This Privacy Policy describes how the information you share with Hello Pal International, Inc. (“HPI”) and other users is handled when you use HPI’s Services, which currently include the website www.hellopal.com, the support helpdesk support.hellopal.com and the apps Hello Pal, Travel Pal, Language Pal, and the Hello Pal Phrasebooks.

When you sign up and use any of our Services, you are submitting your personal information to us. We will collect, use and store the information that you provide, create, publish or send whenever you use our Services, for the entire lifetime of your Account.  When you sign up and use our Services, you must agree to this Privacy Policy. Make sure you read and understand this Privacy Policy before you sign up for any of our Services.

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1. The information we collect

We collect different types of information about you and your activities when you use our Services, which are listed below.

A. Account and profile information

i. Account registration information

The following is a list of information that we collect when you register for our Services. Most of the information you provide during registration are kept confidential and will never appear in your public in-app profile, nor will those details be made visible to other users. Exceptions to this are the information displayed in your in-app profile, such as your username and profile picture and other details that you choose to include in your profile as described in Section 1A-iii of this Privacy Policy (“In-app profile information”).

• If you register through email: We will collect and store your email address, username (i.e., name shown in your profile), and preferred password.
• If you register through mobile: We will collect and store your mobile number, country code, username (i.e., name shown in your profile), preferred password, SMS verification code (used to verify your mobile number), and email address (if you choose to provide it during registration).
  • The mobile registration and sign in option may not be available for older app versions.
• If you register through a third-party account (Facebook, Google or WeChat): We will collect your email address, preferred password and your basic Facebook, Google or WeChat profile information (which includes your name and current profile picture).
  • Some third-party account registration options may not be available depending on your location (e.g., Facebook and Google are not available for users in China).
• During registration, we also collect details about your device and location, as described in Section 1B of this Privacy Policy (“Device and location information”), as well as the specific app that you used to register for an Account.

ii. Account verification information

To help ensure that all our users are interacting with real people, we will ask you to confirm your identity through a 3-step process of verifying your email address, mobile number, and ID. Completing all three verification steps is not required. Depending on the information that you choose to verify, you will increase your “Trust Score,” which determines the app features that will be available to you. Learn more about Trust Scores.

For the verification process, we will ask you to verify any of the following information:

• Email address – We will collect the email address you enter during Account registration or verification and we will send you a verification email which contains a link that you need to click to verify your email address.
  • Verifying your email confirms that you entered a correct and valid email address to which we can send you newsletters or important announcements and notifications about your Account (e.g., instructions for resetting your Account password).
• Mobile number – We will collect the mobile number and country code that you enter during Account registration or verification and we will send you a verification code through SMS that you need to enter in the app’s mobile verification prompt.
  • Verifying your mobile number confirms that you entered a correct and valid number to which we can send you important notifications about your Account (e.g., instructions for resetting your Account password).
• ID or document – We will collect one valid identification document that was issued to you by your local government (e.g., national ID, passport or driver’s license), your current employer, or your educational institution (current student ID). To verify your ID or document, we will ask you to submit: (1) a picture of the front side of your ID (or the side that bears your full name and picture), and (2) a picture of yourself holding your ID next to your face.
  • We will store the pictures you submit temporarily, or only until we finish reviewing your verification request (generally within 1-3 business days). The review process is described below:
    • A Hello Pal staff member will review the pictures you submitted to confirm your identity (if you are the same person as the one shown in the ID) and that you submitted a genuine and valid ID or document.
    • Once we approve your verification request, we will record a portion of your ID or document number (or in the absence of any ID number, we will record your full name as shown in your ID or document), then we will permanently delete your submitted pictures from our database.

The information you provide during Account verification will be kept confidential and will never appear in your public in-app profile or made visible to other users. Only your “Trust Score,” which is represented by a color-coded shield icon, will appear in your in-app profile.

iii. In-app profile information

You can personalize your app experience by setting up your profile, which will be viewable by all users who sign in to our apps. Some details in your profile will also help you find other users who may have something in common with you, such as your language(s), location, or interests. There are certain details in your profile that are automatically calculated and filled in based on your registration and verification information, and on other details that we collect from you as described in this Privacy Policy.

