Last updated: July 2, 2026
Update summary:
We have updated the contact information.
Thank you for using System Messages. Developed and operated by HEYTAP PTE. LTD. ("we", "us", or "our", registered at 138 MARKET STREET #15-03 CAPITAGREEN SINGAPORE 048946), System Messages (the "App") provides third-party apps with fundamental services such as the System Messages feature and InstantWeb.
During your use of our websites, mobile apps, or other products or services, we may collect and use your personal information. In this System Messages 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 System Messages, your rights to your personal information, and the security measures we use to protect your personal information.
Before using the feature, please carefully read this Privacy Notice to understand our practices regarding the collection, use, and protection of personal information. By tapping "Agree" to launch System Messages, you acknowledge that you fully understand the terms below regarding the collection and use of personal information and your rights.
The general terms in Part A apply to you, regardless of your location. Part B only applies to users located in the European Union, Liechtenstein, Norway, the United Kingdom, or Switzerland ("Europe"). Part C only applies to users who are residents of California, Nevada, Colorado, Connecticut, Virginia, or Utah in the United States, and provides more details about personal information to meet the disclosure requirements under the laws of these states. Part D only applies to users located in India. Part E only applies to users located in Brazil.
In principle, this Privacy Notice applies to all jurisdictions where we provide services through the App, as stated herein. However, different jurisdictions may have different requirements regarding the protection of personal information. Therefore, in addition to the general terms, we make disclosures through region-specific terms appended to this Privacy Notice to meet the special requirements of different jurisdictions. The appendices, along with the main part of this Privacy Notice, constitute our notice 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.
This Privacy Notice is divided into the following parts:
A. General Terms
B. Appendix: Europe-Specific Privacy Notice (GDPR-Compliant Terms)
C. Appendix: U.S. State-Specific Terms
D. Appendix: India-Specific Privacy Notice (DPDPA-Compliant Terms)
E. Appendix: Brazil-Specific Privacy Notice (LGPD-Compliant Terms)
Body
A. General Terms
1. How We Collect and Use Your Personal Information
The information we collect depends on the features or services you use, the context in which you interact with us, and the choices you make, including your privacy settings. The features or services provided by the App may vary by country or region, OS/app version, and the apps installed or downloaded on your device. Therefore, the actual features and services provided by the App, personal information that will be processed, and required app permissions are subject to the device you 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 deliver the required services, we may be unable to provide those services, nor will we be able to respond to or address any problems you may encounter. We collect personal information to operate more efficiently and provide you with the best possible experience. The following describes in detail what personal information we collect, as well as how and why we collect and use such information.
We collect information about you in three primary ways:
• 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
The System Messages APK file provides you with fundamental services, including the System Messages feature and InstantWeb.
System Messages
To provide you with push service and send you notifications about software updates or new product launches (including but not limited to marketing messages about our and relevant third-party products or services), you agree that we can temporarily store messages obtained from the concerned developers and collect information relating to your device (such as device identifiers, User ID, Android ID, Google Advertising ID, region and language settings, device model, and OS version), information about the apps using push service (such as the app package names), device status information (such as app launch and exit status, charging status, unlock status, screen-on status, and notification drawer status), network-related information (such as IP or domain name and network type), message sending results, notification status (such as the Notification permission and your interactions with notifications), and Lock screen status (such as whether the screen is locked and whether Lock screen notifications are allowed).
InstantWeb
InstantWeb provides you with enhanced H5 and RPK running performance. In the course of providing you with services, we need to collect information relating to your device (such as device identifiers and User ID) to improve the stability of the engine.
Product feature optimization
System Messages, InstantWeb, and other features of the App need to collect event-tracking information in order for us to optimize our products and services. Event-tracking information mainly includes the following: device identifiers, installed app list, clipboard, device-related information (including device brand, device model, sales region, and network type), system and app information (including OS version, app version, and app package names), categories of event-tracking data, GAID (encrypted), behavioral data (including taps, impressions, and app launches), data about cross-app launches, returned event-tracking data, cache data, device status, records of your use of the aforementioned features, and feature usage stats.
