Privacy Policy - Helo

Last Updated: 9 January 2021

Welcome to Helo (the " Platform"). The Platform is provided or controlled by Poligon Pte. Ltd. , with its registered office at, 1 Raffles Quay, #26-10, South Tower, Singapore 048583 (" we" or " us"). We respect and are committed to protecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will handle it before accessing or using the Platform or the Services. By accessing or using the Platform, or the services, applications, products and/or content available on the Platform (collectively, the " Services"), you acknowledge that you have read and understood this policy and herebyconsent to us collecting, using, processing, disclosing or transferring your personal data in accordance with this policy. If you do not agree with this policy, you should not access or use the Platform or Services.

Please note that Jurisdiction-Specific Supplemental Terms at the end of this policy may apply to you depending on the jurisdiction from which you are accessing and using the Platform and/or the Services, which are deemed to be incorporated into this policy by reference.

For the purposes of this policy, unless the context otherwise requires, "you" and "your" means you, the user of the Services, and "information" means information which we collect about you or which is provided to us by you, including your personal data.

1. The Types of Personal Data We Collect and Use

We may collect and use the following information about you:

Information you give us. You may give us information about you by accessing or using our Services or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register for and/or use the Platform, such as your customer profile, information about your device, your browsing records, the comments you make on our Platform, as well as account and billing details, including but not limited to, your Apple, Google or Windows account, PayPal or other third-party payment channel account where required for the purpose of paying or withdrawing cash. The information you give us may include your name, address, email address, social media account and login details, telephone number, nationality, gender, signature, date of birth, family relations, and credit or debit card information. It also includes information that you give to us, such as a picture, video or other filetype that you may choose to access through or post on our Platform.

Information you choose to share from your social networks. If you choose to link the Platform to your accounts on other social network or public forum platforms (such as Facebook or WeChat), you may provide us or allow your social network provider to provide us with information from your accounts on other social network or public forum platforms, such as your username and public profile. This data may include your use of the Platform on such public forums and/or social networks. We are not responsible for the data processing practices of any third party social network provider. We will likewise share certain information with your social network provider such as your app ID, access token and the referring URL. For further information as to how and for what purpose your social network providers process your data, please see their applicable privacy policies.

Information we collect about you. We automatically collect certain data from you when you access or use the Platform, including your IP address or other unique device identifiers, Cookies (as defined below), mobile carrier, network type and connections, time zone and locale setting, mobile or device model or other such unique handset identifier, operating system and platform, device settings, and other information regarding your use of the Platform. We may also collect information about you by linking your contact or subscriber information with your activity across our Platform or by linking your activity on our Platform across all your devices using your email or social media log-in details.

Behavioral information we collect about you. We also collect information regarding your use of the Services, e.g. your profiles and presumed interests, alongside marketing information such as opt-ins and communication preferences. We collect engagement scores ("likes", comments, repeated views, information about your followers), and related users based on your behaviour. Finally, we collect opt-ins and communication preferences.

Location data. When you use the Platform on a mobile device, we may collect and process information about your location, including location information based on your SIM card, IP address or mobile device location settings, and if activated on your mobile device, by use of a Global Positioning System (GPS). We may use such information to provide you with location-based services, such as advertising and other personalized content. If you do not wish to share your GPS location with us, you can switch off the GPS functionality on your mobile device.

Metadata. When you upload a picture, video or other filetype to the Platform (" User Content"), you automatically upload certain metadata that is connected to the User Content. In essence, metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your file the metadata can describe how, when and by whom the piece of User Content was collected and how that content is formatted. It further includes information such as your account name that enables other users to trace back the file to your user account. Metadata will further consist of additional data that you chose to provide with the User Content, e.g. any hashtags used to mark keywords to the post or comments.

Information from third parties. To the extent that you have consented to such disclosure, we may receive your information if you use any of the other websites we operate or other Services we provide.

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (" Cookies") to enhance your experience using the Platform. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

We use the following Cookies:

Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.

Analytical/performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.

Functionality Cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

If for any reason you wish to not take advantage of Cookies, you may disable Cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of the Platform and we will no longer be able to offer to you personalized content. Unless you opt out of Cookies, we will assume you consent to the use of Cookies.

"Do-not-track" signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to "do-not-track" signals in your web browser.

