Privacy Policy

Foxy ('we' or 'us') acknowledges its responsibility to safeguard your personal data and is dedicated to maintaining the confidentiality, integrity, and security of such information in strict adherence to applicable laws, regulations, and industry standards. This comprehensive Privacy Policy outlines our data handling practices, and we urge you to carefully review its terms prior to accessing or utilizing our Platform and related services ('Services'). By doing so, you will be fully informed and empowered to make deliberate choices regarding your personal information.

Overview of Our Privacy Commitment:

• Voluntary Information Collection: We do not indiscriminately collect personal information based on your acceptance of this Privacy Policy. Information is gathered only when necessary to provide specific functions or services, and you can decline to provide additional data without affecting other services, except where required for basic operations or by law.

• Essential Information Use: This policy details the necessary information we collect and its use, emphasizing our respect for your privacy choices.

COLLECTION OF INFORMATION

We collect two types of information: information you provide voluntarily and information collected automatically.

INFORMATION YOU PROVIDE

When you interact with our Platform, you may provide personal details such as email addresses, names, and other similar data. This information is collected when you register, seek information about our products and services, participate in online forums or contests, or contact us. Additionally, you may choose to register using social media accounts, which allows us to collect relevant login details.

AUTOMATICALLY COLLECTED INFORMATION

When you use our Platform, we automatically collect certain information, including:

• Device and usage data, such as IP addresses, browser and device specifications, operating system, language preferences, and other technical information, which is collected for security, operational maintenance, and analytics purposes.

• Log and usage data, including service-related information such as diagnostic and performance data collected by our servers, including device information, browser type, and activities within our Services.

• Device data, including information about the device you use, such as IP address, device IDs, browser type, and system configuration.

• Location data, including both precise and general location data, which may be collected based on the device and settings used.

YOUR PRIVACY CHOICES AND OBLIGATIONS

• You are responsible for ensuring that all personal information you provide is accurate, complete, and up-to-date.

• You have the right to opt out of certain data collections, such as location services, although this may impact your ability to use specific aspects of our Services.

• You are encouraged to review and adjust your privacy settings and permissions regularly to ensure they align with your preferences.

USE OF COLLECTED INFORMATION

We use the collected information to:

• Enhance security, functionality, and internal analytics.

• Assess performance and improve our Services through the use of cookies and similar technologies.

INFORMATION COLLECTED THROUGH OUR APP

• Mobile device access: We may request permissions to access specific features on your mobile device, including social media accounts. You can modify our access permissions at any time through your device's settings.

• Mobile device data: Our app automatically collects information about your device, including device ID, model, manufacturer, operating system, version, system configuration, application identification numbers, browser type, hardware model, Internet service provider or mobile carrier, and IP address.

• Push notifications: With your consent, we may send push notifications about your account or specific app features. You can disable these notifications in your device's settings at any time.

PURPOSE OF COLLECTING YOUR INFORMATION

We collect your information to ensure the security and efficient operation of our app, troubleshoot issues, enhance our internal analytics, and improve our reporting processes.

COMMITMENT TO PRIVACY

Your privacy is of utmost importance to us. We are committed to maintaining the highest standards of data protection and providing clear options to manage your preferences and control over access permissions. By using our Platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. Any changes will be effective upon posting of the revised Privacy Policy. Your continued use of our Platform after the posting of changes constitutes your acceptance of the revised Privacy Policy.

Data Usage and Protection Policy

We are committed to transparency and respecting your privacy. This policy explains how we collect, use, and share your personal information, ensuring that our practices align with applicable laws and regulations.

Lawful Bases for Data Processing

We process your personal information based on the following lawful grounds:

Contractual Necessity: We use your data to fulfill our contractual obligations, including account creation, login, and management.

Legitimate Business Interests: We process data for legitimate business purposes, such as improving our services, preventing fraud, and ensuring compliance with our terms and policies.

Consent: We obtain your explicit consent for specific purposes, such as featuring testimonials or sending feedback requests.

Legal Compliance: We disclose your information as required by law, court orders, or legal proceedings, including for national security or law enforcement purposes.

Vital Interests: We share your information to address policy violations, fraud, safety threats, or illegal activities, or as part of legal actions.

Data Usage

We use your personal information for the following purposes:

Account Management: To manage and maintain your account's functionality.

User Communications: To enable communication between users and enhance the user experience.

Feedback and Testimonials: To solicit feedback and feature testimonials on our services.

Service Protection: To safeguard our services, including fraud monitoring and prevention.

Administrative Notices: To send information about products, services, features, terms, conditions, and policy updates.

Order Management: To manage your transactions, including orders, payments, returns, and exchanges.

Prize Draws and Competitions: To administer our contests and competitions.

Service Delivery: To deliver and improve the services you've requested.

User Support: To address inquiries and resolve issues with our services.

Information Sharing

We share your personal information only under the following circumstances:

Consent: With your explicit consent for designated purposes.

