Welcome to Proche!
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
In providing Proche, we collect, store and use the following Information relating to you:
" Information" is Personal Information and Non-Personal Information;
" Personal Information" is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:
information you make available to us when you open a Proche account, such as your name, telephone number, email address and credit card information;
any information included in your publicly visible Proche profile, which may include your profile ID, name and photo;
information you make available to us via your use of Proche;
your sharing of your contact list with Proche in the "Recommended Friends" function in order to connect with other Proche users; or
your sharing of your biometric information via Proche – e.g. by using your voice to authentic your identity and log into Proche via Voiceprint. Please note that we will always expressly ask for your consent prior to collecting any biometric information about you;
information made available by another user about you via their use of Proche; and
information we collect as you use Proche, such as certain Location Data and Log Data.
" Location Data" is information that we collect regarding your location (when you use a location-enabled service), including:
the location of your device when you use Proche, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device;
the IP address of the device or internet service you use to access Proche; and
other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located, and Shared Information that you or others post which indicates your location (for example, any geotag information that is embedded in any photos you make available on Proche or that is made available to us when you use the Proche "Shake" or "People Nearby" functions).
technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Proche, your IP address and your device's version and identification number;
information about what you have searched for and looked at while using Proche, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using Proche;
information about communications you have made using Proche, such as the people you've communicated with and the time, data and duration of your communications; and
metadata, which means information related to items you have made available through Proche, such as the date, time or location that a shared photograph or video was taken or posted.
" Non-Personal Information" is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymized form.
" Shared Information" is information about you or relating to you that is voluntarily shared on Proche. Shared Information may include postings that you make on Proche (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device's camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.
HOW WE USE YOUR INFORMATION
We may use your Information for any of the following purposes:
to provide Proche (and the features within Proche) to you – for example, to allow you to place VOIP calls within Proche, to fulfil any purchases you may make within Proche, and to display content based on your location;
for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of Proche;
to provide you with advertising and direct marketing that is more relevant to you (as discussed in more detail below under the "Direct Marketing" section below);
to better understand how you access and use Proche, in order for us to improve Proche and respond to customer desires and preferences, including for us to provide language and location customisation, personalised help and instructions, or other responses to your and other customers' usage of Proche;
to help us develop our new services and improve our existing services;
to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with Proche when your account is subscribed to an official account; and
to allow you to participate in voluntary surveys about our products and services. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys; we will prohibit them from using your Personal Information for any purpose other than to complete the survey.
Use of Personal Information on our other services
In order to provide our users across all of our services with a better experience, to improve Proche and our other services, or otherwise where you have consented, Personal Information collected through Proche may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualized manner).
For example, Personal Information collected during your use of Proche may be used to suggest particular content that can be made available to you on, or be used to present more relevant advertising to you in, another Tencent service. You may also ask us to migrate or export your Personal Information contained in Proche to another Tencent service, where such migration option is available.
Personal Information within Your Content
We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties.
Such products and services (of ours or third parties) include the following:
our products and services and the products and services of our affiliate and subsidiary companies and joint venture partners, including messaging services, online media services, interactive entertainment services, social networking services, payment services, internet search services, location and mapping services, application software and services, data management software and services, on-line advertising services and other social media, entertainment, e-commerce, information and communications software and services (" Internet Services"); and
third party providers of Internet Services and products and services relating to dining, food and beverages, sports, music, film, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewellery, cosmetics, personal health and hygiene, electronics, collectibles, housewares, appliances, home decoration and furnishings, pets, automobiles, hotels, transport and travel, banking, insurance and financial services, loyalty and reward programs and other products and services that we think may be relevant to you.
We will honour your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact our Privacy Officer or follow the relevant instructions on our marketing communications. Please note that following such request, you may still receive advertisements that are not direct marketing.
Please note that we will not share your Personal Information with advertisers unless you have given us your consent to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.
SHARING OF YOUR PERSONAL INFORMATION
Sharing for the provision of Proche
We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes:
providing Proche to you;
assisting us in carrying out the purposes set out under the "How We Use Your Information" section above;
helping us understand and improve Proche.
Sharing for marketing purposes
In addition, we allow third party marketing partners (such as Proche official accounts, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use Proche.
We also provide your Personal Information to third party marketing partners where you have asked us to do so or where it is required in order for us to provide Proche to you.
Other terms relating to the sharing of your Personal Information
Any of the above-referenced third parties in this "Sharing of your Personal Information" section may be located, and use and store your Personal Information, outside of your jurisdiction for the above purposes, including in jurisdictions where there may not be in place data protection laws that are substantially similar to or serve the same purpose as the laws of your jurisdiction.
We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the "Period of use of your Personal Information" section below.
A WORD ABOUT SHARED INFORMATION
Proche enables Shared Information to be shared publicly with your Proche contacts, all users of Proche and/or the public, via features provided by either us or third parties, so that Shared Information can be broadly and instantly transmitted. Shared Information will remain public for as long as you do not delete it; and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.
In addition, we may also provide other Proche-related features that allow you to share Shared Information in public – for example, publicly accessible blogs and forums, or certain social media features within Proche – for example, "plug-ins" (which create a direct link between two websites) and "widgets" (which are interactive mini-programs that provide third party services within Proche). You should be aware that any information you provide within such features may be read, collected and used by third parties who access them.
Please consider carefully what you post and communicate through Proche. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in some of Proche.
