This Timo Privacy Policy explains how Timo ("we", "us")process any personal data we collect from users of Timo application.

We value the privacy of users, subscribers, publishers, members, and others who visit and use the Timo Services (collectively or individually, "you" or "users") and want you to be familiar with how we collect, use, and disclose personal information from and about you.

You may share personal information when using the Timo Services. One example is when you provide information about yourself as part of the Timo account creation process. Another is when you take certain actions on the Timo Services that are public or intended to be public in nature, such as when you post profile information, follow another, or subscribe to a celebrity channel. Given the social nature of some of the Timo Services, that information may be collected, used, or disclosed by others who are part of that social interaction. In addition, some features of the Timo Services are designed to provide others with information about user activity, such as identifying the user who created a particular Clip or the subscription status of users for a given channel. We encourage you to be mindful of this when considering your activity on the Timo Services.

Table of content

  1. What Information Do We Collect
  2. How We Use Your Information
  3. How We Share Your Information
  4. Data Security
  5. Retention of Your information
  6. Changes and Updates to This Privacy Policy

What Information Do We Collect

We obtain information about you through the means discussed below when we provide the Timo Services. Please note that we need certain types of information so that we can provide the Timo Services to you.

i.User-provided Information

ii.Collected Information for Legitimate Interests

User-provided Information

You consent to provide some or all of the following Personal Information when you create an account on the App or use Timo Services, such as uploading contents on the App or contact us for technical support:

Registration information, such as your date of birth, phone number (or email, if applicable), password, user identifier and language;

Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;

User-generated contents ("UGC"), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Timo Services;

Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Timo Services, but such data will only be processed offline to fulfill the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party. In addition, if you utilize Real-Person Profile Picture Authentication, we collect your profile picture and facial-recognition video for Real-Person Profile Picture Authentication on the premise of your approval by comparing your profile picture with face-recognition video. This authentication can protect you from impersonators and fake accounts, or develop the authenticity of Timo Services. We do not retain your face recognition video in our servers, such video is merely for verifying.

Payment information, such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number or other payment information where required for payment;

Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services;

Your social network contacts with your permission, when you activate the "Discover Friends" function and allow us to access your contacts;

Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;

Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints; and Information you provide when participating in in-app surveys and activities.

Information you provide from social media when you create a Timo account by connecting with a third-party social media, such as Facebook, Instagram, Twitter, Google, or if you link a Timo account with a third-party social media account;

Collected Information for Legitimate Interests

We may collect some or all of the following Personal Information about you when you use Timo Services for legitimate interests:

Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users' accounts that you subscribed to, and information regarding your interaction with other users;

Information from Other Sources: We may obtain additional information from third parties and sources other than the Timo Services. For example, we may obtain additional information from games or services you use, or social media networks (such as Facebook) for which you have approved our access. When you access the Timo Services through social media networks or when you connect the Timo Services to social media networks, you are authorizing Timo to collect, store, and use such additional information and content in accordance with this Privacy Policy

Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address;

Information regarding your access to and use of other apps;

Other location information, such as the information based on your SIM card;

Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple's IDFA or Google's AAID) to help us and advertisers provide ads that may be more relevant to your interests;

Metadata, associating with the UGC you provided us, which describes other data and provides information about how, when, and by whom the piece of UGC was collected and how that UGC was formatted, such as hashtags used to label the keywords to the video and captions;

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, to calculate the percentage of users accessing a specific website feature, or to calculate ad impressions served or clicked on.

How We Use Your Information

We will only use your Personal Information when the applicable laws allow us to. In general, we use your Personal Information for the following purposes:

Provision of services: to present Timo Services and its contents to you, including any interactive features on Timo Services, and to provide you with information, products or services that you allow us to; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with promotion activities and sweepstakes;

Improvement of services: to improve and personalize our services by presenting new services, information, recommendations, and feedback;

Customer management: to manage a registered user's account, to provide customer support and notices to the registered user about his account or subscription, and notices about changes to Timo Services or any other product or service we offer or provide through it;

Communication: to communicate and interact with you directly, for an example, we may send notifications regarding upcoming changes, promotion activities or improvements on Timo Services;

Content review: to review pictures, images and contents posted or generated on Timo Services to ensure that we comply with any applicable content regulations in any relevant jurisdiction;

Customization of content: to perform research and analysis about your use of, or interest in contents, products, advertising, or services available on Timo Services in order to develop and display content tailored to your interests on our Website and App;

Performance Analysis: to determine whether users of Timo Services are unique, or whether the same user is using Timo Services on multiple occasions, and to monitor aggregate metrics such as total number of visitors, number of videos viewed, demographic patterns;

Functionality and security: to identify users not meeting the age limit, to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;

Compliance: to enforce our terms of use and to comply with our legal obligations;

Aggregation: to aggregate information we collect about you to which one or more purposes described above.

Additionally, We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.

How We Share Your Information

Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video or a picture each time you upload a video

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to improve, optimize the Platform and to prevent illegal use.

We may share your Personal Information outside of Timo Services when we have your consent, either express or implied.

We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.

We may disclose your Personal Information to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, customization of content, analytics, security, map navigation, data storage and cloud services, supporting our functionality, and other features offered through Timo Services.

These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. However, if you connect to a third-party service through Timo Services or otherwise links your Timo account with a third-party service, you are requesting and authorizing us to share or grant access to information on your behalf with such third party. We may also send information about the content that you watched or your activities on Timo Services to such third party in order to upgrade your experience on Timo Services.

We may disclose or share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred. If such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses information in a manner that is consistent with this privacy policy.

We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) comply with any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or other third parties; or (e) to maintain and protect the security and integrity of Timo Services or infrastructure.

We may disclose aggregated information about our users. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.

Data Security

We take appropriate administrative, technical and physical security measures to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your Personal Information. You should use caution whenever submitting information through Timo Services and take special care in deciding which information you provide us with.

You are responsible for maintaining the secrecy of your password and account information at all times.

Retention of Your information

We will retain your Personal Information and other information for as long as you maintain your Timo Live account.

You may request deletion of your account at any time through the Me > Settings > Delete Account in the app. Following such request with appropriate review by us, we will delete the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, we retains location, device, and usage data for these purposes for a reasonable period as may be necessary; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, we may be unable to delete your account, such as if there's a balance on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete the account as described above.

We may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if we deactivate a user's account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new Timo account in the future.

Changes and Updates to This Privacy Policy

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at Timo Services so you are aware of any changes, as they are binding on you.

If we change anything in our privacy policy, the date of change will be reflected in the "last updated date". By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.