Legal Compliance: As required by law, court orders, or legal proceedings.

Service Provision: With third-party service providers who perform services on our behalf, subject to contractual agreements ensuring data protection.

Business Transfers: In the event of a merger, asset sale, financing, or acquisition.

Vital Interests: To address policy violations, fraud, safety threats, or illegal activities, or as part of legal actions.

Third-Party Service Providers

We share your information with vendors, consultants, and service agents who perform services on our behalf, subject to contractual agreements ensuring data protection. These parties may access your information for tasks like payment processing, data analysis, and customer support.

Publicly Shared Information

Information you share in public service areas or through social network interactions can be seen by all users and may be externally accessible indefinitely. Your social network contacts may see your activity, profile photo, and interaction descriptions within our Services.

By using our services, you acknowledge that you have read, understood, and consent to this Data Usage and Protection Policy. We are committed to protecting your privacy and complying with applicable laws and regulations.

Here is a paraphrased and legally strengthened version of the information sharing disclosure:

Information Sharing and Disclosure Policy

We are committed to transparency and protecting your personal information. This policy outlines how we share your information with specific third-party services, solely based on your consent. We categorize these entities to provide a clear understanding of our data collection and processing practices.

Withdrawal of Consent

If you withdraw your consent, we will cease sharing your information with third-party services. However, please note that this may affect the functionality and performance of our platform.

Third-Party Services

We share your information with the following categories of third-party services:

Third-Party Account Connectivity: Google Account Integration for simplified login and registration processes.

Cloud Computing Services: Google Cloud Platform for scalable and secure cloud computing services.

Functionality and Infrastructure Optimization: Cloud Functions for Firebase, Firebase Realtime Database, and Firebase Hosting for creating scalable solutions, real-time data syncing, and secure hosting.

User Account Registration and Authentication: Google Sign-In for secure and convenient user authentication.

Consent and Revocation

You have the right to withdraw your consent at any time. We will respect your decision and cease sharing your information with third-party services.

Cookies and Tracking Technologies

We use cookies and tracking technologies to collect and retain your data. These technologies enhance your user experience, allow us to understand user preferences, improve site functionality, and tailor content and advertising to your interests.

Social Logins and Personal Information Security

When you use social media accounts to register or log in to our services, we access specific information about you provided by the social media platform. We use this information strictly within the scope described in our privacy notice or as explicitly communicated on our services. We do not control how your social media provider uses your personal information, and we recommend reviewing their privacy policies to understand their data practices.

Data Retention

We retain your personal information only as long as necessary for the purposes outlined in our privacy notice or as mandated by law. We commit to deleting or anonymizing your data when it is no longer necessary.

Information Security

We take robust organizational and technical measures to safeguard your personal information. While we strive to protect your data, we cannot guarantee absolute security against unauthorized breaches.

Scope and Third-Party Services

This Privacy Policy governs the personal information collected through our services, including our client platforms and websites. It does not extend to third-party products or services that are governed by their own privacy policies.

Exclusions

This policy does not apply to:

Third-party products or services linked through our services or advertisements displayed within our software.

Third parties that market their services within our software.

Interactions with Third-Party Services

Your interactions with these third-party services, including any personal information you provide, are subject to their respective terms and privacy policies, not ours. We urge you to carefully review third-party terms and protect your personal information diligently.

Changes to this Policy

We reserve the right to amend this policy at any time. We will notify you of any changes and seek your consent anew if the purposes for which we collect or use personal information change significantly.

Exemptions to Consent

In certain situations, as defined by law, we may collect and use your personal information without your consent, such as cases involving national security, public interests, or legal proceedings.

Cookies and Similar Technologies

We use cookies and similar technologies to enhance user experience and service efficiency. When you interact with our software and services, we may deploy cookies or anonymous identifiers to your device for various purposes, including authentication, security, and service optimization. These technologies help us ensure the safety and efficient operation of our products, improving service responsiveness and user login experiences.

Personal Information Storage and Protection

Data Storage Location: We store personal information in legally compliant facilities within China, in accordance with applicable laws and regulations.

Data Retention Period: We retain personal information only for the duration necessary to provide our software and services. Upon expiration of this period, we will either delete or anonymize the information, unless retention is mandated by law.

Sharing, Transfer, and Public Disclosure of Personal Information

Sharing Conditions:

• We will share personal information with third parties only with your explicit consent.

• We may share information with judicial or administrative bodies as required by law.

• We may share information with our affiliates, strictly for the purposes outlined in this Policy, and with your consent.

• We may share information with authorized partners to enhance customer service and user experience, but only to the extent necessary and with strict confidentiality agreements in place.

Transfer Conditions:

• We will transfer personal information to other entities only with your explicit consent.

Public Disclosure Conditions:

• We will publicly disclose personal information only with your explicit consent.

• We may disclose information as required by law, regulations, or judicial orders, but only after verifying the legitimacy of such requests.

