Carni Privacy Policy

Last updated: January 10, 2024

Welcome to Carni!

This Carni Privacy Policy explains how Carni  (“Carni” “we” “us”) process any personal data we collect from visitors and users of Carni APP, website, and any other services provided in relation to the applications and website or that link to this Privacy Policy(collectively, the “Carni Services”).

We value the privacy of users, subscribers, publishers, members, and others who visit and use the Carni Services (collectively or individually, “you” or “users”) and want you to be familiar with how we collect, use, and disclose personal information from and about you.

You may share personal information when using the Carni Services. One example is when you provide information about yourself as part of the Carni account creation process. Another is when you take certain actions on the Carni Services that are public or intended to be public in nature, such as when you broadcast content, post profile information, follow a channel, or subscribe to a broadcast channel. Given the social nature of some of the Carni Services, that information may be collected, used, or disclosed by others who are part of that social interaction. In addition, some features of the Carni Services are designed to provide others with information about user activity, such as identifying the user who created a particular Clip or the subscription status of users for a given channel. We encourage you to be mindful of this when considering your activity on the Carni Services.

1. What Information Do We Collect

We obtain information about you through the means discussed below when we provide the Carni Services. Please note that we need certain types of information so that we can provide the Carni Services to you.

i. User-provided Information

ii. Collected Information for Legitimate Interests

i. User-provided Information

You consent to provide some or all of the following Personal Information when you create an account on the App or use Carni Services, such as uploading contents on the App or contact us for technical support:

  • Registration information, such as your date of birth, phone number, password, user identifier and language;
  • Profile information, such as your alias, profile images, gender, hometown, self-introduction, social media information, education, and career;
  • User-generated contents (“UGC”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use Carni Services;
  • Facial data, such as when you use some features provided by us to create special effects or emojis for your streaming section or pictures that you uploaded on Carni Services, but such data will only be processed offline to fulfill the special effects or emojis and we will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data; further, we will not use your facial data for marketing or advertising, nor will we share such data with any third party. In addition, if you utilize Real-Person Profile Picture Authentication, we collect your profile picture and facial-recognition video for Real-Person Profile Picture Authentication on the premise of your approval by comparing your profile picture with face-recognition video. This authentication can protect you from impersonators and fake accounts, or develop the authenticity of Carni Services. We do not retain your face recognition video in our servers, such video is merely for verifying.
  • Transaction information such as the transaction serial number and transaction historical records after you purchased Paid Services;
  • Your social network contacts with your permission, when you activate the “Discover Friends” function and allow us to access your contacts;
  • Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;
  • Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints; and
  • Information you provide when participating in in-app surveys and activities.

ii. Collected Information for Legitimate Interests

We may collect some or all of the following Personal Information about you when you use Carni Services for legitimate interests:

  • Network activity information, such as your browsing history, search history, the videos or pages you visited, the date and time of your visits, other users’ accounts that you subscribed to, and information regarding your interaction with other users;
  • Data About Your Accounts on Other Services: We may obtain certain information through your social media or other online accounts if they are connected to your account in our Services. If you login to our Services via Google or Apple id, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, gender, info, and birthday.Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.

If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party. Information and UGC you provide when participating in our events, promotions, challenges, contests, and sweepstakes, or during other interactions with our social media sites.

  • Device identifiers, such as your operating system, browser type, brand, model and serial number of your mobile device, Internet Protocol (IP) address, mobile carrier, screen resolution, language setting, IMEI number, IMSI number, and media access control address;
  • Other location information, such as the information based on your SIM card;
  • Mobile advertising identifiers, which are used by mobile operating systems and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help us and advertisers provide ads that may be more relevant to your interests;
  • Metadata, associating with the UGC you provided us, which describes other data and provides information about how, when, and by whom the piece of UGC was collected and how that UGC was formatted, such as hashtags used to label the keywords to the video and captions; and
  • Cookies, small pieces of data to enable us to provide certain features, which are collected by us or our business partners to measure and understand the web pages you click on and how you use Carni Services, enhance your experience using Carni Services.

We may also collect, use and share your information to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, to generate statistics about our users, to calculate the percentage of users accessing a specific website feature, or to calculate ad impressions served or clicked on.

