Privacy Policy
HAY is a real-time video chat mobile application. You can meet cool and interesting
people from all over the world, enjoy fun chats, and make new friends on our platform.
This Privacy Policy covers what EXU(HK) Limited (“HAY” “HAY App” “we” “our”) does with
the Personal Information (as defined herein) that you share with us and the data we
collect when you are accessing our App and/or our Service. Personal Information about
our users is an integral part of our business, so please read this Privacy Policy
carefully. By using or accessing our App or our Service, you agree to the privacy
policies outlined below.
What Does this Privacy Policy Cover?
This Privacy Policy covers HAY's treatment of Personal Information that we collect
while you are using the App and the Service. This policy does not apply to the
practices of third parties that HAY does not own or control, including but not limited
to third party services you access through HAY, the App or the Service, or to
individuals that HAY does not employ or manage. As our Service integrates with third
party sites, such as Facebook, and other sites and social networks, we assume that you
are already aware of the privacy policies of those other sites and networks when using
our App and/or our Service and when you allow us to interact with these sites and
networks on your behalf.
The Service
The key functionality of HAY is a real-time video chat mobile application where users
can meet cool and interesting people from all over the world, enjoy fun chats, and
make new friends on our platform. It pairs individuals (“Users”) together based on
compatibility and other factors, and to enable individuals to chat and communicate
online through various media including text, video, linking and accessing third party
social network platforms such as but not limited to Snapchat (collectively, the
“Service”).
According to relevant international regulation, Hay will not provide the Service in
the following countries or territories:
• Cuba
• Iran
• Syria
• North Korea
• Crimea
• So-called Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR)
• Russia
• Belarus
Information We Collect
There are three basic ways we collect information:
- - Information you choose to give us
- - Information we get when you use our services
- - Information we get from third parties
Here’s a little more detail on each of these categories.
Information You Choose to Give Us
By visiting and interacting with HAY, its App and/or its Service, you provide us with
Personal Information which may include, but is not limited to, the following:
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- Personally Identifiable Information: may include, without limitation,
information provided when you register to use the App and/or the Service, including
your name, profile picture, date of birth, phone number, phone book content, email
address, gender, Facebook account info and friend list, and/or other social network
usernames and ‘likes' and preferences, friend lists and number of friends you have
via social networks, messages to other users of the App and the Service, use
information regarding your use of the Service, profile picture that you upload via
the App or the Service, and browser information.
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- The information you choose to provide above may be shared with your
contacts on our service. You have total control over your profile information and
you can access to modify at any time. In addition, if you register to our service
with your Facebook account (e.g. Facebook Connect), we may store your Facebook ID
and corresponding token on our servers and, if you give us your expressed consent,
we will have access to and may collect certain information that you make available
on Facebook (for example, your first and last names, email address, profile picture,
your friend lists and birthdays). Your Profile is available to other users of the
Service who are connected to you on our service. In addition, unless you opt-out
(which you may do so at any time in the settings of our application), your Profile
is discoverable by other users. You may choose to “block” any user on our platform
to prevent unwanted access of your Personal Information.
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- You may also choose to share your mobile device’s Contacts list with us
(including names, numbers, emails, Facebook ID, Apple ID, etc) and we will store it
on our servers to help you better improve our service, e.g. connecting with friends
on our service. If you do not want us to store this information, you may opt-out
through your account settings or notify us via email. If done so, we will not be
able to offer some of our features on our service.
Of course, you’ll also provide us whatever information you send through the services.
Keep in mind that the users you send texts, images, and any other content to can
always save that content or copy it outside the app. So, the same common sense that
applies to the Internet at large applies to Hay as well: Don’t send messages or share
content that you wouldn’t want someone to save or share.
It probably goes without saying, but we’ll say it anyway: When you contact Hay Support
or communicate with us in any other way, we’ll collect whatever information you
volunteer.
