PRIVACY POLICY

Our Privacy Policy was updated on Dec 17 th , 2021

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

ABOUT US

S uper Creativity L imi t e d (hereinafter refer to as “ Emotn ”, “ we ”, “our” or “ u s”) take y ou r privacy very seriously. This Privacy Policy is designed wit h your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, yo u h ave contro l of your personal information provided to us .

ABOUT THIS PRIVA CY POLICY

This Privacy Policy explains how Emotn collects, uses, discloses, processes and protects any personal information that you give us or that we collect from you. Should we as k you to pr ov ide certain information by which you can be identified when y ou use the services on our platform, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Under this Privacy Policy, “personal inf or m ation” mea ns information that can be used to directly or indirectly ident if y an individual, either from that information alone or from that information combined with other information Emotn has access to about that individual, except as otherwise specif ic a lly provid ed by applicable laws in your region. We will use your personal i nformation strictly in accordance with this Privacy Policy.

HOW WE CAN HELP YOU

Ultimately, what we want is the best for all our users . Should you have any questions with our dat a h andling pr ac tices as summarized in this Privacy Policy, please contact us a t https://www.emotn.com   to address your specific concerns. We will be happy to hear from you.

1 WHAT INFORMATION IS COLLECTED BY US AND HOW DO WE USE IT?

In order to provide you with services, we will ask you to provide the necessary personal in formation related to these services. We will only collect the information necessary for its specific, specific, clear and legitimate purp ose, and will not further process it in a way that is inconsistent with these purposes. You have the right to choose wh ether to provide the information we request. Depending on the service you choose, we may collect the following types of information:

(1) Provide, process, maintain, improve and develop our services to you;

(2) To deal with your questions or requests for ou r services, such as sending notifications.

2 COOKIES AND OTHER TECH NOLOGIES

Technologies such as cookies, tags, and scripts are u sed b y Emotn and our third party service providers and business partners (for more information see   “How we share, t ransfer, a n d publicly disclose your personal informati on”   below). These technol ogies are used in anal yzing trends, ad minist ering the si te, tr ack in g users’ movements around the website and to gather demographic information about our user base as a whole. We may recei v e reports based on the use of these technol ogies by these companies on an individual as we ll as aggregated basis . These tech nologi es he lp us better understand users’ behavior, tell us which parts of our websites people have visited, as well as f acilitate a nd measure the effectiveness of web searche s. We treat information c ollected by cookies an d other technolo gies a s non person al inf orm at ion, except where Internet Protocol (IP) addresses or similar identifiers are considered personal information by local l a ws.

• Log files:   As true of most websites, we gather certain informati on and store it in log files. This inf ormati on may inclu de Int ern et Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating syste m, date/ti m e stamp, and/or clickstream data. We do not link this automatically collected data to othe r information we gathe r about you.
• Local st or age – HTML5/Flash:   We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences . Third pa r ties with whom we partner to provide certai n features on our sites a lso use HTML5 or Flash cookies to coll ect an d store info rmatio n. Va rious browsers may offer their own management tool for removing HTML5 LSOs.

3 HOW WE SHARE, TRANSFER, AND PUBLIC LY DISCL OSE YOUR PERSONAL INFORMATION

3.1 SHARING

We do not sell any perso nal inf ormation to third parties.

We may somet imes share your perso na l information with third parties (as described below) in or der to pro vide or improve our services, includin g offering ser vices based on yo ur requirements. If you no longer wish to allow u s shari ng this information, please contact us at   https://www.emotn.com   。

3.1.1 SHAR ING THAT YOU ACTIVELY CHOOSE OR REQUEST

With your explic it con sent or at your request, we will share your personal information within the scope of your consent/request with specific third p ar ties designated by you.

3.1.2 SHARING INFORMATIO N WITH OUR GROUP

In order to successfully conduct business operations and to pr ovide you with all the functions of our services, we may share your personal information from time to time to other Emotn affil ia tes.

3.1. 3 SHARING WITH THIRD PARTY SERVICE PROV IDERS AND BUSINES S PARTNERS

To help us provide you with services describe d in t his Privac y Policy, we may, where necessary, share your personal information with our third party service providers and busines s partners.   This includes our data centers, data s torage facilities and other business partners , such as Alibaba cloud and A mazon cloud . These third parties may process your perso nal information on Emotn ’s behalf or for one or more of t he purposes of this P ri vacy Policy.   We guarantee that the sharing of personal informatio n necessary for provid ing services to you is solely for legitimate, legal, necessary, specific, and e xplicit pu rposes. Emotn w ill conduct due diligence and have contrac ts in place to ensure t hat third-party service providers comply with the applicable priv acy laws in your juris diction. There may be occasions th at third-party service providers have their s ub-process ors.