You may choose to fill in all or only a few details in your profile, but note that a few details are required (you cannot leave those details blank):

• Standard profile details collected for use in Hello Pal, Travel Pal and Language Pal:
  • Username (required) – this can be your real first name or nickname, or a pen name
  • Profile picture (required) – you can add 1 picture, but you can add up to 5 profile pictures (if you have at least a “Good” Trust Score)
  • About You – a short self-introduction or description
  • Nationality and Current Location (both required)
  • Gender and Birthday
  • Languages you speak (required) – you can add 1 language, but you can add up to 5 languages
  • Education, Occupation, Company (where you work) and Interests (you can add up to 20 interest tags)
• Additional profile details collected for use only in Hello Pal:
  • State or Province, City and other Connected Places (e.g., country where you studied/worked/lived in)
  • Languages that you are learning (required) – you can add 1 language, but you can add up to 5 languages
  • Your skills or expertise in translation, proofreading, etc. which you are willing to share with others («I can help with» profile section)
  • Any additional information about yourself
• Additional profile details collected for use only in Travel Pal:
  • Countries visited
  • Travel Plans and/or Hosting Profile
• Additional profile details collected for use only in Language Pal:
  • Languages that you are learning (required) – you can add 1 language, but you can add up to 5 languages

We do not ask you to provide information about your race or ethnicity, religion, genetic or biometric data, political opinion or affiliation, your sexual orientation or preference, or any sensitive information during any part of the Account registration and verification process, and even when you update your in-app profile.

iv. Other Account-related information

Star User status

You can apply to be a “Star User” so that you will be given priority in search results within the app, and you will also have a special badge displayed next to your name and on your profile. This is an optional feature that you can apply for through Travel Pal. Learn more about the Star User status.

You can apply to be a “Star User” as long as you meet our requirements, which currently include: having a “Perfect” Trust Score, complete profile information, having either a Travel Plan or Hosting Profile, and that you have a “clean” record (or there are no valid reports against you). We usually don’t collect any additional information from you apart from the details that you’ve already provided when you verified your Account or when you supplied the details related to the requirements listed above.

• “Star User” applications are reviewed by our staff members who check and confirm if you meet the requirements listed above (the review process may take up to 7 business days).

Hello Pal Wallet

The Hello Pal Wallet lets you store digital currencies like Palto (PLT), Bitcoin (BTC) and Ether (ETH). This feature is powered by Whale Bank, a third party service provider. By activating your Wallet, you will be creating a Whale Bank account.

When you activate your Wallet, we will collect the following details on behalf of Whale Bank:

• Your mobile number and country code
• SMS verification code (issued by Whale Bank during Wallet activation)
• Preferred password for your Wallet Account
• Preferred payment PIN (it must include 6 numbers)

Activating the Hello Pal Wallet is optional. If you don’t activate your Wallet, you may still use our Services, but you will not have access to specific features that require the Wallet.

B. Device and location information

We collect information about the device you use and your current location whenever you use our apps. The information we collect includes the following:

• Device OS, OS version, Advertiser ID, type or form factor (phone or tablet) and system language
• Hello Pal Device ID – this is a unique ID that our system assigns to the device that you use when you sign in for the first time through one of our apps
• IP address, actual local time and geographic location (actual physical location) – these details are recorded every time you sign in to any of our apps
• App-related information: the specific HPI app(s) that you use every time you sign in to your Account, your selected app language and your preferences for notifications (push, in-app messages and emails), your privacy or chat settings, and session trackers or cookies (which pages or screens you visited and used, which app features you used, etc.)

When you visit our website, we collect your device and browser information (if you are accessing our website through a computer or mobile device), and any session cookie(s) and web beacons that were automatically stored in your browser from your last visit (including cookies that save your website language preference). Your Account information is not collected when you visit our website (www.hellopal.com).

If you choose to create an account in our support helpdesk (support.hellopal.com), we will collect your helpdesk account information, which includes your name, email address, and preferred helpdesk account password. Note that your helpdesk account is separate from your app Account, and you are not required to create a helpdesk account – you can send support requests through our helpdesk’s contact form without creating a helpdesk account.

