WHATS SENSE APP PRIVACY NOTICE

Whats Sense App Privacy Notice

This App is developed by VTrump Tech (VTrump) and we know privacy and security is important to you.

The privacy of your personal data is also important to us. We will provide you with an experience on our app that is safe and secure.

This Privacy Notice describes (x) the types of information we may collect or that you may provide when you download, install, register with, access or use the Whats Sense app (the “App”), and (y) our practices for collecting, using, maintaining, protecting and disclosing that information. This policy applies only to information we collect in the App and in e-mail, text and other electronic communications sent through or in connection with this App.

1.This App is for People Over the Age of 18

YOU MUST BE AT LEAST 18 YEARS OF AGE TO USE THIS APP. We do not knowingly collect personal data from persons under 18. Accordingly, all users will be required to acknowledge in the App that they are 18 or older prior to initial use. Additionally, if we learn we have collected or received personal data from a person under 18, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us (For more information about us, please see Section 15).

2.This Privacy Notice DOES NOT Apply to the Following Information

This Privacy Notice does not apply to information that we collect offline or on any other of our apps or websites, including websites you may access through the App.

Our websites, our other apps and third parties may have different privacy policies, which we encourage you to read before providing information on or through them. Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, please do not download, register with or use the App.

3.The Whats Sense Device Can be Used without this App

We allowed all the device which applied the Whats Sense protocol to connect to the App. You can use all the compatible device manually or by apps without your personal account.

If you only use the Whats Sense device manually, we do not ask you to provide your email address or other personally identifying information as part of the App installation process or otherwise. However, to use the App with our cloud service to record your personal information, you must create a personal account.

4.Who We are and What We Need

Our Privacy Notice governs the use and storage of your personal data which relates to a living individual who can be identified from that data. “Personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Identification can be by the information alone or in conjunction with any other information in our possession or likely to come into such possession. Our processing of personal data of individuals in the European Union is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).

We collect the following types of personal data from you, which is stored anonymously in the cloud:

• Anonymous ID, avatar
• Remote chatting content, including Text, Pictures and Audio;

The following data will be collected by application, but stored locally in your smart phone.

• Device information, device identifier, device type.
• Total connection time and Times of Heart Heart click times.

When using "Whats Sense", you will need the following permissions,

• Location permission, Starting from Android 6.0 and later,  Bluetooth require you must turn on the location permission.  so when you use the "Whats sense" application to request a device connection, we will ask you to give us the Android application location permission. These location permissions are used only for Bluetooth connection and we do not collect your personal location information.
• Network permissions, Network permission is used save your anonymous ID, avatar, device information, synchronize your chat content, etc.
• Recording permissions, for your voice while chatting.
• SD card permissions, used to access your SD card when you set your avatar.
• Vibration permission, used to provide vibration alerts when you receive a message.

Please note that you can cancel all of the information we collect on our servers on the Whats Sense Privacy Settings page. For third-party services we use, if it is anonymous, this information will continue to be retained, but will not continue to be collected in the future.

In addition, we collect the following types of personal data that may constitute special category personal data (i.e., sensitive personal data about an individual that reveals his or her racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data for the purpose of uniquely identifying such individual, data concerning health or his or her sex life or sexual orientation):

5.Purpose and Legal Basis for Processing Your Personal Data

We comply with our obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We need your personal data for the following purposes:

• Analyze and develop statistical information related to the use of our application, products and services to improve.
• Communicate with you about your equipment, services (such as customer consultation, technical support).
• For research and innovation.
• Detect and prevent fraud, abuse or illegal activities.
• Connect your activities on various services and all devices and you may be able to use each of our services.
• Optimize your experience and ensure that you can use information synchronously on different smart phone.
• Analyze the usage of each functional module and continuously optimize the user’s favorite functionalities.
• Improve user data security.

When you register to use the App, we will require you to provide your email address or phone number, a photograph and a nick name, which will be stored on our servers, and we will provide you with a unique anonymous identifier at the same time.

In addition, if you want to use the App with our cloud service to record your training data, we will need to collect such data. Such data may constitute special category data as described in Section 4. We collect such data for the purpose of providing you with personalized service and improve our services. We will request your explicit consent prior to collecting and processing any such data. If you do not grant such consent, you will not be able to use cloud service to record your training data, but you can still use the Whats Sense  Device manually, by apps locally or by apps without your personal account.

We may also require your consent prior to processing your personal data referred to in Section 4 other than the special category data described above (please refer to our “Consent Form” at [link]). In addition, we may also process your personal data for:

• compliance with a legal obligation to which we are subject;
• protecting your vital interests or that of another natural person;
• the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
• the purpose of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data.

