Kashmir-N.
COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use Kashmir-N, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Kashmir-N for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
A WORD ABOUT SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to Kashmir-N , such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.
Before communicating any Personal Information of a sensitive nature within Kashmir-N, please consider whether it is appropriate to do so.
Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.
THIRD PARTY SERVICES AND YOUR INFORMATION
Kashmir-N may link you to social media or other features or services (including websites, plug-ins and widgets) provided by, or allow you to share certain Information with, a third party. For example:
- you may share content on, or login to, Kashmir-N using services provided by third parties. These third party services will authenticate your identity and provide you with the option to share certain Personal Information with us. They may also give you the option to post information from your third party service account to Kashmir-N as Shared Information (or vice versa), and to share other information with such third parties.
- you may link your Kashmir-N contact list to your contact lists on your device and/or in your account on third party services, in order to search for and connect with contacts on those contact lists who also have a Kashmir-N account. In consenting to such linking, we will use your username and password for the relevant third party service only for the purpose of such contact list linking (and will delete such information immediately after such purpose is completed);
- you may login to Kashmir-N using other sign-in services such as an Open ID provider. These sign-in services will authenticate your identity and provide you the option to share certain Personal Information with us for account registration and login purposes, such as your name and email address; and
- we may (whether in advertisements or otherwise within Kashmir-N) provide you with links or features that allow you to access third party services or websites (or access within Kashmir-N content that is hosted on those third party services or websites). For example, you may be able to access videos hosted by a third party within Kashmir-N.
These third party social media or other services may be hosted by the relevant third party or us. Please note that third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer or device to enable such features to function properly.
Children under the age of 13 are not allowed to use Kashmir-N. We do not knowingly collect Personal Information from any children under the age of 8. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 – we will promptly investigate (and remove) such Personal Information.
TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. Any of the third parties referenced in the “Sharing of your Personal Information” section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances, your Personal Information may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction.
We will ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer.
We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us.
Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of Kashmir-N or any information you provide to us through Kashmir-N.
We may communicate with you electronically regarding security, privacy, and administrative issues relating to Kashmir-N. If we learn of a Kashmir-N security breach, we may attempt to notify you electronically by posting a notice within Kashmir-N or by sending direct communication to you.
If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.
PERIOD OF USE OF YOUR PERSONAL INFORMATION
We will only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the “How We Use Your Information” section above.
ACCESSING, UPDATING, AMENDING OR PORTING YOUR PERSONAL INFORMATION
Subject to applicable laws and regulations, you may have the right to:
- obtain confirmation that we hold Personal Information about you;
- access, rectify or delete your Personal Information that we maintain;
- request and receive a copy of the Personal Information you have provided us and to transmit this information to another provider.
- object to or request the restriction of processing of your Personal Information; and
- have the information deactivated, blocked, anonymised or deleted, as appropriate.
To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us, including consent for email and targeted marketing communication and data transfers. We will use reasonable efforts to apply your preferences going forward.
If you would like to update or amend your Personal Information within Kashmir-N, you may do so in the first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within Kashmir-N.
If you wish to:
- make further changes to your Personal Information;
- exercise any of your rights mentioned above in this section; or
- to request the removal of an unauthorised Kashmir-N account,
please contact our Privacy Officer. We will use reasonable efforts to respond to all such requests made to our Privacy Officer without undue delay and in accordance with any time limits required by law. Please note that your right to access Personal Information in the above manner may be limited in some circumstances by local law requirements.
In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may be extremely impractical or require disproportionate technical effort (e.g. any requests that relate to our backup systems), or are prohibited by law.
Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through Kashmir-N, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using Kashmir-N may put your Personal Information in the hands of third parties that we cannot control.
International Data Transfers
We are a global business. We may transfer Personal Information to countries other than the country in which the data was originally collected. For example:
- we operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction; and
- any of the third parties referenced in the “Sharing of your Personal Information” section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances,
In particular, we may need to transfer your Personal Information to countries that are not considered to provide an adequate level of protection under EU data protection laws. However, we ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer.
Why do we use tracking technologies?
