Privacy Policy
Last updated: August 12, 2023
Presentation clause
LUKA Platform operators (hereinafter referred to as "we") attach great importance to the protection of users' privacy and personal information, and thank you for your trust in us. We will take appropriate security protection measures according to the requirements of laws and regulations, do our best to protect your personal information safe and controllable, and provide you with reasonable and efficient privacy protection. In view of this, we have developed this Privacy Policy (" This Policy/this Privacy Policy ") to explain to you how we collect, use, store, protect and make your information available to the public, and to explain your rights.
This policy applies to the LUKA platform developed and operated by Luka Technology Co., LTD., as well as other Internet products developed and operated by Luka Technology Co., LTD. And its affiliates, provided that the privacy policies of other products are independently set and the collection, use, storage and protection of user information are different from those set out in this policy. The LUKA Platform is prohibited for registration or use by children under the age of 14, and the personal information of children under the age of 14 is subject to this policy and the Children's Privacy Protection Statement. This Privacy Policy does not apply to services provided to you in other independent ways, nor does it apply to products or services on the LUKA Platform that have separate legal notices and privacy policies. When third parties on our platform rely on our platform to provide you with services, the personal information you provide to third parties does not apply to this Privacy Policy.
Before using our products or services, please be sure to carefully read and fully understand this privacy policy, especially the terms marked in bold, may involve your important rights, you should focus on reading, after confirming full understanding and consent to use the relevant products or services. Once you begin to use the products or services provided by us, you have fully understood and agreed to what we have described in this policy.
Part I Definition
LUKA Platform: refers to the LUKA website and client.
LUKA Platform services: LUKA platform operators provide services to you based on the Internet in various forms including LUKA platform website, client, etc. (including new service forms arising from future technological development). If the user logs in or uses the products or services of the affiliated companies of the operators of the LUKA platform, and the associated products or services do not have an independent user service agreement and privacy policy, this privacy policy also applies to those products or services.
LUKA Platform operator: Luka Technology Co., LTD and its affiliates.
User: "You" or "User" refers to the individual or organization that registers, logs in, uses, views, and obtains the Services hereunder.
Personal information: refers to all kinds of information recorded by electronic or other means that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information, including the name of a natural person, date of birth, identity document information, personal biometric information, address, telephone number, etc.
Sensitive Personal Information: It refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment, including identity document information, personal biometric information, bank account, property information, whereabouts and tracks, communication content, information of children under 14 years old, health and physiological information, etc. (We will clearly identify specific personal sensitive information in this Privacy Policy by bolding and underlining).
Personal information deletion: refers to the act of removing personal information from the system involved in the realization of daily business functions, so that it remains unsearchable and inaccessible.
Unless otherwise agreed, the definitions used in this Policy have the same meaning as those in the User Service Agreement.
Part II Privacy Policy
This policy will help you understand the following:
Article 1 How do we collect and use your Personal information
Article 2 How do we use cookies and similar technologies
Article 3 How do we share, transfer and publicly disclose your personal information
Article 4 How do we store your Personal Information
Article 5 How do we protect your Personal information
Article 6 How do we handle minors' personal information
Article 7 How do you manage your Personal information
Article 8 How can this Policy be updated
Article 9 How can I contact us
Article 1 How We Collect and Use Your Personal Information
When you use our products and/or services, we need/may need to collect and use your personal information including the following two types:
1, In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the relevant information, you will not be able to use our products and/or services normally;
2. In order to provide you with additional functions of our products and/or services, you may choose to authorize the information we collect and use. If you refuse to provide, you will not be able to normally use the relevant additional functions or to achieve the functional effect we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.
We would like to remind you that:
1, we are committed to creating a variety of products and services to meet your needs. Because we may provide you with a variety of products and services, and different users choose to use the specific product/service scope is different, the corresponding basic/additional functions and the type and scope of personal information collected and used are different, please refer to the specific product/service function;
2. In order to bring you a better product and service experience, we are constantly striving to improve our technology, and we may introduce new or optimized functions from time to time, which may require the collection and use of new personal information or change the purpose or way of using personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up window, page prompts, etc., and provide you with the means of your own choice and consent, and collect and use after obtaining your express consent. During this process, if you have any questions, comments or suggestions, you can contact us through LUKA official customer service, we will answer you as soon as possible.
3. The LUKA and related services described in this policy may vary depending on the phone model, system version, software application version, mobile client and other factors you are using. The final products and services are based on the LUKA software and related services you use.
First, the basic function needs to collect and use information
(1) Registration and login
In the process of registering an account or logging in to LUKA, you need to submit some necessary information to us: your mobile phone number, created user name, nickname, gender. After verifying the registration and agreeing to this policy and the User Service Agreement, you will be able to complete the account registration, and you will be able to use the functions of sending messages, giving virtual goods, leaving comments and other functions on the LUKA platform. If you do not agree to authorize or refuse us access to the above information, you will not be able to enjoy the functions and services of the above registered users. During the registration process, if you provide the following additional information, it will help us to provide you with a better service and experience: profile picture, birthday, personal signature, interests and hobbies. If you do not provide this information, it will not affect the basic business functions of the Service.
