Effective date: JAN 01, 2022
Sowo ("us", "we", or "our") operates the Sowo mobile application (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. Our Privacy Policy for Sowo is managed through Free Privacy Policy Website
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data ("Usage Data").
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Sowo uses the collected data for various purposes:
Your information, including Personal Data, may be transferred to ?? and maintained on ?? computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside China and choose to provide information to us, please note that we transfer the data, including Personal Data, to China and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Sowo will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Sowo may disclose your Personal Data in the good faith belief that such action is necessary to:
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy:https://policies.google.com/privacy?hl=en
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:https://policies.google.com/privacy?hl=en
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
1.Your UGC
1.All content submitted to our Website or via our Apps by you (or on your behalf) via your User account (or other social media account, if applicable), including without limitation, your name, biographical information and all other names, usernames, pseudonyms, text, likenesses, graphics, logos, marks, images, photographs, code, and all other information and material shall be called your "UGC" for short.
2.You agree to submit UGC to the Website and via our Apps in accordance with the following rules (in particular, the Legal Standards and the Review Guidelines, as those terms are defined below). Please use caution and common sense when submitting UGC to the Website or via our App.
3.Publication of your UGC will be at our sole discretion and we are entitled to make additions or deletions to your UGC prior to publication, after publication or to refuse publication.
4.Please note, any UGC you submit to our Website or via our Apps will be considered non-confidential and non-proprietary.
2.Rights, permissions & waivers
2.1You hereby grant to Sowo and any of our group companies and affiliates a non-exclusive, perpetual, irrevocable, transferable, royalty-free licence (including full rights to sub-license) to use, reproduce and publish your UGC (including, without limitation, the right to adapt, alter, amend or change your UGC) in any media or format (whether known now or invented in the future) throughout the world without restriction.
2.2You warrant, represent and undertake to us that all UGC you submit is your own work or that you have obtained all necessary rights and permissions of the relevant owner of the work and that you have all relevant rights in your UGC to enable you to grant the rights and permissions in this clause 2.
2.3Where your UGC contains images of people or names or identifies individuals, you warrant, represent and undertake to us as follows:
2.3.1that all featured or identified individuals that are over the age of 18 and have expressly consented to their appearance in the UGC and to you submitting the UGC to our Website or via our Apps, and
2.3.2where featured or identified individuals are under the age of 18, that you either:
i.are the parent or legal guardian or such featured or identified individuals, or
ii.have obtained the express consent from a parent or legal guardian of such featured or identified individuals to their appearance in the UGC and to you submitting the UGC to our Website or via our Apps.
2.4You hereby unconditionally and irrevocably waive and agree not to assert (or procure the same from any third party where applicable) any and all moral rights and any other similar rights and all right of publicity and privacy in any country in the world in connection with your UGC, to the maximum extent permissible by law.
3Content standards – legal standards
3.1You warrant, represent and undertake to us that your UGC (including its use, publication and/or exploitation by us) shall not:
3.1.1infringe the copyrights or database rights, trademarks, rights of privacy, publicity or other intellectual property or other rights of any other person or entity; and/or
3.1.2contain any material which is defamatory of any person; and/or
3.1.3contain misleading or deceptive statements or omissions or misrepresentation as to your identity (for example, by impersonating another person) or your affiliation with any person or entity; and/or
3.1.4breach any legal or fiduciary duty owed to a third party, such as a contractual duty or a duty of confidence; and/or
3.1.5advocate, promote, or assist discrimination based on race, sex, religion, nationality, disability, sexual orientation or age; and/or
3.1.6contain any malicious code, such as viruses, worms, Trojan horses or other potentially harmful programmes, codes or material; and/or
3.1.7violate any other applicable law, statute, ordinance, rule or regulation, (together, or individually the "Legal Standards").
3.2If your UGC contains any material that is not owned by or licensed to you and/or which is subject to third party rights, you are responsible for obtaining, prior to submission of your UGC, all releases, consents and/or licenses necessary to permit use and exploitation of your UGC by us without additional compensation. Please see clause 2 above for further details.
