Privacy Policy

Last updated: May 29, 2024

Contents

1.        Overview        

2.        Definitions        

3.        What personal data do we collect and process and when/how?        

4.        On which legal basis and for which purposes do we process your personal data?        

5.        Personal Data Retention Policy        

6.        Delete your personal data or your account        

7.        To whom do we communicate or give access to your personal data?        

8.        Do we transfer your personal data to third countries?        

9.        How do we keep data security?         

10.        Do we receive any information on you from third-parties?        

11.        What are your rights and how can you exercise them?

12.        Do we collect personal data from minors?        

13.        Solely Automated Decision        

14.        Updates to this Privacy Policy        

15.        Questions and complaints – Contact information        

1. Overview

This Privacy Policy (“Privacy Policy”) gives you an overview of the personal data that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Privacy Policy also outlines your data subject rights, including the right to object to some uses of your personal data by us.

2. Definitions

“ShortsGO”, “we”, “our” or “us” refers to HAINAN WUERSUOPU E-COMMERCE CO., LTD., a service provider offering the website, apps and any other platforms, applications or technologies controlled and operated by ShortsGO through which its content, publishing and distribution services are provided to our users .

Depending on the context, “you” means our registered users and visitors(without logging into ShortsGO).

“Personal data”means any information relating to an identified or identifiable natural person and therefore concerns all information about a (directly identified) person or on the basis of which the identity of the person can be derived.

“Services” refers to the platform located at the website www.shortsgo.com , including all sub-domains and associated websites (collectively, the “Website”), the ShortsGO mobile application(s), including iPhone and Android mobile applications (the “Apps”), any and all other platforms on which content is accessed, published, or distributed, and all associated services, features, or content made available through any of the foregoing. The term "Services" is used collectively to describe the Website, Apps and any other platforms, applications or technologies controlled and operated by ShortsGO through which its content, publishing and distribution services are provided to Users..

3. What personal data do we collect and process and when/how?

The type of personal data that we collect and process is dependent on how you use ShortsGO. Even if you don't have an account, if you use ShortsGO, we'll be able to collect some data about you.

We collect and process the following personal data from you when you use our Services:

• Device-related information: device type, software list, Unique Device Identifier (such as IMEI/androidID/DEVICE ID), device memory, storage information, hardware and software information, the type and version of your operating system (“OS”), platform, screen resolution, colour depth, IP address, browser settings, plugins, language setting, font setting, time zone setting, location information, adjust id, Google id, ad block, browser type and similar information about your device settings;
• Contact information: email address, mobile phone number, and any other contact information you may provide; 
• Identification information: your first and last name, your date of birth, your age, your gender, a copy of your ID card or other identification documents, location details (including travel information, precise location data, and latitude and longitude);
• Financial information: your payment history, bank card information, your account number, the name of the account holder used for the payment solutions, personal financial details (including transaction history, balances, virtual gifts, membership rewards, coupons etc.);
• Information about your use of our Services: service details which you have used and how you have used them, and your personal preferences.

The personal data described above are either directly collected or indirectly in the following manner:

• device-related information is collected from your device when you use our Services;
• contact information is directly collected from you when you intend to use our Services;
• identification information is directly collected from you when you use our Services
• financial information is collected from third parties when you apply for payment solutions;
• Information about your use of our Services is collected from you when you use our Services.

4. On which legal basis and for which purposes do we process your personal data?

       4.1 On which legal basis do we process your personal data?

We process your personal data only in accordance with the applicable data protection laws. We only process your personal data for the purposes specified in this Privacy Policy.

Under this section, we tell on what legal grounds we process your personal data. Depending on this legal basis, your rights with regard to our processing activities may differ.

We will process your personal data on the basis of one of the following legal grounds:

• the processing is necessary for entering into a contract or performing a contract;
• the processing is necessary for the purposes of the legitimate interests pursued by the controller (us) or by a third party and does not unduly affect your interests or fundamental rights and freedoms. Please note that, when processing your personal data on this basis, we always seek to maintain a balance between our legitimate interest and your privacy. This data will remain strictly confidential. You can contact us for more information on how we strike a balance (see section 15 for our contact details);
• the processing is necessary for compliance with a legal obligation to which ShortsGO is subject, for example in limited cases to respond to requests from competent authorities in this context;
• you gave your explicit consent for the processing for one or more specific purposes, it being understood that ShortsGO will at all times ensure that your consent is compliant with the applicable laws and regulations.