C. User-created content and app activity

You can create, send or publish different types of content or do different activities when you use our apps. We collect Information related to all your app activities, which include the following:

• Your profile information as described in Section 1A-iii of this Privacy Policy (“In-app profile information”)
• Standard user-created content sent or published through Hello Pal, Travel Pal and Language Pal:
  • Full chat history between yourself and everyone you started chats with – includes all text and voice messages as well as any pictures and videos that were sent or received.
  • Voice and video call logs between yourself and everyone you started calls with – includes the type of call (voice or video), the duration of the call and whether the call was rejected or missed (we do not record the voice or video call itself).
  • Full chat history and voice and video call logs between yourself and users you have “ignored” or “archived” – includes the same details that are listed above (even if you never replied to them).
  • Digital currency transaction history between yourself and everyone you had transactions with (for «Transfer,» «Red Packet» and «Gift» features) and digital currency rewards (earned through the Hello Pal Rewards System) – includes the type of digital currency, the amount sent or received and a short greeting or message from the sender (if any).
    • Digital currency transactions and features are only available to you if you activated your Hello Pal Wallet, as described in Section 1A-iv of this Privacy Policy (“Other Account-related information”).
• User-created content sent or published specifically through Hello Pal:
  • Moments – includes the full written text, any attached media files (voice recording, picture or video), selected category tags, posting date, any location that you tagged, number of likes or reactions received, number of comments received (includes the comment details listed below), any reports filed against your Moments, and whether you personally deleted any of your Moments.
  • Comments that you or others posted for your own or other users’ Moments – includes the commenter’s name, Account ID, profile picture, full text or voice comment, posting date, any reports filed against that comment, and whether the comment was deleted by the comment author or the Moment author.
  • Full game history between yourself and everyone you started games with – includes all text and voice messages sent, game language and level, and whether the game is about to start (invitation pending), ongoing, or if it already ended or was cancelled by either party.
• User-created content sent or published specifically through Travel Pal:
  • Moments – includes the full written text, any attached media files (voice recording, picture or video), selected category tags, posting date, any location that you tagged, number of likes or reactions received, number of comments received (includes the comment details listed below), any reports filed against your Moments, and whether you personally deleted any of your Moments.
  • Comments that you or others posted for your own or other users’ Moments – includes the commenter’s name, Account ID, profile picture, full text or voice comment, posting date, any reports filed against that comment, and whether the comment was deleted by the comment author or the Moment author.
  • Travel Plans – includes your specified destination city or country, requested services (e.g., room, meal, travel guide or advice), host or travel buddy gender preference, date and duration of trip, number of travelers, and any additional details that you provided.
  • Hosting Profile – includes your specified general location of the room or property, the exact address of your room or property and your contact information (e.g., phone number), services offered (e.g., room, meal, travel guide or advice), guest gender preference, date and duration when hosting service is available, number of guests allowed, guest restrictions (whether infants, pets or smokers are allowed), sleeping arrangements available (e.g., bed, sofa/couch or mattress/futon), whether the room or property is private or shared with other guests, pictures of your room or property, and any additional details that you provided.
  • Reviews that you gave to other users – includes your basic profile information (name, Account ID, profile picture, age, gender and current location), whether you were a host, guest or travel buddy to that user, full text feedback and posting date.
  • Reviews that other users gave to you – includes their basic profile information (name, Account ID, profile picture, age, gender and current location), whether they were your host, guest or travel buddy, full text feedback and posting date.
• User-created content sent or published specifically through Language Pal:
  • Questions – includes the language you are learning, the full Question text, any attached media files (voice recording or picture), selected content tags, posting date, number of likes or reactions received, number of answers received (includes the answer details listed below), any written notes you included, any reports filed against your Question, and whether you personally deleted any of your Questions.
    • We also collect information on any advanced Question options that you selected, such as: your preferred answer type and language, whether your post should be shown to users who speak a specific language, and whether you want answers from teachers only or from teachers and learners.
  • Exercises – includes the language you are teaching, the full Exercise text, any attached media files (voice recording or picture), selected content tags, posting date, number of likes or reactions received, number of answers received (includes the answer details listed below), any written notes you included, any reports filed against your Exercise, and whether you personally deleted any of your Exercises.
    • We also collect information on any advanced Exercise options that you selected, such as: the difficulty level of your Exercise, your preferred answer type and language, whether your post should be shown to users who speak a specific language, and whether your Exercise is a contest (with a time limit for accepting answers).
  • Answers that you or others posted for your own or other users’ Questions or Exercises – includes the commenter’s name, Account ID, profile picture, full text or voice comment, posting date, number of “thumbs up” and “thumbs down” received, any reports filed against that comment, and whether the comment was deleted by the comment author or the Question/Exercise author.
  • Full Lesson history between yourself and everyone you started games with – includes all voice messages sent, Lesson mode, language, level and learning schedule, and whether the Lesson is about to start (invitation pending), ongoing, or if it already ended or was cancelled by either party.
  • Full game history between yourself and everyone you started games with – includes all text and voice messages sent, game language and level, and whether the game is about to start (invitation pending), ongoing, or if it already ended or was cancelled by either party.

