O+ Connect Privacy Notice
Last updated: September 1, 2024
Effective date: September 1, 2024
Thank you for using O+ Connect. O+ Connect ("the App") is developed and operated by BRAVO UNICORN PTE. LTD ("we", "us", or "our", registered at 9 Raffles Place, #26-01 Republic Plaza, Singapore 048619) to provide users ("you", or "your") with the feature of transferring images, videos, documents and other data between mobile terminals.
During your use of our accounts, websites, mobile apps, or other products or services, we may collect and use your personal information. In the O+ Connect Privacy Notice (this "Privacy Notice"), "personal information" or "personal data" refers to all information that can be used alone or in combination with other information to identify a natural person.
This Privacy Notice explains how we process your personal information, the purposes for which we collect, use, and disclose your personal information during your use of O+ Connect, your rights to your personal information, and the security measures we use to protect personal information.
Before using O+ Connect, please carefully read this Privacy Notice to understand our practices regarding personal information protection. By tapping "Agree" to launch O+ Connect, you acknowledge that you fully understand the following personal information collection and usage practices and your rights in this regard.
In principle, this Privacy Notice applies to all jurisdictions where we have declared the provision of services through the App. However, different jurisdictions may have different requirements regarding personal information protection. Therefore, in addition to the general terms, we make a disclosure in the form of appendices of specific terms to meet the special requirements of different jurisdictions. The appendices, along with the main part of this Privacy Notice, constitute our notification of personal information processing in specific jurisdictions. If you are in a region listed in one of the appendices, you should also read the appendix applicable to your region. Unless otherwise specified in the appendices, the general terms of this Privacy Notice prevail. In case of any conflict or inconsistency between an appendix and the main part of this Privacy Notice, the appendix prevails.
Regardless of your location, the general terms in Section A apply to you. Section B only applies to users located in the European Union, Liechtenstein, Norway, the United Kingdom, or Switzerland ("Europe"). Section C applies to users in the United States and is only applicable to users domiciled in California, Nevada, Colorado, Connecticut, Virginia, and Utah. Section C provides more details about personal information to meet the disclosure requirements under the laws of these states. Section D applies to the users in India.
This Privacy Notice is divided into the following sections:
General Terms
1. How We Collect and Use Your Personal Information
2. How We Store and Retain Your Personal Information
3. How to Exercise Your Data Subject Rights
4. How We Protect Minors' Personal Information
5. Contact Us
Appendix: Europe-Specific Privacy Notice (GDPR-based Terms)
1. Legal Basis for Processing Personal Information
2. Scope of Personal Information We Process and the Purpose
3. Additional Information on How Your Personal Information Is Transferred Globally
4. Additional Information on Your Rights Regarding Personal Information
5. Contact Us
Appendix: United States-Specific Provisions
1. Categories of Personal Information We Process and Use of Personal Information
2. Additional Information on Your Rights Regarding Personal Information
Appendix: India-Specific Privacy Notice (DPDPA-based Terms)
1. Personal Data We Collect and the Purposes of Data Processing
2. Data Subject Rights
3. Processing of Personal Data of Children
Main Body
General Terms
1. How We Collect and Use Your Personal Information
The information we collect depends on the features or services you use, the environment in which you interact with us, and the choices you make, including your privacy settings and the features or services you use. The features or services provided by the App may vary depending on the country or region in which the App is released, the operating system or app version, and device installation and download conditions. Therefore, the features or services actually provided by the App, personal information processing practices, and permission requests are subject to the actual product you ultimately use.
You are not obliged to provide personal information to us. However, if you choose not to provide the personal information necessary for the App to provide the required services, we may not be able to provide you with such services, nor will we be able to respond to or deal with any problems you may encounter. We collect personal information for the purpose of operating more efficiently and providing you with the best possible experience. The following describes in detail the categories of personal information we collect as well as how and why we collect and use such information.
Our channels for collecting personal information include:
• Directly from you;
• Automatically from your use of the App; and/or
• From third parties.