(2) Real-name authentication
When you want to use the real name authentication function or related services on the LUKA platform, you need to complete the real name authentication. You agree and authorize LUKA Platform to complete the real name authentication necessary for specific products and services through the ID information you submit (all sensitive personal information). The above information will only be used to verify the authenticity of the user's identity, and LUKA Platform will adopt industry-common technologies to protect the personal information you provide, and use encryption, rights restriction and other means to prevent it from being used for other purposes (except for matters authorized by you separately).
If you do not agree to our collection of the above information, you will not be able to use the functions of real name authentication and related services on the LUKA platform, but it will not affect your use of other basic functions of the product.
(3) Browsing and following
As you browse the content of the LUKA platform, you can follow the users you are interested in. To this end, We will collect information about your use of the equipment when LUKA (including equipment types, operating system versions and Settings, IMEI/MEID/Android ID/IDFA IDFV/OAID/MAC address/IMSI/ICCID/UDID/GUID/GAID device identifier and sequence number, equipment Environment, the same below).
(4) Information release
You can post updates within LUKA, comment on other users' updates, and share them. In this process, we will collect your device information, network access log information and user log information (including account, operation time, operation record, network source address and destination address, network source port, client hardware features, nickname, introduction, remarks, identification, user information release, sharing, comment records, the same below).
When you use the personal Tags, friends preferences, News, voice, avatar/Instagram features, your uploaded text, pictures, voice, video messages are stored in our servers, as storage is necessary to implement this feature. You can delete this information at any time. Unless you choose or comply with relevant laws and regulations, we will not provide the above information to the public, or use it for other purposes other than this function. Please note that the information you publicly post may involve personal information or even sensitive personal information of you or others, such as you choose to upload text, pictures, voice, video containing personal information, please consider more carefully whether to share or even publicly share relevant information when using our services. If you do not agree to our collection of this information, please do not upload/post, this will not affect your use of other basic functions of the product.
Additional functions need to collect and use information
(1) Recharge consumption function
When you use LUKA top-up consumption function, we will collect your top-up record, consumption record information, so that you can query your own transaction records, while protecting your property and virtual property to the greatest extent. During the payment process, we may collect the user ID of your third-party payment channel. The above information is sensitive information, but the collection of the above information is necessary to achieve the relevant functions, otherwise it will not be able to complete the transaction. We cannot obtain your personal property information based solely on this information, nor can we identify specific natural persons.
(b) Additional functions based on camera/camera
You can use the functions of taking pictures, video shooting, scanning codes and face recognition after enabling camera/camera permissions. You can also use auxiliary devices such as flash in scenes such as photos. During a video call, we collect the content of your video call.
(3) Additional functions for photo/video access and upload based on photo album (photo library/video library)
You can use relevant functions to upload your photos/pictures/videos after opening the permission, so as to upload/change your profile picture, publish/share news, communicate with customer service and provide proof.
(4) Additional services based on microphone voice technology
After enabling the microphone permission, you can use the microphone to chat or record audio. During this process, we collect your voice content. Please be aware that even if you have agreed to enable microphone rights, we will only receive voice messages through the microphone when you actively click on the microphone icon in the client.
(5) Introduce Tencent bugly SDK to count the error information of the APP
In order to optimize the service functions of the APP, we use Tencent Bugly SDK to count the error information of the APP (such as APP flash back log, stuck log, etc.), for which we need to obtain your unique device ID. Tencent bugly SDK privacy agreement link: https://static.bugly.qq.com/bugly-sdk-privacy-statement.pdf
(6) Introduction of Google API
Sign in with your Google account (get your account information after you confirm), and invoke Google Play payment (pay process after you confirm);
Google Privacy Policy Links:
https://www.google.com/policies/privacy/
(7) Search
When you use the search service, we will collect your search keyword information, clipboard, to provide efficient search services.
(8) Customer service disputes and handling
When you contact us or file a complaint, appeal or consultation, in order to protect your account and system security, we require you to provide the necessary personal information to verify your true user identity. In order to facilitate contact with you, help you solve the problem as soon as possible, or record the solution and results of the relevant problem, we may save your communication, correspondence/call records and related content (including account information, other information you provide to prove relevant facts, or contact information you leave). If you refuse to provide the above information, we may not be able to provide timely feedback on complaints, appeals or consultation results.
(9) Security guarantee
To ensure the safe operation of the software and services, protect network security, prevent cybercrime, identify anomalies in your account, and for anti-fraud purposes, We collect your network access log information and user log information, device information, device location information (including IP address, GPS location, and WLAN access points, Bluetooth and base stations that can provide relevant information, i.e. sensor information), software version number, method of access to the network, type and status, carrier, SSID and BSSID, network quality Data, software installation list, running process information, overall operation of the application, overall installation usage, performance data, application source, and other log information (details of time and frequency of use, device statistics, critical operation paths, error logs, crash logs, language and time zone, Internet Protocol (IP) addresses, Internet service provider (IS) P), reference/exit page, operating system, date/time stamp and clickstream data).