3. How We Use Your Personal Data

We will use the information we collect about you in the following ways:

  • to administer the Platform (i.e. to provide our Services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and to solicit your feedback;

  • to verify your age and identity;

  • to allow you to participate in interactive features of the Platform, when you choose to do so;

  • to personalize the content you receive and provide you with tailored content that will be of interest to you;

  • to improve and develop our Platform and conduct product development;

  • to measure and understand the effectiveness of the advertising we serve to you and others;

  • to provide you with services based on the country settings you have chosen, such as advertising and other content that is related to the country settings;

  • to make suggestions and recommendations to you and other users of the Platform about goods or services that will interest you or them;

  • to allow other users to identify you via the "Invite friends" function as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socializing function of the Services;

  • to provide you with your profile information to send to anyone you choose and to enable you to participate on the Platform and interact with other users;

  • to make your information available to other users in accordance with the privacy settings you chose for the respective information;

  • to show you content that is similar to content you liked or interacted with (by commenting and/or watching the content), content from your region as well as content from users you follow;

  • to show you advertisements that are relevant to you;

  • to promote the Services and use information that you give to us, such as User Content that you can choose to post on our Platform, as part of our advertising and marketing campaigns to promote the Platform;

  • to help us detect abuse, fraud, and illegal activity on the Platform and to ensure your safety and security including by reviewing user content, messages and associated metadata for breaches and inappropriate content;

  • to keep the Platform safe, stable and secure;

  • to notify you about changes to our Services;

  • to send you information or communicate with you;

  • to provide you with user support;

  • to respond to, handle, and to process queries, requests, applications, complaints, and feedback from you;

  • to enforce our terms, conditions and policies;

  • to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

  • for any other purposes for which you have provided the information;

  • to transmit your information to third parties including our business partners, third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

  • any other incidental business purposes related to or in connection with the above.

4. How We Share Your Personal Data

We may share your personal data with selected third parties in or outside your country, including:

  • our business partners so that we can make you special offers via the Platform;
  • with respect to on-screen ads, advertisers and advertising networks that require the data to select and serve advertisements to you and others. We will not share your contact details with our business partners so they will not contact you directly, but we will share other information so that they can make you offers tailored to your requirements;
  • cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we entered into with you
  • analytics and search engine providers that assist us in the improvement and optimization of the Platform.
  • IT service providers (including but not limited to sharing your telephone number with our partners if you have chosen to authenticate your login through GSMA);
  • Our data center and the servers of our host providers;
  • We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above ("How We Use Your Personal Data").
  • We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

  • comply with a legal obligation, process or request (including tax and related reporting requirements);

  • enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

  • If you choose to register to use the Platform with your other social network account details (e.g., TikTok, Facebook, Twitter, Instagram, Google) or choose to link your Platform account with other social network accounts, you will provide us or allow your social network service provider to provide us with your username and public profile for that social network account. Where you opt to share User Content you created or uploaded on the Platform to other social media platforms, your User Content, username and accompanying text (if any) will be shared on such platforms.

We may also disclose your information to third parties:

  • in the event that we sell any business or assets, in which case we may disclose your data to the prospective buyer of such business or assets; or
  • if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, your user information may be among the transferred assets.

5. Where we store your information

The information about you that we collect from you may be transferred to, and stored at, a destination inside or outside of your country, for the purposes as described in this policy. By submitting your information, you agree and consent to such transfer, storing or processing. We will take reasonable steps to secure your information and treat it in accordance with this policy. Where we transfer any personal data out of the country where you live, including for one or more of the purposes as set out in this policy, we will do so in accordance with the requirements of applicable data protection laws, including by entering into data transfer agreements with the recipient to ensure your personal data is accorded an adequate level of protection.

6. Your choices and rights

You can access and edit most of your profile information by signing into your account. We provide tools in settings that allow you to control how you use the Platform. If you have any questions on how to use or want to know about any rights you may have in the country where you live, please contact us at feedback@helo.com.

7. The Security of Your Personal Data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these third party policies. Please check these third party policies before you submit any information to these websites.

8. Data Retention

We retain your information for as long as it is necessary to serve the purpose(s) for which such information was collected, including to provide you with the Platform or the Services. Where we do not need your information in order to provide the Platform or the Services, we retain it only for so long as we have a legitimate business or legal purpose in keeping such information. However, there are occasions where we are likely to keep this information for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform or Services, we can store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we can also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

9. Information Relating to Children

The Platform is not directed at or suitable for use by children under the age of 14 . Users under the age of 14 are not allowed to use the Platform or register an account on the Platform. If we become aware that personal data has been collected from a person under the age of 14, we will delete this information and terminate the person's account. If you believe that we may have personal data about or collected from a child under the age of 14, please contact us at feedback@helo.com.

