Published on:August 1, 2024
Effective on:August 1, 2024
Introduction
Welcome to use the AnyTrans products and/or services provided by METAVERSE CLOUD PTE. LTD.. AnyTrans platform provide you with language translation service through the access of third-party’s AI Bots.
Your personal data security means a lot to us, and we will try our best to provide you with a secure online environment. This Privacy Policy describes the purpose, methods, scope and information security measures regarding the collection, use, storage, sharing, transfer and processing of your personal information in the process of our offer of the products and/services at our platform to you. It also describes your choices regarding your exercise of the rights to access, correct, supplement and delete your personal information. To facilitate your reading and understanding, we have used clear and intelligible language and defined key terms as shown in the “[Schedule 1: Definitions of Key Terms” attached hereto.
You must carefully read and fully understand this Privacy Policy before using AnyTrans products and services, especially the clauses highlighted in bold, and acknowledge that you have fully understood and agreed to this Privacy Policy before using the relevant products or services. You can contact us using the contact details (support@anytrans.ai) published by AnyTrans if you have any questions about this Privacy Policy. If you disagree with the terms of this Privacy Policy, you shall stop using the AnyTrans products/services immediately.
This Privacy Policy will help you understand the following:
I. How we collect and use your personal information
II. How we use Cookies and similar technologies
III. How we share, transfer or disclose your personal information
IV. How we store your personal information
V. How we protect your personal information
VI[. How you exercise the rights in personal information
VII. How we process children’s personal information
VIII. How we update and revise this Privacy Policy
IX. How you contact us
X. Other legal basis for processing your personal information (only for EEA)
[Schedule 1: Definitions of Key Terms
I. How we collect and use your personal information
(I) Personal information obtained by us when you use our products/services
We may need to collect and use your relevant personal information to achieve the basic business functions of our platform. The following will provide a detailed list of our basic business functions and the type of information necessary for achieving these functions, and we will collect and use such personal information only with your consent:
1.When you register/log in to your account, you are required to provide your [email address/phone number and password] to complete the account registration. You may also choose to complete registration through authorizing a third-party account, in which case we will collect your [third-party account information].
2.When you use our paid services/products, we will collect your [order information, billing address, billing contact of yourAnyTrans account, and payment information], so that we can send you invoices and complete the payment process for your orders.
3.Input Information of users: When you use our[Language Translation] basic business functionservice, we will collect your personal information, if any, contained in the [input content,glossary, uploaded files or feedback] (collectively, “Input Information”) that you provide to our services for outputting the content meeting your needs,and we recommend you don’t use AnyTrans to translate texts that contain any personal information. If you do not provide Input Information, you will be unable to use our Language Translation service.Please note that we will not create the user profile based on the user’s Input Information and usage.
4.Communication Information: If you contact us by means of communication, we may collect your [name, contact information, and any messages you send to us during the communication (“Communication Information”)] in order to verify your identity and solve the problems you raise.
5.When you browse or log in to use our products/services, we may collect your user-side system time, time zone, and IP address. By doing so, we can count user traffic based on user-side system time, time zone and IP address and conduct data analysis to keep our system secure.
6.We will collect your [Cookie information] to identify the login user. We will also collect the [browser language type] you select when you use the services, and switch the corresponding website language based on the language you select, so that you can read and use our services. In addition, we collect [User-Agent information] to recognize the [browser type and version] and ensure compatibility with browser API, thereby enhancing your experience when using our platform’s services.
7.We may aggregate or de-identify your personal information and Input Information based on the information collected as described aboveso that it may no longer be used to identify you and use such aggregated information to analyze the effectiveness of our services, thereby improving and adding features to our services. We may analyze the general behavior and characteristics of our users from time to time based on the information collected as described above, summarize and analyze such data, and share with third parties, publish or publicly disclose such summary information. You should understand that such summary information does not belong to users’ personal information because it cannot identify specific individuals, and we will not re-identify individuals from such summary information.
(II) Your personal information obtained by us from third parties
1. We may obtain your personal information from a third party (partner) with your consent. In such case, the third party acts as a data processor (controller) of your personal information, and the type and scope of personal information provided by you to the third party as well as methods of provision will be determined by the third party based on its products/services. You shall read the privacy policy and user agreement of the third party in detail. We will process your personal information under mandate from the third party only in accordance with the contract signed by us and the third party. We guarantee that we will process your personal information in strict accordance with the provisions of the contract signed by us and the third party, and applicable laws.