To provide performance measurement, analysis, and ot her business services , we may also share information (non-personal information) with thi rd parties in aggregat ed form. We use the information we have to help our business partners evaluate the effect iveness and coverage of their services, and understand th e types of people who u se their services and how people interact with their websites, ap ps, and services. We m ay also share general usage trends of our services with them, such as the numbe r of custo mers in a particular group of people who purchase certain products or engage i n certain transactions.

3.1. 4 OTHER

In accordance with legal requir ements, legal procedur es, litigation and/or requests fro m public agencies and government agencies, we may need to disclose your personal information. If the disclosure is necessary or appro pr iate for national security, law enforcement, or other matters of public importance, we may also disclose information abou t you.

In order to enforce our terms or prote ct our bus iness, rights, assets or services, or to protect users, o r if the disclosure i s reasonably necessary for the following purposes (detecting, preve nting and resolving fr aud, unauthorized use of the servi ce, violations of our terms or policies, or o ther harmf ul or illegal activities), we may also disclose informati on about you. (There ma y be occasions when we may collect, use or disclose your personal information without y our consent if it is and only to t he extent it is permitted under applicable da ta protect ion laws). This may include providing your personal infor mation to public or g ov ernment agencies; communicating with third-party partners about t he reliability of your account to prevent fraud, violati ons, and other harmful behaviors.

In addition , we may s hare your personal information with:

• our accountants, aud itors, lawyers, or si mi lar advisers when we ask them to provide us with professional adv ice; and
• investors and other relevant third parties in t he event of an actual or potential sale or ot her corpor ate transaction related to an entity of Emo t n a ffiliates ; and
• any other third pa rties, if authorized by you to do so in relation to a specific di sclosure.

3.2 TRANSFE R

We will not transfer your informa tion to any subject except in the following c ases:

• Wher e we have obtained your explicit consent;
• If Emo t n is inv olved in the merger, ac quisition, or sale of all or part of its assets, we will notify y ou of any changes in the ownership, use, and any choice of your personal information you possibly pos sess by em ail and/or by posting a prominent notice on our websites.

3.3 PUBLIC DISCLOSUR E

We will only publicly disclose your personal information under th e following circumst ances:

• Where we have obtained your e xplicit consent;
• Public disclosure based on l aw or reas onable grounds: including laws and regulations, legal pro cedures, litigation, or at the request of the competent government departments.

3 .4 Exce ptions for obtainin g prior authorization and consent whe n sharing, transferring, and publicly disclosing person al information

In any of the following cases , n o prior co nsent is required to sh are or disclose your information :

• It is related to our fulfillmen t of obligations as stipulated by laws and regulations;
• It is directly related to national security and nationa l defense security;
• It is directly related to public safe ty, public health, an d major public interests;
• It is directly related to criminal invest igation, prosecutio n, trial, and execution of judgments;
• For the purpose of safeguarding the life, property and other i mportant legal rights and interests of personal i nformation subject s o r other individuals, it is difficult to obtain authorization and co nsent of the subjec t;
• The personal information involved is disclosed to the public by the pe rsonal information subject;
• The personal information is collected from legal ly publicly disclosed i nformation, such as legal news reports, government information di sclosure, academic research results, and other channels;
• Other circumstances stipulated by laws and regulations .

 

4 HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

4 .1 How do we store yo ur personal information

We will store your information with securit y techn ological pro tection measures, including local sto rage, data cach ing , database and server log. All your p ersonal information will be stored on secure servers and protected in controll ed facilities. Your information will be classified according to its importance and sen sitivity, and your personal informati on will surely possess the required level of security. We have special access controls for cloud-based data stor age. A periodic revie w will be performed on o ur information collection, storage and proc essing practices, i ncluding physical security measures, to prevent any unauthorized access and use.

4. 2 E mo t n 'S S ECURITY SAFEGUARDS

We are committed to keep ing your per sonal information sec ur e. In order to prevent unauthorized access, disclosure or other s imilar risks, we have put in place all legally required physical, electronic and managerial procedures to safeg uard and secure the information we collect fr om you. We w ill ensure that we sa fe guard your personal information in accordance with applicable law .