If you request that we stop processing some or all of your personal data or if you withdraw your explicit consent for our use or disclosure of your personal data for purposes set out in this Privacy Notice, we may not be able to provide you all of the services and customer support offered to our users and authorized under this Privacy Notice.

Upon your request, we will close your account and remove your personal data from view as soon as reasonably possible, based on your account activity and in accordance with applicable laws.

6.Where We Do with It

Your personal data will be processed in 1888 Yishan Road, Room 508, Shanghai located in China. Hosting and storage of your data takes place at the facilities of Alibaba Cloud, which is located in China.

7.Safeguarding and Retention of Personal Data

We have implemented administrative, technical and physical measures designed to safeguard your personal data in our custody and control against theft, loss and unauthorized access, use, modification and disclosure.

We restrict access to personal data on a need-to-know basis to employees and authorized third party service providers who require access to fulfill their job requirements.

We keep your personal data for no longer than reasonably necessary in order to provide you with a personalized experience and improve our services.

After the relevant retention period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information.

8.Sharing Your Personal Data

Your personal data will be strictly confidential. We will only share your data with third parties outside of us after you grant explicit consent.

We may disclose your non-personal information to other members of the Whats Sense corporate family or to third parties. This disclosure will improve the user experience of our products and build some statistic data.

9.Non-personal Identified Information We Collected

We use third party service providers to collect certain analytical information to help us improve our products and the quality of the App. These third parties have stated to us that they will collect such data in an aggregate, anonymous form that does not personally identify any individual user. Such anonymous analytical data include the App features used and time spent on the App. As part of our commitment to your privacy, we will add an option to enable you to turn on/off the anonymous collection in the recent release.

10.What are Your Rights

Unless there is an exception under the GDPR, you have the following rights with respect to your personal data:

• to request a copy of your personal data that we hold about you;
• to request that we correct any personal data if it is found to be inaccurate or out of date;
• to request your personal data be erased where it is no longer necessary for we to retain such data;
• to withdraw your consent to the processing at any time in case where consent is relied upon as the condition for processing;
• to request that we provide you with your personal data and where possible, to transmit such data directly to another data controller (where applicable), in cases where we process your data by automated means and the processing is either (x) based on your consent or (y) necessary for the performance of a contract with you;
• where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• to object to the processing of personal data (where applicable), in case where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority vested in us), and in case where the personal data are processed for direct marketing, scientific/historical research and statistics purposes;
• to lodge a complaint with the relevant supervising authority.

11.Transfer of Your Personal Data Abroad

Your personal data will be transferred to mainland China where we are situated. Such transfer of your personal data will be protected by our undertaking made in accordance with the Standard Contractual Clauses adopted by the European Commission as appropriate safeguards. You can get a copy of our undertaking from [link] .

12.Further Processing

If we wish to use your personal data for a new purpose not covered by this Privacy Notice, we will provide you with a new notice explaining this new purpose prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

13.Changes to the Privacy Notice

We may update this Privacy Notice to reflect changes to our privacy and data practices. We encourage you to periodically review this notice. We may notify you the changes to this Privacy Notice by email (if possible) or by posting a notice at http://blog.whatssense.com/privacy/whatssense_policy_en.html

14.Third Party Privacy Notice

Please note that this Privacy Notice does not apply to products and services provided by third parties. Our products and services may include third parties’ services and links to third parties’ websites. When you use such services, they may collect your information too. Therefore, we strongly recommend you read such third parties’ privacy notices as you have taken time to read our Privacy Notice. We are not responsible for and cannot control how third parties use personal information that they collect from you. Our Privacy Notice does not apply to other websites linked from our services.

Here are the third party privacy notices that apply when you use these specific products or services, please carefully read before you use the services:

• By using Flurry’s Analytics Service, you are agreeing to:

https://privacy.oath.com;

and

https://developer.yahoo.com/flurry/legal-privacy/terms-service/flurry-analytics-terms-service.html

· By using RongCloud or any RongCloud related services, you are agreeing to:

http://www.rongcloud.cn/tos

15.Contact Details

In the event that you wish to complain about how we have handled your personal data, please contact us at dataservice@vtrump.com or in writing at 1888 Yishang Road, Room 508, Shanghai, China. We will look into your complaint and work with you to resolve the matter.

If you still feel that your personal data have not been handled appropriately according to applicable laws, you can contact relevant supervising authorities and file a complaint with them.