Date of Last Revision:November 7,2024
Welcome to SUGO(the “Platform” or “SUGO”). The Platform is provided and controlled by Mobile Alpha Limited(“we” or “us”). We are committed to protecting and respecting your privacy.
This Privacy Policy (the “Policy”) covers the experience we provide for users aged 18 and older on our Platform. IF YOU ARE UNDER THE AGE OF 18 OR THE AGE OF MAJORITY AS DETERMINED BY THE LAWS OF YOUR COUNTRY, PLEASE DO NOT USE OUR SERVICES.
This Policy is written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.
We know that other people’s use of your personal data is a big concern for social network users, so we have developed this Policy to let you know how we use your personal information (or "personal data").
Our Policy applies to your use of SUGO. When you access or use SUGO, it indicates your agreement to our “Terms and Conditions” and “Privacy Policy”, and you consent to our collection, storage, use, and disclosure of your personal information in accordance with this Policy. By installing, using, registering to or otherwise accessing the services, you agree to this Policy and give explicit and informed consent to the processing of your personal data in accordance with this Policy.
IF YOU DO NOT ACCEPT AND AGREE WITH OUR “TERMS AND CONDITIONS” AND “PRIVACY POLICY”, PLEASE DO NOT ACCESS OR USE SUGO.
SUGO reserves the right to change our Policy at any time to address Services updates, legal changes, and other factors. We will make commercially reasonable endeavours to notify all the users uniformly of any changes to this Policy that may materially and substantially affect your rights, for example through notices or pop-ups on the Platform. We also recommend you regularly review this Policy to check for any changes. We will indicate the Last Update date at the top of the Policy and your continued use of our Services after the update date signifies your agreement to the updated Policy. If you do not agree with the updated version of our Policy, please do not use our Services.
Here are the topics that we cover:
I. What information do we collect
II. How we use your information
III. How we share your information
VII. Cookies and other technologies
Personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified. We collect personal data from a variety of sources, including you directly provide, we directly collect when you use, and information we collect about you from other sources.
For certain activities, such as when you register, upload content to the Platform, make broadcast or contact us directly, you may provide some or all of the following information:
• Registration information, such as nickname, age, gender, username, avatar, and phone number（including verification code and password）.
• Profile information, such as your height, weight, occupation, location, nationality. These pieces of information are not mandatory; you may choose whether or not to provide them.
• User-generated content, including comments, pictures, text and voice messages, photographs, videos, and virtual item videos that you choose to upload or broadcast on the Platform (“Content”).
• Facial data, if you plan to become one of our certified streamers, or want to complete real person certification (including gender authentication and avatar authentication) for obtaining more benefits, we will collect and compare your profile picture and facial-recognition video for authenticity verification on the premise of your approval. This authentication can protect you from impersonators and fake accounts and protect the legitimate rights and interests of other users. We do not retain your face recognition video in our servers, such video is merely for verifying, and will not be used for any other purpose.
• Transaction information, such as recharge records, transaction records and history, date, items, amounts. We will not retain and collect your credit card name, number or password, these payment information will be collected by the third-party payment channel（such as PayPal）as you choose.
• If you contact our Customer Support team via contact@sugochat.com, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you).
• User logs, you may be required to upload certain user log file information if you report the problems you met when you use our Services, including your operation parameters, operation time, service response time, operation steps, and error reasons.
We collect the following categories of personal data about you automatically when you use SUGO, including:
• Activity information, network information and device information, such as the data we receive when you interact with our app (e.g., your purchase records, search history, log data, or actions you take within the App) or information about your device (e.g., your device version, Device ID, Android ID, Google Advertising ID, IDFA, Hardware Serial Number, Device Model, operating system, system language and region, Mac address), and the network information（e.g., your network carrier and network type);
• Coarse geolocation data, such as location information we receive about you (e.g., based on your Internet Protocol (IP) address, Wi-Fi SSID, etc.);
We will only collect your GPS information with your express consent, you can withdraw your consent at any time by turning off location permissions. GPS information is the sensitive information, if you refuse to provide, you will not able to use the location-based services, but it will not affect your use of SUGO other services.
When you use our Services, your location, microphone and phone camera permissions shall be used upon your explicit authorization, we will ask for your consent via in-app pop-ups when you access to the relevant functions.