(10) Provide personalized recommendation, display or push services
In order to analyze the characteristics of your preferences, habits and location in order to provide you with more suitable customized services, we will collect the following information from you:
2. Feedback, Posting, likes, comments, tips and other interactive information provided by you will be stored in our servers, because storage is necessary to achieve this function;
3. The location information of the device after obtaining your express consent (IP address, GPS location, and WLAN access points, Bluetooth and base stations that can provide relevant information, namely sensor information), GPS location information is sensitive information, refusal to provide this information will only make you unable to obtain the platform services based on GPS location, but will not affect your normal use of other functions. You can go to [My → Settings → Privacy Settings] to select nearby stealth, clear location information, show/hide the distance between other users.
4. Name and information about the device running application.
5. Obtain device GAID for identifying interactive users.
Unless authorized by you or otherwise required by law or regulation, we will not combine the above information with any personally identifiable information you provide in the application to ensure that you are not personally identified. We will combine the above information with the information from our other services to carry out feature and preference analysis through the program algorithm and indirect population portrait based on the feature label, in order to personalized recommend, display or push specific chat room, audio and video, user, dynamic and other information that you may be interested in, or push specific functions or services that are more suitable for you:
1. Show, recommend or push chat rooms, audio and video that are more relevant to you;
2. Recommend users, audio and video information of relevant cities and regions;
3. Use the scope and method agreed in the User Service Agreement to push and invite business information to you.
(10) Additional functions based on local storage
By enabling the local storage permission, you can download some text, pictures, videos and other content cache data to your mobile storage, and upload your local pictures, videos and other data to LUKA through mobile storage.
Third, we may apply for access to the equipment
In the process of providing services, in order to collect the above information and implement the above functions, we may need to apply for some device application permissions from you. These permissions are not turned on by default and are only used with your express authorization to implement specific features or services, and you can withdraw your authorization. In particular, even if we have obtained these sensitive permissions with your authorization, we will not collect your information when it is not needed by the relevant function or service. At the same time, please be aware that we use third-party SDKS for the functional and security needs of our business and products, and you may also use H5 pages or small programs developed by third parties in the process of our products, and these third parties may also apply for or use relevant operating system permissions.
You may apply for and use the following operating system permissions:
(1) List of application permissions of Android operating system
1. Read the contents of the SD card (read the storage space/photo permission)
Function description: Provides the function of reading the data in the storage space of the mobile phone
Usage Scenario and purpose: Allows apps or small programs to read pictures and files in storage. It is mainly used to help you publish information, upload pictures and files such as avatars, and record crash logs locally
2. Write/delete contents in SD card (write/delete/storage space/photo permission)
Permission Function description: Provides the function of writing to external storage
Usage scenario and purpose: Allow the App or small program to write/download/save/cache/modify/delete pictures, files, crash logs and other information
3. Read the status and identity of the phone (phone permissions, device permissions)
Permission function description: To provide information such as reading the mobile phone device ID, please rest assured that the permission cannot monitor and obtain any of your call content and information
Usage Scenario and purpose: Read the call status and identification code of the device, identify the device ID, and perform functions such as audio and video, information display, account login, and security
4. Access approximate location information
Permission Function Description: Obtain approximate geographical location information through network location information, such as base stations and WLAN
Usage scenario and purpose: It is used to complete security services and location-based services (LBS), such as recommending nearby users, publishing coordinate positioning of works, and using location-based services for small programs
5. Access precise location information
Access to accurate geographic location information through Global Positioning System (GPS) or network location information (such as base stations and WLAN)
Usage scenario and purpose: It is used to complete security services and location-based services (LBS), such as recommending nearby users, publishing coordinate positioning of works, and using location-based services for small programs
6. The recording android. Permission. RECORD_AUDIO
Permission Function Description: Use the microphone to record audio
Usage Scenario and purpose: This function is used to help you release audio and video information, broadcast live, and make voice calls
7. Take photographs and video android. Permission. CAMERA
Permission function description: Use to take photos and videos,
Usage Scenario and purpose: This function is used to help you release audio and video information, broadcast live, take photos, and make video calls
(2) List of application permissions for the iOS operating system
1.NSPhotoLibraryAddUsageDescription
Permission Function Description: Add content to the album
Usage scenario and purpose: Allow the App to write/download/save/modify/delete pictures, files, crash logs and other information
2.NSPhotoLibraryUsageDescription
Permission Function Description: Read the contents of the album
Usage scenario and purpose: Allow App to read stored pictures, files and other content, mainly used to help you publish information and other functions
3.NSCameraUsageDescription
Permission Function Description: Use the camera
Usage scenario and purpose: This function is used to help you release audio and video information, broadcast live, take photos, and make video calls
4.NSLocationAlwaysUsegeDescription
Permission Function Description: Continuously obtain the geographical location
Application scenario and purpose: Used to provide security assurance, recommendation information, and location-based services (LBS)
5.NSLocationWhenInUseUsageDescription
Permission function description: Get the geographical location only when the App is used
Application scenario and purpose: Used to provide security assurance, recommendation information, and location-based services (LBS)
6.NSLocationAlwaysAndWhenInUseUsageDescription
Permission Function description: Get the location continuously and only when the App is in use
Application scenario and purpose: Used to provide security assurance, recommendation information, and location-based services (LBS)
7.NSContactsUsageDescription
Permission Function Description: Read the user address book
Usage scenario and purpose: For friend recommendation
8.NSMicrophoneUsageDescription
Permission Function Description: Use the microphone
Usage scenario and purpose: This function helps you release audio and video information, broadcast live, and make voice calls
10.NSUserTrackingUsageDescription
Permission Function Description: Obtain the device ID to identify device information
Usage scenario and purpose: Identifies devices, ensures service security, and improves browsing experience
Information from third parties
(1) Third-party account authorization
When you register or log in to the product through a third-party account, we will obtain the public information (including profile picture, nickname, gender, age) of the third-party account you use to log in, and bind the account to your product account. This is to remember your login identity as a LUKA user in order to provide you with better quality products and/or services. We will only collect and use your personal information within the scope of your consent. If you do not agree to authorize or refuse us to obtain the above information, you will not be able to register or log in to the product through a third-party account, but it will not affect your normal use of other functions of the product.
