Privacy policy

Your privacy is important to us.

Poooli and its affiliates ("Poooli", "we", "us" or "our") are dedicated to protecting the privacy of our users ("users" or "you"). This Privacy Policy (the "Policy") is meant to explain our practices regarding how we collect, store, use, manage and protect your user information (including your personal details) during your use of our websites www.hprt.com (collectively, the "Sites") and through any of our mobile applications available on other mobile devices, such as Apple and Android devices (the "Services"), with the exception of those Poooli applications which have separate privacy policies.

Please note that the scope of this Policy is limited solely to your user information (including your personal details) collected or received by Poooli when you are using the Sites and the Services. In this Policy, "personal details" refer to information that either identifies you or that can be used to identify you when used in association with other personal information that Poooli can access, including your name, address, phone number and email address.

BY USING OUR SITES AND OUR SERVICES, YOU ARE EXPRESSING YOUR CONSENT TO THIS POLICY AND THE COLLECTION, PROCESSING, DISCLOSURE AND SHARING OF YOUR USER INFORMATION, INCLUDING YOUR PERSONAL DETAILS IN THE MANNER PROVIDED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THIS POLICY OR ANY SUBSEQUENT CHANGES TO THIS POLICY, PLEASE DO NOT USE OUR SITES OR OUR SERVICES.

The Information We Collect

In order to provide and improve the Sites and Services, Poooli will collect, to the extent permitted by laws and only when you are browsing the Sites or using certain functions and Services, your personal details and user information in accordance with this Policy. If you do not provide this information, we may be unable to provide you with our products or Services.

The Information You Provide to Us

When you use the Sites or the Services, we might recommend you sign up for a Poooli ID ("Poooli ID") to take full advantage of the Sites, the Services and all their features. When you create a Poooli ID, we will collect certain information that can be used to identify you, such as your Poooli ID user name and mobile phone number and so on ("personal details").

Network Information

When you use the Sites or the Services online, we will collect information about the network you use, including the name of the operator and the type of network, so as to understand the distribution of operators and networks used by our users. In addition, we will collect information such as the name of the WiFi to which you connect and the duration of your WiFi connection to understand the scenarios in which you use our Services.

Location Information

We will collect your Location Information, including the country code, latitude and longitude, network location, IP address and the system country and system time zone recorded on your device. This information will help us understand user distribution and usage scenarios, and allow us to provide users with the correct version of our apps and better services. Except as otherwise provided in this Policy, we will not share this Location Information with any third parties. If you no longer wish to allow us to collect or use such information, you may turn off your Internet access or GPS, or disable our access to information about your network, GPS and device.

Log Information

When you use some of the Services, including generating and browsing certain content, we will automatically collect certain relevant log information stored in the Poooli App ("Log Information"). Log Information may include (i) details on when and how often you use the Services, (ii) device statistics, including critical operation paths, errors, crashes, language and time zone. This Log Information is used to improve the Services and is NOT USED to identify our users individually.

Image Information

By choosing to use the editing feature of our service, you understand and agree that we must upload your photos to our server for processing before returning processed photos to you for the purposes of providing such service to you and continuous optimization and that we will also receive the EXIF data about your photos (EXIF data may contain GPS coordinates where photos were taken and processed, equipment type, ISO and information about the front and rear cameras and creation time, depending on the equipment manufacturer) for the purpose of further optimizing our services.

Cookies

When you are browsing the Sites, Poooli or a third party designated by Poooli will use cookies, tags and scripts to collect information in log files and locally cached information for the purposes of analyzing trends, managing the Sites, tracking users’ activity on the Sites and collecting demographics on the user base. Information in log files may include information about your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring and exit pages, your operating system, dates and timestamps, and clickstream data.

Information Collected as Part of User Experience Programs

We may launch a user experience program on our products to improve our products and services and improve user experience. You may choose to join and leave such user experience programs at any time. After you have agreed to join a user experience program and before you choose to leave the program, we will collect your information in accordance with the program. This information will be used by us to better understand and improve our technologies and Services and will not be used to identify you.

