Release Date: November 1, 2022
Effective Date: November 1, 2022
Summary
Homily Link platform is a financial APP developed by CAPITALMASTER PTE.LTD. to serve the retail investors, recognized as Homily Link. Homily team is committed to establish Homily Link platform into a financial Internet platform, providing users with a large amount of stock market information, and redefining the push client by continuously learning user preferences with top algorithms to help users to quickly capture the most core and needed information in the increasingly explosive information era.
Homily Link ("we") attach importance on the protection of users' personal information and personal privacy. This Privacy Policy includes provisions concerning our collection, processing, storage, use, sharing, transfer, publicly disclosing and protecting the personal information (hereinafter or the "Information") of user (the "You").
We know the importance of personal information to you, and we will do our best to hold your personal information safe and reliable. We are committed to maintaining your confidence in us, adopt the following principles to protecting your personal information: consistency of power and obligation, clear purpose, choice consent, minimum adequacy, security, subject participation, openness, and transparency, etc. At the same time, we promise that we will take the appropriate security protection measures to protect your personal information in accordance with the safety standards of the industry.
Please read and understand this Privacy Policy carefully prior to using our services and the various business functions included therein (hereinafter called the "Services" or "Our Services") to assist you in understanding our rules for handling your personal information and the way you maintain your privacy rights. If you have any questions about this Privacy Policy, you can contact us via our contact information published in this Privacy Policy.
（1）Definition
1.Homily Link: refers to an APP developed by CAPITALMASTER PTE. LTD. To provide investors with financial information.
2. Affiliate: refers to any company or institution currently or in the future controlled, controlled or under common control by a party. "Control" represents the right directly or indirectly to manage or influence the management and policies governing the entity. Whether through voting equity or other means, such as contracts.
3. Personal information: refers to electronic or other records can alone or combined with other information to identify the specific person identity or reflect the activity of the specific person information, such as Name, Date of birth, Identification number, Personal biological identification information, Address, Communication contact information, Communication records and content, Account ID password, Property information, Credit information, Track, Accommodation information, Health and physiological information, Transaction information, etc.
4. Personal sensitive information: refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment.
5. Unique device identifier: refers to a string of characters programmed into the device by the device manufacturer, which can be used to uniquely identify the corresponding device (such as the IMEI, IDFA, MAC address of a mobile phone). If you are using an Android system phone, limited by the technical features of the Android system, we need to use the IMEI as the unique device identifier for your device; But starting from the Android 10 system, based on the technical improvements of the Android system. We will be able to use alternative codes to identify your device, and we will no longer collect the IMEI of your device unless otherwise mandated by law or for other legitimate and reasonable purposes and with your express authorization.
Privacy Policy
This Privacy Policy will help you understand the following
1. The governing law and scope of this Privacy Policy.
2. How do we collect and use your personal information.
3. How do we store your personal information.
4. How do we use Cookie and similar technologies.
5. How do we entrust to process, share, transfer, public disclosure your personal information?
6. How can we protect your personal information.
7. Your right to manage your personal information.
8. Protection of minors' personal information.
9. Update of this privacy policy and how to get in touch with us.
10. How to contact us.
11. Dispute Resolution.
Scope of application of this Privacy Policy
This Privacy Policy applies to all services provided by Homily Link. You may visit the website and use the services provided by Homily Link.
(2) How do we collect and use your personal information
We will only collect and use your personal information for the following purposes as described in this Privacy Policy:
1. Register as our user
Before you can use our services, you need to register an account to become our user. In order to register for an account, you need to provide us with information as required by the relevant web page so that we can provide you with services. This includes the display name, your display language, password, and phone number. If you are an individual user, you can register on the relevant web page using your name and mobile number (so you must ensure that the mobile number is registered with the respective telecom company to provide the service in your own name and that the mobile number is being used by you).
2. You use the services we provide
Our services include some basic business functions, such as information release (including posting, comments), and interactive communication functions (including following, favorites, likes, sharing, gift).
For serving you, we need to collect, save, and use the following information related to you. If you are unwilling to provide relevant information, you will not be able to use the basic functions we provide.
3. Device information
We collect information about you from the device you use to access Homily Link, including: Information about your connection, such as your IP address and browser type. Information about your device and its Settings, such as device, operating system, carrier, language, memory, installed apps, and battery level.