If the following clauses explicitly state that relevant information about you is only kept locally, then the information is collected and processed only on your device and will not be uploaded to our servers, and such information is not bound by this Privacy Notice. We aim here to provide clarification on any questions you may have and to be transparent about our processing of personal information.
Please note that if you provide other people's personal information to us, you must ensure that you have obtained their authorization.
1.1 App features, personal information we collect and use, and intended purposes
(1) Device connection
In order to provide you with a device connection feature, you need to permit the App to use Bluetooth and access your location information and wireless data so that it can obtain information about nearby hotspots, and initiate a request for connecting the source device to the destination device. You also need to permit the App to access your device type, name, model, and system version to check the feature compatibility. Such information will be processed only on your device/across your devices, and will not be uploaded to our servers. It will be deleted immediately after use, and will not be stored on your device.
(2) Data transfer
In order to provide you with the feature of transferring files between devices, the App may need to access your photos, audio, video, documents, and archives to complete the data transfer. Such information will be processed only on your device/across your devices, and will not be uploaded to our servers. It will be deleted immediately after use, and will not be stored on your device.
(3) Device display name setting
The App allows you to set a device display name, making it easier for other devices to identify yours during searches. The changes you make to your device display name in the App will appear on your device/across your devices and be stored on your device. The display names are not uploaded to our servers.
1.2 Cookies and other similar technologies
Currently, the App does not use cookies or any other similar technologies to collect or store user preferences or any information about you.
2. How We Store and Retain Your Personal Information
2.1 How long we store your personal information
Pursuant to laws and regulations, we will retain your personal information for the minimum period necessary to provide you with the required products or services. We will delete or anonymize your personal information upon the expiration of the retention period or when other conditions for its deletion are met, unless otherwise specified by applicable laws or regulations.
When you set a device display name in the App, we will process your device name and retain it until you stop using the App.
If we discontinue some or all of our products or services for any particular reason, we will promptly inform you and stop the collection and processing of your personal information in connection with such products or services. We will also delete or anonymize any such information in our possession unless otherwise specified by laws and regulations.
2.2 Where we store your personal information
As a company operating globally, we provide products and services through resources and servers around the world. For the purpose of ensuring the high quality of our services (such as ensuring a high processing speed) and subject to local data protection laws, we will store your personal data based on the region where your mobile phone is purchased or configured. We have established data centers in France, the United States, Singapore, India, and Indonesia. This means that your personal information may be transferred to or accessed from a jurisdiction outside the country or region where you use the relevant products or services.
You understand that there are different risks under different data protection laws. We will take measures to ensure that the data we collect is processed in accordance with this Privacy Notice and applicable laws, and that, when your personal information moves across borders, it is as well protected as it is in the country or region where you use the relevant products or services. For example, we will obtain your consent to the cross-border transfer of your personal information or take security measures such as encryption, de-identification, or entering into a necessary data transfer/sharing agreement with the recipient of your data before transferring such data across borders.
3. How to Exercise Your Data Subject Rights
We respect your rights to your personal information and are committed to safeguarding your control over it. We therefore provide a variety of secure and convenient ways for you to configure privacy settings and manage personal information, thus ensuring the security of your personal information. Please note that the settings may vary by device model, operating system version, and App version. In addition, we may adjust the settings from time to time to improve your user experience. Therefore, the paths described below are for your reference only. If you have any questions regarding such paths or the ways of exercising your rights, you may contact us via the manner disclosed in the "Contact Us" section of this Privacy Notice. You are entitled to the following rights to your personal information:
3.1 Right to be informed
We inform you of how we process and protect your personal information by publishing this Privacy Notice. We are committed to staying transparent about how we use your personal information. You can regularly check this Privacy Notice, receive emails and SMS messages that contain a description of the updates to this Privacy Notice, and contact us in the manner disclosed in this Privacy Notice to learn about our collection and use of your personal information. You can go to "Settings - Privacy Notice" of the App on your phone to view it.
