Updated: February 23, 2023
Effective date: February 23, 2023
Thank you for your trust and use of Soda. We have updated the Soda Privacy Policy in accordance with the latest laws, regulations and regulatory policy requirements, please read and fully understand the following terms.
("We"), the owner of the SodaAPP product. This Privacy Policy ("Policy") describes how we will handle your personal information and affirms our commitment to protecting the privacy of our users. We will collect and use your personal information in accordance with the Personal Information Protection Law of the People's Republic of China, the Data Security Law of the People's Republic of China, the Network Security Law of the People's Republic of China, and other relevant laws, regulations and technical specifications, and make every effort to protect the security and control of your personal information.
This Privacy Policy applies to Soda services, and we collect and use information about you when you use Soda. We understand the importance of personal information and in order to better demonstrate and explain to you our privacy rules and your rights as a user, as well as to explain to you how Soda collects, uses and stores your personal information and your rights, we will explain in this Privacy Policy the types of personal information we collect about you and the purposes for which we collect it, so that you can understand the specific types of personal information we collect for a particular function The types of personal information we collect for a particular function, the reasons for its use, and how we collect it. Please read and thoroughly understand this Privacy Policy before using Soda, and use the products or services after confirming that you fully understand and agree to it.
The following section will help you understand in detail how we collect, use and protect your personal information; help you understand the way to inquire, access, delete, correct and withdraw authorized personal information. In particular, we have bolded important terms regarding your personal information rights, so please pay special attention to them.
I. Definition and basic principles
II. How we collect and use personal information
Third, how we use cookies and other similar technologies
IV. How we share, transfer and publicly disclose personal information
V. How we protect, store and transmit personal information
VI. Personal information management and information destruction
VII. Terms for minors
VIII. Revision of the Privacy Policy
IX. Dispute resolution
X. Contact us
I. Definition and basic principles
1. Definition
- Personal information (from GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): refers to all kinds of information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. The actual specific types of personal information we collect are described below.
- Personal sensitive information (from GB/T 35273-2020 "Information Security Technology Personal Information Security Specification"): refers to personal information that, if leaked, illegally provided or misused endangers the safety of persons and property, and is highly likely to lead to damage to a person's reputation, physical and mental health or discriminatory treatment. The actual specific types of personal sensitive information we collect are described below. Compared to other personal information, sensitive personal information has a greater impact on your personal rights and interests. We kindly remind you to consider carefully before providing us with your sensitive personal information.
- Minor: A natural person under the age of eighteen is a minor. Minors over sixteen years of age who use their own labor income as their main source of living are considered to be fully capable of civil behavior. (From the Civil Code of the People's Republic of China)
- Authorized Consent: This refers to your explicit authorization for specific processing of your personal information, including authorization by positive action (i.e., express consent) and authorization by negative inaction. (from GB/T35273-2020 "Information Security Technology Personal Information Security Specification") Please know that "authorized consent" is sometimes expressed in this policy as "authorization", "consent ".
- User profiling: The process of collecting, aggregating and analyzing personal information to make analysis or prediction of your personal characteristics, such as occupation, economy, education, personal preferences, credit and behavior, and form its personal characteristics model. (from B/T35273-2020 "Information Security Technology Personal Information Security Specification")
- Anonymization: refers to the process of making the subject of personal information unrecognizable or unassociable through technical processing of personal information, and the processed information cannot be recovered. (From GB/T 35273-2020 "Information Security Technology Personal Information Security Specification")
- De-identification: refers to the process of making personal information unidentifiable or unassociable to the subject of personal information through technical processing of personal information without the help of additional information. (from GB/T 35273-2020 "Information Security Technology Personal Information Security Specification")
- Delete: The act of removing personal information from the system involved in the realization of daily business functions, so that it remains unretrievable and inaccessible. (from GB/T 35273-2020 "Information Security Technology Personal Information Security Specification")
2. Basic principles
We will collect, use and store personal information that you voluntarily provide in the course of your use of Soda or as a result of such use in accordance with the principles of lawfulness, reasonableness and necessity and for the purposes described in this Policy. If we want to use your personal information for purposes other than those described in this policy, or use the information collected for a specific purpose, we will again inform you and obtain your consent before doing so.