1.2 Cookies and other similar tracking technologies
Currently, the App does not use cookies or similar technologies to collect or store your preferences or any information about you.
2. How We Store and Retain Your Personal Information
Pursuant to laws and regulations, we will retain your personal information for the minimum period needed to provide you with products and/or services. We will delete or anonymize your personal information upon the expiration of the retention period or when it can be deleted, unless otherwise specified by applicable laws or regulations.
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 applicable laws and regulations.
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 products or services. For example, when a third-party app pushes a message to you, we will need to collect information about your device. Once you have provided us with such information and while you are using this feature, we will need to retain the information in order to deliver the feature as intended and to ensure that the message from the third-party app is successfully sent to your phone.
After you take the initiative or ask us to delete your personal information, we will delete or anonymize your personal information as soon as possible in accordance with laws and regulations, unless otherwise specified by laws and regulations.
We determine the minimum retention period mainly based on the following: (1) The purposes for which the personal information is processed have been fulfilled or are unable to be fulfilled, or the processing becomes unnecessary due to business changes or discontinuance; (2) It is necessary for us to maintain relevant transaction and activity records to address your information query requests or complaints you might raise in the future; (3) You authorize us to retain the personal information for a longer period; and (4) Laws or administrative regulations have otherwise specified the retention period for personal information.
During your use of this App, if your actions constitute a serious violation of laws, regulations, agreements, policies, or rules relating to this App, the records of your violations, as well as your credit records and personal information relating to this App, will be retained for the maximum period permitted by law.
If we discontinue the operations of some or all of the services on this App for special reasons, we will publish an announcement on this App at least 30 days in advance, and we will cease to collect your personal information and no longer use it for commercial purposes. Within the minimum time limit permitted by laws and regulations, we will delete or anonymize the personal information we hold that relates to this App, 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 our resources and servers around the world. For the purpose of ensuring the quality of our services (such as to ensure processing speed) and subject to local data protection laws, we will store your personal data based on the area where your phone is purchased or the region set for your phone. Our data centers are located in Russia, Singapore, France, the United States, and India. 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 collected by us 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 protecting your control over it. To this end, we provide multiple options to help you manage your privacy settings and personal information more easily and securely. Note that the settings may vary by device model, OS version, and app version. In addition, we may adjust the settings from time to time to improve your user experience. Therefore, the operation paths described below are for your reference only. If you have any questions regarding the operation paths or how to exercise your rights, you may contact us using the methods set out in the "Contact Us" section of this Privacy Notice. Refer to the below for your 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 being 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, or contact us through the methods disclosed in this Privacy Notice to learn about our collection and use of your personal information.
3.2 Right of access
You have the right to view your personal information by contacting us as set forth in "Contact Us".
3.3 Right to rectify
If you find that any of your personal information processed by us is inaccurate or incomplete, you have the right to request that we correct or complete it. You have the right to correct your personal information by contacting us as set forth in "Contact Us".
3.4 Right to erasure
You have the right to delete the personal information you have provided to us by contacting us as set forth in "Contact Us".
3.5 Right to change the scope of authorization or withdraw consent
The performance of each service function requires certain basic personal information (see the "How We Collect and Use Your Personal Information" section of this Privacy Notice). By deleting information, turning off app permissions, changing settings on the specific product or feature settings page, or deleting your account, you can either change the scope of the personal information you authorize us to continue collecting or withdraw your authorization. Specifically:
You can go to "Settings - Notifications & status bar - App notification settings" to disable certain app notifications and prevent the app from pushing messages to you again.
3.6 Right to get a copy of your personal information
You have the right to request that we provide a copy of the personal information you provided to us or transfer the copy to a third party you designate. If you need a copy of your personal information, please contact us as outlined in the "Contact Us" section of this Privacy Notice and send us a request. We will provide you with a copy promptly.
3.7 Right to lodge a complaint
You have the right to lodge a complaint by contacting us as outlined in the "Contact Us" section.
You have the right to lodge a complaint with the competent supervisory authority regarding our personal information protection practices or to file a lawsuit with a court with jurisdiction. However, we would appreciate the opportunity to address your concerns and resolve any issues before you contact the relevant authorities. Please reach out to us first.