After you register or log in with a third party account, your third party account will be bound to your LUKA account, but you can choose to unbind your account in [My → Settings → Account and security], or contact the LUKA website customer service: [My - customer service] - enter "Manual customer service" for operation.
(2) Information shared by other users contains your information.
Sensitive personal information
Before providing any sensitive Personal information, please clearly consider that such provision is appropriate and agree that your sensitive Personal Information may be processed for the purposes and in the manner described in this Policy. We will collect and use your sensitive personal information to achieve relevant business functions after obtaining your consent, and allow you to choose not to consent to the collection and use of such sensitive personal information, but refusing to use such information will affect your use of relevant functions.
Vi. Exceptions to authorized consent
According to relevant laws and regulations, we may collect and use some necessary personal information without your authorization and consent under the following circumstances:
1. Directly related to national security and national defense security;
(2) Directly related to public safety, public health and major public interests;
(3) Directly related to criminal investigation, prosecution, trial and execution of sentences;
4, for the protection of your or other individuals' life, property and other major legitimate rights and interests, but it is difficult to get my consent;
5. The collected personal information is disclosed to the public by you;
6. Collect your personal information from legally publicly disclosed information, such as from legitimate news reports, government information disclosure and other channels;
7. Necessary for the signing and performance of the contract according to your requirements;
8, necessary for the safe and stable operation of LUKA's products and/or services, such as the detection and disposal of product or service failures;
9. Necessary for legitimate news reporting;
10. When an academic research institution conducts statistics or academic research in the public interest, and provides the results of academic research or description to the outside world, it de-identifies the personal information contained in the results;
11. Other circumstances provided by laws and regulations.
Please be aware that if we take technical measures and other necessary measures to process personal information in such a way that the recipient of the data cannot re-identify a specific individual and cannot recover it, the use of the data after such processing does not require further notice to you and your consent.
If we stop operating the LUKA Platform products or services, we will promptly stop the activities of continuing to collect your personal information, notify you of the suspension of operations in the form of one-by-one delivery or announcement, and delete or anonymize the personal information held by us related to the closed business.
Article 2 How We Use Cookies and similar Technologies
Similar technologies such as cookies and device information identification are commonly used in the Internet. When you use LUKA and related services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device in order to collect and identify information about your access to and use of the Product. We undertake not to use cookies for any purpose other than those described in this Policy. We use cookies and similar technologies primarily to achieve the following functions or services:
(a) to ensure the safe and efficient operation of products and services
We may set authentication and security cookies or anonymous identifiers that allow us to verify that you have logged into the Service securely or that you have been subjected to theft, fraud or other wrongdoing. These technologies will also help us improve service efficiency and speed up login and response times.
(2) Help you get a more relaxed visit experience
Using such techniques can help you avoid repeating the steps and processes you used to fill out your personal information and enter your search content (example: record search, form filling).
(3) To recommend, display, and push content or users that you may be interested in
1. We may use such technology to understand your preferences and usage habits and conduct data analysis to improve products and services and recommend information or features of interest to users.
2. We may use cookies to record browsing activity, to recommend information to you, to detect crashes, delays related anomalies, and to explore better ways to serve.
(4) Clearing of cookies
Most browsers provide users with the ability to clear the browser cache data, you can do so in the browser Settings function. If you clear, you may not be able to use the services or functions provided by us that rely on cookies.
Article 3: How We share, transfer, and publicly disclose your Personal Information
(1) Sharing
We will keep your information confidential and will not share or provide your personal information, except in the following circumstances:
1. Sharing with express consent: After obtaining your express consent, we will share your personal information with you.
2. Sharing under legal circumstances: We may share or provide your personal information with judicial and administrative authorities in accordance with laws and regulations, litigation and dispute resolution needs, or as required by administrative and judicial authorities.
(2) 3. Sharing with Affiliates: In order for us to provide you with products and services based on LUKA's or its affiliates' accounts, recommend content and information that may be of interest to you, identify account anomalies, and protect the security of LUKA's or its affiliates' accounts and property, your personal information may be shared with our affiliates and/or their designated service providers. We will only share necessary personal information, and subject to the purposes stated in this policy, if we share your personal sensitive information or affiliates change the purpose of the use and processing of personal information, we will again seek your authorized consent.
