[Audpud] Privacy Policy
Last Updated: April 10, 2022
Effective date: April 10, 2022
TENCO MOBILE LIMITED (hereinafter referred to as “[Audpud]”, "we”, “us”, “our”) is the service provider and operator of [Audpud] and its Service (hereinafter referred to as “This Application”). We fully respect your privacy and will do our utmost to protect the security of your personal information. We may collect, use or otherwise process your personal information based on your consent or in accordance with the relevant provisions of applicable laws and regulations during your use of this Application or its services (collectively, our “Service”). This Privacy Policy (hereinafter referred to as “Policy”) is meant to help you understand how we collect, use, disclose, process and protect your personal information with regard to your use of [Audpud] and its Service, your rights regarding the personal information provided to us, and how we safeguard your rights. This Policy applies to all the products and services provided by [Audpud], including applications, mini-programs, websites, SDK for third-party websites or applications, APIs and other forms that may be available in the future.
It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties, please prudently determine whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.
We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.
Before using our products or services, providing your personal information to us or allowing us to collect your personal information, please read this Policy carefully to understand our practices regarding your personal information and access it frequently to understand the updates to this Policy. If we update this Policy, we will notify you by announcements in the product or website to let you know about the changes we made. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of the Privacy Policy for the latest update time.
If you have any questions, please feel free to contact us by the following means:
Privacy@tecno.com
You can also access this Privacy Policy by the following means:
[Audpud] >ME > Setting > Privacy Policy
This Privacy Policy will help you understand the following contents:
[Audpud] firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by us, regardless of where such natural person lives.
We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.
We may collect your personal information by the following means: 1) information you provide directly to us (such as your nickname, profile picture, name and phone number you provide to us when you login to your account or take part in the promotion activity we held); 2) information we obtain automatically during your use of this Application (such as device information, service log information); 3) information we obtain from other sources.
You have the right to choose whether or not to provide the personal information when you use [Audpud] and its Service or when we have requested. You are not required to provide your personal information to [Audpud], but in some cases, if you choose not to do so, we will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:
[Audpud] mainly provides you with services including custom audio curves exclusively for you and earphone device management.
To facilitate your full use of the functions and services of the software conveniently, we will automatically assign an account ID to you when you first activate Audpud. When logging in and using this Application, you may choose to provide, fill in and modify your nickname (including your real name), profile picture (including your real portrait),and your location. However, your refusal to provide additional information will not affect your registration or login.
We will provide you with audio curve customization to help you obtain better hearing services. The information we collect depends on how you interact with us. In order for your normal use of our products and services, we will acquire your account ID, hearing test information, hearing test time and testing equipment and generate an intelligent hearing test report for you. We will customize audio curves for you based on your hearing test report. You may name your custom curves by yourself to facilitate your management of the audio curves.
You may connect your Bluetooth earphone through this service. In this case, we will need to acquire your earphone Bluetooth information and MAC address. To search accessory devices, we will need your permission for geographical location, which is required for connecting your earphone. You may turn off your permission at any time via “Settings -> App Management -> Permission Management”. The path to turn off the permission may vary depending on different versions. If you refuse to provide such information, we may not be able to help you connect your earphone.
You may do the hardware upgrading of your earphone through this device. In this case, we will judge whether it is necessary to send upgrading notifications for your earphone based on your earphone Bluetooth information, MAC address and earphone firmware version No. If there is already a new firmware version, you may choose whether to do the firmware upgrading in this service.
We may also send you service notifications, events, prizes and other messages based on your device identifier, operating system version, user nickname of current device, network information and information about your use of the app. To unsubscribe from notifications, events, prizes, etc., you can withdraw your consent via Settings > Notification Centre > Notification Management, permission management may vary for different versions.
We will collect and respond to your suggestions or comments in our feedback service. In this case, we will need your feedback and contact information (such as QQ ID, WeChat ID, phone number, etc.) so that we can understand your thoughts and contact you in a prompt manner. We may combine information from a service with information from other services to provide you with better services, content and recommendations.
To improve our products or services, we will invite you to add such information as your gender and age and acquire your country/region based on your IP address when you access this service for the first time. We will combine this with other information generated by this service to make a summary so that we can improve the content of our products and services as well as our product design.
You may refuse to provide the above information and access this service by selecting “Skip”.
Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
In order to better improve our product layout and provide you with great services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take technical measures and other necessary measures to process such data, so that the data cannot be re-identified to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such processed data can be used without separately notifying you or obtaining your consent.
The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Currently, [Audpud] may store your personal information in: India, Ireland.
In particular:
The personal information collected and generated during our operations in India will be stored on servers located in India.
The personal information collected and generated in our business outside India will be stored on servers in Ireland.
According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.