D. Report and support request information

When you send reports against another user or their published content, we collect all information related to the user or content that you are reporting, which include the following:

• Your Account ID and the ID of the user you reported (for reported Moments, Questions or Exercises, the Account ID of the post or comment author)
• The reason for reporting the user or post
• Date when you filed the report
• Number of reports that you filed against the user or post
• Whether you reported the other user from your chat room with them or from their profile
• For reported Moments, Questions, Exercises or Comments: the full content of the reported post (including all media attachments)

When you send us a support request by filling out our helpdesk form (support.hellopal.com), we collect the following information:

• Your helpdesk account details (if you created one), or your name and email address
• Subject or title of your request
• Account ID or email address that you used for your Account in Hello Pal, Travel Pal, Language Pal or the Hello Pal Phrasebooks
• The specific app that you need help with
• Details about the app and your device: app version, device model and OS
• Description of the problem or question
• Any attachments that you include in your request, such as screenshots or a video showing the error or problem

When you send us a support request by sending an email directly to [email protected], we will ask you to provide the same details listed above or any additional details (depending on your specific question or issue), unless you already included those details when you write to us initially.

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2. How we use and share the information we collect

We use your information primarily for customizing or personalizing your experience when you use our Services. Some of the information we collect is also used when we process your support request, troubleshoot issues (as part of preparing updates to our Services), and especially when we enforce our Terms of Service, Privacy Policy and Community Guidelines.

A. Ensuring Account portability

Because you can use one Account for all our apps, we collect information related to your Account, chats, and the content you create or publish so that when you replace your device(s), or when you switch from one of our apps to another, you will be able to access and use your data and keep everything up to date. This is important especially for some features that are shared across all our apps, such as your chat history, profile information and Account verification status.

i. Shared features and information among our apps

Some features are present in a few or all of our apps, and this means information related to those shared features may also appear in our other apps, including apps that you did not use or sign in to yourself (unless you’ve opted out from having your profile appear in the other apps through your Account settings).

• Features shared by Hello Pal, Travel Pal, Language Pal and Hello Pal Phrasebooks:
  • Standard profile as described in Section 4B-i of this Privacy Policy (“Publicly-viewable information in your profile”) – for the Hello Pal Phrasebooks, your profile is only visible to you, and does not include any details or links to your Moments feed, Follower and Following lists
• Features shared by Hello Pal, Travel Pal and Language Pal:
  • Chats – includes text messaging, media sharing (voice, picture and video) and voice and video calling functions
  • “Find a Pal” search – search results show a snippet of your profile, a link to your full profile, and a button for starting Chats, Games, or Lessons, depending on which app you are using (e.g., Lessons are only available in Language Pal)
  • “Followers” and “Following” lists and counts – note that the actual list of users in your Followers and Following lists will only be viewable by you
  • “Star User” badge – this is displayed next to your name when your profile or parts of your profile appears in search results or in post feeds (Moments, Questions or Exercises)
  • Digital currency transaction features («Transfer» and «Red Packet») – note that your Wallet activation status will only be viewable by you (there is no Wallet status indicator displayed in your profile)
• The Hello Pal Wallet and digital currency transaction features may not be available for older app versions.
• Features shared by Hello Pal and Travel Pal:
  • Moments and related comments for each post
• Features shared by Hello Pal and Language Pal:
  • Phrasebook Games

Our user base is shared among all our apps, but your profile will not be shown to other users by default in these specific cases:

• If you registered for an Account through any Hello Pal Phrasebook app – you will not appear in Hello Pal, Travel Pal and Language Pal “Find a Pal” searches until you sign in through one of those apps
• If you registered for an Account through Hello Pal or Travel Pal – you will appear Hello Pal, Travel Pal and Language Pal “Find a Pal” searches
• If you registered for an Account through Language Pal – you will not appear in Hello Pal and Travel Pal “Find a Pal” searches until you sign in through one of those apps

B. Communicating with you

We use your information to notify you about updates to our Services and for any administrative purpose regarding your Account. This includes automated messages used for account verification (when verifying your email and mobile) or when you use the “Forgot Password” link from our app’s login screen, automated and manual in-app message warnings or notifications, as well as marketing and support-related messages that are personally written and sent by our staff members.