2. We may obtain and appropriately use publicly available information about you through webpage and other public channels, or obtain from third parties the business information that your company has publicly disclosed, so as to help us better understand our customer base, such as your industry, and the scale and website URL of your company.
++We hereby give you a reminder that if such information cannot identify your personal identity individually or together with other information, it will not belong to your personal information defined by the law; if your relevant information can identify your personal identity individually or together with other information, or we use any data that cannot be linked with any specific personal information in combination with your other personal information, such information will be treated and protected as your personal information in accordance with this Privacy Policy during the period of combined use.++
II. How we use Cookies and similar technologies
When you use our services, we will store small data files called Cookies on your computer or mobile device in order to ensure the normal operation of our website. Cookies usually contain identifiers, site names and some numbers and characters. The main functions of Cookies are to facilitate your use of our platform’s products and/services and help our website count unique visitors. With Cookies, we can provide you with more personalized services and allow you to set specific service options. When you use our platform’s products and/or services, we will send Cookies to your device. When you interact with services provided by us to partners, we allow Cookies (or other anonymous identifiers) to be sent to our servers.
We will not use Cookies for any purpose other than as set forth herein. You can manage or delete Cookies based on your preferences. You can clear all Cookies stored on your computer, and most web browsers have the function to block Cookies. Accordingly, if you do this, you may need to change the user settings every time you visit our website, and you may not be able to log in or use the services or functions provided by AnyTrans with reliance on Cookies.
For more information about the types of Cookies we use, reasons and how to control Cookies, please refer to AboutCookies.org.
III. How we share transfer or disclose your personal information
(I) Sharing
We will not share your personal information with any third party, except for the following circumstances:
1. With your express consent. We will share your personal information with other parties after obtaining your express consent;
2. We may share your personal information in accordance with applicable laws, regulations, legal procedures, or governmental requirements, including national security, emergency services or law enforcement requirements;
3. It is necessary to provide your personal information to a third party for protecting your or the public’s interests, property or safety to the extent required or allowed by law;
4. You disclose the personal information to the public by yourself, or we can obtain the personal information from other lawful public channels.
5. Sharing with our affiliates: Your personal information may be shared with our affiliates; we will only share the necessary personal information, subject to this Privacy Policy. If an affiliate intends to change the purpose of processing personal information, we will seek your authorization and consent again; or
6. In order to provide you with more comprehensive and high-quality products and/or services, certain functions may be provided by our service partners, such as third-party service providers, contractors or agents. We may entrust these service partners to process certain personal information on our behalf. For example, third-party suppliers may send emails or push notifications, or conduct statistical analysis of de-identified information on our behalf.
We will sign a strict confidentiality agreement or data processing agreement with any company, organization and individual entrusted to process your personal information, which shall define entrusted matters, entrusted processing purpose, duration, processing methods, type of personal information to be processed, protection measures, and the rights and obligations of the two parties, and require such company, organization and individual to process personal information in strict accordance with our requirements, this Privacy Policy, and relevant confidentiality and security measures. We will oversee the personal information processing activities of these third-party service providers. If such third parties change the purpose of processing personal information, they should seek your consent again, and we will also monitor the same. If you refuse to allow our service partners to collect or use the personal information necessary for providing the services, you may be unable to use certain services provided by these partners among our products and/or services.
(II) Transfer
We will not transfer your personal information to any company, organization and individual, unless:
1. With your express consent; or
2. You disclose the personal information to the public by yourself, or we can obtain the personal information from other lawful public channels.
In case of personal information transfer involved in a merger, acquisition or bankruptcy liquidation, we will inform you of the name or contact information of the recipient, and will request the new company or organization holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will request such company or organization to seek your authorization and consent again. If personal information transfer is not involved, we will inform you fully, and delete or anonymize all personal information under our control within fifteen business days.
We will request the aforementioned third party through agreements or otherwise to take proper confidentiality and security measures when they handle personal information.
(III) Public disclosure
Subject to applicable laws and regulations, we will not publicly disclose your personal information without your express consent.
IV. How we store your personal information
(I) Storage location
In principle, we will store your personal information on servers located in Singapore. However, considering that we may access ++GPTBOTS.AI platform++ and that the GPTBOTS.AI platform utilizes the LLM capabilities of OpenAI, L.L.C., the Input information while you use our products/services may be transmitted and stored in Singapore and United States (where OpenAI, L.L.C.'s data centers ).