To help us better understand and provide Kashmir-N to you and our users
Tracking technologies enable us to better understand and provide Kashmir-N to you – for example, tracking technologies help us collect the following Information:
- we require your authentication information in order to provide Kashmir-N to you;
- our mapping and location-based services (such as “Shake” and “People Nearby”) may require Information about your location;
- our translation services may require Information about your language preferences; and
- we require certain other Information about our users in order to provide Kashmir-N and to develop new features for Kashmir-N.
To help us deliver relevant and safe advertising to you
Advertising helps keep Kashmir-N and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:
- more effective for advertisers – for example, by delivering them further information regarding who has viewed their advertisements;
- more safe for you – for example, by ensuring that you do not receive repeated or fraudulent advertisements or prohibited content within such advertisements; and
- more relevant to you – for example, by delivering advertisements based on which official Kashmir-N channels you may have followed or based on your location.
What are tracking technologies?
The “tracking technologies” that we use within Kashmir-N include the following:
- A cookie is a small file containing a string of characters that is placed on your computer, mobile phone or other device when you access a website or other web content.
- Web beacons are electronic image files or other technologies that may be embedded within websites or emails that may be used to keep count of visitors, record when and if an email or website is viewed, or access certain cookies.
- Certain information is automatically gathered and stored in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
- An entity tag (or ETag) are HTTP headers that are sent-behind-the-scenes between a web browser and a web server. They can be used to track unique users in place of cookies, and allow us to better understand and improve Kashmir-N.
- Anonymous identifiers are used to deliver advertisements in services where cookies may not be available (for example, in mobile applications).
How do we use tracking technologies?
Tracking technologies used in partnership with third parties
We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:
- Our analytics partners helps us better understand Kashmir-N generally – for example, to collect website and app usage statistics and to gather demographic information about our user base as a whole, as well as to analyse any relevant trends.
- Our marketing partners (including analytics partners, advertisers and Kashmir-N official account partners) help us deliver better and more relevant advertising to you.
- Our customer support service partners help us deliver better responses to any queries from you and to deliver a better Kashmir-N experience to our users.
- Our service partners help us administer and deliver certain features within Kashmir-N – for instance, hosting, language translation and mapping services.
We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis.
We may use Google Analytics to collect and process certain Kashmir-N-related usage data. Google provides additional privacy options regarding cookie use described at http://www.google.com/policies/privacy/partners/.
Our own tracking technologies
In addition, we also use our own tracking technologies to personalise your experience on Kashmir-N and for various other purposes. For example, we use such tracking technologies to:
- remember you within Kashmir-N. For example, cookies and web beacons can help us identify you as a registered user of our services or keep the preferences or information that you have previously provided; and
- analyse how you use Kashmir-N. We can use tracking technologies to understand what users are doing on our services, or which pages or sections are most popular.
Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyse how you and others use our services and to serve advertising.
General terms in relation to tracking technologies
While we may have agreements in place with these third parties in relation to the proper handling and protection of your Personal Information, we cannot guarantee their privacy practices as they are third parties.
If you wish to opt out of interest-based advertising, click here: http://preferences-mgr.truste.com/. Please note you will continue to receive generic ads.
If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out by contacting [email protected]. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for Kashmir-N via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered Kashmir-N. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.
How you can control tracking technologies
You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal Kashmir-N experience and some or all of Kashmir-N features may not function properly.
You may also control what tracking technologies-collected Information we receive by certain settings within Kashmir-N – for instance, by using the “Clear Location” option within Kashmir-N.
Specific types of cookies
We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.
|Category of cookies use||Description|
|Authentication||These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region.|
|Security||We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.|
|Functionality||We use such cookies to perform and improve the functions of our services. In particular, we use these cookies to help us collect information about how our users are interacting with Kashmir-N – for example, your most recent searches and the profiles that you most frequently visit on Kashmir-N.|
|Analysis and Research||We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions. For example, these cookies helps us better understand the demographics of the Kashmir-N user base, which in turn helps us consider what new Kashmir-N features may be the most relevant for our users.|
We use mobile analytics software to allow us to better understand the functionality of Kashmir-N as used on your phone. As part of such process, we may (via Kashmir-N) record information such as how often you use Kashmir-N, the events that occur within Kashmir-N, aggregated usage, performance data, and where and when Kashmir-N was downloaded from on your device. We do not link such mobile analytics information that we collect with any personally identifiable information you submit within Kashmir-N.
Last modified: 2018-07-08