3.2 Right to access
You can go to the relevant product or service pages to directly query or access your personal information, and learn how your personal information is collected and used. For example, you can go to "Settings - Name" of the App to view the device display name you set in the App.
3.3. Right to rectify
You have the right to request that we correct or supplement any personal information we process about you that you believe is inaccurate or incomplete. You can correct and modify some of your personal information on the relevant product or service pages. For example, you can go to "Settings - Name" of the App to change or complete your device display name.
3.4 Right to change the scope of authorization or withdraw consent
The performance of each service feature requires certain basic personal information (see the "How We Collect and Use Your Personal Information" section of this Privacy Notice). You can change the scope of the personal information you authorize us to continue collecting or withdraw your authorization by deleting information, turning off app permissions, changing settings on the relevant product or feature settings pages, or deleting your account. Specifically:
You can go to "Settings - Privacy & Security - Permission manager" to turn off relevant app permissions so as to withdraw your consent to our use of such app permissions.
You can go to "Settings" of the App and tap "Withdraw consent to Privacy Notice" to withdraw your consent to this Privacy Notice.
3.5 Right to complain
You have the right to file a complaint by contacting us as set forth in "Contact Us".
You have the right to lodge a complaint with the competent supervisory authority regarding our personal information protection practices, or file a lawsuit in a court with jurisdiction. However, we hope that we have the opportunity to solve your concerns or issues before you contact relevant authorities, so please first contact us directly.
4. How We Protect Minors' Personal Information
We greatly value our obligation and responsibility for protecting children's personal information. We strive to create a healthy cyber environment for minors and make extra efforts to protect children. We treat anyone under the age of 18 (or a similar minimum age of full legal capacity defined in the jurisdiction concerned) as a child. Most of the features and services provided by the App are intended for adults, and not for children. We do not provide services directly to children. Please note that, due to technical limitations and other objective factors, the App may not be able to actively identify your age.
According to applicable laws and regulations, if you are a child, you must obtain the consent of your parent or another guardian before using the App, and be sure to carefully read this Privacy Notice together with them. If you are the guardian of a child, before assisting the child in using the App, you must carefully read both the Children's Privacy Statement (if any) and this Privacy Notice. Please note that children are not allowed to use the App without the consent of their parents or guardians.
We do not actively collect, store, use, transfer, or disclose children's personal information, let alone use their personal information for marketing purposes. If you are a child, or if you are a parent or guardian of a child, or if you otherwise find that any information we processed may contain the personal information of a child, please contact us in the manner disclosed in this Privacy Notice. We will try to delete the relevant data as soon as possible.
5. Contact Us
To learn more about how we protect your personal information, please refer to the Privacy Notice (https://brand.heytap.com/eu/privacy.html).
If you have any questions, complaints, or suggestions regarding this Privacy Notice or our privacy practices, you may contact us as set forth below. We will verify your identity and respond within the stipulated time limit, in accordance with local laws and regulations. Given the complexity and volume of individual requests, as well as the technical feasibility involved, this timeframe might be extended when necessary.
If you have any questions or concerns about this Privacy Notice or our privacy practices, please contact us at:
BRAVO UNICORN PTE. LTD.
Address: 9 Raffles Place, #26-01 Republic Plaza, Singapore 048619
Data Subject Rights Platform: https://brand.heytap.com/en/privacy-feedback.html
Appendix: Europe-Specific Privacy Notice (GDPR-based Terms)
This section only applies to users located in the European Union, Liechtenstein, Norway, the United Kingdom, or Switzerland ("Europe").
GDPR divides roles in personal data processing into data controller and data processor. A data controller refers to any natural person, legal person, public authority, institution, or group that, alone or together with others, determines the purposes and means of processing personal data. (It is almost the same concept as the personal information processor in "General Terms"). A data processor refers to any natural person, legal person, public authority, agency institution, or group that processes personal data on behalf of a data controller. (It is almost the same concept as the party that is entrusted to process personal information described in "General Terms"). If you are a user located in Europe, BRAVO UNICORN PTE. LTD acts as the "data controller" as defined in the European General Data Protection Regulation (GDPR) and is able to determine the purpose for which your personal information is collected and processed and process your personal information in compliance with this Privacy Notice and applicable terms in the GDPR.