Other Information

We may also collect other information which is not related to your identity. For example, we may collect information on the type and version number of your operating system to better understand system upgrades, we may collect information on your system language for the purpose of language adaptation, and we may collect your App list to understand user preferences. If we choose to collect such information, we will do so for the purpose of improving our Services provided to you.

How We Use Information

We collect user information and personal details so that we can provide our products and Services to you and ensure our compliance with relevant laws. We will use your user information and personal details as provided under "The Information We Collect" for the following purposes:

(i) Services. To provide, process, maintain, improve and develop our Sites and/or our Services provided to you, including customer support, and other services provided through our devices or our Sites.

(ii) Statistical analysis. To develop and analyze statistics on the use of our products and Services for the purpose of improving our products and our Services.

(iii) To create a Poooli ID. The personal details that we collect when you use our Sites or Services to create a Poooli ID will be used by us to create your Poooli ID and profile.

(iv) To facilitate your use of forums. Your personal details may be used when we display your profile, when you interact with other users and when you publish forum posts.

(v) To provide location-based services. When you use our Services, we or third-party service providers may take advantage of your location information to provide you with the correct version of our Services and help you gain good user experience.

(vi) To improve user experience. Certain optional features such as user experience programs allow Poooli to analyze data regarding the use of our products and our Services and improve user experience.

(vii) To provide push services. Poooli ID numbers and device information may be used by us to provide push services to assess the performance of adverts and the success of software updates, or provide notifications on new product releases. You may turn off this feature at any time by changing your preferences under "Settings".

(viii) To verify your identity. Verifying your identity using a text message when you log in to your account helps prevent unauthorized logins to your account.

(ix) To collect feedback from you. Your feedback is a great value in helping Poooli improves our Services. To keep track of your feedback, Poooli may use the personal details provided by you to contact you and retain the records.

(x) Other purposes. We will store and maintain information about you for the purpose of running our operations and satisfying our legal obligations.

Information Sharing and Disclosure

We will not sell any personal details to third parties. We have no right to share with or disclosure to third parties your personal details in whole or in part except for the purposes of:

(i) protecting the security of others or their property;

(ii) preventing or dealing with Internet fraud;

(iii) safeguarding the legitimate rights and interests of Poooli;

(iv) taking action in line with our purposes as described in the "The Information We Collect" section, provided that recipient of any such disclosure by us is also bound by this Policy and can provide adequate protection for your information; and/or

(v) complying with laws and regulations or requests by government departments or judicial authorities, which are typically designed to uphold Internet security and the rights, property and safety of us, our users and third parties.

Information Security

We will take reasonable measures to prevent the loss, improper use of, unauthorized access to or disclosure of information. For example, some of our Services will use encryption techniques (such as SSL) to protect your personal details. However, you understand and accept that (in the Internet industry) even though we will take all possible security measures, we cannot always guarantee that your information is 100% secure. You understand and accept that the system and communication network used by you to access our Services may fail due to factors beyond our control.

Information Access and Control

We will take all reasonable and appropriate technical measures to ensure that you can access, update and correct your personal details or other personal details provided to us by you when using our Services. Before you access, update, correct or remove such personal details, we may verify your identity in order to protect the security of your account.

Governing Law

This Policy is established, comes into force, and shall be enforced and interpreted under the law of the People's Republic of China (excluding the laws of the Hong Kong Special Administrative Region and the Macao Special Administrative Region). Any disputes arising hereunder shall also be resolved in accordance with the law of this jurisdiction. We do not represent or warrant that this Policy complies with the privacy law of any jurisdiction. Therefore, you should not interpret this Policy in accordance with such law.

Amendments to this Policy

You agree that we may update this Policy according to relevant laws and regulations or based on Poooli’s business decisions, and you agree to be bound by any such revisions hereto. We will post any significant

changes to this Policy on our Sites or notify you by other means accordingly.