Information We Get When You Use Our Services
When you use our services, we collect information about which of those services you’ve
used and how you’ve used them. We might know, for instance, that you used one of the
filter in app and the number of times you have used this filter. Here’s a fuller
explanation of the types of information we collect when you use our services:
Usage Information. We collect information about your activity through our services. We
may collect information including but not limited to:
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- How you interact with the services, such as which filters you view or the
number of times apply to discover.
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- How you communicate with other Hay users, such as their names, the time and
date of your communications, the number of messages you exchange with your friends,
which friends you exchange messages with the most, and your interactions with
messages (such as when you open a message or capture a screenshot). We allow you to
share text messages, photos, screenshots, videos and other forms of communications
on our service with other users, and if you choose to do so your text messages,
photos, screenshots, videos and other communications may be stored on our servers.
In addition, if you choose to share these items with other users, we may not be able
to remove them from our servers or make them unavailable to anyone you have shared
them with. Sending and sharing text messages, photos, screenshots, videos or other
communications on our service is your decision. By choosing to share that
information, you should understand that you may no longer be able to control how
that information is used and that it may become publicly available. We are not
responsible for any use or misuse of information you share.
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- Device Information. We collect device-specific information, such as the
hardware model, operating system version, advertising identifier, unique application
identifiers, unique device identifiers, browser type, language, wireless network,
none direct display of content moderation, and mobile network information (including
the mobile phone number).
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- User content e.g. photos, screenshots, comments, and other materials that
you create on the service may also be collected. Your photos and videos may be
captured by other users on the service, and those content can be stored and used by
us or third party services (e.g. Facebook) for content moderation and community
safety monitoring purposes. You can change third party sharing options in our
product settings or writing to us directly.
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- Device Phonebook. Because HAY is all about communicating with friends, we
may—with your consent—collect information from your device’s phonebook.
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- Location Information. When you use our services we may collect information
about your location. With your consent, we may also collect information about your
general location using methods that include GPS, wireless networks, cell towers,
Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and
compasses.
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-Information Collected by Cookies and Other Technologies. Like most online
services and mobile applications, we may use cookies and other technologies, such as
web beacons, web storage, and unique advertising identifiers, to collect information
about your activity, browser, and device. We may also use these technologies to
collect information when you interact with services we offer through one of our
partners, such as commerce features. Most web browsers are set to accept cookies by
default. If you prefer, you can usually remove or reject browser cookies through the
settings on your browser or device. Keep in mind, though, that removing or rejecting
cookies could affect the availability and functionality of our services. To learn
more about how we use cookies and your choices, please check out our Cookie
Statement. To learn more about how third parties use these technologies on our
services, be sure to read the Analytics and Advertising Services Provided by Others
section of our privacy policy.
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- Log Information. We also collect log information when you use our website.
That information includes, among other things:
- - Details about how you’ve used our services.
- - Device information, such as your web browser type and language.
- - Access times.
- - Pages viewed.
- - IP address.
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- Identifiers associated with cookies or other technologies that may uniquely
identify your device or browser.
- - Pages you visited before or after navigating to our website.
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- If you contact us by email and other means (Twitter, Facebook etc) we may
keep a record of your contact information and correspondence and will use these
contact info and correspondence if we respond to you.
Information We Collect from Third Parties
We may collect information that other users provide about you when they use our
services. For example, if another user allows us to collect information from their
device phonebook—and you’re one of that user’s contacts—we may combine the information
we collect from that user’s phonebook with other information we have collected about
you. We may also obtain information from other companies that are owned or operated by
us, or any other third-party sources, and combine that with the information we collect
through our services.
How We Use Information
What do we do with the information we collect? The short answer is: Provide you with
an amazing set of products and services that we relentlessly improve. But we do a lot
more as well, such as:
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- Develop, operate, improve, deliver, maintain, and protect our products and
services.
- - Communicate with you.
- - Monitor and analyze trends and usage.
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- Personalize the services by, among other things, suggesting friends or
profile information, or customizing the content we show you, including ads.
- - Enhance the safety and security of our products and services.
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- Verify your identity and prevent fraud or other unauthorized or illegal
activity.