The personal information herein (also "personal data") refers to any information related to a natural person that has been identified or is identifiable. Personal data of special types refers to sensitive personal data which includes data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as data for unique identification of a natural person, such as genetic data, biometric data, health data, or data relating to sex life or sexual orientation.
1. Legal Basis for Processing Personal Information
The processing of your personal information described in "How We Collect and Use Your Personal Information" is lawful only if and to the extent that at least one of the following applies:
(1) We have obtained your express consent in advance, and you can withdraw your consent at any time;
(2) Information processing is necessary for us to enter into a contract or perform the contract concerning our products and/or services;
(3) The processing of relevant personal information is indispensable for fulfilling our legal obligations;
(4) Disclosing your personal information is necessary for the purpose of the legitimate interests pursued by us or a third party. We will process your personal information on this lawful basis only after balancing our or the third party's interests against your privacy rights.
2. Scope of Personal Information We Process and the Purpose
When you use O+ Connect, we may collect, use, or disclose your personal information for the purposes and procedures set forth below or for other reasonably related purposes:
| Feature and processing purpose | Personal information fields collected | Legal grounds |
| Device connection | Location, device type, name, model, and system version (the above information is processed only on your device/across your devices) | When your personal information is used in scenes where relevant local laws and regulations apply, we will obtain your consent so as to meet the requirements of the relevant laws and regulations. |
| Data transfer | Photos, audio, video, documents, and archives (the above information is processed only on your device/across your devices) | |
| Device display name setting | Device display name (the above information is processed only on your device/across your devices) |
3. Additional Information on How Your Personal Information Is Transferred Globally
In principle, personal information generated and collected in Europe will be stored in Europe. Where your personal information is transferred to a country or region outside the European Economic Area (EEA), we will take the necessary security measures. For example, we will ensure that:
The recipient is located in a country that the European Commission has, through an adequacy decision, recognized as providing adequate protection;
The recipient has signed a contract in accordance with the "Standard Contractual Clauses" issued by the European Commission, requiring them to protect your personal information; or
In the absence of appropriate safeguards, we will obtain your express consent for the transfer of your personal information. In addition, we will use techniques such as encryption or de-identification to protect your personal information.
For more information about the safeguards relating to personal information transfers outside Europe, please contact us and submit your request through:
Data Subject Rights Platform: https://brand.heytap.com/eu/privacy-feedback.html
4. Additional Information on Your Rights Regarding Personal Information
According to the GDPR, you have the following rights:
4.1 Right to access
We inform you of how we process your personal information by publishing this Privacy Notice and, where required by laws and regulations, by posting a specific notice or contacting you by SMS or email. We are committed to staying transparent about how we use your personal information.
You can go to "Settings - Privacy Notice" of the App to view this Privacy Notice and learn about how we process your personal information.
4.2. Right to rectify
If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and to request the supplementation of your personal data where appropriate.
4.3 Right to restrict processing
In certain cases, for example, when you contest the accuracy of your personal data, you are entitled to request that we restrict the processing of your personal data so that we can verify its accuracy. We will keep enough data or process such data as is necessary to ensure that we comply with your restriction requests in the future.
4.4 Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to any processing based on your legitimate interests. Should you decide to object to the processing, we will stop processing the personal information concerning you, unless we can demonstrate compelling reasons for continued processing that override your interests, rights, and freedoms, or in the case that we establish, exercise, or defend our legal claims. You can object to direct marketing activities at any time for any reason.
4.5 Right to data portability
You are entitled to obtain a copy of your personal data in a structured, commonly used, and machine-readable format and transmit such data to another provider. In certain circumstances, you can transmit your personal data to any other provider.