C. Troubleshooting and improving our Services

We use your information to test and troubleshoot our Services so that we can address the problem that you need help with (if you submitted any support request) and also so we can improve and update our Services further. We also use your information for any research or data-gathering that we do as part of designing and developing new app features and other services.

D. Keeping all users safe

We use the information that we collect from you and all our users as part of enforcing our Terms of Service, Privacy Policy and Community Guidelines. Some of your information is used for automated measures, as described in Section 2D-iii of this Privacy Policy (“Automated warnings and penalties”), and other details are used by our staff members for manual report processing.

Note that although we collect and store your account details, chat and post history, we do not actively view or monitor your information at all times. We access specific parts of your information only when necessary, as described below.

i. Processing your and other users’ reports

If you reported someone from their profile page, we use the information from your report to check their profile and any Moments, Questions and/or Exercises that they published. In case we do not find any specific violation from their profile and published content, we may review your chat history with them as well.

If you reported someone from a chat room, we will review your chat history with them. Usually, we only review the messages that were sent or received around the time when you filed the report, but if we do not find any violation within those messages, we may review your chat history in full, including all media files (voice messages, pictures and videos) and messages that were previously deleted by you or the other person (see next subsection, “Deleted user-created content”).

If you reported someone’s published content (Moments, Questions, Exercises or Comments), we will review the entire post and related comments, including any content that was previously deleted by the post author (see next subsection, “Deleted user-created content”).

ii. Deleted user-created content

When you delete any message or content that you previously sent or published in our apps, the message or content will be removed from your and other users’ view as soon as you delete them. However, your deleted message or content will still remain in our records (visible only to our staff members) and we may check those too as part of processing reports. This is important especially for cases when the person you reported tries to backtrack and delete their older messages to try to invalidate your report or if they feel you might report them at a later time.

From time to time, we may delete any publicly-viewable content (Moments, Questions, Exercises or Comments) that you published if it includes anything that violates our Terms of Service or Community Guidelines. Any content that our staff members delete will only be removed from your and other users’ view, but that content will still remain in our records as a way to keep track of repeated major or minor violations of our Community Guidelines.

Note that deleting your Account permanently (through any of our apps or upon request at [email protected]) will completely remove your full message and content history from our database, including any content that previously remained visible to our staff members. If your Account was permanently suspended for violating our Terms of Service or Community Guidelines, you may still delete your Account, but some of your information may be retained in our records as described in Section 4D-i of this Privacy Policy (“Account information retained from suspended Accounts”).

iii. Automated warnings and penalties

As described in Section 5 of our Terms of Service (“Your conduct when using our Services”), some automated warnings and app restrictions are sent or applied to your Account when others report you and vice versa. There are certain details from reports that also trigger specific automated warnings and app restrictions. For example, if you reported someone for “inappropriate avatars” or “sexual pictures,” they may be restricted from sending or sharing pictures in all our apps automatically if 2 or more users (aside from you) also reported them for the same reason.

E. Cooperating with government or law enforcement agencies

We cooperate with international government and law enforcement officials to enforce and comply with the law. We report proactively, and we may disclose information about you to government or law enforcement officials of your country or region in order to: (1) protect the safety and security of our users and members of the public or (2) to satisfy subpoenas, court orders, or other legal requests.

i. Compliance to the US Children’s Online Privacy Protection Act (COPPA)

As long as the Children’s Online Privacy Protection Act (COPPA) is presumed to apply to our Services, our Services are not primarily directed towards children below 13 years old, as stated in our Terms of Service. If you are under the age of 13, you may not use our Service.

If you are a parent or guardian of a child below 13 years old who is currently using our Services, you may delete your child’s Account yourself (if you have access to their Account login details), or you may request to have your child’s Account deleted by contacting [email protected]. We will grant your request immediately, as long as you specify the email address that your child used for their Account, or if you provide enough identifying details about your child’s Account (e.g., Account ID, mobile number, profile name, etc.).

F. Sharing information with another company

We may share or transfer your information to another business or company in connection with a proposed or actual sale, assignment, merger or transfer of all or part of our business. In such cases, the new business owner will be required to honor the terms of this Privacy Policy, including enforcing the same (or a higher level of) confidentiality and data protection measures that we implement when we collect and store your information.

G. Sharing information with third party service providers

We transfer or share your information with third party vendors, service providers and other partners who support certain aspects of our business and Services, as described below.

Some of your information may be stored in computers or servers maintained by third party service providers that are located outside your country or region, where data protection laws may be different from those that are enforced in your country or region.