          4.2 For which purposes do we process your personal data?

We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose.

Accordingly, we process your personal data for one of the following purposes:

• fulfilment of Services : we use your personal data (i) to manage our customer relationship with you for each service you use; (ii) to respond to queries, requests and complaints; (iii) Verifying accounts and transactions; (iv) Investigating suspicious activity; (v) Anti-piracy measures; (vi) Monitoring and prevention of spam and other security issues or poor user experiences.
• (direct) marketing: we use your personal data to send or contact you to provide you with the e-mail address you have provided for direct e-mail marketing with commercial information about our Services. We will only inform you about Services that are similar to those services you have used in the past and in case you have not objected to the use of your personal data for marketing purposes;
• improvement of our Services: we use, to the extent necessary, any category of personal data to evaluate, improve and ensure our Service(s) are working as intended. This includes but is not limited to (i) communicating with you (customer support, reviews of our products and services, information on new products and features, surveys etc.), (ii) monitoring the usage of the Website after a publicity or marketing campaign, (iii) analysing the use and performance of our products, services and websites, (iv) tuning, enhancing, improving and facilitating the functionality of the Website and App;
• compliance with applicable rules: we use, to the extent necessary, any category of personal data to comply with applicable legal requirements and industry standards and policies.

            4.3 Overview of our processing activities for you

Purposes (namely, what we are doing, why and when)	Categories of personal data may be used for this purpose, and their source (See section 3. for more information on each category)	Legal basis for the processing under the relevant regulations
Fulfilment of Services.	Device-related information; Contact information; Information about the goods and services; Identification information; Financial information; Information about your use of our Services.	The processing is necessary for the performance of the contract we concluded with you.
Improvement of our Services	Device-related information; Information about your use of our Services.	The processing is based on ShortsGO’s legitimate interest (being to improve our Services).
Compliance with applicable rules	Any category of personal data (to the extent necessary for the purpose for which they are processed).	The processing is necessary for compliance with legal obligations to which ShortsGO is subject to.

5. Personal Data Retention Policy

We retain your personal data for as long as it is necessary to provide you with the Service or fulfil the transactions you have requested or authorised. Where we do not need your personal data in order to provide the Service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, including to comply with our legal obligations, enforce our agreements, resolve disputes, and as necessary for the establishment, exercise or defence of legal claims.

Any deleted conversations are removed from our systems within 30 days, unless we are legally required to retain them in an aggregated and anonymized format.

6. Delete your personal data or your account

We will delete your personal data in an active way for the following cases

• The processing purpose has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose；
• The storage period has expired；
• You withdraw your consent；
• Other circumstances as stipulated by laws and administrative regulations.

If you wish to delete your account, please contact us at dataprotection@shortsgo.com.

If you would like to access or view the personal data we hold about you or would like to correct or request for deletion of such personal information, you can also send your request to us at dataprotection@shortsgo.com.

We will delete your personal data no more than 30 days from the date of receipt of your written request.

7. To whom do we communicate or give access to your personal data?

We do not sell or otherwise disclose personal data we collect about you to third parties, except as described in this Privacy Policy. We will share personal data to enable the performance of our Services that you have intended to or chosen to use. In this respect, we may share your personal data with our cooperated third parties, our affiliates or other relevant persons (the “Partners”).

When you use our Services, some third party tools(SDKs) integrated within our Services may collect and use certain personal data collected from your device. Such personal data may include software list Unique Device Identifier (such as IMEI/androidID/DEVICE ID), version of your operating system (“OS”), screen resolution, browser settings, plugins, language setting, device memory, storage information, IDFV, IDFA or Android Advertising ID, time zone setting, location information and IP address.

The third party SDKs we currently access are listed below：

SDK Name	Purpose	Permission acquisition	Company Name	Privacy Policy
sentry	To identify, monitor, and alert developers to errors, bugs, and other performance issues that are occurring in our application; To improve our Service	1 Crash logs 2 Diagnostic information	FUNCTIONAL SOFTWARE, INC.	https://sentry.io/privacy/
firebase	To analyse our application crash reports or error reports online; To improve our user’s experience.	1 Crash logs 2 Diagnostic information 3 Other application performanc-e data	Google LLC	https://policies.google.com/privacy

When making a payment, you may choose to use third party payment processors offered by ShortsGO to facilitate the transaction. To authorize payment through these processors, you will need to provide your order details, including amount and payment credentials, directly to the processor. By continuing with payment, you acknowledge and agree that ShortsGO may share limited personal data with payment processors as necessarily needed to complete the transaction securely and verify its authenticity. This may include device and network-related data. Any personal data you provide directly to third party payment processors will be subject to the respective third party privacy policies. ShortsGO is not responsible for these third party policies or the information handling practices of its payment partners.