II. How we collect and use personal information
In order to protect your normal use of the platform's basic functions and normal services, improve and optimize our service experience, and protect your account security, when you use our platform's services or access the platform's web pages, we will automatically receive and record information about your computer and mobile device, including your IP address, language used, date and time of access; if you download or use our or our affiliates' client If you download or use our or our affiliates' client software, or access mobile web pages to use the services of our platform, we will read information related to your mobile device, (including your hardware model, operating system version, device configuration, unique device identifier, International Mobile Equipment Identity Code IMEI, network device hardware address MAC, advertising identifier IDFA), device connection information (type of browser, telecommunications carrier, language used) and device status information (including device sensor data, list of device application installations) . For the information collected from your various devices, we correlate them so that we can provide you with consistent service across these devices.
(A) Functional use and account services
In order to enhance your entertainment experience at Soda, we collect and use your personal information for the following features. If you do not provide this personal information, you can still use some of the features of Soda:
(B) the collection and use of personal information and the corresponding change of use
In order to provide you with better service, you agree that we may obtain your personal information from third parties, including but not limited to our affiliates, partners, and products, and that we may obtain account information (including but not limited to avatar, nickname, and account information) from third parties that you are authorized to share, and that your third party account may be tied to your account after you agree to this Privacy Policy. We will use such personal information in accordance with this policy and in compliance with relevant laws and regulations.
We make adjustments to Soda as our business grows. When new features or services are related to registration, plaza, ad push, posting graphics, interactive communication, search, inquiry, authentication, and virtual property scenarios, the personal information collected and used is of direct relevance to the original purpose. In scenarios not directly related to the original purpose, we collect and use your personal information, and we will again ask for your consent. Please note that several of our services allow you to share information not only with your own social networking circle, but also publicly with all users who use the feature, such as information you upload or post on our platform, your responses to information uploaded or posted by others, and location data, audio information including in connection with such information. Other users of our Services also share information about you including your location data, audio information, and posting information. In particular, our social media services are designed to enable you to share information with users around the world, and you can make the shared information available in real time and widely. As long as you do not delete the shared information, it will remain in the public domain; even if you delete the shared information, it will still be independently cached, copied or stored by other users or unaffiliated third parties not under our control, or kept in the public domain by other users or third parties. Therefore, please consider carefully the content of the information you upload, post and exchange through our Services. In some cases, you may be able to control the range of users who are entitled to view the information you share through the privacy settings of some of our Services.
(iii) When we obtain your personal information from third parties
In order to provide you with better service, you agree that we may obtain your personal information from third parties, including but not limited to our affiliates, partners, and products, and that we may obtain account information (including but not limited to avatar, nickname, and account information) from third parties that you have authorized to share, and that your third party account will be linked to your account after you have agreed to this Privacy Policy. We will use such personal information in accordance with this policy and in compliance with relevant laws and regulations.
(D) Exceptions to the use of personal information
According to the relevant laws and regulations, we may collect and use some necessary personal information without your authorized consent in the following cases:
1. directly related to national security and national defense security;
2. directly related to public safety, public health, and significant public interest;
3. directly related to crime investigation, prosecution, trial and sentence enforcement;
4. for the protection of your or other individuals' life, property significant legitimate rights and interests but it is difficult to get my consent;
5. The personal information collected is disclosed by you to the public at your own discretion;
6. collect your personal information from lawful public disclosures, such as from lawful news reports, government information disclosure channels;
7. necessary for the conclusion and performance of the contract at your request;
8. necessary for maintaining the safe and stable operation of Soda's products and/or services, such as detecting and disposing of product or service failures;
9. Other circumstances specified in laws and regulations.
Third, how we use cookies and other similar technologies
Technologies such as cookies and device information identifiers are commonly used on the Internet. We may use these technologies to send one or more cookies or anonymous identifiers to your device when you use Soda in order to collect and identify information about your access to and use of this product. We promise that we will not use cookies for any purpose other than those described in this Privacy Policy. We use cookies and similar technologies primarily to enable the following features or services:
1、Guarantee the safe and efficient operation of products and services
We may set cookies or anonymous identifiers for authentication and security purposes that allow us to verify that you are securely logged in to the Service or that you are not experiencing theft, fraud, or other wrongdoing. These technologies also help us improve the efficiency of our services and increase login and response times.
2. Help you get an easier access experience
The use of such technology can help you eliminate the need to repeat the steps and processes of filling in your personal information and entering search content.
3、Clearance of cookies
Most browsers provide users with the ability to clear browser cache data, which you can do in the browser settings function; you can also manage and clear all cookies saved by SodaApp on your mobile device; if you do so, you may not be able to use the corresponding functions provided by us.
