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HANA
PRIVACY POLICY

Effective Date: February 20, 2025

Joy-sharing Cloud Limited ("we", "our" or "us"), with Viola Luck as the developer, is the operator of the website: https://be.jubeebeauty.com and its subdomains ( "Website" ), the application Hana (the "App") and any related features (collectively, the "Services").

This Privacy Policy (the "Policy") is an integral part of the Hana Terms of Services (the "Agreement"). All the terms used herein are used with the same meanings as the Agreement provides unless otherwise are directly set out hereby.

We are committed to protecting and respecting your privacy, so we take your privacy seriously and will use your personal data (the "data") to administer your account and to provide the services only after obtaining your consent for the collection and processing of your data as follows. The Policy explains what data, when, where, and why we collect the data of yours, on what legal basis we process and how do we use it, the conditions under which we may disclose the data to others, your rights in respect of your personal information, as well as how we keep it secure. Whether you have any questions, please contact us via customer service in the app.

Our platform and services are not intended for children. Children are strictly prohibited from using any of our services for any reason. If you are a guardian and discover that a child under your care has accessed our platform, please contact us immediately to have their account deleted. Users must be at least 18 years old to use our app and services. Providing false information about your age to gain access to the platform is strictly forbidden and may result in the suspension or removal of your account.

By using the Service, you agree that collection and processing of your data will be covered by terms of this Policy.

1. INTRODUCTION

1.1 According to the Policy herein, we can use your personal information to:

- Ascertain Users Identity.

- Provide our Application to the User.

- Inform the User of the updates and promotions.

- Protect, maintain, and improve the Application.

- Defend both our legal interests and Users'.

2. YOUR PERSONAL INFORMATION AND THE WAY WE USE IT

2.1 Login details may involve: your name, the Account Photo, nickname, ID, birthdate, gender, and your social media user credentials. You are the data source. Login details are necessary for you to have access to the Service and to use it. Your consent to processing personal data, as well as the execution of a contract between us, and/or taking measures, as per your request to conclude such a contract, constitute the legal background for such processing.

2.2 All personal information, which is sent by default by User's installed software, including without limitation: IP-address of the User, files content of cookies, personal information, which is conveyed by the browser or different software allowing you to have access to our Service, and also, time/date and the URL of your requested page, an ID of your digital wallet, CSP name. When you purchase products or/and services from us, we might collect your name and surname, a partial number of your credit card, and/or other payment details. Your consent and contract performance between us and/or taking measures, as per your request, to conclude such a contract, constitute the legal bases for such data processing. We put all commercially reasonable efforts to be convinced that the number of your credit card and other payment details is kept highly confidential using only those third-party billing services, and have branch standard encryption technology for your credit card number protection from unauthorized usage.

2.3 Utilization data is the information of your use of the Application. Utilization data is commonly identifying information, which is non-personal and is made available by servers, web browsers, and such services, like Google Analytics, for instance, the type of browser, language choice, referring website, as well as the time of every visit. Among the other information we may have access to, there is the way you use the Application (for example, search inquiry), your rough location, and so on. Utilization data might include the following: 1) Data collected mostly for behavior statistics, email, and business intelligence campaigns ("business analytics"). We collect the traffic data of the Application by means of Google Analytics; 2) Data, which is gathered mostly for the reasons of curb fraud and technical security or monitoring errors ("technical info"); The legal ground for such processing is our lawful interests and/or by third-parties, particularly to keep track of the Service quality, to make improvements to the Application, and to avoid, diagnose and track down fraud, acts of crime or other wrongful use of the Application, as well as to prevent safety concerns.

2.4 Communication data may be defined as any information, which is stored or related to messages you send to us or generate by means of the Application herein. Communication data consists of: 1) All the requests, messages, and/or other correspondence with our Customer Support that may take place by emails, support tickets, in the course of a dispute review process, or using other means of communication; 2) All your correspondence and enclosure or other data, which is generated mainly by your communications with other Users; Communication data can consist of a full name, nickname, email, and IP address, avatar, video and audio files, and for manual ID verification: User's photo, User's personal ID photo, as well as the photo of the utility bill of the User or associated document. Also, our system can take screenshots of your correspondence with other Users in random order. The reasons for processing your communication data may be for communicating with you or/and keeping records to investigate and settle disputes, keep from wrongdoing and abominable behavior, provide better service to our customers and make improvements to our Application. Our lawful interests constitute the legal background for such processing, particularly, proper administration of the Service herein, as well as our business, prevention of amoral and/or disorderly conduct.