4. Sharing with authorized partners: In order to provide you with more complete and high-quality products and services, we may entrust authorized partners or access third-party services to achieve some technical functions (such as embedded code, plug-ins, SDKS, etc.) to provide services for you or perform functions on our behalf. We will only share your information for the lawful, legitimate, necessary, specific and clear purposes of this policy statement, and the above third party services can only access the user's personal information needed to perform their duties, and guarantee that they will adopt industry-common technologies to protect your personal information security.
Currently, our authorized partners include the following types:
(1) Basic service providers: including payment, message push, geolocation, anti-fraud partners, and information sharing with these service providers is mostly through the SDK.
(2) Partners who provide data services (including data statistics and data analysis) : In order to maintain/improve our products/services and provide you with better content, we may share your relevant information with designated partners who provide such services (including: Device information, terminal model, geographic location), we will not share your personally identifiable information with them unless we have your consent.
(3) Content Security Monitoring service providers: We may work with certain content security monitoring service providers for non-compliance audio and video tagging and analysis, and may share live stream information with these service providers.
(4) Partners that provide broadcasting or live streaming services: When we cooperate with third-party platforms that provide broadcasting or live streaming services, we may share user data that has been made public in chat rooms, such as user nicknames, leaderboards, and tip information.
(2) Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
1. Transfer with express consent: After obtaining your express consent, we will transfer your personal information to a third party;
2. In the case of mergers, acquisitions and bankruptcy liquidation, such as the transfer of personal information, we will require the transferee to continue to be bound by this policy, otherwise we will require the transferee to seek authorization from you again.
(3) Public disclosure
We only publicly disclose your personal privacy information in the following circumstances:
1. With your express authorized consent or based on your active choice;
2. Disclosure based on national laws and regulations;
3. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of LUKA Platform, or in order to protect the personal and property safety of LUKA Platform users or the public from infringement, we may disclose your personal information in accordance with laws and regulations or with your consent.
Article 4: How We Store Your Personal Information
(1) Storage location
In order to provide services to users around the world, we operate globally. You hereby authorize us to transfer, store and use your data in any country or territory where we operate, including the following: Hong Kong, China. To this end, we will ensure the security of your data and the protection measures will be no less than the protection standards in your country.
(2) Storage period.
We will only retain your personal information for as long as necessary to achieve the purposes described in this Policy, unless retention is required by law. In determining the storage period of personal information, we mainly refer to the following criteria and take the older one as the criterion:
1. To comply with applicable laws and regulations;
2. To comply with court judgments, orders or other legal procedures;
3. To comply with the requirements of government authorities or legally authorized organizations;
4. Use reasonably necessary to implement the Platform agreement or this Policy, safeguard the public interest, protect the personal safety or other legitimate rights and interests of LUKA and its affiliates, other users or employees.
After your personal information has exceeded the retention period, we will delete your personal information or anonymize it.
Article 5 How We Protect Your Personal Information
1. We attach great importance to the security of your personal information, and strive to take all reasonable security measures (including technical and management aspects) to protect the security of your personal privacy information, and prevent the personal privacy information you provide from being improperly used or unauthorized access, public disclosure, use, modification, damage, loss or disclosure.
2. We will use reasonable and feasible means to protect your personal information, such as encryption technology and anonymization, which are no less than those of our peers in the industry, and use security protection mechanisms to prevent malicious attacks on your personal information.
4. We have developed a strict emergency response plan and regularly organized drills to ensure that losses can be reduced to a minimum in case of emergencies. In the event of a user information security incident (leakage, loss, etc.), we will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you. We will timely inform you of the relevant events in the form of push notifications, emails, letters, SMS, etc. If it is difficult to inform you one by one, we will take a reasonable and effective way to release announcements. At the same time, we will also report the disposal of user information security incidents in accordance with the requirements of relevant regulatory authorities.
5. We have set up a dedicated personal information protection department to implement internal control management within the company.
6. While ensuring the security of your personal privacy information, we also suggest that you improve your awareness of personal privacy information prevention, do not disclose your personal privacy information to others through the Internet, and do not click the link sent by others at will.
Article 6 [How We Handle Minors' Personal Information]
LUKA's products and services are aimed at adults. If you are a minor, we recommend that you do not use our products and/or services, if you must use our products and/or services, you should read this policy with a guardian, and you should ensure that you have obtained the consent of your guardian to use our services and provide us with your information.
If your guardian does not agree with your use of our services or the provision of information to us in accordance with this policy, please terminate your use of our Services immediately and notify us in time.
In cases where personal information of minors is collected with the consent of parents or legal guardians, we will only use or publicly disclose this information when permitted by law, with the express consent of parents or guardians, or when necessary to protect minors.
If you are the guardian of a minor and have questions about the personal information of a minor under your custody, please contact us using the contact details in Section 9 of this Policy, "How to Contact Us". We will protect the confidentiality and security of minor user information in accordance with relevant national laws and regulations and the provisions of this policy. If we become aware that a minor's personal information has been collected without prior verifiable guardian consent, we will seek to delete the data as soon as possible.
Please note that children under the age of 14 are prohibited from registering and using our products and/or services. If we identify that the user is a child under the age of 14, or if the information shared by other users contains a child's personal information, the child's personal information is subject to both this policy and the Children's Privacy Protection Statement.