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- Use information we’ve collected from cookies and other technology to
enhance the services and your experience with them.
- - Enforce our Terms of Service and other usage polices.
We may also store some information locally on your device. For example, we may store
information as local cache so that you can open the app and view content faster.
How We Share Information
In certain instances, we may share your personal information with third-party service
providers to further improve and optimize our service for you. We may share
information about you in the following ways:
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- With other users. We may share the following information with other users
- - Information about you, such as your username and name;
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- Information about how you have interacted with the services, such as the
names of users you are friends with, and other information that will help users
understand your connections with others using the services. For example, because it
may not be clear whether a new friend request comes from someone you actually know,
we may share whether you and the requestor have Hay friends in common;
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- Any additional information you have consented for us to share. For example,
when you let us access your device phonebook, we may share information about you
with other users who have your phone number in their device phonebook;
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- With all users and the general public. We may share the following
information with all users as well as the general public:
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- Public information like your profile pictures that you submit to Local. If
a Local service is streamed on the web or broadcast in some other media, it may be
viewed by the public at large.
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- With our affiliates, we may share information with entities within the HAY
family of companies.
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- With third parties, we may share your information with the following third
parties:
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-With service providers, sellers, and partners. We may share information
about you with service providers who perform services on our behalf, sellers that
provide goods through our services, and business partners that provide services and
functionality.The information is shared to theses partners to facilitate our
services-in some cases directly and in some cases in a support function. Below is a
representative list of the main providers we work with, a brief description of the
types of services they provide for Hay, and a link to their privacy policies.
Example partners include
TrustDecision (anti-fraud, credit analytics, and compliance). From time to time, we may update
this list to make sure you understand who we partner with.
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- With third parties for legal reasons. We may share information about you if
we reasonably believe that disclosing the information is needed to:
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- Comply with any valid legal process, government request, or applicable law,
rule, or regulation;
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- Investigate, remedy, or enforce potential Terms of Service violations;
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- Protect the rights, property, and safety of us, our users, or others; or
detect and resolve any fraud or security concerns.
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- With third parties as part of a merger or acquisition. If Hay gets involved
in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all
or some portion of our business to another company, we may share your information
with that company before and after the transaction closes.
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- In the aggregate or after de-identification. We may also share with third
parties, such as advertisers, aggregated or de-identified information that cannot
reasonably be used to identify you.
You expressly agree that information provided when you register the App and/or the
content your created when using the App (including without limitation, photos, text,
messages, posts, html, URLs, pictures, video and other content), may be recorded,
stored, published and made available to the rest of Hay users. Furthermore, other
users may follow you on the App, and your followers can see, for example, the user
contributed content that you have uploaded to the App. Individuals reading this
information may use it or disclose it to other individuals or entities without our
control and without your knowledge. We therefore urge you to think carefully about
including any specific information you may deem private in the information you
provided or content that you create in the App.
Your information may also be stored and process in any country in which we provide
service to due to server facilities and third-party service teams. By using our
service, you consent to any such transfer of information outside of your country.
If you do not agree with all of the terms of this Privacy Policy, please do not use
our service. Community safety is our number one priority and some of the above user
information are mandatory in order to create a safe community for all users.
Information You Choose to Share with Third Parties
The services may also contain third-party links and search results, include
third-party integrations, or be a co-branded or third-party-branded service that’s
being provided jointly with or by another company. By going to those links, using the
third-party integration, or using a co-branded or third-party-branded service, you may
be providing information (including personal information) directly to the third party,
us, or both. You acknowledge and agree that we are not responsible for how those third
parties collect or use your information. To the extent that you use a profile that may
be available to others on our Service, you are solely responsible for its content and
accuracy at all times. As always, we encourage you to review the privacy policies of
every third-party website or service that you visit or use, including those third
parties you interact with through our services.