• Cloud server and content delivery providers such as: Azure International, Azure China, Azure CDN and Netcenter
  • All information related to your Account and our Service (including our data and data processing resources) are hosted and stored by these providers, which are mostly headquartered in the United States and with satellite offices in various international locations, except for Azure China (solely dedicated to hosting the information of all our users in China).
• iOS and Android app stores and app analytics providers such as: iTunes/App Store, Google Play Store, Amazon Appstore and Crashlytics
  • Information about your device and app activity are shared with these providers to monitor and analyze your use of our Services, such as when you download or uninstall our apps, how often you sign in and use our apps, and when you experience app errors or crashes. These providers do not have access to any personal information that you provided during Account registration and verification, or in your in-app profile.
• Email delivery providers such as: SendGrid, Amazon SES and SendCloud
  • These providers handle processes related to sending system email notifications (e.g., for email verification, password reset requests, etc.) and marketing or informational emails (e.g., news or announcements). We share your username and verified email address with these providers whenever emails are sent to you as described above, except for cases when you have opted out of any email notifications.
• Push notification delivery providers such as: JPush, Huawei and Xiaomi
  • These providers handle processes related to sending push notifications (e.g., when you receive a new message or request though the apps you use). We share information like your Account ID, Device OS and app language preference with these providers whenever push notifications are sent to you as described above.
• Helpdesk service provider: Zendesk
  • This provider handles processes related to any support requests that you send to us through email ([email protected]) or through our helpdesk form (support.hellopal.com), including storing your support request history and hosting all the tutorial articles or guides for all our apps. We share the information related to your support request, as described in Section 1D of this Privacy Policy (“Report and support request information”), with this provider whenever you send us a support request.
• Digital wallet service provider: Whale Bank
  • This provider handles processes related to the Hello Pal Wallet and the digital currency transactions that you do within the HPI app(s) that you use. We share the information related to your Wallet Account, as described in Section 1A-iv of this Privacy Policy (“Other Account-related information”), as well as select details from your digital transactions (i.e., amount and type of currency sent or received), with this provider whenever you use the Wallet and transaction features through any HPI app.

Whenever we share your information with the third party service providers listed above, they will be required to honor the terms of this Privacy Policy, including enforcing the same (or a higher level of) confidentiality and data protection measures that we implement when we collect and store your information.

H. Your information will not be shared with third parties

Except as described in Sections 2E to 2G of this Privacy Policy (“Cooperating with government or law enforcement agencies,” “Sharing information with another company” and “Sharing information with third party service providers”), in connection with Account verification (and then only for that purpose), or to enforce our rights under this Privacy Policy and our Terms of Service, we do not share the following personal information with any third party for any reason: your full name, date of birth, address or exact location, phone number(s), email address(es) or any contact information.

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3. How we store and secure your information

We are committed to ensuring that the information you submit to us, including your Account login details, will be stored safely and securely.

We use industry-standard security measures to prevent the loss, misuse and alteration of the information under our control, which includes the encryption of your information upon collection and storage, and the use of technologies offered by the third party service providers that we work with. However, we cannot guarantee that our security measures will absolutely prevent hackers or other external entities from illegally obtaining your information. We may store all information that we collect indefinitely, but we do not promise to do so for any particular period of time, or until you decide to delete your Account yourself.

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4. How you can control, modify or delete your information

You may check and modify your Account and profile information yourself at any time by signing in to your Account through any of our apps. You may remove any of your profile information, except for details that are required as specified in Section 1A-iii of this Privacy Policy (“In-app profile information”).

You may opt out of any push, in-app or email notifications through the «Me» (Settings) > «Notifications» screen of our apps. In case you cannot access your Account or you’ve already removed our app(s) from your device(s), you may send a request to have your notifications disabled (especially email notifications) by contacting [email protected].

You may remove or replace the information that you previously provided for Account verification (i.e., email, mobile or ID) at any time by signing in to your Account through any of our apps. If you want remove most of your previously-verified information, you must keep either your email or mobile verified because you need one of those details to sign in to your Account.

In case the app version you are using does not let you remove your previously-verified information, or if you’ve already removed our app(s) from your device(s), you may request to have your verified information removed from your Account by contacting [email protected]. We will grant your request immediately, as long as you write to us using the email address that you used for your Account, or if you provide enough identifying details about yourself and your Account (e.g., your Account ID, mobile number, profile name, etc.).

A. Your Account login information

You are responsible for keeping your Account and login details private or known only to you.