4Content standards – review guidelines
4.1You warrant, represent and undertake to us that your UGC:
4.1.1is accurate, where it states facts; and/or
4.1.2is genuinely held, where it states opinions (for example, in product or services reviews).
5Consequences of breach
5.1We will determine, in our discretion, whether you have failed to comply with this UGC Policy when submitting UGC to our Website or via our Apps. If you have failed to comply, we reserve the right in our sole discretion to suspend you from using the Website and/or our Apps without notice to you and/or to edit or remove (in whole or part) any of your UGC from our Website and our Apps on a temporary or permanent basis.
5.2Notwithstanding clause 5.1 above, if you or your UGC does not comply with this UGC Policy, and as a result of this, we suffer any loss or damage, you will be liable to us and hereby agree to indemnify us for any such loss or damage. This means that you will be responsible for any loss or damage we suffer as a result of your failure to comply with this UGC Policy, including but not limited to our Legal Standards and/or Review Guidelines.
5.3We also reserve the right:
5.3.1to pass on any UGC that gives us concern to the relevant authorities; and
5.3.2to disclose your identity to any third party (or their professional advisor) who claims that any of your UGC constitutes a violation of their intellectual property rights, or of their right to privacy.
6Changes to this UGC Policy
6.1We may change this UGC Policy from time to time, in which case an up to date version will be available via the Website and our Apps. You should check this UGC Policy regularly to ensure that you are happy with any changes. You will be deemed to have accepted any changes to this UGC Policy after you have been notified of the changes on our Website or our Apps and/ or if you continue to access or use the Website or our Apps, where the updated UGC Policy will be available for you to view.
We will retain your Personal Information and other information for as long as you maintain your account.
You may request deletion of your account at any time through the Message > Service in the app, or through sending email to us Following such request with appropriate review by us, we will delete the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, we retains location, device, and usage data for these purposes for a reasonable period as may be necessary; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, we may be unable to delete your account, such as if there’s a balance on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete the account as described above.
We may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if we deactivate a user’s account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new account in the future.
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 Services and its contents to you, including any interactive features on 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 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 Services; Content review: to review pictures, images and contents posted or generated on 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 Services in order to develop and display content tailored to your interests on our Website and App;
Performance Analysis: to determine whether users of Services are unique, or whether the same user is using 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.
You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.
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.
Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video or a picture each time you upload a video We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to improve, optimize the Platform and to prevent illegal use. We may share your Personal Information outside of Services when we have your consent, either express or implied.
We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
We may disclose your Personal Information to our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, customization of content, analytics, security, map navigation, data storage and cloud services, supporting our functionality, and other features offered through Services. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes. However, if you connect to a third-party service through Services or otherwise links your account with a third-party service, you are requesting and authorizing us to share or grant access to information on your behalf with such third party. We may also send information about the content that you watched or your activities on Services to such third party in order to upgrade your experience on Services.
We may disclose or share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred. If such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Information uses information in a manner that is consistent with this privacy policy.
We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) comply with any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or other third parties; or (e) to maintain and protect the security and integrity of Services or infrastructure.
We may disclose aggregated information about our users. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.
You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Please note that your choice to disable cookies will be specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
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 also hide your location, videos uploaded, recent active time and other information by adjusting “Privacy” setting.
You can choose not to provide us with Personal Information, but that may result in you being unable to use certain features of Sowo 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 change the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device’s privacy settings. For more information on how to change the advertising identifier privacy settings on your device, please visit http://www.networkadvertising.org/mobile-choice or http://youradchoices.com/appchoices.
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.
You may submit a request to access, modify or delete the Personal Information we collect about you by (a) using Help or Feedback function on Sowo Services or (b) by sending your request to us via email at . We will respond to your request consistent with the applicable laws as soon as practicable after proper verification procedures.