2.5 It may refer to the use of information for statutory compliance, safety management, and inspection, litigation, or pre-litigation. You give consent for using your personal information as evidence that you actually used our Application in the event, we have a controversy with the User. The legitimate grounds for such processing are our legal interests, particularly the assertion and defense of our legitimate rights, your legitimate rights, as well as the legitimate rights of others.

2.6 Complementary to the particular purposes, which are outlined hereof, and in respect of which we might process your information, the other reasons for our processing of your information are aimed to protect fundamental interests of yours or of another physical person. The validity of the personal information, which you provide, is not determined by the company. We expect you to deliver accurate personal information, so we maintain it current. Please make sure not to provide us with any non-mandatory personal information.

3. PERMISSIONS NOTICE

To provide full functionality of our app, we request certain permissions from your device. Below is an explanation of what permissions we collect, why we need them, how we obtain them, and how your data is protected.

3.1 Permissions Requiring User Consent

We will explicitly request your approval for these permissions through system pop-ups when needed:

(1) CAMERA

Purpose: Enables live-streaming and video call features.

How: System pop-up appears when you initiate these features.

(2) RECORD_AUDIO

Purpose: Allows audio capture for live streams and video calls.

How: System pop-up appears when you initiate these features.

(3) READ_EXTERNAL_STORAGE

Purpose:

The READ_EXTERNAL_STORAGE permission allows our social app to access photos and stored on your device's external storage (e.g., gallery, SD card). This permission is used in the following scenarios:

- Updating Profile Picture: When you choose an existing photo from your gallery to set as your profile picture.

- Sending photo in Chats: When you attach an image from your gallery to send in a chat.

How:

- Android 12 & Below: We utilize the EasyPhotos open-source SDK to facilitate smooth photo selection. The app will request this permission via a system pop-up window when you first attempt to access a file.

- Android 13 & Above: Due to Android's updated privacy policies, this permission is no longer required. Instead, we've adopted the Android system Photo Picker to access files without broad storage access.

(4) WRITE_EXTERNAL_STORAGE

Purpose:

The WRITE_EXTERNAL_STORAGE permission allows our app to save certain files to your device's external storage (e.g., SD card or internal shared storage). This permission is used in the following scenario:

- Saving Photos: When you take a photo within the app (e.g., for sending photo in a chat), we need this permission to store the file on your device before uploading it to our servers.

How:

- Android 12 & Below: We utilize the EasyPhotos open-source SDK which requires this permission to save newly captured photos to your device. The app will request this permission via a system pop-up window when you first attempt to save a file. You can accept or deny the request.

- Android 13 & Above: Due to Android's updated privacy policies, this permission is no longer required.

3.2 Normal permissions

These permissions are automatically granted upon installation for core functionality:

(1) INTERNET

Purpose: Connects to our servers.

(2) ACCESS_WI-FI_STATE

Purpose: Checks Wi-Fi connection status.

(3) ACCESS_NETWORK_STATE

Purpose: Monitors network availability, connection status, and connection type. This helps us to prevent data loss or processing delays due to network interruptions, and it can also be used for risk assessment and to identify unusual network behavior.

(4) READ_PHONE_STATE

Purpose: Checks device capability for video calls and tracks active status.

(5) BLUETOOTH

Purpose: Detects Bluetooth headset connections.

(6) POST_NOTIFICATIONS

Purpose: Sends promotional and social activity alerts.

(7) AD_ID

Purpose: Accesses Google Advertising ID for personalized ads. If you wish to disable this permission, you can turn it off from "Personalized Ads" in your device settings.

3.3 Data Security & Sharing

All data transmissions are encrypted using HTTPS protocol. For improved ad targeting and marketing optimization, we share collected data with Adjust, our third-party analytics partner. This helps us deliver more relevant advertisements and measure campaign performance.

You may review or revoke permissions at any time through your device settings, though this may limit certain app features.

4. INFORMATION THAT YOU DECIDE TO DISPLAY PUBLICLY THROUGH OUR SERVICE

4.1 Several Users often choose to supply openly personal or sensitive information while using our Application. It happens when optional fields in the profile are used, during communications in chats, or when a conversation was changed from private to public. Such information that is posted of your free will in the Application sections visible to the public is treated as public, even though it is in its essence private or sensitive. When publicly posting information of this kind on your accord, it indicates that you have no longer privacy rights for it.

4.2 Please, note that if you select to provide identifiable information when using specific public functions of the Application herein, this information might be used or disclosed by individuals, who read it, to 3rd parties without our control or your awareness of it, as well as search engines might index such information. For this reason, we prompt you to give it a second thought before including any peculiar information you might consider as private, which is either created by you or submitted via our Application.