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 online environment for minors and provide additional protections for 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 features and services provided by the App are intended for adults, 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 users' ages.
According to applicable laws and regulations, if you are a child, you must obtain the consent of your parent or guardian before using the App, and be sure to carefully read this Privacy Notice together with them. If you are the parent or guardian of a child, before assisting the child in using the App, you must carefully read 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, nor do we use it for marketing purposes. If you believe that any information we have processed may contain the personal information of a child, whether you are the child, the child's parent or guardian, or any other individual, please contact us as set forth in this Privacy Notice. We will endeavor to delete such 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/en/privacy.html).
If you have any questions, suggestions, or complaints regarding this Privacy Notice or our privacy practices, you can contact our data protection officer or us as set forth below. We will verify your identity and respond within the stipulated time limit in accordance with local laws and regulations. This time limit may be extended when necessary, depending on factors such as the complexity and volume of individual requests and technical feasibility.
Data Subject Rights Platform: https://brand.heytap.com/en/privacy-feedback.html
Alternatively, please visit https://brand.heytap.com/en/privacy/contact-person.html to find out whether there is a local data protection officer, representative, or point of contact in your country or region.
B. Appendix: Europe-Specific Privacy Notice (GDPR-Compliant Terms)
This Part 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 a natural or legal person, public authority, agency, or any other body 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 Part A "General Terms"). A data processor refers to a natural or legal person, public authority, agency, or any other body that processes personal data on behalf of a data controller. (It is the same concept as the party that is entrusted to process personal information described in Part A, "General Terms".) If you are a user located in Europe, HEYTAP PTE. LTD. acts as the "data controller" as defined in the EU 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 relating to an identified or identifiable natural person. "Personal data of special categories", or "sensitive personal information", refers to personal data that reveals the racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union memberships of a natural person, as well as genetic data, biometric data, and health-related data that are processed to uniquely identify a natural person and data concerning a natural person's sex life or sexual orientation.
1. Legal Bases for Processing Personal Information
The legal bases for the processing of your personal information described in the "How We Collect and Use Your Personal Information" section are as follows:
(1) We have obtained your express consent in advance, which you can withdraw 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 a third party or us. 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. Purposes and Scope of Our Processing of Personal Information
In Europe, we provide the System Messages service on our devices.
When you use the App, we may collect, use, or disclose your personal information for the purposes and procedures below or for other reasonably related purposes:
| Intended feature and purpose | Personal information to be collected | Legal bases |
|---|---|---|
| System messages | Messages obtained from the concerned developers, information relating to your device (such as device identifiers, User ID, Google Advertising ID, region and language settings, device model, battery level, and OS version), version of the push SDK, network-related information (such as IP or domain name and network type), message sending results, notification bar status (such as the Notifications permission and your interactions with notifications), and Lock screen status (such as whether the screen is locked and whether lock screen notifications are allowed) | Marketing messages: Your consent or protecting the legitimate interests of the concerned developersService messages: Performance of the contract between the developers and you |
3. Global Transfers of Your Personal Information
We determine your location based on the country/region you have selected in "Settings - Language and region". If you have not selected the country/region, we will determine your location based on the country/region where you purchased your phone.
In principle, personal information generated and collected in the European Union will be stored in the European Union. 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 as set forth in the "Contact Us" section and submit your request.
Data Subject Rights Platform: https://brand.heytap.com/en/privacy-feedback.html
4. Your Rights Regarding Personal Information
According to the GDPR, you have the following rights and can send us your request through the Data Subject Rights Platform (https://brand.heytap.com/en/privacy-feedback.html).
4.1 Right of access
We inform you of how we process your personal information by publishing this Privacy Notice and, where required by law or regulation, by posting a notice or contacting you via SMS or email. We are committed to being transparent about how we use your personal information.
4.2. Right to rectification
If you find that the personal data we process about you is inaccurate or incomplete, you have the right to request that we make rectifications without undue delay and, where appropriate, complete your personal data.
4.3 Right to erasure
You have the right to request that we delete the personal information you have provided to us.