2. How We Use Your Information

We will only use your Personal Information when the applicable laws allow us to. In general, we use your Personal Information for the following purposes:

  • Provision of services: to present Carni Services and its contents to you, including any interactive features on Carni Services, and to provide you with information, products or services that you allow us to; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with promotion activities and sweepstakes;
  • Improvement of services: to improve and personalize our services by presenting new services, information, recommendations, and feedback;
  • Customer management: to manage a registered user’s account, to provide customer support and notices to the registered user about his account or subscription, and notices about changes to Carni Services or any other product or service we offer or provide through it;
  • Communication: to communicate and interact with you directly, for an example, we may send notifications regarding upcoming changes, promotion activities or improvements on Carni Services;
  • Content review: to review pictures, images and contents posted or generated on Carni Services to ensure that we comply with any applicable content regulations in any relevant jurisdiction;
  • Customization of content: to perform research and analysis about your use of, or interest in contents, products, advertising, or services available on Carni Services in order to develop and display content tailored to your interests on our Website and App;
  • Performance Analysis: to determine whether users of Carni Services are unique, or whether the same user is using Carni Services on multiple occasions, and to monitor aggregate metrics such as total number of visitors, number of videos viewed, demographic patterns;
  • Functionality and security: to identify users not meeting the age limit, to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
  • Compliance: to enforce our terms of use and to comply with our legal obligations;
  • Aggregation: to aggregate information we collect about you to which one or more purposes described above.
  • Cookie: We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform and improve our services. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

Additionally, we link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.

3. How We Share Your Information

  • With Other Users:

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is the stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

  • With Our Service Providers and Partners:

We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.

We may also share information with partners who distribute and assist us in advertising our Services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

  • When Required by Law:

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

  • To Enforce Legal Rights:

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

  • Monitor:

Moderators to monitor activity on the site/apps and approve content. Fraud prevention and anti-spam providers to protect the service from criminal activity.

  • Change of Control:

In the event that our Services or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, reorganization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

4. International Data Transfers

Your Personal Information may be processed by us, our trusted third party suppliers outside of the country (s) in which you reside, including in countries where data protection and privacy laws or regulations may be equivalent to, or as protective as, the data protection laws and regulations in your country. In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your country to a jurisdiction that has a less adequate level of protection of personal data.  These measures include (where applicable) transferring pursuant to data transfer agreements implementing standard data protection clauses. 

We may also transfer your personal information outside of your country as permitted by applicable data protection and privacy laws and regulations.  Examples include where we need to transfer your personal information: (a) to perform a contract with you (or to take steps before the contract at your request); (b) perform a contract in your interests; or (c) in relation to legal claims.

5. Links to Other Websites or Application

When you click on a link to any other website, mobile application or third-party content through Carni Services, you will go to another website or other mobile application and another entity may collect information from or about you. We have no control over, do not review, and cannot be responsible for, these third-party websites or mobile applications or their contents. Please be aware that the terms of this privacy policy do not apply to these third-party websites or mobile applications or content, or to any collection of information after you click on links to these third-party websites, mobile applications or content.

6. Data Security

We take appropriate administrative, technical and physical security measures to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your Personal Information. You should use caution whenever submitting information through Carni Services and take special care in deciding which information you provide us with.

You are responsible for maintaining the secrecy of your password and account information at all times.

7. Your Choices

  • You can at any time request to opt out from allowing us to send you push notifications by adjusting the permissions in your mobile device.
  • You can switch off GPS location, Microphone, Camera or other similar functions on your mobile device if you do not wish to share them.
  • You can choose not to provide us with Personal Information, but that may result in you being unable to use certain features of Carni Services because such information may be required for you to register as a user, purchase Paid Services, participate in a promotion, survey, sweepstakes or make complaints.
  • You can make changes to your information, including accessing your information, correcting or updating your information or deleting your information by editing your profile in the App.

 