If you are the guardian of a child, you should carefully read this policy, product-specific privacy guidelines (if any) and the Children's Privacy Protection Statement. If you have any questions or rights regarding the protection of the personal information of a child under your custody, please contact us through the contact information disclosed in the Children's Privacy Protection Statement. We will process and respond to you within a reasonable time.
Article 7: How You Manage Your Personal Information
We attach great importance to your management of personal information, and do our best to protect your rights to query, access, modify, delete, withdraw consent, cancel account, complain and report, and set up privacy functions of your personal information, so that you have the ability to protect your privacy and information security.
(1) Change or withdraw the scope of authorization
1. Change or revoke sensitive permission Settings
You can turn off precise geolocation information, camera, microphone, photo album permissions in the device's own operating system to change consent or withdraw your authorization. We will no longer collect information related to these permissions after the authorization is withdrawn.
2. Change or withdraw consent
You may change or withdraw your consent by contacting us through the contact details in Section 9 of this Policy, "How to Contact Us."
3. Change or withdraw authorized information processing
Specific business functions and services will require your information in order to complete, when you withdraw consent or authorization, we can not continue to provide you with the corresponding functions and services to withdraw consent or authorization, and no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect our previous processing of personal information based on your authorization.
(b) Access, delete, correct/modify your personal information
1. Query, access, correct/modify, and delete personal account information
You can query, access your avatar, nickname, gender, birthday, signature, personal tag, and you can query, access, correct/modify your profile at "Modify Profile".
2. Query, access, correct/modify, delete other personal information
a. Go to [News] to access and delete your post's news
b. Access [Follow] to access and query the information of the following account, click the "followed" button (if any) after the corresponding account in the follow list or go to the home page of the corresponding follow account, click the upper right corner to unfollow the account
c. Access [Account and Security] to access, correct/modify, bind mobile phone number, third-party account
d. For security and identification reasons, you may not be able to modify some of the information submitted; If you really need to modify such information, please contact us through the "How to contact us" section of Article 9 of this policy, we will review the problem as soon as possible, and have your user identity verified by a person to reply in a timely manner.
3. Control the visibility of information
a. Enter the "blacklist" to control whether others can communicate with you and whether they can view your account content
When we assist you in deleting the relevant information, we may not be able to immediately delete the relevant information from the backup system due to applicable laws and security technologies, and we will securely store your personal information and isolate it from any further processing until the backup can be erased or anonymized.
(3) Cancel your account
You can apply for cancellation of your account in the following ways:
Self-service application for cancellation: 【 Account and security 】-【 Account cancellation 】 to apply.
You need to meet the conditions of LUKA account cancellation to apply for cancellation, LUKA platform personnel after approval by the user to confirm the cancellation. You acknowledge and understand that the act of canceling your account is irreversible, and when you cancel your account, we will delete the relevant information about you or anonymize it, except as otherwise provided by laws and regulations.
After the account is cancelled, all the content you have posted will be published anonymously. If you need to delete the content, please handle it yourself before applying for cancellation.
The cancellation of the account does not mean that the conduct and related responsibilities before the cancellation of the account are exempted or mitigated in any form.
(4) Constraint information system automatic decision-making
In some business functions, we may make decisions based solely on non-human automatic decision mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us to make an explanation, and we will also make a reasonable explanation without infringing LUKA's trade secrets or other users' rights and interests, social public interests, and national interests.
(5) Complaints and reports
You can make a complaint or report according to our published system. If you believe that your personal information rights may have been infringed, or if you find a clue that your personal information rights have been infringed, you may contact us using the contact details in Section 9 "How to Contact Us" of this Policy.
(6) Responding to your above requests
When you make the above request, we may ask you to verify your identity in order to protect the security of your account. If you refuse to provide relevant supporting materials, we will not be able to respond to your request.
Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all of your requests and we will respond to your requests within a reasonable period of time.
In the following circumstances, according to the requirements of laws and regulations, we will not be able to respond to your request:
1. Related to national security, national defense security and national interests;
2. related to public safety, public health, major public interests;
(3) related to criminal investigation, prosecution, filing, trial and enforcement of judgments;
4. There is sufficient evidence to show that you have subjective malice or abuse of rights;
5. Responding to your request will cause serious damage to the legitimate rights and interests of other individuals and organizations;
6. Involving trade secrets;
7. Other circumstances provided by law.
Article 8 [How this Policy is Updated]
In order to ensure that you can get better service and in response to the platform business adjustment and future development, this policy will also be updated with The Times. However, at the same time of updating, we will obtain your authorization in a separate and obvious way, otherwise we will not reduce your rights under this privacy Policy currently in effect.
We will remind you of the update of the relevant content in a reasonable, appropriate and obvious way after the update of the application, the official website or the announcement of the platform, so that you can understand the change of your rights more quickly. You can also go to [I - Settings About - Privacy Policy] to view the full content of this policy.
For major changes, we will also provide more prominent notification methods (we will express policy updates to you by means including but not limited to email, SMS, in-site messages, announcements, home page or special reminders on the browsing page).