4.4 Right to restrict processing
In certain cases, for example, when you contest the accuracy of your personal data, you have the right to request that we restrict its processing to verify its accuracy. We will retain sufficient data or process the necessary data to ensure our future compliance with your request for restrictions.
4.5 Right to object
You have the right to object at any time, on grounds relating to your particular situation, to any processing carried out on the basis of legitimate interests. If you choose to object to the processing of your personal data, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds for continuing the processing that override your interests, rights, and freedoms, or where the processing is necessary for the establishment, exercise, or defense of legal claims. You can object to direct marketing activities at any time for any reason.
4.6 Right to data portability
You have the right to obtain a copy of your personal data in a structured, commonly used, and machine-readable format and to transmit such data to another provider, or, in certain cases, to have the data transmitted directly to another provider.
4.7 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 - Notifications & status bar - App notification settings" to disable certain app notifications and prevent the app from pushing messages to you again.
4.8 Right to complain
You have the right to lodge a complaint with the local data protection authority in your country regarding our processing of your personal information. To view information about the local data protection authority in your country, please tap the corresponding link below.
EU: https://edpb.europa.eu/about-edpb/about-edpb/members_en
United Kingdom: https://ico.org.uk/
Switzerland: https://www.edoeb.admin.ch/en
We will respond to your complaint as soon as possible. In general, we will respond within one month of receiving 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. If this is the case, we will notify you of the reason for the extension within the first month we receive your complaint.) If you are not satisfied with our response, you may file a lawsuit with the supervisory authority in your jurisdiction.
5. Contact Us
If you have any questions, suggestions, or complaints regarding this Privacy Notice or our privacy practices, you can contact us, our representative, or our data protection officer as set forth below:
Email address (for users in Europe, excluding the UK): privacy_eu@heytap.com
Email address (for users in the UK): privacy_uk@heytap.com
If you are a user located in Europe, you may contact our Data Protection Officer, Collegium Auditores GmbH.
Email address: datenschutz@collegium-auditores.de
Postal address: Haufeld 2a, 53721 Siegburg, Germany
If you are a user located in Europe (excluding the UK), you can contact our European representative, Reflection Investment B.V.
Postal address: Hofplein 20, 3032AC Rotterdam, the Netherlands
Users located in the United Kingdom may contact our UK representative, Unumplus Limited.
Postal address: 7 Albert Buildings, 49 Queen Victoria Street, London, United Kingdom, EC4N 4SA
C. Appendix: U.S. State-Specific Terms
In the United States, we provide the System Messages service.
This appendix applies to users who are residents of California, Nevada, Colorado, Connecticut, Virginia, or Utah in the United States, and 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 How We Use Personal Information
Personal information falls into the following categories according to the laws of the above-mentioned states:
| Category | Example |
|---|---|
| A. Identifiers | Name, alias, postal address, unique personal identifiers (such as customer number, unique pseudonym or alias, device identifier, cookies, beacons, pixel tags, mobile advertising ID or similar technology, and other persistent or probabilistic identifiers), online identifier, Internet Protocol ("IP") address, email address, account name, driver's license number, passport number, and other similar identifiers. |
| B. Other personal information in compliance with the California Customer Records Act (Cal. Civ. Code § 1798.80(e)) | Signature, phone number, ID numbers, bank account number, credit card number, debit card number, or any other financial information. |
| C. Characteristics of protected classifications under California or federal law | Characteristics of protected classifications under California or federal law, such as age and gender. |
| D. Commercial information | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| E. Biometric information | Any biological or behavioral characteristic that can be used to authenticate your identity, such as a fingerprint or a face image that is used to create a faceprint. |
| F. Internet or other electronic network activity information | This includes but is not limited to browsing history, search history, and information regarding your interactions with our services, or third-party websites, apps, or ads. |
| G. Location data | Geographic location information about you or your device, including the precise location collected with your consent. |
| H. Sensory data | Audio, electronic, visual, thermal, or other similar information. |
| I. Professional or employment-related information | Current or past work experience. |
| J. Non-publicly available education information under the FERPA (20 U.S.C. § 1232g; 34 CFR Part 99) | Educational records maintained by an educational institution or a party acting on its behalf that relate directly to a student, such as a student's academic transcripts and identification number. |
| K. Inferences | Inferences drawn from any of the information mentioned above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, and behavior (such as data related to the personalized ads delivered to you). |
| L. Sensitive personal information | Government-issued identifiers (such as driver's license number, state identification number, or passport number), login credentials (username, account ID, or card number, any of which is combined with the required access/security code or password), precise location, and the text of letters, emails, and SMS messages (unless we are the intended recipient). |
According to the laws of the above-mentioned states, we must provide the following details regarding the information that we collect from the 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.