We may transfer data to third parties who process data in the context of performing or offering our Services on our behalf. Those actors act either as processors for us. For example , we may utilize the Superset analytics tool to access certain personal data with the goal of optimizing and enhancing our Service. When acting as our processors, they are not authorized to use the data or disclose it in any way except as described above or to comply with legal requirements. The processors accessing your personal data generally operate in the information systems. We contractually require our Partners to appropriately safeguard the privacy and security of personal data they process on our behalf.

We also may disclose data about you: (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials in accordance with their competences, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm, or (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity, as obliged by applicable law. Moreover, we can reasonably share your personal data with third party service providers for the purpose of improvement of our Services as set forth in section 4 above. We also reserve the right to transfer any personal data we have about you in the event we sell or transfer all or a portion of our business or assets affecting the website. Should such a sale or transfer occur, we will ensure that (i) you are informed of such an event and (ii) personal data you have provided to us remains to be treated in a manner that is consistent with this Privacy Policy.

If you want more information on the entities to whom we disclose, please contact our data protection team (see contact details in section 15 below).

8. Do we transfer your personal data to third countries?

We are a global business. Currently we store your personal data in Indonesia, however, personal data may be processed in any country where we do business, or where our service providers do business. We may transfer your personal data to countries other than your own country, including to the Philippines, Indonesia, Saudi Arabia, United Arab Emirates and Israel, as necessary for the legitimate purposes outlined in our Privacy Policy

These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose personal data in response to lawful requests from officials (such as law enforcement or security authorities).

9. How do we keep data security?

We take your personal data security very seriously. We don’t allow publicly disclose any personal and sensitive user data related to financial or payment activities. We also don't allow unauthorized publishing or disclosure of people's non-public contacts. We securely handle all personal and sensitive user data, protecting it with appropriate technical and organizational security measures. This includes transmitting user data over encrypted HTTPS connections to safeguard transfers and prevent unauthorized access or viewing of transmitted content.

We encrypt all personal data at rest (AES-256) and in transit (TLS 1.2+), and use strict access controls to limit who can access data. Our security team has an on-call rotation that has 24/7/365 coverage and is paged in case of any potential security incident. Periodically we run a penetration test for disclosure of vulnerabilities discovered on our platform and products.

Technical and administrative measures are employed to protect personal data from misuse, unauthorized access, disclosure, alteration, loss or destruction. Encryption techniques, anonymization processes and other reasonable practices are used to protect personal data at a standard equal to or above industry peers. Security safeguards help prevent malicious attacks on your personal data.

While reasonable and legally compliant steps are taken, internet and technical limitations mean complete security cannot be guaranteed. We make best efforts to ensure the safety of personal data provided.

You understand and agree that the systems and networks used may experience issues beyond our control. We strongly advise taking proactive security measures like using complex unique passwords and changing them regularly, and keeping login details private.

When using other websites, services or content outside of ShortsGO, we have no ability or direct obligation to protect any personal data submitted outside our services, regardless of initial access path.

10. Do we receive any information on you from third-parties?

Yes, you clearly know that third parties may directly collect and process your information if you use our Services. We will evaluate the legality and necessity of such third parties to collect information and require them to take protective measures for your information.

For example, If you register with ShortsGO using your credentials from third party services like Facebook, Google, TikTok, etc., we may receive certain basic personal data from those third parties to facilitate account creation and login.

The third party services have their own privacy policies that govern what personal data can be shared. For registration through such services, we will request only the minimum data necessary to establish your user profile with us. Any further data sharing is subject to the third party's privacy practices and your settings with them.

11. What are your rights and how can you exercise them?  

              11.1 Data protection rights

In accordance with applicable regulations, you have the following rights:

1. Right to access

At any time, you have the right to access your personal data that we process, meaning that you have the right to obtain a copy of your personal data that is processed by us.