IV. How we share, transfer, and publicly disclose your information
(A) Entrusted processing
Some specific modules or functions of the business functions provided on the platform are provided by external vendors. For example, we may engage service providers to assist us in completing real-name authentication for real-name users. We have strict confidentiality agreements with companies, organizations and individuals that we entrust with the processing of personal information, requiring them to handle personal information in accordance with our requirements, this Privacy Policy and any other relevant confidentiality and security measures.
(ii) Sharing of your personal information
Some specific modules or functions of the business functions provided on the platform are provided by external vendors. For example, we may engage service providers to assist us in completing real-name authentication for real-name users. We have strict confidentiality agreements with companies, organizations and individuals that we entrust with the processing of personal information, requiring them to handle personal information in accordance with our requirements, this Privacy Policy and any other relevant confidentiality and security measures.
1. in accordance with the provisions of laws and regulations or the requirements of the relevant departments of the government/state agencies;
2. necessary to protect the legitimate rights and interests, public interest, property or safety of us, our affiliates or users; / requirements of the relevant departments of state agencies;
3. Sharing your personal information with our affiliates: You agree that we may share your personal information with our affiliates and their products.
4. Providing your personal information to partners: Some of our services will be provided by authorized partners only to achieve the purposes stated in this policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. Our partners do not have the right to use the personal information shared for any other purpose. Our authorized partners include the following types:
(1) Authorized Partners in the Analytics Services category. We will not share your personally identifiable information with partners who provide analytics services unless we have your permission to do so.
(2) Vendors, Service Providers and Other Partners. We send information to vendors, service providers and other partners with whom we provide services to you on a global basis, including providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service or prizes, marketing promotions, payment facilitation or conducting academic research and surveys, such as when you need to use geolocation functionality. In order to do so, we collect your location information and related device information (e.g., hardware model, operating system version number), which is de-identified, and provide it to the aforementioned providers. You may refuse to provide such information, but this will not affect your use of other services. Companies, organizations and individuals with whom we share personal information may be subject to strict confidentiality agreements, and we may assess their data security capabilities and environment and require third parties to handle such information with confidentiality and security measures no less stringent than those required by this policy. They are required to handle personal information in accordance with our instructions, this policy and any other relevant confidentiality and security measures. If a third party has a business need to use personal information beyond the scope of the foregoing authorization, that third party will be required to seek your consent again.
In order to ensure the stable operation of Soda or to achieve the relevant functions, we will access the software development kit (SDK) provided by the third party to achieve the aforementioned purpose, the third-party SDKs that Soda accesses are detailed in this directory
5. necessary to deal with disputes or controversies between you and others;
6. If you violate the relevant laws and regulations or the relevant agreements and rules of our platform, you need to disclose to a third party.
(iii) Transfer
We will not transfer your personal information to any company, organization or individual unless we have your express consent to do so. In the event of a merger, acquisition or liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy.
(D) Exceptions to the sharing, transfer, and public disclosure of personal information authorized consent
You are fully aware that your authorized consent is not required for us to share, transfer, or publicly disclose your personal information in the following circumstances:
1. related to national security and social public interest;
2. related to crime investigation, prosecution, trial and sentence enforcement;
3. For the purpose of safeguarding the life and property of the subject of personal information or other individuals with significant legitimate rights and interests but it is difficult to obtain their consent;
4. the personal information collected is disclosed to the public by the subject of the personal information himself/herself;
5. Where your personal information is collected from lawful public disclosures, such as lawful news reports, government information disclosure channels;
6. violate the law or violate the rules of our platform so that we have taken the necessary measures against you;
7. necessary for the conclusion and performance of the contract at your request;
8. necessary for maintaining the safe and stable operation of the product or service provided, such as the detection and disposal of product or service failures;
9. necessary for legitimate journalism;
10. academic research institutions or based on the public interest or based on non-profit purposes necessary to carry out statistical or academic research, and when the results of academic research or description are made available to the public, the personal information contained in the results is de-identified;
11. Other circumstances specified in laws and regulations.
According to the law, sharing or transferring personal information that has been de-identified and ensuring that the recipient of the data cannot recover and re-identify the subject of the personal information is not an act of sharing, transferring or publicly disclosing personal information to the public, and the storage and processing of such data will not require separate notification to you and your consent.
V. How we protect, store and transmit personal information
We take the security of your personal information very seriously, and in order to safeguard your information, we strive to adopt various reasonable physical, electronic and managerial aspects in line with industry standards to ensure that our personal information handling activities comply with the requirements of laws, administrative regulations or other regimes applicable by law, and to prevent unauthorized access as well as leakage, falsification and loss of personal information. This includes, but is not limited to, deployment of host intrusion detection systems, encrypted storage of important and sensitive information, access control in data centers, and security audits of log records.