If you are our registered user and your place of residence is not in Singapore. you agree to the cross-border transmission and storage of your personal information to Singapore and the location of our partners’data storage centers.
(II) Storage period
We will keep your personal information within the shortest time as required by laws and regulations only for the purposes as set forth herein, and will delete or anonymize such personal information, if any, upon expiration of such storage period. However, subject to applicable laws and regulations, we may extend the storage period of your personal information for defending litigation, safeguarding public interest and protecting personal property or legitimate rights.
V. How we protect your personal information
1. We have taken safety precautions meeting the industry standards to protect the information you provide and prevent data from unauthorized access, disclosure, use, alternation, damage or loss. We will take reasonably practicable measures to keep your data secure. For example, data exchange between your browser and the “services” will be protected by SSL encryption; we will also provide https for our website; we will use encryption technology to ensure confidentiality of data; we will deploy trusted protection mechanisms to prevent data from being maliciously attacked; we will implement access control mechanisms to ensure that only authorized personnel can access personal information; and we will regularly organize security and privacy protection training courses to enhance employees’ awareness of the importance of personal information protection.
2. Our data security capabilities: We have established security defenses based on data life cycle that cover data collection, transmission, storage, use, circulation, archiving, deletion and other data processing stages.
3. We will take reasonably practicable measures to avoid collecting unrelated personal information. We will store your personal information only within the period necessary for achieving the purposes as set forth herein and take technical measures such as encryption for the stored information.
4. The internet has no absolute security, and email, instant messaging, and other forms of communication with other users are not encrypted, so we strongly recommend that you should not send personal information through such means. Please use complicated password and regularly change it to help us guarantee the security of your account.
5. No internet environment is completely safe, so we will do our best to ensure the security of any information you send to us. We have used necessary and reasonable efforts, but there may exist a risk of personal damage, property, reputation and other losses posed to you and your users due to theft, illegal occupation or misuse of data. You have been aware of such risk and voluntarily assume it.
6. After any personal information security incident occurs unfortunately, we will, as required by laws and regulations, promptly inform you of: basic information on the security incident and its possible impacts, handling measures taken or to be taken by us, suggestions that you may solely prevent and reduce risks, remedies granted to you, etc. We will timely inform you of the relevant information on the accident through such methods as email or notification push. If it is difficult to inform the personal information subjects one after another, we will take reasonable and effective methods to make announcements. Meanwhile, we will also actively report the handling progress of personal information security incidents as required by regulatory authorities.
VI. How you exercise the rights in personal information
We attach great importance to your management of personal information and try our best to protect your rights to access, view, copy, modify, supplement and delete personal information, so as to keep your privacy and information secure.
1. Rights to be informed and make decisions
a. We inform you of how we process your personal information through the publication of this Privacy Policy. We are committed to presenting transparency in the use of your information; we will remind you of this Privacy Policy and allow you to make an independent decision whether to agree or disagree when you first register or every time you log in to your account. In addition, you can view this Privacy Policy in whole at any time according to the guidelines provided in the Section titled [How we update and revise this Privacy Policy] hereof.
b. If the products cease service or operation, we will promptly stop collecting your personal information, notify you of this situation individually or through an announcement at least thirty calendar days, and delete or anonymize all of your personal information we hold within fifteen business days after the products cease service or operation formally.
2. Right of access
You may directly view or access your personal information on the [Personal Center] at our website, including logging in to your account at any time on the relevant product page to access the personal information related to your account. If you are unable to view or access your personal information on your own or encounter any problem when exercising your right to access data, you can contact us according to the guidelines provided in the Section titled [How you contact us] hereof to request us to provide your personal information.
3. Rights of correction and supplement
If you would like to exercise your rights to correct and supplement data, e.g., you want to edit the corporate/individual information in your account, change your password or add information, you can access the Personal Content of AnyTrans to perform such operations.
If you are unable to correct or supplement your personal information on your own or encounter any problem when exercising your right to correct or supplement data, you can contact us according to the guidelines provided in the Section titled [How you contact us] hereof to request us to provide your personal information.