We may use (and may have ever used in the twelve (12) months before the effective date of this Privacy Notice) the aforementioned categories of personal information for one or more of the purposes stated in this Privacy Notice, or for one or more of the following purposes.
Without informing you, we will not collect other categories of personal information about you (other than as set forth above or elsewhere in this Privacy Notice) or use the personal information we collect for materially different, irrelevant, or incompatible purposes.
When you use the App, we may collect, use, or disclose your personal information for the purposes and procedures below or for other reasonably related purposes:
| Category of personal information | Source | Purpose | Disclosure to third parties |
|---|---|---|---|
| Messages obtained from the concerned developers, information relating to your device (such as device identifiers, User ID, Google Advertising ID, region and language settings, device model, battery level, and OS version), list of installed apps that use the push service, version of the push SDK, network-related information (such as IP or domain name and network type), message sending results, notification bar status (such as the Notifications permission and your interactions with notifications), and Lock screen status (such as whether the screen is locked and whether lock screen notifications are allowed) | Obtained from the concerned developers or directly collected by us | To send messages | None |
2. Disclosure, Sale, and Sharing of Personal Information
According to the law in California, "share" means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
We do not sell or share your personal information (we collected in the past 12 months) with any third parties for commercial purposes. If we intend to sell your personal information in the future, we will notify you in advance through this appendix, and respect your right to restrict and refuse such action.
3. Your Rights Regarding Personal Information
You may have the following rights as a data subject. 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 which the 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 know. You have the right to request information regarding our disclosure of personal data to third parties for business purposes.
(3) Right to correct. You have the right to correct inaccurate personal data that we may hold about you.
(4) Right to delete. You have the right to request that we delete your personal information, except in cases where certain exceptions apply.
(5) Right to opt-out. You have the right to opt out of the sale or sharing of your personal data with third parties.
(6) 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.
(7) Right to non-discrimination. You have the right to non-discrimination for exercising any of the above rights.
Making a Shine the Light request
The Shine the Light law (Cal. Civ. Code § 1798.83) allows residents of California who are also our service users to request: (1) the list of personal information categories we shared with third parties for direct marketing uses in the last calendar year; (2) the identities of such third parties.
If you have any questions, suggestions, or complaints regarding this Privacy Notice or our privacy practices, you can contact us as set forth below:
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 need to verify your account or 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 part of your requests, we will explain the reasons for our refusal.
In addition, we do not sell or share your personal information, so the right to opt out of the sale or sharing of personal information for targeted advertising does not apply to us.
4. Submitting a Request Through an Authorized Agent
In some cases, to the extent that we can verify the permission given to an authorized agent to act on your behalf, you can designate an authorized agent (a term defined by the California Consumer Privacy Act of 2018) to act on your behalf to submit a request using the method provided in this Privacy Notice.
For a request to know about, delete, or correct personal information we hold about you, we need the following information for identity verification:
(a) An authorization letter from you or your authorized agent that is valid under California laws; or
(b) Sufficient evidence to indicate that you have: 1) provided the authorized agent with a signed license to act on your behalf; and 2) verified your identity directly with us as set forth in this Privacy Notice; or directly confirmed with us that you have granted permission to your authorized agent to submit the request on your behalf.
For requests to opt out of "selling" or "sharing" personal information, we require a signed license certifying that the authorized agent has authorization to act on your behalf.
5. Contact Us
If you reside in the United States and have any questions, suggestions, or complaints regarding this Privacy Notice or our privacy practices, you can contact us as set forth below.
Email address: privacy_us@heytap.com
D. Appendix: India-Specific Privacy Notice (DPDPA-Specific Terms)
This appendix applies only to users located in India.