We may receive the information described in this Policy from other sources, such as:
• Social Media. If you choose to link or sign up using your third-party social network platform (such as Facebook, X, Instagram, or Google), we may collect information from these social media services, including your nickname as it appears on your social media profile, your user ID and your profile image, this depends on the policy of the social media platform and your privacy settings.
• Third-Party Services. We may collect information about you from third-party services, such as advertising partners, payment partners and analytics providers. However, please note that this Policy does not and will not extend to how the third-parties collect and process your information, which shall be subject to the respective their own privacy policies.
We may use your personal information for the following purpose：
• Services Provision and Operation: To provide you with SUGO Services and maintain the normal operation of the services, such as voice chat, video chat, interactive communication between users, discovering friends, motivating tasks, posting your social updates and your other activities through SUGO；
• Identification and Authentication: To verify your identity and create a profile for you when you register with us, identify your device, access and use our Services, or otherwise engage with us, and to ensure the security of your personal data;
• Contractual Obligations: To carry out our contractual obligations to you under the Terms and Conditions or to take steps at your request before entering into such agreement；
• Service Improvements and Analyse: To continually improve the user experience, identify network status, monitor account anomalies, and understand the suitability of products and services;
• Security: To keep users’ activities and accounts security;
• Recharge Services: To support and verify user payment behavior;
• Communications and Customer Service: Respond to your requests to us and notify you of changes to SUGO services and this Policy;
• Advertising and Marketing: To understand your preferences, and to help determine which marketing materials would be of interest to you. Where required by law, we will obtain your consent before sending such marketing materials;
• Exercising our Rights and Complying with our Obligations: Exercise our legal rights where it is necessary, for example to detect, prevent, and respond to infringement claims or violations of law. We may process your personal data to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
We are committed to maintaining your trust and personal information safety. We will not provide, disclose or share your personal information to or with any third parties unless we have obtained your consent or such provision, disclosure or sharing of personal information is permitted under applicable laws. The potential circumstances in which we may share your information with necessary third parties are listed in this Policy as below.
Please be informed that when you upload and publish your personal information, posts, comments, videos and other contents, the above contents may be seen by anyone on the platform, and SUGO cannot guarantee that your above contents will not be found on other third-party platforms. You should be cautious to disclose personal information while engaging. We are not responsible for the information you choose to submit.
• Cloud service providers: provide basic data storage services;
• Payment service providers: help you process and complete transactions. Any payment sensitive information (such as card number, payment password, CVV number and so on) is collected and processed by the payment processor you choose;
• Advertising and attribution service providers: provide you with advertisements when you visit our Services, to market our Services and statistical advertising conversion rate;
• Data analysis and security service provider: count and monitor the number of users, conduct data analysis, identify fraud and ensure user safety.
• Other business partners: help us operate, promote, and improve the Services.
In particular, in relation to the advertising displayed in SUGO app, we use third-party advertising companies to serve ads when you use our app. These companies may use information about your visits to this and other websites in order to provide you with various advertisements.
We may share your information with our parent companies, subsidiaries, or other affiliates of our corporate group for better service. We will take measures to have our group companies with which the personal information is shared comply with this Policy.
If there is any transaction between companies pertaining to our business to which this Policy is applicable, such as acquisition, merger or change of business entity, personal information may also be transferred to the successor of the business to the extent permitted under applicable laws.
SUGO wishes to maintain a healthy community, and we will cooperate with all the related third parties to enforce their intellectual property or other rights.
We may disclose your information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of SUGO, the Platform, our affiliates, users, or the public. We may also share your information to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law in our discretion.
We will also cooperate with law enforcement inquiries from within or outside your country of residence. When we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, or legal process served on us, we may raise or waive any legal objection or right available to us.
To the extent permitted under applicable laws, regarding your personal information that we process, you have the right to access, the right to rectification, the right to erasure, the right to restriction of processing, the right to withdraw your consent, the right to data portability, the right to confirm if we process any personal information of yours, and the right to request a review of any automated decisions that may be made as a result of the processing. And, we will not discriminate against you for exercising any rights.
If you want to exercise your right against us to process your personal information, correct or delete your personal information that is contrary to facts, notify you of the purpose of use of your personal information, or other rights permitted under applicable laws, you may contact us via contact@sugochat.com.
After verification of your identity, we will respond to your request within a reasonable period of time, and in accordance with relevant laws. If, however, permitted under applicable laws, we may not be able to respond to your request when any of the following applies:
• is likely to harm the life, body, property, or other rights or interests of yours or another user / individual;
• is likely seriously impede the proper execution of our business;
• is likely to violate other laws and regulations;
• when we failed to verify your identity; or
• we are otherwise permitted under applicable laws to refuse your request.