Material changes referred to in this Policy include, but are not limited to:
1. Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
2. We have made significant changes in our ownership structure, organizational structure, etc. Such as business adjustment, bankruptcy merger and acquisition caused by the owner change;
3. The main object of personal information sharing, transfer or public disclosure has changed;
4. Significant changes in your rights to participate in the processing of personal information and the way in which they are exercised;
5. When the department responsible for handling personal information security, contact methods and complaint channels change;
6. When the personal information security impact assessment report indicates that there is a high risk.
If you do not agree with the revised Privacy Policy, you have the right and shall immediately stop using LUKA's products and services. If you continue to use LUKA's products or services, you will be deemed to accept the changes made by LUKA to the relevant terms of this Policy.
Article 9 How to Contact Us
If you have any questions, comments or suggestions about this policy, you can contact us by:
E-mail: lukadeveloper01@gmail.com
We will review the issue as soon as possible and respond within seven working days of verifying your user identity.
The validity, interpretation, modification, execution and dispute resolution of this Agreement shall be governed by the laws of Hong Kong, China. Any dispute arising out of this Agreement shall be handled in accordance with the laws of Hong Kong. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimate rights and interests, the LUKA platform operator shall negotiate with you to solve the problem. If no agreement can be reached through negotiation, either party shall submit the case to the Hong Kong Arbitration Center for arbitration in accordance with the arbitration rules of the Hong Kong Arbitration Center. The place of arbitration shall be Hong Kong and the language of arbitration shall be Chinese.
Children's Privacy Statement
Last updated: August 12, 2023
The operator of the LUKA Platform (hereinafter referred to as "We") is committed to protecting the personal information of children (minors under the age of 14, the same below). The purpose of the Children's Privacy Protection Statement (" This Statement ") and the Privacy Policy is to explain to guardians (" you ") and children how we collect, use, store and process children's personal information and how we provide you with access, correction, deletion and protection of such information. Unless otherwise agreed, the terms and acronyms used in this statement have the same meaning as those in the User Service Agreement and Privacy Policy.
Special instructions for Guardians of children:
The LUKA Platform prohibits children from registering and using our products and/or services. If we recognize that a user account is registered and/or used by a child, we will block the account and take special measures to protect the child's personal information in accordance with this statement. We hope that you can work with us to protect children's personal information, educate and guide children to enhance their awareness and ability to protect personal information, and guide, remind and require them not to provide any personal information to any network products and service providers without your consent.
Special note for children:
We recommend that any child participating in online activities should obtain the prior consent of their guardian. If you are a minor under the age of 14, you should read this statement carefully with your guardian and not use our products, services or provide information to us.
Please understand that this statement applies to our collection, use, storage, sharing, transfer and disclosure of children's personal information through the Internet. The Privacy Policy sets out how we generally handle personal information, and its contents also apply to children. If some provisions of the Privacy Policy are inconsistent with the terms of this Statement, this Statement shall prevail within the scope of such terms, and the Privacy Policy shall prevail for matters not covered in this Statement. Please understand that due to the nature of the Internet service, we may not be able to accurately identify the children of real users. If you are a guardian of a child or a child and believe that we may be improperly holding information about you or your child under custody, or have any questions about this Statement or matters related to this Statement, you may contact us through the publicly available contact information set out at the end of this statement. We will process or reply as soon as possible
We remind you that important terms in this Statement that are closely related to your rights and interests and those of the children in your custody (which may be) have been specially reminded in bold font for your attention.
If you have any questions or rights requests during the reading of this statement and other personal information related matters, we provide you with a special feedback channel, specifically refer to the "How to contact us" section of Article 6 of this statement, we will answer you as soon as possible.
This statement contains the contents
I. Collection and use of children's personal information
2. Sharing, transfer and disclosure of children's personal information
Storage and protection of children's personal information
Management of children's personal information
Six, how to contact us
I. Collection and use of children's personal information
We strictly abide by the provisions of laws and regulations and the agreement with the user, according to the specific circumstances of the user's choice of products and services, collect and use your and your children's personal information:
1. In the real name authentication of some individual services or products, we may ask users to enter their birthday, personal age or identity authentication to identify whether the user is a child. When we identify that the user is a child under the age of 14, we will refuse the user to register and/or continue to use the relevant products or services, block the user account, and terminate the collection of the user's personal information.
2. When we identify the user as a child under the age of 14 based on the above information provided by the user, we may collect your contact information, including mobile phone number and email address, and use this information to contact you to verify the guardianship relationship between you and the child under your custody. In order to better protect the rights and interests of the child, we may also collect additional information from the guardian (such as name, ID information or other proof of guardianship) to further verify the guardianship relationship between the guardian and the child. We may, but are not obligated to, transfer the child's account to you, provided that you do not return the account to the child, in accordance with the specific program for verifying the guardianship relationship for the product or service and obtaining your consent. Please understand that you can choose whether to fill in or provide us with specific information, but if you do not fill in or provide certain specific information, we may not be able to verify your guardianship relationship with the child, and you may not be able to normally use our products, services or related specific business functions.
3. We may not be able to identify the user as a child under the age of 14 for various reasons, and we will collect relevant personal information in the process of using the product or service. For details, please refer to the section "How we collect and use your Personal Information" in Article 1 of the Privacy Policy to learn more about the purposes, methods and types of personal information we collect and use.