You understand that these terms have 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 fiduciary is an entity that, alone or together with others, determines the purposes and means of processing personal data (roughly equivalent to the personal information processor described in "General Terms"). A data processor is an entity that processes personal data on behalf of the data fiduciary. (It is the same concept as the party that is entrusted to process personal information described in Part A, "General Terms".)
In general, we act as a data fiduciary to process your personal data. However, there might be third parties involved in providing the Message Push Service. You understand that in some cases, such third parties may have separate purposes and means of processing your personal data and that they will constitute independent data controllers and process your personal data independently.
1. Personal Data We Collect and the Purposes of Data Processing
In India, we provide the Message Push Service feature.
We collect your personal data only for the purposes of providing services relating to System Messages to perform the relevant functions.
Please note that your consent is not required for the processing of your personal data 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 interests 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 law currently in force in India, or judgments, rulings, or orders in relation to contracts or civil claims under the law 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;
(2) All the data fiduciaries and processors that process your personal data, and the categories of personal data we share.
(3) Information required to be disclosed by relevant laws and regulations.
2.2 Right to rectification and erasure
You have the right to (1) correct, complete, and update your personal data and (2) delete your personal data.
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. 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 Data Protection Board of India.
2.4 Right to withdraw consent
You have the right to withdraw your consent to our processing of your personal data.
After you withdraw your consent, we will cease processing your personal data. You understand that the withdrawal of consent does not affect the lawfulness of our processing of your personal data based on consent before its withdrawal.
2.5 Right to designate an authorized agent
If you are a child or a 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 steps to verify the agent's identity for a qualification review.
3. Processing of Personal Data of Children and Persons with Disabilities
In principle, our products and services are not intended for children (individuals under the age of 18). We do not knowingly collect or solicit personal data from children. If you are under 18, do not attempt to register for our services or send us any personal data.
Please note that in India, "children" refers to natural persons under the age of 18.
In certain exceptional circumstances, if we need to process the personal data of the following groups, we must obtain verifiable consent from their parents or legal guardians in advance:
· Children: individuals under the age of 18.
· Persons with disabilities: individuals with disabilities who have a legal guardian and whose guardian's consent is required under applicable laws.
If you are a parent or legal guardian and discover that your child or ward has provided us with personal data without your consent, contact us immediately using the contact information provided at the bottom of this policy. We will verify the situation and delete the relevant data.
E. Appendix: Brazil-Specific Privacy Notice (LGPD-Compliant Terms)
This appendix applies only to users located in Brazil.
1. Legal Bases for Processing Personal Data
The following are the legal bases for our processing of your personal data:
1.1 Consent
We may process your personal data after obtaining your consent. In particular, we may ask for your consent to participate in our promotional activities, such as sending you promotional messages or inviting you to opt in for our user experience program or specific services, through which we may collect location information. You have the right not to give consent, or to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you have given consent to our use of your personal data, we will use that data only for the purposes specified in the statement of consent. Please note that our processing is based on your consent. If you refuse to give consent or withdraw your consent, we may be unable to provide you with the services related thereto. Your initial refusal or withdrawal of consent does not have any negative consequences, unless otherwise specified.
1.2 Performing or entering into a contract with you
This legal basis applies when the processing of your personal data serves the following purposes:
(1) To provide you with services, process your orders, or fulfill the contract between you and us.
(2) To activate the services you have purchased, warranty services, and specific software licenses, as well as to provide software update notices.
(3) To permit and manage your participation in our lucky draws, competitions, or other similar promotional activities.
(4) To diagnose product issues, repair customer equipment, and provide other customer care and support services.
1.3 Compliance with legal obligations
We may be obliged to process your personal data to fulfill our legal obligations, such as retaining it to comply with tax laws or to conduct business.
1.4Legitimate interests
The processing of your personal data may also be necessary for our legitimate interests. This may serve the following purposes:
(1) To conduct customer surveys to enhance your user experience.
(2) To analyze the customer market (including the number of users for product marketing and promotion) based on the country where you use our services.
(3) To analyze the efficiency of our business operations.
(4) To analyze error logs to improve our phone quality and app features.