If you no longer wish to use SUGO or if you withdraw your consent to SUGO's processing of your personal information which is necessary for us to provide services, you may choose to delete your entire SUGO's account by the following steps：
• Open SUGO
• Tap Me＞Settings>Account and Safety>Delete account
• Click “Request deletion” or “Think again”
【Note: You will have 7 days to withdraw your account deletion application after you click the “Request deletion” and “Delete account” by logging in again within this time period, and it will be considered that you have canceled your application of deletion. Otherwise, with the 7 days passed, your account will be permanently deleted and cannot be recovered. To delete your account means that we will delete your identity information, your access to your account, all your user content, account benefits, transaction history, and friends/chat heat/chat history on SUGO.】
However, the withdrawal of your consent will not in any way affect the lawfulness of our processing of your Personal Data based on your consent that was given before the foregoing withdrawal.
SUGO is a global social app operating through servers located in a number of countries around the world, including the United States. In providing our services, we may store your personal information outside the country or region where you reside. When that happens, we will take measures to ensure your personal information is processed and stored according to the applicable laws. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. We will store your personal information within the reasonable and necessary period prescribed by laws and regulations. We will delete or anonymize the information beyond the above period.
SUGO has implemented reasonable and appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal information. SUGO uses reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls. Our technical experts at SUGO work hard to ensure your secure use of our site.
While we take reasonable precautions against possible security breaches of our website, member database and records, you understand that no website or Internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your password) and to log out of your account after use.
We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk. Once we have received your information we have procedures and security features in place to try to prevent unauthorized access.
You may not disclose your password to any third parties or share it with any third parties. If you lose your password or give it out, your personal information may be compromised. If that happens, please report it to Support via our Online Customer Service. You should change your password immediately via your “Settings” page. SUGO cannot be held responsible for your failure to keep your password secure and failure to do so may violate our Terms and Conditions.
To make the application work effectively, we sometimes place small data files called Cookies on your device. Most applications’ developer do this. A Cookie is a small text file that website saves when you visit the site. It enables the website to remember your actions and preferences, designed to improve use experience.
You can control whether or not to accept Cookies by contacting us or your browser settings. If, however, you deactivate Cookies or limit the ability to set Cookies, you may not be able to obtain the full benefit of our services or access all of its functions, which may limit your overall user experience.
To make the application work effectively, we sometimes place small data files called cookies on your device. Most application’s developer do this. A cookies is a small text file that website saves when you visit the site. It enable the website to remember your actions and preferences, designed to improved use experience.
You can control whether or not to accept cookies based on settings or by using other tools. If,however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of our services or access all of its functions, which may limit your overall user experience.
We may install modules of other companies in the SUGO to analyze how the service and product have been used or provided. With regard to your personal information that is processed by a third-party through a module provided by such third party,the privacy policy of such third party will aplly and we also encourage you review it(if any).
WE DO NOT PROVIDE SERVICES TO MINOR USERS UNDER THE AGE OF 18 (OR THE AGE OF MAJORITY UNDER LOCAL LAW). We do not knowingly or deliberately collect or retain the personal information of individuals under the age of 18. If we learn that personal information of individuals under the age of 18 has been collected on or through our Services, we will take appropriate measures to delete such information and delete the corresponding account.
If you become aware that your child is using our Services or that we have collected information about your child, please contact us at contact@sugochat.com and we will assist you in deleting all of your child's information and taking action to block the relevant account.
You can use our instant message function, which allows you to communicate with other users of SUGO. But we recommend and encourage you (and all our users) to consider carefully about the disclosed information of other users. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names, addresses, credit card details, national identity numbers or drivers’ license details and other sensitive information in your Profile, which may open to abuse and misuse.
Moreover, please be careful to post sensitive details about yourself on your Profile such as your religious denomination and health details. You may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, but we never desire to deliberately collect them. Please remember that any photographs or video clips that you post on SUGO may reveal these kinds of sensitive personal data. When you upload and post this sensitive information about yourself, you are explicitly consenting to our processing of your information. And you will at your own risk to do this. If you post anything which is inconsistent with our Terms and Conditions or this Policy, we reserve the right to disable your account.
Questions, comments and requests regarding this policy should be addressed to contact@sugochat.com.