5. TRANSFER OF YOUR PERSONAL DATA TO 3RD PARTIES

5.1 We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.

5.2 We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the website/app, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the website/app. We will likely share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you.

5.3 We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website/app in a shared location, and type of the device used to visit the website/app. They may aggregate information about our advertising and what you see on the website/app and then provide auditing, research and reporting for us and our advertisers. We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

5.4 Graphic images (uploaded by the user, as well as generated by the service) are not transferred to Third Parties under any circumstances and are the private property of the users who uploaded and/or generated the image data.

6. PROTECT YOUR INFORMATION

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to Hana or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

7. DATA RETENTION AND DELETION

7.1 Retention of Personal Data

Hana will retain your Personal Data as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

In addition, Hana may retain your Personal Data for longer periods, provided that retaining such information is necessary for Hana's legitimate interests, such as fraud prevention and record keeping. The specific retention period for different types of data is determined based on the following criteria:

- Data for Service Provision: Personal data necessary to provide and maintain our services (such as account information, usage records) will be retained for the duration of your use of the app, plus a reasonable period thereafter to ensure service continuity and address potential post-termination inquiries.

- Legal and Regulatory Requirements: If required by applicable laws, regulations, or court orders, we may retain certain data beyond the standard period to comply with such obligations.

- Dispute Resolution: Data relevant to unresolved disputes, claims, or legal proceedings will be retained until the dispute is fully resolved.

7.2 How to delete your account and data

You may request the closure of your account and the deletion of your personal data at any time. To initiate this process, log into your account and navigate to the account settings to request deletion. Account deletion requests will be processed within 30 days. After the processing period, your account and associated personal data will be permanently deleted, and reactivation will not be possible.

When you submit an account deletion request, we delete the content you have posted, and you won't be able to recover that information later. Information that others have shared about you is not part of your account and won't be deleted.

Please note that your request is subject to our retention policy, and the Hana reserves the right to retain certain Personal Data to fulfill service-related obligations or as required by applicable laws.

If you have any questions or need assistance with the account deletion process, please contact us via email at viola.luck.chow@gmail.com

8. YOUR RIGHTS

8.1 Access right. You are entitled to confirm, whether we can process your personal information or not, and, if we do, access to your personal information. If such an act doesn't prejudice the rights and freedoms of other people, we will be able to deliver you a copy of your data. The first copy is provided for free, whereas extra copies maybe for a fee. To access your personal data, you can get in touch with our Customer Support.

8.2 Right to rectification. You can request to correct any misinformation about you and, considering the aim of processing, to complete any partial personal information about you.

8.3 Right to erasure. You can request to erase your personal information. Our policy for keeping and removing personal data.

8.4 Right to answer back the processing. You are entitled to answer back to your information processing by our Service for reasons of your peculiar situation, but only when there is a lawful excuse for processing like this, that it is required for conducting a task, which is done for the public benefit or under the procedure outlined by any official body assigned to us; or the purposes of the lawful rights which we or any 3rdparty pursue. In case such objection is made, we terminate the processing of your data if no reasonable, lawful excuse for this processing is provided by us to outweigh your interests or rights and freedoms; otherwise, such processing is for the government circles, exercise, or protection of lawful claims.

8.5 The right to limitation. You are entitled to ask for the termination of your data processing in peculiar cases, for example, when your right to object is exercised as specified above, or when you fight for accuracy of your information, that is processed by us.

8.6 Data portability right. To the effect that your consent is the legal background for us to process your information, and we conduct such processing with the help of automated means, you may request us to supply you with your information in a structured way, which is in a generally valid and machine recognizable format. This right is not applied, though, in cases, when may prejudice rights and freedoms of others.

9. NOTIFICATION OF CHANGES TO PRIVACY STATEMENT

We reserve the right at our discretion to make changes to this Privacy Policy. You may review updates to our Privacy Policy at any time via links on our website. You agree to accept electronic communications and/or postings of a revised Privacy Policy on Joy-sharing Cloud Limited and Hana website, and you agree that such electronic communications or postings constitute notice to you of the Privacy Policy. Please review it frequently.

When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement. If we make material changes to this policy, we will notify you by publishing a revised Privacy Policy or by means of a notice on our website, or as required by law. You agree to review the Privacy Policy periodically so that you are aware of any modifications. You agree that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of the Privacy Policy, you should not use the Service.

10. WAYS TO CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please feel free to contact us through the following means:

- Email: viola.luck.chow@gmail.com

- Application Website: https://be.jubeebeauty.com

- In-app Customer Service: You can also get in touch with us via the customer service function within the app.

Business hours: 9AM to 6PM, Monday to Friday.