You must never allow any person, other than yourself, to sign in and use your Account. You are solely responsible for any content that is used or posted through your Account, even if it was created and posted by someone else who has gained access to your Account, until you notify us of any unauthorized access to your Account. If you believe someone accessed and used your Account without your permission, please notify us immediately at [email protected].

If you decide to share your Account login details with someone else, you are doing so at your own risk.

B. Information in your profile and published content

i. Publicly-viewable information in your profile

As described in Section 1A-iii of this Privacy Policy (“In-app profile information”), we only require you to fill in a few specific details for your in-app profile. Filling in optional details like your education or occupation information is entirely up to you.

Aside from details that you provide when updating your profile, there are certain details that are automatically calculated or set based on your Account registration and verification information, and on any content that you publish through our apps. The following is a list of publicly-viewable information in your profile:

• Standard profile details displayed in Hello Pal, Travel Pal and Language Pal:
  • Username
  • Profile picture(s)
  • Account ID (automatically filled)
  • Trust Score (automatically filled) – shown in words (e.g., “Low,” “Good” or “Perfect”) and with a color-coded shield icon
  • Star User badge (automatically filled) – displayed in your profile if you applied for the Star User status and your application was approved
  • Local time and date or time when you were last online (both automatically filled)
  • About You
  • Nationality and Current Location
  • Gender, Zodiac Sign and Age – your zodiac sign and age are automatically set based on the birthday you entered in your profile (your actual birthday is not displayed publicly)
  • Languages you speak
  • Followers and people you are Following – the total number of users that you follow (Following) and those that follow you (Followers) are displayed in you profile, but the actual list of users in those lists are only viewable by you
  • Education, Occupation, Company and Interests
  • Date when you registered (automatically filled)
  • HPI apps where you are active in (automatically filled) – this indicates if you also use or you signed in to Hello Pal, Travel Pal, and/or Language Pal.
• This profile detail may not be available for older app versions.
• Additional profile details displayed only in Hello Pal:
  • State or Province, City and other Connected Places
  • Languages that you are learning
  • Total number of your posted Moments and a link to your personal Moments feed
  • Any additional information about yourself
• Additional profile details displayed only in Travel Pal:
  • Countries visited
  • Total number of your posted Moments and a link to your personal Moments feed
  • Travel Plans and/or Hosting Profile (if you created any)
• Additional profile details displayed only in Language Pal:
  • Languages that you are learning
  • Total number of your posted Questions and Exercises and links to your personal post feed

Note that although you can register or sign in to any of our Hello Pal Phrasebook apps, your profile information will only be visible to you because the Phrasebook apps are designed only for personal use.

We do not recommend displaying your sensitive (e.g., ethnicity, religion, sexual orientation, etc.) and personal information (including any contact information) in your in-app profile, nor do we recommend sharing those details with other users through chats or your published content (Moments, Questions, Exercises or Comments). If you decide to share your personal information with other users, you are doing so at your own risk.

You may delete your chat messages or clear up your chat history with other users as well as delete any of your published content (Moments, Questions, Exercises or Content) any time by signing in to your Account through the relevant app (e.g., use Hello Pal or Travel Pal to delete Moments). Note that deleting these user-created content means the content will only be removed from your and other users’ view, but they will remain visible or accessible to us, as described in Section 2D-ii of this Privacy Policy (“Deleted user-created content”).

C. Information shared among our apps

As described in Section 2A-i of this Privacy Policy (“Shared features and information among our apps”), some of your information related to shared app features may also appear in other apps, including apps that you did not use or sign in to. You can opt out of having your profile appear in searches done through the HPI app(s) that you do not use at any time through your Account settings.

In case the app version you are using does not let you do so, you may request to have your information opted out from the app(s) you specify by contacting [email protected]. We will grant your request immediately, as long as you write to us using the email address that you used for your Account, or if you provide enough identifying details about yourself and your Account (e.g., your Account ID, mobile number, profile name, etc.).

D. Deleting your Account and personal information permanently

If for any reason you don’t want to use our Services anymore, you may permanently delete your Account any time by signing in to our app and going to “Me” (Settings) > “Account Management.” Deleting your account will completely remove your Account information, which includes the details you previously provided during Account registration and verification, your chat and post history, any email subscriptions, and any report you filed against other users (and any report that others filed against you) from our records.

Once you confirm the deletion of your Account, it may take up to 24-48 hours to completely remove your information from our database, including details that were previously shared with third party services as described in Section 2G of this Privacy Policy (“Sharing information with third party service providers”).