4. We strictly abide by the provisions of laws and regulations and the agreement with users, and use the information collected by you and the children under your custody for the following purposes:
(1) Verifying the identity of children and guardians;
(2) For the optimization of products or services, safety and security, service investigation, and handling of complaints related to children.
2. Sharing, transfer and disclosure of children's personal information
(1) Sharing
We may share a child's personal information with third parties only with the prior consent of the guardian, except in the following circumstances:
1. Sharing with the Guardian, we will share some of the child's personal information (such as the child's user name, account number, password, as well as the child's transaction content and behavior logs in some of our products and services) with the guardian, and the guardian can access and manage the child's personal information;
2. For the purpose described in Article 1 of this Statement, "Collection and Use of Children's Personal Information";
(2) Transfer
1. With the continuous development of our business, when merger, acquisition, asset transfer and other transactions occur, it may lead to the transfer of children's personal information to the transferee. We will conduct a security assessment and require the transferee to continue to be bound by this statement, otherwise we will require the transferee to seek authorization from the guardian again.
2. When we do not recognize that the user is a child under the age of 14, we transfer the user's personal information in accordance with the Privacy Policy.
3. After obtaining the consent of the guardian, we will transfer the child's personal information to other parties.
(3) Disclosure
Under normal circumstances, we will not disclose children's personal information without the prior consent of the guardian, except in the following circumstances:
1, comply with applicable laws and regulations and other relevant provisions;
2. Comply with court judgments, rulings or other judicial requirements;
3. Comply with the requirements of relevant government agencies or other legally authorized organizations;
4. We have reason to believe that we need to comply with relevant laws and regulations;
5, for the implementation of the relevant service agreement or this statement, to safeguard the public interest, to protect our customers, our or our affiliates, other users or employees of the personal property safety or other legitimate rights and interests of reasonable and necessary purposes.
Storage and protection of children's personal information
The personal information of children collected and generated by our operations is stored in Hong Kong, China. To this end, we will ensure the security of children's data, and the protection measures will be no less than the protection standards in your country.
When we do not recognize that the user is a child under the age of 14, we will store and transfer the child's personal information, which may include cross-border transfers, in accordance with section 4 "How we Store Your Personal Information" of the Privacy Policy.
We will use encryption and other technical measures to store children's personal information to ensure information security. We will not store children's personal information for longer than is necessary to achieve the purpose for which it was collected and used. Please refer to section 4, "How We Store Your Personal Information," section 5, "How We Protect Your Personal Information," and section 6, "How We Handle Minors' Personal Information," of the Privacy Policy to learn more about how we store and protect children's personal information.
When our products or services cease to operate or the storage period of your and children's personal information expires, we will delete or anonymize your and children's personal information within a reasonable period of time.
Management of children's personal information
When we recognize that the user is a child under the age of 14, we will block the user account. Children will no longer be able to use the account to manage their personal information, but you can manage the ward's personal information. If we entrust your children's account to your management, you may refer to Article 7 of the Privacy Policy, "How do you Manage your Personal Information", to manage your guardian's personal information.
You and the child in custody may also use the contact information provided by us (see Section 6 of this statement, "How to Contact Us") for feedback and inquiries. We will contact you as soon as we have verified your feedback. Please understand that during the verification process, we may require you to provide personal information such as your child's account number, child's date of birth, contact information, identity document information, etc., in order to continue to respond to your needs after completing identity verification and problem verification.
(1) Access to children's personal information
You can view personal information provided or generated by children users in using our products or services, including but not limited to username, password, profile picture, nickname, gender, and unsolicited content.
(2) Correcting children's personal information
When you find errors in the personal information we collect, use and process about children, you can contact us to correct them. After we complete the identity verification and verification issues, we will take timely steps to correct them.
(C) Delete children's personal information
You can contact us to delete personal information collected, used and processed by children. We will take timely steps to remove the identity verification and verification issue after completion.
However, please note that if you ask us to delete the personal information of certain children, it may result in your being unable to continue using our products and services or certain specific business functions in our products and services.
5. Changes to this Statement
We may revise the terms of this Statement from time to time, and such revisions form part of this Statement.
We do not limit your rights under this Statement without your express consent. We will remind you of the update of the relevant content in a reasonable, appropriate and obvious way after the update of the application, the official website or the official announcement, so that you can be aware of any changes made in this statement.
For material changes, depending on the circumstances, we may also provide a more prominent notice describing the specific changes to this Statement.
The material changes referred to in this statement are as follows:
1, our service model has changed significantly;
2, LUKA platform ownership structure, organizational structure and other aspects of major changes;
3, the main object of information sharing, transfer or public disclosure has changed;
4, your rights to participate in the processing of personal information and the way they are exercised have changed significantly;
5. Our responsible departments, contact methods and complaint channels for handling personal information security have changed;
6. The personal information security impact assessment report indicates high risk.
Six, how to contact us
If you have any questions, comments or suggestions about this policy, you can contact us by:
E-mail: lukadeveloper01@gmail.com
We will review the issue as soon as possible and respond within seven working days after verifying your user identity;