4. Log information
When you view content on our products and services or otherwise interact with our products and services, even if you have not created an account or are logged out, we may receive information such as:
IP address; Browser type and language; Operating system; Reference web pages; Access time; Pages visited; Location; Your mobile carrier; Device information (including device and application ids); Identifiers generated by Twitter; And the identifier associated with the Cookie. We also receive log information when you click on, view, or interact with links on our services.
Comparison table of device sensitive permission and request purpose
S/N Device sensitive permissions The purpose of calling permission Permission authorization method Whether you can close it yourself
1 Storage / Camera / Photo album Based on the user's active operation, you can take/upload pictures, publish them in the forum moments, and interact with friends. Pop-up prompt when the user first uses the APP Yes
2 System notification Send a notification to the user Pop-up prompt when the user first uses the APP Yes
3 Microphone (recording) Based on the user's active operation, you can shoot/upload and recorded videos, publish them in the forum moments, and interact with friends. Pop-up prompt when the user first uses the APP Yes
4 Device Unique Identifier (ANDROID ID) Safe operation and risk control verification. To ensure the safe operation of the software and services, to prevent your personal information from being illegally obtained, and to more accurately prevent fraud and protect the account security Pop-up prompt when the user first uses the APP Yes
5 Network permissions Turn on the Internet access function, read and update in real time yes
6
(3) How do we store your personal information
Unless otherwise provided by laws, regulation, rules, or normative documents, we will store your information for the following period:
1. We will retain your personal information for the period necessary to achieve the purposes stated in this Privacy Policy, unless required by laws, regulations, rules, or normative documents require or permit the storage of such information for a longer period.
2. Your personal information is anonymized and the data can be used and circulated. We do not require further notice and consent for the preservation and processing of such data.
(4) How do we use Cookie and similar technologies
1. Cookie
To ensure that the website works efficiently and gives you easier access experience, we sometimes store minor data files called Cookie on your device terminal / system. Cookie will favor recalling in your information during subsequent visits to our website, simplifying the process of filling out your personal information (such as login, etc.).
We will not use Cookie for any purpose other than the purposes stated in this Privacy Policy. You can manage or delete Cookie according to your preferences. You can clear all Cookie saved on your PC or mobile device, and you have the right to accept or reject Cookie. Most browsers automatically accept Cookie, But you can usually modify your browser's settings to refuse cookies according to your own needs; Also, you can clear all cookies saved in the software. But you may not be able to fully experience some of our convenient service functions.
2. Other similar technologies
At present, we do not use other similar technologies other than cookies.
(5) How do we entrust to process, share, transfer, public disclosure your personal information?
1. Entrusted processing
Technical modules of certain functions in our service are provided by a third party and are connected to our APP in the form of a Software Development Kit (SDK) or an Application Interface (API). We will sign strict confidentiality agreement with such third parties, requiring them to properly protect and process your personal information in accordance with our requirements, this Privacy Policy and related confidentiality and security measures.
Specific situation of user information collection and used by third party SDK
S/N SDK name Purpose of usage Collection of personal information used Name of third-party organization Third-party website links 1 Baidu Map Map, location Networking Information, Network Requests, IP Addresses, Location Information Beijing Baidu Netcom Science and Technology Co., Ltd. https://lbsyun.baidu.com/ 2 Umeng SDK Used for data analysis Networking information, Mac address, Unique Device Identification code (IMEI/IMSI), IP address, location information Youmeng Tongxin (Beijing) Technology Co., Ltd., https://www.umeng.com/ 3 Alibaba Cloud Push For message push Networking information, Network status, Mobile phone status, Unique device identification code (IMEI/IMSI), IP address Alibaba Cloud Computing Co., Ltd. https://www.aliyun.com/product/cps/ 4 Alibaba Cloud one-click login Number authentication service, based on the mobile phone number to complete the login or authentication Network information, Mobile phone number, Operation type, Mobile phone model, IMEI, IMSI, Mac, IP address, SIM card type Alibaba Cloud Computing Co., Ltd. https://www.aliyun.com/product/dypns 5 HMS HMS Core provides end-to-end and cloud open capabilities to help developers achieve efficient application development, rapid growth, and commercial monetization, enabling developers to innovate, and providing high-quality content, services and experiences for global users. Unique device identification code (IMEI/IMSI), IP address, Storage permission, Network request, Phone model, System type Huawei Terminal Co., Ltd. https://developer.huawei.com/consumer/cn/hms 6 Our product is developed based on DCloud uni-app (5+App/Web2App). During application operation, you need to collect your unique device identification code (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information, OAID) to provide statistical analysis services, and improve performance and user experience through application startup data and abnormal error log analysis, so as to provide better services for users. For details, please visit DCloud User Service Terms.
