Papaya Privacy Policy


Effective from: May 24, 2018


This website, and services provided hereto, are provided by Papaya Group Co., Limited, Beijing Papaya Mobile Technology Co., LTD and its affiliate entities (hereinafter referred to as "Papaya" or "we"). Here's how we protect your data and respect your privacy.

By visiting or using the www.papayamobile.com website or service, and any other linked pages, features, content, or any other services we offer from time to time by in connection therewith (collectively, "Papaya"), or sign up to be an Affiliate partner, you shall read the following privacy policies.

Our responsibilities

If you are (going to be) a registered Affiliate partner (hereinafter referred a visitor to our website we act as the ‘data controller’ of personal data. This means we determine how and why your data are processed.

Your responsibilities

Read this Privacy Policy

If you are already our Affiliate, please also check the contracts between us: they may contain further details on how we collect and process your data.

If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.

When and how we collect data

From the first moment you interact with Papaya, we are collecting data. Sometimes you provide us with data, sometimes data about you is collected automatically.

How does Papaya collect information?

Our services are designed to connect publishers and advertisers around the world. For the personal data, we will not collect such as the user’s advertising identifier, precise location, or interest or demographic information such as age and gender. We may still receive data such as the user’s IP address, Cookies for limited purposes based on separate legal grounds for processing, such as legal necessity or legitimate interests.

How We Use the Information We Collect

Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data: keeping Papaya running, improving Papaya and affiliate support.

Types of data we collect

Contact details

Your name, address, telephone number, email address.

Financial information

Your bank account number, sort code, credit/debit card details

Data that identifies you

Your IP address, login information, browser type and version.

Data on how you use Papaya

Your URL clickstreams (the path you take through our site), products/services viewed.

What about really sensitive data?

We don’t collect any "sensitive data" about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences) except when we have your specific consent, or when we have to to comply with the law.

What about children's data?

Papaya is a business-to-business service directed to and intended for use only by those who are 18 years of age or over. Papaya does not knowingly collect or solicit Personal Information from anyone under the age of 16 or knowingly allow such persons to register. If you are under 16, please do not attempt to register for Papaya or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 may provide any Personal Information to Papaya or through Papaya. In the event that we learn that we have collected Personal Information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at gdprcompliance@papayamobile.cn.

Legal basis for this data usage: Consent, Contract, Legitimate interests

Here is what each of these "legal bases" mean:

Consent

You have given clear consent for you to process your personal data for a specific purpose. You can change your mind!

If you have previously given consent to our processing your data you can freely withdraw such consent at any time. You can do this by emailing us at gdprcompliance@papayamobile.cn .

If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights.

Contract

Processing your data is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

Legitimate interests

Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests are:

  • gaining insights from your behaviour on our website
  • delivering, developing and improving the Papaya service
  • enabling us to enhance, customise or modify our services
  • determining whether marketing campaigns are effective
  • enhancing data security

In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests

Your privacy choices and rights

Your choices

You can choose not to provide us with personal data

If you choose to do this, you can continue to use the website and browse its pages, but we will not be able to process transactions without personal data.

You can turn off cookies in your browser by changing its settings

You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the website and browse its pages, but Papaya and certain services (like Intercom) will not work effectively.

You can ask us not to use your data for marketing

We will inform you (before collecting your data) if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by emailing us at gdprcompliance@papayamobile.cn.

Your rights

You can exercise your rights by sending us an email at gdprcompliance@papayamobile.cn.

You have the right to access information we hold about you

This includes the right to ask us supplementary information about:

  • the categories of data we're processing
  • the purposes of data processing
  • the categories of third parties to whom the data may be disclosed
  • how long the data will be stored (or the criteria used to determine that period)
  • your other rights regarding our use of your data

We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person's confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.

You have the right to make us correct any inaccurate personal data about you

You can object to us using your data for profiling you or making automated decisions about you

You have the right to port your data to another service

You have the right to receive the personal data concerning you that we have collected.

You have the right to be 'forgotten' by us

You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of our service.

You have the right to lodge a complaint regarding our use of your data

Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the supervisory authority.

How secure is the data we collect?

We have physical, electronic, and managerial procedures to safeguard and secure the information we collect.

And please remember:

You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure.

You are responsible of your username and password: keep them secret and safe.

If you believe your privacy has been breached, please contact us immediately on gdprcompliance@papayamobile.cn.

Where do we store the data?

The personal data we collect is processed at our offices in Beijing and in any data processing facilities operated by the third parties.

By submitting your personal data, you agree to this transfer, storing or processing by us. If we transfer or store your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

How long do we store your data?

We will archive and stop actively using any personal identifiable information about you within 13 months from the last time you used Papaya. We will delete your personal data from our archives no later than 6 years from the last time you used Papaya or as agreed with you in a separate contract.

Third parties who process your data

Tech businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Policy.

Cookies

We use cookies. Unless you adjust your browser settings to refuse cookies, we (and these third parties) will issue cookies when you interact with Papaya. These may be ‘session’ cookies, meaning they delete themselves when you leave Papaya, or ‘persistent’ cookies which do not delete themselves and help us recognise you when you return so we can provide a tailored service.

How can I block cookies?

You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies we have no control over how those third parties use those cookies

If you have any question about this Privacy Policy or otherwise related, please contact us at gdprcompliance@papayamobile.cn .

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