1.Information security protection
Some specific modules or functions of the business functions provided on the platform are provided by external vendors. For example, we may engage service providers to assist us in completing real-name authentication for real-name users. We have strict confidentiality agreements with companies, organizations and individuals that we entrust with the processing of personal information, requiring them to handle personal information in accordance with our requirements, this Privacy Policy and any other relevant confidentiality and security measures.
(1) Technical security measures. We will use encryption, de-identification technology, anonymization and related reasonable and feasible means to protect your personal information in accordance with the industry standard level, and use security protection mechanisms to prevent malicious attacks on your personal information.
(2) Management system . We will establish a special security department, security management system, and data security process to protect your personal information. We adopt a strict data use and access system to ensure that only authorized personnel have access to your personal information. We regularly educate and train personnel on security, and conduct security audits of data and technology when appropriate. We also adopt strict management of employees who have access to your information, including but not limited to adopting different authority control according to their positions, signing confidentiality agreements with them, and monitoring their operation measures.
We will develop and organize the implementation of emergency plans for personal information security events and immediately activate the emergency plans in the event of personal information security events, and make efforts to control the impact of these security events and prevent the expansion of adverse consequences. In the event that a personal information security incident (leakage, tampering, loss) occurs or may occur, we will promptly inform you of the following in accordance with the requirements of laws and regulations: the type, cause and possible harm caused by the occurrence or possible occurrence of leakage, tampering, loss of personal information, the remedial measures we have taken, the measures you can take to mitigate the harm and the way to contact us. We will promptly inform you about the incident in the form of push notifications, emails, letters, SMS and related forms, and when it is difficult to inform you one by one, we will take reasonable and effective ways to make announcements. At the same time, we will also report the disposition of personal information security incidents in accordance with the requirements of relevant regulatory authorities.
(3) Security Tips . Although we have taken reasonable and effective measures as described above and have complied with the standards required by relevant laws and regulations, please understand that due to technical limitations and the possibility of various malicious means, in the Internet industry, even with all efforts to strengthen security measures, it is not always possible to guarantee the security of 100% of the information, and we will do our best to ensure the security of the personal information you provide to us. You are aware and understand that the systems and communication networks you use to access our services may experience problems due to factors outside of our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information, including but not limited to the use of not disclosing your cell phone number verification code, account information and related personal information to others.
2. Storage of information
(1) The way and duration of information storage
We store your information by secure means, including local storage (e.g. data caching using the App), databases and server logs. In general, we will only store your personal information for as long as is necessary to fulfill the purpose of the service or under conditions specified by law or regulation, such as
a) Mobile phone number: After you have registered and logged in using your cell phone number, we need to continuously keep your cell phone number in order to provide you with normal services, respond to your possible inquiries and customer complaints, and protect your account and system security.
b) Content and related information posted by you will be retained for the purpose of providing you with ongoing business functions until you withdraw, delete or cancel your account.
c) We will delete or anonymize your personal information if you cancel your account, voluntarily delete your personal information, or after the information has been retained beyond the necessary retention period, with the following exceptions:
Comply with the requirements of laws and regulations regarding information retention (e.g., the E-Commerce Law stipulates that information on goods and services and transaction information shall be kept for a period of not less than three years from the date of completion of the transaction). Reasonable extension of the period is required for financial, audit, dispute resolution and other purposes.
We are committed to storing your personal information for as long as reasonably necessary. We will immediately delete or anonymize any personal information that exceeds this period.
(2) Geographical location of information storage
We will store the personal information of users collected within the territory in accordance with the laws and regulations in China.
Currently and in the future, we do not transfer or store your personal information across borders.
(3) Notification when a product or service ceases operation
When our products or services are discontinued, we will notify you by push notification or announcement, and delete your personal information or anonymize it within a reasonable period of time, except as otherwise provided by laws and regulations.
VI. Personal information management and information destruction
We take your concerns about your personal information seriously and make every effort to protect your rights to access, correct, delete, and withdraw consent to your personal information so that you have the full ability to safeguard your privacy and security. Your rights include:
1.Inquiry and correction of your personal information
You can access and correct the personal information you provide when using our products and services through your personal profile page. If you require access to other personal information generated in the course of your use of Soda, we will provide it to you upon reasonable request.
2. Destroy your personal information
You can delete the personal information you provided through your personal information page. If you believe that we have violated any laws or administrative regulations or have not collected or used your personal information in accordance with the agreement with you, please contact us through the contact information at the end of the article to correct or destroy it.