(5) To provide you with personalized services, and recommend and display the content and ads tailored for you through our services.
(6) To communicate with you and address the feedback or comments you submit through any channel.
(7) To ensure the functionality and safety of our services.
(8) To verify your identity.
(9) To conduct internal audits to prevent and investigate fraud, cybersecurity threats, or other improper uses of your personal information.
(10) To improve and develop our services, including relevant security features, to enhance the user experience, user-friendliness, performance, functionality, and design of our products.
(11) To pursue or defend against claims.
We process your personal data on the grounds above only after carefully assessing and balancing our interests against your privacy rights. In specific cases, we may also process your personal data on other legal bases provided under applicable laws.
2. How Your Personal Data Is Transferred Globally
Should your personal data be transferred to jurisdictions outside Brazil, we will ensure that appropriate safeguards are put in place. For example:
(1) The recipient of your personal data is located in a country that the Brazilian National Data Protection Authority (ANPD) has, through an adequacy decision, recognized as providing adequate protection (if applicable).
(2) The recipient has signed a contract in accordance with the ANPD-approved Standard Contractual Clauses (if applicable), requiring them to protect your personal information.
(3) In the absence of the safeguards above, we will ask for your express consent to cross-border transfers of your personal data, or we will take other recognized measures to protect your personal data properly.
For more information on the safeguards we adopt for the transfer of personal data outside Brazil, please submit a request through our Data Subject Rights Platform at https://brand.heytap.com/en/privacy-feedback.html.
3. Our Use of Cookies and Other Similar Tracking Technologies
Currently, the App does not use cookies or similar technologies to collect or store your preferences or any information about you.
4. Your Rights Regarding Personal Data
In accordance with the General Data Protection Law (LGPD), you have the following rights:
(1) Right of access: You can request access to your personal data that we hold about you.
(2) Right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to request that we correct it without delay and, where appropriate, complete your personal data.
(3) Right to erasure: You may submit a request for deletion of your personal data. In certain cases, we are obliged to delete such data without undue delay, for example, if we no longer have a lawful basis under applicable laws and regulations to continue processing your personal data. Please note that erasing all data from your device does not mean that you have erased all data about you that we have collected and processed. Therefore, we encourage you to contact us (see "Contact Us") to request the erasure of your personal data.
(4) 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. After receiving your request, we will retain only the necessary data or process the data required to ensure future compliance with your restriction request.
(5) Right to object: You have the right, at any time and on grounds relating to your particular situation, to object to any processing based on legitimate interests. Should you decide to object to the processing, we will stop processing the personal data concerning you, unless we can demonstrate compelling reasons for continued processing that override your interests, rights, and freedoms, or the processing serves to establish, exercise, or defend our legal claims. You also have the right to object at any time to our processing of your personal data for direct marketing purposes.
(6) Right to data portability: You are entitled to obtain a copy of your personal data in a structured, commonly used, and machine-readable format. In certain circumstances, you can transmit your personal data to any other provider.
(7) Right to withdraw consent: If you have given consent to our processing of your personal data but later change your mind, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before its withdrawal. If you wish to withdraw your consent to receiving promotional messages, you can unsubscribe as described in each promotional message. If you withdraw your consent, we will no longer be able to provide you with related services.
(8) Right to complain: You are entitled to lodge a complaint with the competent authority or to file a lawsuit regarding our processing of your personal data. Relevant information can be obtained from the local data protection supervisory authority.
(9) Right to request anonymization: Under certain circumstances, you have the right to request the anonymization of your personal data, meaning your data will be transformed to prevent identification. This right aims to reinforce the protection of your privacy.
(10) Right to obtain information about companies sharing your personal data: You have the right to know which companies and third parties have received your personal data from us. This ensures transparency regarding how your data is shared and used.
(11) Right to know possibilities and consequences of consent withdrawal: You have the right to be informed of how withdrawal of consent may affect data processing, including the potential impact on your access to certain services or features.
You can submit a request or contact our data protection officer through our Data Subject Rights Platform:
Name: Juliana Mantuano de Meneses
Contact information: https://brand.heytap.com/en/privacy-feedback.html