8. Your Rights

  • Some jurisdictions’ laws grant specific rights to Carni users, which are set out in this section. You may have all or some of the following rights set forth below according to applicable laws. We will respond to your request consistent with the applicable laws as soon as practicable, normally within one month, after proper verification procedures. Your exercise of these rights is usually free of charge, unless we deem it is chargeable under the applicable laws.
  • Right to access-You may submit a request to access the Personal Information we collect about you by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email atwinkerwinker7@gmail.com.
  • Right to rectification-You may submit a request to rectify the Personal Information we collect about you by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email at winkerwinker7@gmail.com.
  • Right to erasure-You may submit a request to erase the Personal Information we collect about you by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email at winkerwinker7@gmail.com. Though we cannot guarantee a complete erasure of your data that has been stored in our backup servers, we promise that we will not use the data within the backup servers for any other purpose.
  • Right to data portability-You may ask us to transfer some of your Personal Information, if it is collected on the basis of your consent, in structured, commonly used and machine-readable formats to you or other environments designated by you, if technically feasible, by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email at winkerwinker7@gmail.com.
  • Right to withdraw consent-You may withdraw your consent and ask us not to continue to collect or process your Personal Information at any time if that information is collected on the basis of your consent by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email. Your exercise of this right will not affect the processing activities that occurred before your withdrawal.
  • Right to restrict processing-You may request us to stop processing your Personal Information if you believe such information is collected unlawfully or you have other reason by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email at winkerwinker7@gmail.com. We will examine your request and respond accordingly.
  • Right to object-You may object to the processing of any Personal Information we collect about you, if such information is collected on the basis of legitimate interests, at any time by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email at winkerwinker7@gmail.com. Please note that we may reject your request if we demonstrate compelling legitimate grounds for the processing, which override your interests and freedom or the processing is for the establishment, exercise, or defense of legal claims.
  • Right concerning automated decision making and profiling-You may ask us to stop automated decision making or profile, if you believe such automated decision making and profiling has legal or similarly significant effect upon you by (a) using Help or Feedback function on Carni Services or (b) by sending your request to us via email at winkerwinker7@gmail.com. We will examine your request and let you know if your request is applicable under the relevant laws and regulations.
  • In addition to the foregoing rights, you also have the right to lodge complaints to the competent data protection authority (“DPA”), usually the DPA of your home country.

9. Children

We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that Personal Information of persons under 18 has been collected on or through the Carni Services, we will take appropriate steps to delete this information.

If you believe that we have inappropriately collected Personal Information from a Young User, please contact us at winkerwinker7@gmail.com.

10. Retention of Your information

We will retain your Personal Information and other information for as long as you maintain your Carni account.

11. Deletion of Account

Before you submit a request to delete your account (“Deletion Request”), ensure that your Account satisfies the following requirements:

  1. The account has no economic contract: If you are the guild leader and you still have hosts in your guild, you will not be able to complete the deletion; you need to terminate the relationship with the brokerage company before you can cancel.
  2. Account in Good Standing: Your account is in good standing and is not the subject of any ongoing investigations, penalties or allegations for violation of our terms of use and/or applicable laws and regulations;
  3. Accounts that have been registered within 7 days and have been recharged cannot be deleted. 
  4. No outstanding transactions: You should not have any pending orders, payment obligations, refunds, deliveries, returns and/or disputes on the account. Your most recent order(s) must have been completed and delivered at least seven (7) calendar days prior to the date of this Deletion Request;
  5. Virtual Items balances(if applicable): There should not be any virtual items balances (including Diamonds, Rubies, Golds) for your Carni account. Please ensure that you have used up all Virtual Items balances in your account, alternatively, you have the option to forfeit the remaining balance to proceed with the account deletion process;
  6. any other criteria that Carni may notify you from time to time.

To delete your account:

Open Carni App and log in, Tap Mine > Settings > Account Management > Delete account > Confirm to delete your account.

Subject to satisfaction and/or waiver of the conditions for deletion as set out above, the Account will be deleted 7 days after your request if there is login data. Please note that, if you login 7 days after your request, your Deletion Request will be regarded as withdrawal.

If you delete your account:

  1. You can't regain access to your account.
  2. Your personal profile will be deleted（moments/avatar), and your friends can no longer contact you at Carni. However, some information, such as messages, reviews, comments and other contents or information submitted by you to the Platform, are not stored in your Account. This means that other users may continue to have access to the messages you have sent and reviews, comments, or other contents you have posted on the Platform even after your Account has been deleted.
  3. If your account has enabled the application subscription function, the account will not automatically cancel the subscription after the account is deleted. You need to cancel the subscription yourself to prevent continued deduction after deleting the account.
  4. If there are remaining assets in your account, applying for account deletion will be considered as automatically giving up the remaining assets in your account; it is recommended that you apply for account deletion after consuming them
  5. We may retain certain log data in our databases even after you delete your account, but such data will be disassociated from any identifying information such that it can no longer be linked to your account. To do this, on a regular basis, we wipe certain identifying information from this log data, and we replace any instance of your account ID with a replacement identifier which cannot be linked back to your account once it is deleted.

We may also keep your information for things like legal issues, terms violations, or harm prevention efforts.

12. Changes and Updates to This Privacy Policy

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version so you are aware of any changes, as they are binding on you.

If we change anything in our privacy policy, the date of change will be reflected in the “last updated date”. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

13. Contact us

If you have any questions regarding this privacy statement, the processing of your personal data, you can contact us directly. We are also available to you in the case of requests for information, requests or complaints:

E-MAIL: winkerwinker7@gmail.com