4. Right of deletion
You can contact our customer service through emailing ++support@anytrans.ai++ to request us to delete the personal information you provide if:
(1) we collect and use personal information in violation of laws and regulations;
(2) we collect and use personal information in violation of the agreement between you and us;
(3) we collect and use your personal information without your consent;
(4) we share with or transfer to a third party personal information in violation of laws and regulations or the agreement between you and us, in which case we will immediately stop such act and notify the third party of timely deleting it;
(5) we publicly disclose personal information in violation of laws and regulations or the agreement between you and us, in which case we will immediately stop such act and notify the relevant recipients to delete it;
(6) you no longer use our products or services, or you have cancelled your account; or
(7) we cease to provide you with the products or services.
When deleting the relevant information, we may verify your identity to ensure account security. Once the request for deletion is responded to, your personal information will be deleted within fifteen business days, unless otherwise required by laws and regulations.
Please note that if you request us to delete specific personal information about a user, such user may be unable to continue to use our products and services.
5. Withdrawal of your authorization
In general, each of business functions may be realized with some basic personal information collected, and you can contact our customer service by emailing support@anytrans.ai to request withdrawing your consent with respect to the collection and use of your personal information. After you withdraw your consent, we will no longer collect and use your relevant personal information. However, please understand that once you withdraw your consent or authorization, we will be unable to continue to provide the specific functions and/or services associated with the withdrawn consent or authorization. If you withdraw your consent, this will not affect our processing of your personal information with your consent prior to such withdrawal.
6. Account cancellation
You may cancel your previously registered account at any time by clicking "Personal Center" - "Preferences" - "Account Deletion" on the web site, and follow the relevant operation instructions on the page to delete your account. You should know that cancellation of your AnyTrans account will make you permanently lose your rights to the account and the data therein. We will provide you with account cancellation services after verifying your identity and fully handling assets in your account through consultations with you. After your AnyTrans account is cancelled, we will cease to provide you with the products or services and delete or anonymize, upon your request, your personal information within fifteen business days, unless otherwise provided by laws and regulations.
7. Refusal of notification push
We may send marketing messages or product introduction information to your email address or phone number，you can choose not to receive marketing emails/messages from AnyTrans according to the unsubscribe/opt-out instructions in the received emails/messages, or directly indicate your unwillingness to receive any marketing call from AnyTrans when receiving the same. You can also contact customer service by emailing support@anytrans.ai to opt out of future marketing emails/messages.
Please note that even if you choose to opt out of marketing communications, we may still send you non-promotional information related to updates of our Service Terms or Privacy Policy, security alerts, and other notifications related to your access or use of our products and services.
8. Protection of deceased individuals’ personal information
After a user (individual only) dies, the user’s close relatives may exercise the rights to access, copy, correct or delete the personal information of the deceased using the contact information as set forth herein for his or her own legitimate and proper interests, unless otherwise arranged by the deceased user during his or her lifetime.
You understand and acknowledge that in order to fully protect the personal information rights of the decreased user, the close relative who applies for exercising the rights specified in this Section shall submit the identification document and death certificate of the deceased user, the identification document of the applicant, the certificate of relationship between the applicant and the deceased user, type of the rights that the applicant applies for exercising, and purpose according to the process designated by us or our customer service instructions. You can obtain further information on protection process, conditions and other related matters concerning the personal information of the deceased user using the contact details specified in this Privacy Policy.
9. Response to your requests above
For the security, we may need to verify your identity before processing your requests. You may need to provide written document or otherwise prove your identity. In principle, we will respond to all of your requests under this Section within fifteen business days after receiving the same and verifying your identity.
We generally do not charge any fees for your reasonable requests as described above. We may refuse requests that are unreasonably repetitive, require excessive technical means (such as the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are highly unrealistic (such as requests involving information stored on backup tapes).
We will be unable to respond to your requests under any of the following circumstances:
(1) related to our fulfilment of obligations under laws and regulations;
(2) directly related to public security, public health or major public interests;
(3) we have sufficient proof that you have subjective malice or engage in any abuse of rights;
(4) for the purpose of safeguarding your or other individuals’ life, property or other significant legitimate rights and interests, it is hard to obtain your or their consent;
(5) responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations; or
(6) involving trade secrets.
If you have any questions regarding the exercise of the rights as described above, you can contact us using the contact details as set forth in Section X hereof.
