妙回输入法隐私政策

Last Updated: February 2025

Welcome to Chatterly. This Privacy Policy is designed to help you understand how we collect, use, and protect your personal information. Game4play Limited ("we") is committed to protecting your privacy and personal information, and complies with relevant regulations including the EU Digital Services Act (DSA).

1. Information Collection and Legal Basis

We collect and process your personal information based on the following legal grounds:

• Performance of our service contract with you
• Compliance with legal obligations
• Our legitimate interests (provided they don't override your rights and freedoms)
• Your explicit consent

Information we collect includes:

• Input Data:
  • All input data is processed locally on your device
  • We do not upload or store your input content
  • You can clear input history on your device at any time
• Sticker Content:
  • User-uploaded sticker files (only for providing sticker sharing services)
  • Sticker usage statistics (such as usage frequency, sharing count, etc.)
  • Sticker metadata (such as file size, format, upload time, etc.)
  • We only serve as a technical service platform and do not review sticker content
• Usage Data:
  • App performance data
  • Feature usage statistics
  • Crash reports
• Device Information:
  • Device model
  • Operating system version
  • Language settings
  • Time zone information

2. Information Use Purpose and Method

We use the collected information to:

• Provide, maintain, and improve our Chatterly services
• Provide sticker sharing and storage services
• Develop new features and enhance user experience
• Troubleshoot technical issues
• Send essential service notifications
• Prevent fraud and abuse
• Handle copyright infringement complaints
• Ensure compliance with legal requirements

3. Data Storage and Transmission

About your data:

• Storage Location: Data is stored on servers in the EU and Hong Kong
• Storage Period: We retain your data only for as long as necessary
• Data Transmission: If data is transferred across borders, we ensure compliance with GDPR and related regulations
• Data Minimization: We only collect necessary personal information

4. Information Security Measures

We take the following measures to protect your data:

• Data encryption for transmission and storage
• Access control and identity verification
• Regular security audits
• Employee data protection training
• Incident response plan

5. User Rights

Under GDPR and DSA regulations, you have the following rights:

• Right to Access: Obtain a copy of your personal data that we hold
• Right to Rectification: Request corrections to inaccurate personal data
• Right to Erasure: Request the deletion of your personal data
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to our processing of your data
• Right to Withdraw Consent: Withdraw your consent at any time

6. Algorithm Transparency

In accordance with DSA requirements, we maintain transparency regarding:

• The principles and operations of Chatterly's algorithms
• The basis for our personalized recommendations
• Our content sorting and filtering mechanisms
• Options to disable personalization features

7. Child Privacy Protection

We take special measures to protect child privacy:

• We will not intentionally collect personal information from children under 13
• Delete immediately if collected by mistake
• Provide special protection measures for minors

8. Sticker Content Responsibility Statement

Regarding user-uploaded content in sticker features:

• We only serve as a technical service platform, providing users with technical tools for sharing and storing stickers
• Users are responsible for the sticker content they upload, and we do not assume responsibility for such content
• We do not actively review user-uploaded sticker content
• If rights holders believe their intellectual property rights are infringed, they may contact us through the following methods:
  • Complaint email: [email protected]
  • Please provide identity proof of the rights holder, proof of the infringed work, location of infringing content, etc.
  • We will handle valid complaints promptly and may remove related content
• We encourage users to only upload content they own or have obtained authorization for

9. Third-Party Services

We use the following third-party services:

• Firebase:
  • Purpose: Performance monitoring and crash analysis for Chatterly
  • Data Processing: Complies with GDPR
  • Details: Firebase Privacy Policy
• Adjust:
  • Purpose: Installation and usage analysis
  • Data Processing: Complies with GDPR
  • Details: Adjust Privacy Policy
• Cloud Storage Services:
  • Purpose: Sticker file storage and distribution
  • Data Processing: Only stores user-uploaded sticker files, no content review
  • Security Measures: Uses encrypted storage and transmission

10. Complaints and Appeals

If you believe your data protection rights have been violated:

• You may contact our Data Protection Officer directly
• File a complaint with the relevant data protection authority
• We will respond to your concerns within 30 days

Regarding sticker copyright infringement complaints:

• Complaint email: [email protected]
• Please provide the following information in your email:
  • Identity proof and contact information of the rights holder
  • Detailed description of the infringed work and proof of rights
  • Specific location and screenshots of the infringing content
  • Statement that you believe the use is unauthorized
• We will handle valid complaints promptly and may request additional materials from you

11. Contact Information

For data protection inquiries, please contact:

Company: Game4play Limited
Address: UNIT 225-22, 2/F, MEGA CUBE, 8 WANG KWONG ROAD, KOWLOON BAY, HONG KONG
Data Protection Officer Email: [email protected]
General Inquiries: [email protected]

Last updated: February 2025