We conduct due diligence on bu siness partners and thi rd party service providers to make sure that they are able to protect your personal information. We also check t hat a ppropriate secur it y standards are maintained by these third parties by putting in place appropriate contractual rest rictions, and where nec essary, carrying out audits and assessm ents. In addition, our employees and those of our business partners and t hird party service pr ov iders who access your personal information are su bject to enforceable contractual obligations of c onfidentiality.

We cond uct security and privacy protection tra ining courses and tests to enhance our employees' awareness of the import ance of protecting pe rs onal information. We will take all practicable an d legally required steps to safeguard your person al information. However , you should be aware that the use of t he Internet is not entirely secure, and for this reason we cannot guarant ee th e security or in te grity of any personal information when transferre d from you or to you via the Internet.

We handle personal data breaches as required by applicable data protecti on law which includes, where required, notifying the breach to the releva nt da ta protection su pe rvisory authority and data subjects.

4. 3 WHAT YOU CAN DO

You can not disclosing your sign-in password or account informat io n to anybody (unless such person is duly authorized by you) to avoid password leaks to other websites which ma y harm your account s ec urity . When ever possible, please do not disclose the verifi cation code you received to anyone (including those who claim t o be Emo t n ’ s customer service). If you ne ed to use your account to log in to use our servic es , particularly on somebody else's comp ut er or on public Internet terminals, you should always sign out at the end of your session.

We cannot be held responsible for lapse s in security caused by third party accessing your personal information as a r esult of your failure to keep your personal in fo rmation private. Notwithstanding the foregoing, you must notify u s immediately if there is any unauthorized use of your a ccount by any other Internet user or any other breach of security. Your assistance will help us protect the priv acy of your personal in formation.

4. 4 RETENTION POLICY

We retain personal information f or the period necessary for the purpose of the informatio n collect ion described in this Privacy Policy, or as required by applicable laws. We wi ll cea se to retain and de lete or anonymize per so nal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we te rminate t he operation of the corresponding service. An exception to this is personal in format ion that we are pro cessing for public in te rest, scientific, historical research, or statistical purposes. We will continue to retain this type of information for l onger tha n its standard retention period, where permitted based on applicable laws or y our re quest, even if furt her data processing i s not related to the original purpose of collection.

5 YOUR RIGHTS CONTROLLING YOUR PERSONAL INFORMATION

5.1 CONTROLLING S ETTINGS

We recogniz es that privacy concerns differ from person to person. Theref ore, we prov ide examples of way s Emo t n makes availab le to you to restrict the collection, use, disclosure or pr o cessing of your personal information and control your privacy s ettings, such as sign in or out of the Account.

If you have previously agreed to us using you r personal informat ion for the aforement io ned purposes, you may change your mind at any time by emailing us with the following email address: support@emotn.com   .

5.2 YOUR RIGHTS TO YOUR P ERSONAL INFORMATION

Depending on applicable law s and regulations, yo u have the r ight to access, rectification, and erasure of any other personal information that we hold about you (hereinafte r referred to as the request).

You may also access and update th e detail s relating to the personal information in your Acco unt by l o gg ing into your account on your device. For additional information, please write to us or contact us at   https://www.emotn.com .

This Privacy Policy requires that your request satisfy a pplicable law s and re gu lations and the following conditions:

(1)   Through Emo t n 's particul ar request submission channels listed below, and your reque st should be in writing (unless the local law expli ci tly recognizes the oral request), for the protection of you r information securit y;

(2)   Provide sufficient information to enable Emo t n to verify your identity and ensure that you are the subject of the reques ted information or a personal legally authori zed t o a ct on the subject’s behalf.

Once we obtain sufficient infor mation to con firm tha t your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applic able data protection laws.

In detail:

• You hav e the ri ght to be provided with clear, transparent and easily under standable inf ormation a bout how we use your personal information and your rights. Thi s is why we are providing you with the information in this Privacy Policy.
• Based on the requirements of appl ica ble laws, a copy of your personal data collected and proces sed by us wil l be pro vi ded to you upon your request free of charge. For any extra req uests for relevant information, we may charge a reasonable fee based on actual administrative costs acco rding to the applicable laws.
• If any information we are holding on you is incor rect or in complete, you are entitled to have your personal information c orrected or completed.
• • Based on the requirements of appli cable laws, you have the right to request the dele tio n or removal of your personal information where there is no compelling r eason fo r us to keep using it. We shall consider the grounds regarding y our erasure request and take reasonable steps, including te chnical measures.   If the right is upheld, we may n ot be able to immediately remove the information from the back up system due to appl ic able law and/or technology limitations. If this is the case, w e will securely store your personal information and isolate it from any further processing until the bac kup c an be cleared or be made anonymous.
• You have the right to obje ct to certain types o f processing, and under certain circumstances where the legal ba sis for processing is our legitimate interests..