VII. How we process children’s personal information
We have clearly stated in the service premise that we do not accept the registration of any child as defined in the laws of your country or region as our user, and nor do we accept children’s personal information you provide, so you are advised to exercise caution when providing information.
Given the existing technologies and business patterns, it is difficult for us to proactively identify children’s information. If a child’s guardian discovers unauthorized collection of personal information of a child, the guardian may notify us to delete it. If we ourselves discover such situation, we will also proactively delete the information, unless retention of such data is required by law.
VIII. How we update and revise this Privacy Policy
To provide you with better services, our platform and relevant services will be updated and changed from time to time. We will revise this Privacy Policy at the appropriate time. Any revision of this Privacy Policy constitutes a part of, and has the same legal force with this Privacy Policy. Without your express consent, we will not reduce the rights that you should have in accordance with this Privacy Policy.
We will release the updated policy at our official website or by sending an email/message to you. We will also remind you of the updated content in an appropriate manner before the updated terms take effect, so that you can keep informed of the latest version of this Privacy Policy.
Regarding any material change, we will also provide more prominent notifications, including, for certain services, giving notifications by means of email, message or announcement, which describe the specific changes to this Privacy Policy. Therefore, please review and understand the privacy policy with which you should comply at any time. If you disagree with the terms of this Privacy Policy, you shall stop accessing and using our services，otherwise it is deemed that you have accepted the updated Privacy Policy.
The “material changes” referred to in this Privacy Policy include but are not limited to:
1. any material changes in our service mode, such as the purpose of processing personal information, type of processed personal information and how personal information is used;
2. any material changes in our ownership structure, organization structure and others, such as the change of owner due to any business adjustment, bankruptcy, merger or acquisition;
3. the change of the main object which personal information is shared with, transferred to, or publicly disclosed to;
4. any material changes in your rights involved in personal information processing and in how you exercise such rights;
5. the change of our responsible department, contact information and complaint channels for personal information protection; and
6. any high risks as shown in a personal information impact assessment report.
This Privacy Policy and its updates constitute an integral part of the AnyTrans User Service Agreement. AnyTrans reserves all rights not expressly granted under this Privacy Policy.
IX. How you contact us
We would like to resolve any dispute related to data protection practices between you and us. AnyTrans has established a special privacy protection group, and you can raise your questions or seek assistance by sending an email to our privacy protection group (compliance@engagelab.com).
If you have any questions, comments or complaints regarding your account information, personal information or other documentation technologies, or exercise your rights, you can contact us at support@anytrans.ai or using any other specified method. In general, we will respond within fifteen business days.
X. Other legal basis for processing your personal information (only for EEA)
If you are from the EEA, the legal basis for our collection and use of the aforementioned personal information will depend on relevant personal information and the specific context in which we collect it.
However, we generally collect personal information only under the following circumstances: when we need the personal information to perform a contract signed between you and us, when the processing is in our legitimate interests and not covered by your data protection rights and interests or fundamental rights and freedoms, or when we have obtained your consent. In certain cases, we may also have a legal obligation to collect personal information from you, or may need the personal information to protect your or others’ vital interests. For example, we may provide your personal information as required by relevant authorities for public safety purposes or respond to requests from law enforcement agencies.
If you have any questions or require further information about the legal basis for our collection and use of your personal information, please contact us using the contact details as set forth in the Introduction of this Privacy Policy.
Appendix 1: Keyword definition
The specific words used in this policy is defined as follows:
1. We : METAVERSE CLOUD PTE. LTD..
2. Affiliates: it refers to a subsidiary company or other affiliated enterprise within the scope of the consolidated statement with Metaverse Cloud PTE.LTD. company or other entity which controls, is and will be controlled by or is under common control with AnyTrans.
3. Control: means the ability directly or indirectly to influence the management of the company referred to, whether through ownership, voting shares, contracts or other means legally identified.
4. You: means the registered user who uses our products and/or services and the purchaser of the paid service.
5. AnyTrans or this platform: refers to the AnyTrans platform.
6. Personal Information: Information that is electronically or otherwise recorded that can be used alone or in combination with other information to identify a natural person or to reflect the behavior of a natural person.
7. Personal information subject: It refers to the natural person identified by personal information.
8. De-identification: It refers to the technical processing of personal information. The personal information subject cannot be identified without additional information after this processing.
9. Anonymization: It refers to the process of making personal information subject unrecognizable through the technical processing of personal information, and the processed information cannot be recovered.