2. Right to rectification

You have the right to have inaccurate or incomplete personal data rectified, respectively completed (which may involve providing a supplementary statement to the incomplete data).

3. Your right to erasure

You may ask us to erase the personal data concerning you in the following circumstances:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw your consent on which the processing is based and there is no other legal ground we can invoke for the processing activity concerned;
• you object to the processing of personal data concerning you which is based on the necessity of processing for (i) the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or (ii) the purposes of the legitimate interests pursued by us or by a third party, which includes profiling based on those provisions, and there are no overriding legitimate grounds for the processing;
• you object to the processing of personal data concerning you for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation to which we are subject;

However, we do not have to agree to delete all your personal data in those situations as prescribed by law where we are allowed or required to keep your personal data for a longer period of time.

4. Your right to restrict processing

If you have an issue with the content of the information we hold or with the way we have processed your personal data, you may limit the way we process your personal data.

You have the right to obtain restriction of processing by us in the following circumstances:

• you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to the processing of personal data concerning you which is based on the necessity of processing for (i) the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or (ii) the purposes of the legitimate interests pursued by us or by a third party, which includes profiling based on those provisions, pending the verification whether our legitimate grounds override yours.

1. Your right to data portability

Where legally applicable, you have the right to have the personal data you have provided to us to be returned to you or, where technically feasible, transferred to a third party in a structured, commonly used and machine-readable format. Upon your request, we will provide you or the recipient designated by you in your written request, a copy of such personal data in a CSV or similar format.

2. Your right to object

You have the right to object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing. In some cases and depending on the legal basis of our processing of your data, your right to object may be limited.

3. Your right to withdraw your consent

Where the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time. Such withdrawal will not affect the lawfulness of past data processing. Please note that opposing some processing can, however, affect some aspects of your use of our Services as ShortsGO cannot provide these without processing necessary elements of your personal data.

4. Your right not to be subject to a decision based solely on automated processing  

You have the right to ask that we do not make our decision solely based on automated processes, including profiling. You can object to such an automated decision, and ask that a person review it unless such decision is authorised by applicable law to which we are subject.

             11.2 How to exercise your data protection rights

You may exercise all of your data protection rights as mentioned in this section 9. of this Privacy Policy in accordance with the applicable data protection laws and regulations, by sending our data protection team (see contact details in section 14 below) a request mentioning your first and last name, and, when necessary to verify your identity, a copy of your ID card / identification document (passport or other proof of identity).

We do our best to respond to your request within a reasonable timeframe.

Exercising any of your data protection rights as mentioned in this section 9. This Privacy Policy is free of charge. However, we reserve the right to charge reasonable fees if your request is clearly unfounded, repetitive or excessive.

12. Do we collect personal data from minors?

We do not knowingly collect personal data from or market to children under 18 years of age. By using the services, you represent that you are at least 18 or you are the parent or guardian of such a minor and consent to such minor dependent’s use of the services. If we learn that personal data from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

Please also be aware and consent that we may use the information collected from you to identify minors.

If ShortsGO does change in the future to include under 18 years olds within our customer base, we will also take strict measures to protect the personal data of minors. If you are under 18 years of age, you should obtain prior written consent from your parent or legal guardian before using our Services. If you are the guardian of a minor, please contact us via the contact information in Section 15 if you have any questions related to your minor's personal data.

13. Solely Automated Decision

No. Our Services do not subject individuals to decisions made solely by automated means that affect your legal rights or access to services. beings are involved in all decision-making processes to ensure fairness and compliance with privacy and data protection laws

14. Updates to this Privacy Policy

We reserve the right to amend or modify this Privacy Policy in accordance with the applicable laws. You can check any material changes through our website, application, or through other regular means of communication. Your continued use of the website or Services after a modification of this Privacy Policy entails your acceptance of the modified Privacy Policy.

We will take into account the potential impact of the change on you.

15. Questions and complaints – Contact information

If you have a question about this Privacy Policy or about data protection at ShortsGO, you can contact our data protection team (see contact details in section 15 below). Please also send an email to our data protection team if you wish to exercise your right of access or data deletion or any other data protection right under relevant applicable regulations.

• Our data protection team email at: dataprotection@shortsgo.com

In case you contact us, you are required to provide at least your first and last name, and a copy of your ID card / passport / other identification document, when necessary to identify you. Otherwise we won’t be able to identify you and, consequently, reply to your complaint.