UPDATING OR AMENDING YOUR PERSONAL INFORMATION
If you would like to update or amend your Personal Information within Proche, you may do so at first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the "Clear Location" option within Proche.
If you wish to make further changes to your Personal Information; request access to, or deletion of, your Personal Information from Proche; or to request the removal of an unauthorised Proche account, please contact our Privacy Officer. We will respond to your request within a reasonable timeframe.
In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may require disproportionate technical effort or extremely impractical (e.g. any requests that relate to our backup systems), or are prohibited by law.
COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use Proche, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Proche for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
A WORD ABOUT SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as "sensitive" and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to Proche, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.
Before communicating any Personal Information of a sensitive nature within Proche, please consider whether it is appropriate to do so.
Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.
THIRD PARTY SERVICES ON Proche
Proche may link you to social media or other features or services (including websites, plug-ins and widgets) provided by a third party. For example:
you may share content on, or login to, Proche using services provided by third parties. These third party services will authenticate your identity and provide you with the option to share certain Personal Information with us. They may also give you the option to post information from your third party service account to Proche as Shared Information (or vice versa).
you may link your Proche contact list to your contact lists on your device and/or in your account on third party services, in order to search for and connect with contacts on those contact lists who also have a Proche account. In consenting to such linking, we will use your username and password for the relevant third party service only for the purpose of such contact list linking (and will delete such information immediately after such purpose is completed);
you may login to Proche using other sign-in services such as an Open ID provider. These sign-in services will authenticate your identity and provide you the option to share certain Personal Information with us for account registration and login purposes, such as your name and email address; and
we may (whether in advertisements or otherwise within Proche) provide you with links or features that allow you to access third party services or websites (or access within Proche content that is hosted on those third party services or websites). For example, you may be able to access videos hosted by a third party within Proche.
These third party social media or other services may be hosted by the relevant third party or us. Please note that such third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such features to function properly.
Children under the age of 13 are not allowed to use Proche. We do not knowingly collect Personal Information from any children under the age of 13. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 – we will promptly investigate (and remove) such Personal Information.
TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.
We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.
In Proche, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access Proche may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.
PERIOD OF USE OF YOUR PERSONAL INFORMATION
We will generally only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the "How We Use Your Information" section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:
in order to comply with applicable laws or regulations;
in order to comply with a court order, subpoena or other legal process;
in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere);
where we believe it is reasonably necessary to comply with applicable laws or regulations; or
Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer, or where we offer this option in Proche, you may also log into your account with us and make the appropriate changes. We will use reasonable efforts to respond to all such requests made to our Privacy Officer within 60 days.
Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through Proche, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using Proche may put your Personal Information in the hands of third parties that we cannot control.
Why do we use tracking technologies?
To help us better understand and provide Proche to you and our users
Tracking technologies enable us to better understand and provide Proche to you – for example, tracking technologies help us collect the following Information:
we require your authentication information in order to provide Proche to you;
our mapping and location-based services (such as "Shake" and "People Nearby") may require Information about your location;
our translation services may require Information about your language preferences; and
we require certain other Information about our users in order to provide Proche and to develop new features for Proche.
To help us deliver relevant and safe advertising to you
Advertising helps keep Proche and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:
more effective for advertisers – for example, by delivering them further information regarding who has viewed their advertisements;
more safe for you – for example, by ensuring that you do not receive repeated or fraudulent advertisements or prohibited content within such advertisements; and
more relevant to you – for example, by delivering advertisements based on which official Proche channels you may have followed or based on your location.
What are tracking technologies?
The "tracking technologies" that we use within Proche include the following:
A cookie is a small file containing a string of characters that is placed on your computer, mobile phone or other device when you access a website or other web content.
Web beacons are electronic image files or other technologies that may be embedded within websites or emails that may be used to keep count of visitors, record when and if an email or website is viewed, or access certain cookies.
Certain information is automatically gathered and stored in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
An entity tag (or ETag) are HTTP headers that are sent-behind-the-scenes between a web browser and a web server. They can be used to track unique users in place of cookies, and allow us to better understand and improve Proche.
Anonymous identifiers are used to deliver advertisements in services where cookies may not be available (for example, in mobile applications).
How do we use tracking technologies?
Tracking technologies used in partnership with third parties
We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:
Our analytics partners helps us better understand Proche generally – for example, to collect website and app usage statistics and to gather demographic information about our user base as a whole, as well as to analyze any relevant trends.
Our marketing partners (including analytics partners, advertisers and Proche official account partners) help us deliver better and more relevant advertising to you.
Our customer support service partners help us deliver better responses to any queries from you and to deliver a better Proche experience to our users.
Our service partners help us administer and deliver certain features within Proche – for instance, hosting, language translation and mapping services.
We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis.
Our own tracking technologies
In addition, we also use our own tracking technologies to personalise your experience on Proche and for various other purposes, including:
remembering you. For example, cookies and web beacons can help us identify you as a registered user of our services or keep the preferences or information that you have previously provided; and
analysing how you use our services. We can use tracking technologies to understand what users are doing on our services, or which pages or sections are most popular.
Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyse how you and others use our services and to serve advertising.
General terms in relation to tracking technologies
If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for Proche via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered Proche. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.
How you can control tracking technologies
You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal Proche experience and some or all of Proche's features may not function properly.
You may also control what tracking technologies-collected Information we receive by certain settings within Proche – for instance, by using the "Clear Location" option within Proche.