Exceptions to Consent Requirements:

• We may share, transfer, or publicly disclose personal information without consent in certain circumstances, including:

￮ National security and defense

￮ Public safety and health

￮ Legal proceedings

￮ Protection of legal rights

￮ Self-disclosed information

￮ Legally public information

Security Measures:

• We are committed to implementing reasonable security measures to protect personal information against unauthorized use, access, disclosure, alteration, damage, or misuse.

• Our security measures include:

￮ Industry-standard encryption and anonymization technologies

￮ Specialized security infrastructure and data security protocols

￮ Restricted access to personal information

￮ Regular security audits and emergency response plans

• We acknowledge the limitations of internet security and strive to maintain high standards of data protection.

Proactive Security Practices:

• We have established protocols to swiftly address information security incidents and mitigate their impact.

• We will notify you promptly in the event of a security breach, including the nature of the incident, potential impact, and our remedial actions.

• Our incident response actions will comply with legal and regulatory requirements, ensuring transparency and accountability.

Important Reminders:

• This Privacy Policy applies exclusively to our software and related services. We cannot guarantee the safety of personal information outside our domain.

• While we take extensive measures to protect your data, we also encourage you to practice safe internet usage and be vigilant about your personal information's security across different platforms and services.

Your Rights Regarding Personal Information

Managing Your Information:

We prioritize your ability to manage your personal information, ensuring you have rights to access, modify, delete, and withdraw consent regarding your data. This empowerment helps safeguard your privacy and security.

• Withdrawal of Consent: You have the flexibility to retract your consent or authorization for us to collect personal information at any time, either by disabling certain functions or adjusting the application's permissions in your device settings. It's important to note that withdrawing your consent may impact our ability to deliver specific services or functionalities. However, this withdrawal does not affect any data processing carried out prior to your decision.

• Accessing Privacy Policy: The complete Privacy Policy is accessible within the app under Settings/My - Privacy Policy, allowing you to stay informed about our data protection practices.

• Service Cessation: In the event we cease operations, we will halt the collection of your personal information, notify you promptly, and take steps to delete or anonymize any held personal information.

• Account De-registration: You can cancel your registered account through the FoxyAPP under My -> Account Security -> Deregister. Upon de-registration, we will cease providing services and delete your personal information, barring any legal requirements to retain data.

Minors Clause

For users under 18, this Privacy Policy should be reviewed and consented to under parental or guardian supervision. We commit to protecting minors' personal information in compliance with laws, ensuring any collection, usage, or disclosure is legally permitted, guardian approved, or necessary for minors' protection. Should unauthorized collection of minors' data occur, we will endeavor to promptly delete such information.

Amendments to Privacy Policy

Policy Updates:

• We periodically update this Privacy Policy to reflect changes in our services or data practices. Any amendments will be integrated into this policy, holding the same legal validity.

• Updated policies will be communicated within the app and before the enactment of new terms, ensuring you are informed of any changes. Continued use of our services post-update implies acceptance of the revised policy terms.

• For substantial updates, particularly those involving sensitive personal information, we will seek your explicit consent in a clear and prominent manner.

Significant Changes:

• Changes in service models, such as the purposes and types of data processing.

• Shifts in ownership or organizational structure, for example, due to mergers, acquisitions, or business adjustments.

• Modifications in the primary recipients of shared, transferred, or publicly disclosed personal information.

• Significant alterations in your rights concerning data processing and how those rights are exercised.

• Updates to the contact details or complaint channels of the department responsible for personal information security.

Scope of Application

This Privacy Policy governs all services provided by Foxy and its affiliates, encompassing various platforms such as client applications and websites. It's important to note that this policy does not extend to third-party products or services that maintain their own privacy policies separate from this document.

Exclusions from this Policy:

Third-party Products and Services: This includes any third-party products, websites, and advertising content that might be displayed or linked within our services. It also encompasses other products or websites linked to our software services.

Third-party Advertisers: Those who advertise within our software services are also not covered by this policy.

It is crucial for users to review the privacy policies and terms of service of any third-party services before sharing personal information. This policy also advises caution and prudence in sharing personal information with third parties, recommending such actions only when necessary.

The services and software mentioned in this Privacy Policy may differ based on various factors such as mobile phone model, system version, and software application version, with the final products and services being determined by the specific software and services utilized by the user.

Additional Provisions:

• Headings: The headings included in this Privacy Policy are designed for convenience and ease of reading, and do not impact the interpretation of the policy's provisions.

• Definitions:

￮ Affiliate: Refers to any entity that is controlled by, controls, or is under common control with Foxy, where "control" is defined as the ability to direct the management and policies of an entity.

￮ De-identification: The process by which personal information is technically processed to obscure the identity of the data subject, making identification impossible without additional information.

￮ Anonymization: A process whereby personal information is technically processed such that the data subject cannot be identified, and the information cannot be restored.

The copyright to this Privacy Policy is held by Foxy. The company reserves the right, to the extent permitted by law, to interpret and amend the policy as necessary to reflect changes in services or legal requirements.