Privacy Policy Last updated: Sep 1, 2019 This Privacy Policy describes how Zhuhai Poge Technology Co.,Ltd.(referred to in this Privacy Policy as "Company", "POKA", "we", or "us"), as the operator of the website https://financecam.pro (the "Site") and the developer of the associated FinanceCam mobile application (the "App"), collects information when you visit the Site or use the App (separately and collectively, the "Service"). It also explains how we use and disclose the information we collect from you, and your rights in relation to that information. By accessing, visiting or using the Service, you expressly consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you must not use the Service. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service located at https://api.financecam.pro/terms/en/terms_of_use.html. Any product and service related with the Privacy Policy is operated by Zhuhai Poge Technology Co.,Ltd and its related company. If you have any questions or relevant issues about this Privacy Policy, please contact us at legal@financecam.pro. 1. REVISIONS TO THIS PRIVACY POLICY Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We will notify users of changes to this Privacy Policy by posting the amended terms on the Site or Service in advance of the last updated date of the changes. If you do not agree to the changes, you should discontinue your use of the Site or Service before the modified privacy policy takes effect. If you continue using the Site or Service after the modified privacy policy takes effect, you will be bound by the modified privacy policy. 2. COLLECTING INFORMATION Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, iOS ad identifier (IDFA), Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI) The equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location of the language, the time zone and the network state (WiFi and so on), the hard disk, the CPU, and the battery use, etc. 2.1 Account Information If you create an Account, we’ll collect certain information that can be used to identify you, such as your email address ("PII"). If you create an Account using your login credentials from one of your Social Networking Sites (the "SNS") Accounts, we’ll be able to access and collect your name and other PII that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered PII because it cannot be used by itself to identify you. 2.2 Information Collected Using Cookies and other Web Technologies Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information. "Cookies" are small text files that are placed on your device by a web server when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your device. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties. "Web Beacons" (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail). 2.3 Information Related to Use of the Services Our servers automatically record certain information about how a person uses our Services (we refer to this information as "Log Data"), including both Account holders and non-Account holders (either, a "User"). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance the Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to fight spam, malware and identity theft. We also use the IP Address to generate aggregate, non-identifying information about how our Services are used. 2.4 Information Sent by Your Mobile Device We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services. 2.5 Location Information In some cases we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device. 2.6 Third-Party Payment Processing We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, "App Stores"), SNS such as Facebook, and other third-party payment processers. The third party application may collect certain financial information from you to process a payment on behalf of us, including your name, email address, address and other billing information. 3. SHARING OF DATA We will not share any PII that we have collected from or regarding you except as described below: 3.1 Information Shared with Our Services Providers We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to your PII only for the purpose of performing services on our behalf. We may also share your PII except with our marketing service providers to help us better market our products and services to you. Our marketing service providers may use your PII only for the purpose of helping us better market our products and services to you and are prohibited from transferring your PII to others. If you don’t want FinanceCam to use your information for these purposes, you can opt out by contacting us at legal@financecam.pro. 3.2 Information Disclosed in Connection with Business Transactions Information that we collect from our users, including PII, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your PII, may be disclosed or transferred to a third-party acquirer in connection with the transaction. 3.3 Information Disclosed for Our Protection and the Protection of Others We cooperate with government and law enforcement officials and/or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: to respond to claims or legal process (including subpoenas, warrants or court orders); to protect our property, rights and safety, and to protect the rights, property and safety of a third party or the public in general to prevent or stop any activity we consider illegal, unethical or legally actionable activity. 4. LEGAL BASIS FOR DATA PROCESSING We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites. 5. YOUR RIGHTS Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information we recommend that you carefully review the privacy policies of other websites and services that you access. Interstitial ads or ads that interrupt or block the user experience will clearly indicate that they are an ad, will not manipulate or trick users into tapping into them, and will provide easily accessible and visible close/skip buttons large enough for users to easily dismiss the ad. Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by contacting us through legal@financecam.pro. If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law. We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. 5.1 Opt-Out We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to "opt-out" (either through your Account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing. 5.2 Modifying Your Information You can access and modify the PII associated with your Account through your Account settings or by contacting us at legal@financecam.pro. You can request to deactivate your account (Settings - Account & Security - More - Deactivate Account). Before deactivating your account, we will confirm information such as your identity, security status, trusted devices. Please note that deactivation is irreversible. Once you deactivate your account, we will no longer collect personal information and delete all information related with your account. We guarantee that such information will not be revealed. Meanwhile, you are not able to access our service with deactivated account. You can request to export your data by contacting us at talk@financecam.pro. Before exporting your data, we will confirm information such as your identity, security status. 6. THE SECURITY OF YOUR INFORMATION We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. 7. LINKS TO OTHER SITES Our Services may contain links to websites and services that are owned or operated by third parties (each, a "Third-party Service"). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to that owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access. 8. CHILDREN‘S PRIVACY Children are not eligible to use our services and we do not knowingly collect or solicit personal information from children under 13. If you are a minor, you can use the service only in conjunction with your parents or guardians. If we are aware that a child under 13 has provided us with personal identifiable information, we will delete such information from our files. We use your email address and, in rare situations your mailing address or phone number, to contact you regarding administrative notices from time to time. 9. QUESTIONS Please contact us at legal@financecam.pro if you have any questions about our Privacy Policy.