We will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
We do not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with our affiliated companies. We will only share your information within our affiliated companies for legitimate and explicit purposes, and only share the information necessary to provide the services, and are bound by the purposes stated in this Privacy Policy. If a purpose concerned is not included in this Policy, we will state it in the corresponding privacy policy or notice of the specific product or service.
We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, in order to enable you to share information to third party platforms, use location service and other kinds of services and features, we may embed third party SDK or other similar applications of authorized partners in this Application. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system). When we embed the third party SDK or other similar applications of authorized partners in this Application, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.
In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated data to help partners (e.g., advertising service providers) understand the effectiveness, feedback and usage trends of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.
[Audpud] will not transfer your information to any other parties, except in the following circumstances:
According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, [Audpud] may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your personal information to the resources or servers stipulated in section III of this Policy for storage or processing, we may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The privacy protection laws of these countries or regions may be different, and the jurisdiction in which these global resources or servers are located may or may not protect personal information to the same standards as in your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal information, and we will follow the legal requirements of the country or region where the personal information is located to carry out the corresponding cross-border transfer and other processing of personal information.
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
We inform you how we collect and process personal information through this Policy or in the form of a privacy policy or notice of the specific product or service. You have the right to confirm or reject such collection and processing via a check box or other methods. However, after you reject, some features that require your explicit authorization and consent to use may no longer be available. You can directly access the personal information you have provided to us in the interface of our products or services. For those that you are unable to access, you can send an email to privacy@tecno.com. We will handle it promptly after receiving your email.
When your personal information is changed, or when you find that your personal information collected and processed by us is inaccurate or incomplete, you have the right to ask us to make corrections or additions. You can directly correct or modify some of your personal information on the relevant product/service function pages. When your personal information collected by us has fulfilled the purpose of collection or is no longer required, or when you find that our collection and processing of your personal information violates the provisions of laws and regulations or this Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal information that we have not provided you with a channel for correction or deletion, you can request that it be corrected or deleted by contacting privacy@tecno.com.
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when we are legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
To achieve the respective features of our various products or services, we will require necessary personal information in accordance with the applicable local laws. This is described in the "How We Collect and Use Your Personal Information" part of this Policy. You can withdraw your consent previously granted to us for a specific purpose by deleting your audio curves via “Setings ->Delete Data” in this service and turning off device features, including the collection, use and/or disclosure of your personal information that we manage or control. You can email us at privacy@tecno.com for above operations. We will process your request within a reasonable time after you send the request, and thereafter will not collect, use and/or disclose your personal information in accordance with your request.
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of [Audpud] and its Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
You have the right to lodge a complaint by sending us an email at privacy@tecno.com. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”, “Text Message”; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via Settings > App Management > Permission Management or contact us via privacy@tecno.com to change your decision.
You can request to cancel your account by uninstalling the Application or by contacting us via privacy@tecno.com.
We hereby kindly remind you that, if you wish to cancel a certain service or account, such cancellation may prevent you from using some of [App’s name] features and its services, and such act of account cancellation is irreversible. Once you cancel your account, we will delete or de-identification your relevant information.
If you sign in to the accounts of [App’s name] through a third-party account (e.g., via Facebook, Google ID), you need to apply for cancellation of the account from the third party.
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:
We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
[Audpud] does not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal information for the purposes of marketing. If you find that a child’s information has been collected to us, please send an email to privacy@tecno.com to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from [App’s name] as soon as possible.
With the upgrades of this Application, you may receive links to third-party websites or content and services provided by third parties other than us during your use of Audpud and its Service, and some third parties’ products or services can be accessed in the form of SDKs and others. You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your personal information. Therefore, when you submit any information to a third party, please carefully review the third party’s privacy policy and take care of your personal information.
We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you of the latest Policy here (this webpage), or by posting it on http://tuner.tecno.com/web/privacy.html or sending you separate notifications. Please pay attention to this website and the notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent.
We will ask for your explicit consent again in accordance with applicable laws before we collect additional personal information from you or when we use or disclose your personal information for new purposes. Your continued use of the products and services on the website, mobile and/or any other device constitutes your agreement to the updated Privacy Policy.
The content of [Audpud] and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
Shenzhen TaiHengNuo Technology Co., Ltd. is a joint controller with us and we are jointly responsible for processing your personal information. TENCO MOBILE LIMITED and Shenzhen TaiHengNuo Technology Co., Ltd. have allocated respective responsibilities including GDPR according to applicable laws. You can contact us for more details regarding the joint controllership by the contact information in section x. "How to Contact Us".
If you have any comments, questions or concerns with respect to our Privacy Policy or practices of personal information protection, please contact us via:
Email: privacy@tecno.com (Note: This mailbox is used for receiving messages related to our Privacy Policy or our protection of personal information only)
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.
Thank you for your time to read our Privacy Policy!