4.6 Right to change the scope of authorization or withdraw consent
If we process your personal information based on your consent, you have the right to withdraw your consent at any time, and we will stop processing your personal information immediately. For example:
You can go to "Settings - Privacy & Security - Permission manager" to turn off relevant app permissions so as to withdraw your consent to our use of such app permissions.
You can go to "Settings" of the App and tap "Withdraw consent to Privacy Notice" to withdraw your consent to this Privacy Notice.
4.7 Right to complain
You have the right to lodge a complaint with the national data protection authority in your country about the ways we process your personal information. You may go to https://edpb.europa.eu/about-edpb/about-edpb/members_en to view information about the local data protection authority in your country.
We will respond to your complaint as soon as possible. In general, we will respond within one month following the receipt of your complaint. (If the complaint is overly complex or requires large amounts of personal information, we may extend this time limit by two months when necessary or permitted by law. In such cases, we will notify you of the reason for the extension within one month of receiving your complaint.) If you are not satisfied with our response, you can file a lawsuit with the supervisory authority in your jurisdiction.
5. Contact Us
For users located in Europe, you can contact our European representative OROPE Germany GmbH. Please use the email or postal address below:
Email Address: Privacy_eu@heytap.com
Postal address: Graf-Adolf-Platz 15, 40213, Düsseldorf, Germany
For users located in the UK, you may contact our UK representative Unumplus Limited. Please use the email or postal address below:
Email: privacy_uk@heytap.com
Postal address: 7 Albert Buildings, 49 Queen Victoria Street, London, United Kingdom, EC4N 4SA
C. Appendix: United States-Specific Provisions
Section C applies to users in the United States and is only applicable to users domiciled in California, Nevada, Colorado, Connecticut, Virginia, and Utah. Section C provides more details about personal information to meet the disclosure requirements under the laws of these states.
1. Categories of Personal Information We Process and Use of Personal Information
According to the laws of the aforementioned states, we are required to provide the following details regarding the information that we collect from residents of those states. The information we collect depends on the context of your interactions with us and the choices you make, including your privacy settings and the products and features you use.
The aforementioned categories of personal information may have been used (and may have been used in the twelve-month (12) period prior to the effective date of this Privacy Notice) for one or more of the purposes provided in our privacy notice, or for one or more of the following purposes.
We will not collect any personal information from other categories or (unless otherwise provided in the above terms or in this Privacy Notice) use the personal information we collect for materially different, irrelevant, or incompatible purposes without informing you.
In the United States, the features we provide are detailed in Section 1.1 in the "General Terms" of this document.
2. Additional Information on Your Rights Regarding Personal Information
You are entitled to the following consumer data privacy rights. Please note that these rights are not absolute and may be subject to conditions or limitations.
(1) Right to access and data portability: You have the right to know and access the categories and specific information we collect about you, the sources from which we collect such information, the purposes for our collection of such information, and the types of third parties with whom your personal information is shared. Where technically feasible, we provide you with such personal data in a structured, commonly used, and machine-readable format so that you can transmit it to another entity.
(2) Right to request: You have the right to request information regarding our disclosure of personal data to third parties for business purposes.
(3) Right to rectify: You have the right to correct inaccurate personal data that we may have about you in our possession.
(4) Right to opt out: You have the right to opt out of the sale or sharing of your personal data with third parties.
(5) Right to limit the use of sensitive personal information: We do not use or collect sensitive personal information to infer user characteristics, so this right does not apply.
(6) Right to non-discrimination: You will not be discriminated against if you exercise any of the above rights.
You may contact us in the manner set forth below to exercise your data subject rights:
Data Subject Rights Platform: https://brand.heytap.com/en/privacy-feedback.html
Before handling your request, we need to verify your identity and confirm that you are a resident of California, Nevada, Colorado, Connecticut, Virginia, or Utah, USA. To verify your identity, we usually match the personal information you provide in your request with the information we hold about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or the date of the last transaction made on our services.
In some cases, we may reject requests to exercise the rights described above, particularly if we are unable to verify your identity or locate your information in our systems. If we are unable to satisfy all or parts of your requests, we will explain the reasons for refusing to satisfy your requests.