3. Withdrawal of the agreed authorization
You can give or withdraw consent for notifications, location information, camera, photo album, file storage and access, microphone authorization in your personal device system, the way the permissions are displayed and turned off varies from device to device, please refer to the device and system developer's instructions or guidelines for details. You can also turn off or withdraw your consent or authorization in "My - Settings - Privacy Settings - System Permissions" in the Soda app. When you withdraw your consent, we will no longer process your personal information, but please understand that after you withdraw your consent or authorization, we cannot continue to provide you with the specific features and/or services for which you have withdrawn your consent or authorization. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.
4. Obtain a copy of personal information
You have the right to obtain a copy of your personal information by contacting us, and we will process your request within fifteen days of verifying your user identity.
VII. Terms for minors
The Soda Privacy Statement for Minors applies to users under the age of 18.
1. Minors under the age of 18 should read this Privacy Policy with a parent or guardian, and use of our products and services requires the consent of a guardian. We value the protection of personal information of minors, and it is important that minor users ask their guardians to read this Privacy Policy carefully and to ensure that they have obtained your guardian's consent to use our services and provide us with your information. If your guardian does not consent to your use of our services or provision of information to us in accordance with this policy, please terminate your use of our services immediately and notify us promptly.
2. If you register or use Soda, according to the relevant laws and regulations, if you are a minor, before using Soda, you should follow the registration and use process and obtain prior consent from your parent or legal guardian, and have your parent or legal guardian help you complete the registration process for Soda so that you can use the products or services provided by us.
3. If you are the guardian of a minor, you should read this policy and the Soda Privacy Statement for Minors carefully before helping the minor to register and use the products or services, and decide whether you agree to this policy and the Soda Privacy Statement for Minors and help the minor to register and use so that the minor can use the products or services provided by us.
4. We do not collect personal information from minors without their knowledge. Minors should not register for an account or send us personal information about their name, address, phone number, or email address unless their guardian agrees. We will protect the confidentiality and security of minor user information in accordance with relevant national laws and regulations and the provisions of this policy.
5. We will not display the search results of personal information of minors without the consent of their guardians; if the guardians of minors request us to remove or block the personal information of minors related to them on Soda, please contact us.
In particular, in order to better protect the privacy rights of minors, we remind you to be careful about posting content containing images of minors. Once posted, you are deemed to have obtained the consent of your guardian to display the likeness and voice of minors and to allow us to use and manage such content related to minors in accordance with the User Service Agreement and this Privacy Policy. If the right holder notifies us that the content you post infringes on the rights of minors, we have the right to dispose of the content you post for the protection of the rights of the right holder and the rights of minors.
7. We shall not be responsible for the actions of minor users in the course of using the Service and for all consequences arising from their use of the Service, which shall be borne by minors and their guardians.
VIII. Revision of the Privacy Policy
We may revise our Privacy Policy from time to time, and such revisions form part of this Privacy Policy. We will not reduce your rights under this policy without your express consent. We will notify users of material changes to this Privacy Policy by prominently posting the terms and conditions on our web pages or by posting a tweet. If you do not agree with the revised Privacy Policy, you have the right and should immediately stop using Soda, and by continuing to use Soda, you agree to be bound by the revised Privacy Policy.
IX. Jurisdiction and application of law
1. Soda has the final right to interpret this privacy policy.
2. The laws of the People's Republic of China shall apply to the establishment, effectiveness, performance, interpretation and dispute resolution of this Privacy Policy, and no conflict of laws shall apply.
3. In case of any dispute or controversy between you and us, both parties shall negotiate amicably.
4. The terms of this Privacy Policy shall be partially invalid for whatever reason, and the remaining terms shall remain in effect and binding on the parties. No waiver of any provision of this Privacy Policy shall be deemed a further or continuing waiver of such provision or any other provision, and the failure of us to assert any right or provision under this Privacy Policy shall not constitute a waiver of such right or provision.
X. About Contact Us
When you have any requests, questions, complaints or suggestions related to personal information, send email to sodavoice.fm@gmail.com, contact our personal information protection officer, service hours: 9:30-18:30 (Monday to Friday, except legal holidays). For security purposes, we will ask you to verify your identity before processing your request. You will need to provide a written request, or otherwise prove your identity. We will review the issues involved as soon as possible and will generally respond within fifteen business days of verifying your user identity. In principle, we do not charge a fee for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. We will deny requests that are unwarrantedly repetitive, require excessive technical means (e.g., require development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, fall within the authorized consent exception, or are highly impractical (e.g., involve backing up information stored on tapes).