Note: The above SDK collects personal information by the SDK directly from the user through the APP and uses it according to the purposes listed in the above SDK. The relevant SDK may request for relevant permissions based on the purpose of its use when the APP is in the background, if requesting your MAC address, etc., please know.
2. Shared
We will not share your personal information with any company, organization or individual, except in the following cases:
a) Get your explicit consent or authorization in advance.
b) Based on legal circumstances: requirements made by judicial organs or government agencies in accordance with the legal provisions and litigation and other dispute resolution need.
3. Transfer
We will not transfer your personal information to any other company, organization, or individual, except in the following cases:
a) As our business evolves, we and our affiliates are likely to execute mergers, acquisitions, asset transfers, or other similar transactions. If the transaction involves the transfer of your personal information, we will require the companies, organizations and individuals that hold your personal information to continue subject to subject to this Privacy Policy, otherwise we will require the company, organization, and individuals to re-obtain your authorized consent.
b) After the transfer with your express consent, i.e., with your express consent, we will transfer your personal information we obtain from other parties.
4. Public disclosure
We will only publicly disclose your personal information in:
a) Have already obtained your clear consent.
b) In the case of providing your personal information under the requirements of national laws, mandatory administrative law enforcement or judicial activity, we may publicly disclose your personal information according to the type of personal information and the method of disclosure required. To the extent possible, when we receive the request for the disclosure of the information mentioned above, we will request the requesting party to publish the legal documents, such as a summon or a letter of investigation.
c) Other circumstances permitted by the national law.
(6) How can we protect your personal information
1. Data security measures
To secure your information, we strive to take a variety of physical, electronic, and administrative security measures that meet industry standards to protect your personal information from unauthorized access, public disclosure, use, modification, damage, or loss. We will do our best to take all possible measures to protect your personal information. Use SSL encryption protection to exchange data between your browser and services; provide https secure browsing of the website itself; use encryption to ensure data confidentiality; use protection mechanisms to prevent malicious attacks; deploy access control mechanisms to ensure that personal information is accessible by authorized personnel; And hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
2. Account security
The Internet is not an absolutely secured operating environment. We strongly recommend that you protect your account by a complex password. If you find out that your personal information is leaked, especially if your account number and password is leaked, please contact us instantly according to the contact information provided in this privacy policy, so that we can take appropriate measures.
3. Handling of personal information security incidents
In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the laws and regulations of the country where you are located: the basic situation and possible impact of the security incident, the measures we have taken or will take, and you can prevent and reduce risks on your own. advice, remedies for you, etc. We will promptly notify you of the relevant information of the event by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
(7) Your right to manage your personal information
In accordance with Chinese laws and with appropriate reference to the general practice of other countries or regions, we guarantee that you exercise the following rights to your personal information:
You have the right to access and edit your personal information, except for exceptions required by law. If you want to exercise your right to access and edit data, you can access and edit it yourself in the following ways. If you want to access and edit any personal information in your account or change your password, you can do it on the APP.
(8) Protection of minors' personal information
Based on the characteristics of our services, our websites and services are primarily for the adults, we do not provide any services to minors, and we refuse to gather private information about minors or send any promotional materials to them.
We will not seek or attempt to seek to receive any personal information from the minor. If a parent or guardian has a reason to believe that the minor has submitted private information to us without prior consent, please contact us to ensure that such personal information is deleted and warrants that the minor cancels its subscription and uses our services.
(9) Update of this Privacy Policy
To provide you with a better service, we will update the term of this policy in accordance with the product updates and the relevant requirements of laws and regulations. These updates will be part of this policy. We will not reduce your rights under this policy currently enforced without your express consent. In case of any case of this policy update, we will notify you through the APP client or other reasonable means so that you can keep abreast of the latest version of this policy.
(10) How to contact us
If you have any complaints, suggestion, questions about your personal information protection related issues, or if you have any questions about this policy, you can contact us through the following ways. We will review the questions involved and reply as soon as possible: support@capitalmaster.com.sg
(11) Dispute Resolution
If you are not satisfied with our response, especially if you believe that our personal information processing has harmed your legitimate rights and interests, you can also bring a lawsuit to the court with jurisdiction where the defendant is domiciled, or file a lawsuit by other means. Refers to solutions permitted by law in your country.