Particular ly under the laws of some jurisdictions:

• You have the right to obtain from us the restriction of processing your personal inf ormation . We shall consider the grounds regarding your restriction reque st. If the grounds apply to GDPR, we shall only process you r personal information under applicable circu mstan ces in GDPR and inform you before the restriction of processin g is lifted.
• You hav e the right not to be subject to a decision based solely on auto mated processing, which produces legal effects concerning y ou or similarly significantly affects you.

 

• Y ou ha ve the right to apply for your personal information in a struc tured, common ly used fo rmat and transmit the information to another data controller.

We have the right to refuse to process requests that are fr ivolous requests that damage others' right of priv acy , extremely unrealistic requests, requests that require dis proportionate technic al work, and requests not required under local law, information that have been made public, information given under confide ntial conditions. If we believe that certain aspec ts of the request to delete or access the information may resu lt in our ina bility t o legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.

6 HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY

Emo t n proc esses and backs up pers onal information thro ug h a global operating and c ontrol infrastructure. Currently, Emo t n has data centers in the United S tates an d China . For th e purposes described in the Privacy Policy, your information may be transferred to these data centers in accorda nce with applicable l aw .

We may also transfer yo ur personal information to third-party service providers and business pa rtners a nd your data ma y therefore also be transmitted to other countries or regions. The jurisdiction in which these global facilities are located may or m ay not protect personal info rmation to the same standards as in your jurisdiction. There are differe nt risks under differen t data protection laws. However, this does not change our commitment to comply wit h this Privacy Policy and to p rotect your personal in formation.

If we need to t ransfer personal information outside of your jurisdiction, whether to ou r affili ates or third-p arty service providers, we will comply with related applicable laws. We ensure tha t all s uch transfers meet the requirements of appli ca ble local data protection laws by implementing uniform safeguards. You can find out about the safe guards t hat we have in place by contacting us at   https://www.emotn.com .

7 PROTECTIO N OF MINORS

We consid er it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer s ervices directly to a child or use personal data of children for the purposes of mark eting.

If you are a parent or guardian and you b el ieve that the minor ha s provi ded Emo t n with personal information, please contact us at   https://www.emotn.com   to ensure that the personal information is removed immediately and that t he minor is unsubscri be d from any of t he appli cable Emo t n services.

8 DO I HAVE TO AGREE TO ANY THIRD PARTY TE RMS AND CONDITIONS?

Our Privacy Po licy does not apply to products or ser vices offered by a third party. Depending on the service you use, it may i ncorporate a third pa rt ies’ p roducts o r servic es. Some of these will be provided in the form of links to third parties’ websites. Your informati on may also be collected when you use these services. For this reason, we strongly suggest that you take the tim e to read the third p ar ty’s p rivacy po licy jus t like you read ours. We are not responsible for and cannot cont rol how third parties use personal information which they collect from y ou. Our Privacy Policy does not apply to other sites linked from our servi ces.

9 HOW WE UPDATE TH IS PRI VACY POLICY

We re view the Privacy Policy periodically based on changes in busines s and technology, and we may updat e this Privacy Policy. If we make a ma terial change to this Privacy Policy, we will notify you via your register ed co ntact informatio n such a s email (sent to the email address specified in your account) or pub lish on Emo t n websites or n otify you via mobile devices so that you can learn about t he information we collect and how we use it. We encourage you to check thi s pa ge regularly for th e lat est information on our privacy practices. Your continued use of the services will be deemed acknowledgement of the u pdated Privacy Policy. We will ask for your explicit consent when we collect additional perso nal information fro m you or when we use or disclose your personal information for new purposes.

10 CONTACT US

If you have a ny comments or questions about this Priv acy Policy or any questions relating to Emo t n ’s c ollection, use, or d isclosure of your perso nal information, ple ase contact us at the f ollowing address : ( 1 ) O f ficial cu stomer service email: support@emotn.c om   ；（ 2 ） O f ficial website: https://www.emotn.com . When we receive pri vacy or personal in formation questions about acc es s/download requests, we have a professional team to solve your problems. If y o ur questi on i tself invo lves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will prov ide informatio n on the relevant complaint channels that may be applicable based on your actual situation.