Note that simply removing one or all of our app(s) from your device(s), will not automatically delete your Account. As with any app that has an Account registration feature, you must delete your Account before you proceed with removing our app(s) from your device(s).

Deleting your Account is irreversible. Once you’ve deleted your account, we cannot retrieve or restore any information from your old Account for you, even if you sign up for our Services again using the same email address or mobile number that you used for your old Account.

Because you can use one Account for all our apps, deleting your Account through one of our apps will also revoke your access to the rest of our apps. If you only want to stop using one of our apps, you may simply sign out and remove that particular app from your device(s).

In case you cannot sign in to your Account to delete it yourself, or you’ve already removed our app(s) from your device(s), you may request to have your Account deleted permanently by contacting [email protected]. We will grant your request immediately, as long as you write to us using the email address that you used for your Account, or if you provide enough identifying details about yourself and your Account (e.g., your Account ID, mobile number, profile name, etc.).

i. Account information retained from suspended Accounts

If we suspended your Account for violating our Terms of Service or our Community Guidelines, you still have the option to delete your Account yourself, or you may request to have your Account deleted at [email protected]. Most of your Account information (as described above) will be removed from our records, except for the following details: your email address and/or your mobile number (which you used for Account registration and verification), Device Advertiser ID, and IP address.

We will retain the details mentioned above in our records for the specific purpose of preventing you from creating a new Account and returning to any of our Services.

ii. Hello Pal Wallet information

If you activated your Hello Pal Wallet, note that permanently deleting your Hello Pal Account through one of our apps will not automatically delete your Whale Bank account. Your Whale Bank wallet account will remain active even after you’ve deleted your Hello Pal Account.

After deleting your Hello Pal Account, all information related to your Wallet will continue to be stored in Whale Bank’s server. This information includes your Wallet balance(s), your transaction log, and the data you provided during Wallet activation, as described in Section 1A-iv of this Privacy Policy (“Other Account-related information”). To continue using your Wallet outside HPI apps, you can access your account through the Whale Bank app.

In case you’d like to delete your Wallet account as well, you may do so by accessing your account through the Whale Bank app. Alternatively, you may request to have your Wallet account deleted by contacting the Whale Bank team at www.whalebank.cn or [email protected].

E. Requesting for assistance about your information

You may ask us for details on the personal information that we collect from you or request for specific assistance with your Account at any time by contacting us at [email protected] or the other contact details listed in Section 6 of this Privacy Policy (“Our contact information”).

You may download or obtain a copy of your Account information, or specific details from your Account (e.g., chat history with a specific user), at any time by signing in to your Account through any of our apps. In case the app version you are using does not let you do so, or if you’ve already removed our app(s) from your device(s), you may request for a copy of your Account information by contacting [email protected]. We will grant your request as long as you write to us using the email address that you used for your Account, or if you provide enough identifying details about yourself and your Account (e.g., your Account ID, mobile number, profile name, etc.). Depending on when you registered your Account or on the amount of content you created through our apps, it may take a maximum of 30 days to prepare a copy of your information that you can download into your device.

• You may also obtain a copy of your Account information by taking screenshots of the relevant app screens yourself. Please refer to your device user manual for instructions on how to take screenshots.

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5. Updates to our privacy policy

We reserve the right to change this Privacy Policy at any time, and we will inform you of major changes before such changes will take effect, through email or in-app notification. You are responsible for keeping yourself aware of any changes to this Privacy Policy by reading the notification that we send to you, or by reviewing the latest Privacy Policy in our website or through our app’s “Me” (Settings) > “About” screen. If you do not agree with this Privacy Policy or on any future updates to this Privacy Policy, or if you don’t want to use our Services anymore, you may delete your Account and remove the app(s) from your device(s).

This Privacy Policy was originally written in English and translated into a few languages for use in our website and app localizations. If there is any inconsistency between the English version and the translated version of this Privacy Policy, note that the English version of this Privacy Policy will apply to the fullest extent permitted by applicable law.

Now the website is owned and operated by HELLO PAL ASIA LIMITED(11F HOLLYWOOD CENTRE 77-91 QUEEN’S ROAD WEST SHEUNG WAN).

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6. Our contact information

If you have questions regarding this Privacy Policy, please contact us.

Web: www.hellopal.com

Email: [email protected]

Helpdesk: support.hellopal.com

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Date Effective: December 12, 2018

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