10. Feedback

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at feedback@helo.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority or follow the dispute resolution process provided in the Terms of Service.

11. Changes

We will use commercially reasonable efforts to generally notify all users of any material changes to this policy, such as through a notice on our Platform. However, you should look at this policy regularly to check for such changes. We will also update the "Last Updated" date at the top of this policy, which reflects the effective date of such changes to this policy. Your continued access to or use of the Platform and/or Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform and Services.

12. Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to the email address of feedback@helo.com.

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of policy, the relevant jurisdictions' Supplemental Terms – Jurisdiction-Specific will supersede and control.

Indonesia.

If you are using our Services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of these Terms, the following terms shall prevail.

  • Consent to the Privacy Policy. By checking the box or continuing use the Services or continuing accessing the Platform, you acknowledge that you have read and understood this policy and herebyconsent to us collecting, using, processing, disclosing or transferring your personal data in accordance with this policy. If you do not agree with this policy, you should not access or use the Platform or Services.

  • Information Relating to Children. If you access the Services or Platform and you are below 21 years of age, or is not married and is under guardianship, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s) unless you indicate otherwise. By consenting to this policy, your parent(s) or legal guardian(s) are agreeing to take responsibility for: (i) all your actions in connection with your access to the Services; (ii) any fees or charges associated with your use of any of the Services (as applicable); (iii) your compliance with this policy; and (iv) ensuring that any of your participation in Services will not, in any event, result in any violation of applicable laws and regulations relating to child protections. If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Services. You are not allowed to use the Platform or register an account on the Platform . If we become aware that personal data has been collected from a person under 21 years of age, or is not married and is under guardianship without any consent from their parents or legal guardian, we will delete this information and terminate the person's account. If you believe that we may have personal data about or collected from a child under the age of 21 years old, please contact us at feedback@helo.com.

  • Right to Erasure. You have the right to ask us to delete personal data we hold about you by contacting us at feedback@helo.com

  • where you believe the personal data we hold about you is being unlawfully processed by us;

  • where you have withdrawn your consent for the processing of your personal data by us;
  • where the processing of your personal data is not in accordance with the original purposes of processing the personal data;
  • where the processing of your personal data has exceeded the prescribed retention period pursuant to the applicable laws and regulations in Indonesia; and/or
  • where your personal data have been disclosed and such disclosure has made you to incur certain damages.

    • DataRetention. We retain your information for as long as it is necessary to serve the purpose(s) for which such information was collected, including to provide you with the Platform or the Services. Where we do not need your information in order to provide the Platform or the Services, we retain it only for so long as we have a legitimate business or legal purpose in keeping such information. However, there are occasions where we are likely to keep this data for period of 5 years (or longer, if required) in accordance with our legal obligations or where it is necessary for our legal obligations, for the enforcement of our agreements, the establishment, exercise or defense of legal claims.

    • Language . This policy has been prepared in the English language and Indonesian language. In the event of any inconsistency or different interpretation between the English text and Indonesian text, the English text shall prevail and the relevant Indonesian text shall be deemed to be automatically amended to conform with and to make the relevant Indonesian text consistent with the relevant English text. You acknowledge that you have read this policy and understands its content and that this policy has been agreed =freely and without duress. You acknowledge that you fully understand the language and the content of these Terms, and you agree that you will not use the provisions under Law of the Republic of Indonesia No. 24 of 2009 on Flag, Language, State Emblem and National Anthem, Presidential Regulation No. 63 of 2019 on Use of Indonesian Language or any other laws and regulations to invalidate this policy.

Malaysia

If you are using our services in Malaysia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

  • Information Relating to Children.By accessing and/or using the Services, you represent that you are at least 18 years of age. If you are below 18 years old, your parent or legal guardian must consent to the terms of this policy on your behalf.

  • Requirement to Process Personal Data. Unless otherwise specified in this policy, your personal data is necessary for our performance of the Services and such other purposes described herein; if you do not provide such personal data, we may not be able to provide you with the Services.

  • Contact and Feedback. If you have any questions or if you want to make any complaints about how we use your personal data, please contact: feedback@helo.com