How Long We Keep Your Content
Finally—and this is important—you should understand that users who see the content you
provide can always save it using any number of techniques: screenshots, in-app
functionality, or any other image-capture technology. It’s also possible, as with any
digital information, that someone might be able to access messages forensically or
find them in a device’s temporary storage. If any deletion of user information of our
App happens, we cannot promise that deletion will occur within a specific timeframe.
And we may also retain certain information in backup for a limited period of time or
as required by law.
How We Protect Your Information
Protecting user privacy and personal information is a top priority for us. We process
your personal information to improve and enforce our security measures, combat spam,
malware, malicious activities, or security risks, and to monitor and verify your
identity so that unauthorized users do not access your account with us. Access to any
user information is restricted to our employees, contractors, agents, and third-party
service providers ONLY whom needs to know the information in order to provide,
operate, develop, maintain, support, and optimize the our service experience and
security. We use password protection, access logs, and system monitoring to safeguard
the confidentiality and security of all user information. Due to the inherent nature
of the internet and related technology, we do not guarantee the protection of
information under our control against loss, misuse, or alteration.
Control over Your Information
We want you to be in control of your information, so we provide you with the following
tools.
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- Access and Updates. We strive to let you access and control the personal
information that we have about you. There are limits though to the requests we’ll
accommodate. We may reject a request for a number of reasons, including, for
example, that the request risks the privacy of other users or is unlawful. You can
access and update your account information right in the app by visiting the app’s
Settings page. If you need to access, update, or delete any other personal
information that we may have, you can put in a request here. Because your privacy is
important to us, we may ask you to verify your identity or provide additional
information before we let you access or update your personal information. You can
also remove our service from your mobile device or process account deletion.
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- Revoking Permissions. If you change your mind about our ongoing ability to
collect information from certain sources that you have already consented to, such as
your phonebook, camera, photos, or location services, you can simply revoke your
consent by changing the settings on your device if your device offers those options.
Of course, if you do that, certain services may lose full functionality.
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- Erasure. You have the right to ask for your personal information to be
deleted in certain circumstances. Please note that your right to erasure may be
limited if the data are necessary for compliance with a legal obligation or for the
establishment, exercise or defence of legal claims.” - Restriction on Processing:
You have the right to object to and ask for restrictions on the processing of your
personal information in certain circumstances.
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- Objection: You have the right to object, on grounds relating to your
particular situation, at any time to processing of your personal information. Hay
shall no longer process the personal information unless Hay demonstrates compelling
legitimate grounds for the processing which override your interests, rights and
freedoms or for the establishment, exercise or defence of legal claims.
Data Removal
You can choose to remove your data anytime you want. If you ask us to delete your
account, we will use commercially reasonable efforts to remove your data from our
servers, subject to any applicable legal or other requirement to maintain certain
records of your personally identifiable data. Please note that the deletion of your
personally identifiable data from our database may result in us not being able to
provide you with the Service. If you need to delete any data or personal information
that we may have, you can simply tap “Me-Settings-About Hay-Delete Account”, but we
may ask you to verify your identity or provide additional information before we let
you delete your personal information.
Analytics and Advertising Services Provided by Others
We may let other companies use cookies, web beacons, and similar tracking technologies
on the services. These companies may collect information about how you use the
services and other websites and online services over time and across different
services. This information may be used to, among other things, analyze and track data,
determine the popularity of certain content, and better understand your online
activity.
Additionally, some companies may use the information they collect on our services to
deliver targeted advertisements on behalf of us or other companies, including on
third-party websites and apps. Hay does not currently respond to do-not-track signals
that may be sent from your device. If we do so in the future, we will provide
information about that practice in an updated version of this privacy policy.
Children
Our services are not intended for—and we don’t direct them to—anyone under 18. And
that’s why we do not knowingly collect personal information from anyone under 18.
Revisions to the Privacy Policy
We may change this privacy policy from time to time. But when we do, we’ll let you
know one way or another. Sometimes, we’ll let you know by revising the date at the top
of the privacy policy that’s available on our website and mobile application. Other
times, we may provide you with additional notice (such as adding a statement to our
websites’ homepages or providing you with an in-app notification).