D. Appendix: India-Specific Privacy Notice (DPDPA-based Terms)
This appendix applies only to users located in India.
You understand that this appendix has been prepared in accordance with the Digital Personal Data Protection Act (DPDPA) of India and the relevant personal data protection laws. DPDPA defines two roles for data processing: data fiduciary and data processor. A data processor refers to any entity that, alone or together with others, determines the purposes and means of processing personal data. (It is almost the same concept as the personal information processor in general terms). A data processor refers to any entity that processes personal data on behalf of a data fiduciary. (It is almost the same concept as the party that is entrusted to process personal information described in Part A "General Terms").
1. Personal Data We Collect and the Purposes of Data Processing
In India, we provide the feature of transferring images, videos, documents, and other data between mobile terminals.
We collect your personal data only for the purposes of providing O+ Connect related services and realizing relevant features. For more information, please refer to Section 1 "How We Collect and Use Your Personal Information" in Part A "General Terms".
Please note that the processing of your personal data is permitted without your consent in the following circumstances:
(1) Where you voluntarily provide the data to us for a specific purpose without giving an express representation that you object to our processing of such data;
(2) As necessary for the country and its agencies to provide or issue prescribed subsidies, benefits, services, certificates, and licenses to you;
(3) As necessary for the country or its agencies to perform their functions under the laws currently in force in India, or in the interest of safeguarding the sovereignty, integrity, and national security of India;
(4) As necessary for any person to fulfill any obligation under the laws currently in force in India to disclose any information to the country or its agencies;
(5) As necessary to comply with any judgment, ruling, or order issued under the laws currently in force in India, or judgments, rulings, or orders in relation to contracts or civil claims under the laws currently in force outside India;
(6) As necessary to take measures to provide medical treatment or health services to any individual in the event of an epidemic, disease outbreak, or any other threat to public health;
(7) As necessary to take measures to protect the safety of any individual or to provide assistance or services in the event of any disaster or public disorder.
2. Data Subject Rights
Under the DPDPA, you have the following rights as a data subject. You can exercise such rights in the ways described below. You can also directly submit a data subject rights request in the manner disclosed in the "Contact Us" section.
2.1 Right to be informed
You have the right to know about:
(1) The scope of personal data we are processing and the data processing activities we are carrying out. For details, please refer to Section 1 "How We Collect and Use Your Personal Information" in Part A "General Terms";
(2) Information required to be disclosed by relevant laws and regulations.
2.2. Right to rectify
You have the right to correct, complete, and update your personal data. For details, please refer to Section 3.3 "Right to rectify" in Part A "General Terms".
2.3 Right to redress for grievances
If you believe that we have failed to meet our obligations regarding the processing of your personal data, you may contact us for redress and remediation. For details, please refer to Section 3.3 "Right to rectify" and Section 3.5 "Right to complain" in Part A "General Terms". In general, we will respond to your data subject rights request within 15 workdays of the date we receive it. If you believe that we are unable to respond to your request, you may file a complaint with the Personal Data Protection Commission of India.
2.4 Right to withdraw consent
You have the right to withdraw your consent to our processing of your personal data. For details, please refer to Section 3.4 "Right to change the scope of authorization or withdraw consent" in Part A "General Terms".
After you withdraw your consent, we will cease to process your personal data accordingly. You understand that the withdrawal of consent does not affect the lawfulness of our processing of your personal data based on your consent before its withdrawal.
2.5 Right to designate an authorized agent
If you are a child or person with a disability, you have the right to designate an authorized agent to act on your behalf to exercise your rights as a data subject. When you use an authorized agent, we will take the necessary action to verify the identity of the agent for a qualification review.
3. Processing of Personal Data of Children
In principle, we do not provide our products and services to children. For details, please refer to Section 4 "How We Protect Minors' Personal Information" in Part A "General Terms".
Please note that in India, children refer to natural persons under the age of 18.