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Pivot88 Chính sách bảo mật

At Pivot88, our Apps, site and Services are designed with your privacy in mind. We only collect data that is necessary and relevant to providing you with our Services. You should always know exactly what data we collect from you and how we use it. You should always have control over this access too, so you can remove it at any time. We provide you with the tools to decide what information to share with us and provide you with quick and simple ways to get in touch with us.

In the following Privacy Policy, we outline the:

  1.  Information You Share With Us
  2.  Links
  3.  Information We May Share or Disclose (and not)
  4.  What we do not Share
  5.  Pivot88
  6.  Ways to Manage Your Personal Information With Us
  7.  Security of Your Data
  8.  Terms of Use
  9.  Ways to Contact Us
  10.  Changes
  11.  Definitions


1. Information You Share With Us 

We limit the amount of Personal Data we obtain from you to provide the Services, or access to and use of our Apps, Site and Services.


  1. 1   Basic Account Information

For the Pivot88 app (“Apps”), you will need an account (“Account”) with us to use our Services. You will share a small amount of Personal Data, including your email, name and password. You can also choose to add a phone number. Your password is encrypted so nobody can access it. In addition, when you sign up for our App, we store the date and time you created your account, the date you consented to our Privacy Policy and subscription type.


  1. 2   Newsletters

You may be in our mailing list to receive newsletters from us previously. You can among others, opt in from within some of our Apps or on our Site. These newsletters allow us to send emails to subscribers and are linked to certain statistics such as how many people are opening our emails and what people are mostly clicking on. They allow us to improve the kind of content we are publishing or emailing and help us keep in touch with our users about updates on Us, our Services, on the Apps or new releases.

You can quickly and easily unsubscribe at any time, using the unsubscribe link included inside the email. Upon doing so, you will immediately stop receiving emails from us and your details are deleted from our database within thirty (30) days.

Third Party Email Providers can store some personally identifiable information, although we try to keep this to a minimum by only asking for your name and email address. We dislike spam as much as you do and we will never sell-on or share your email address to a third party or an advertiser.


  1. 3   Pivot88 Support

We use information we collect, like your email address, to interact with you directly. For example, you may need to write to us to obtain customer support, when utilizing our Apps and Services. We try to make this a seamless experience for you and respond to all queries as soon as is possible. We may retain the email correspondence together with the information you provide us, to help with the nature of your enquiry, future enquiries and bug fixes. We may also collect certain technical information about your device or cross-reference the basic account information you provided, if appropriate, so that this data is accessible when corresponding with our support team.

We may also send you a notification if we detect suspicious activity, like a suspicious attempt to sign in to your Account. Or we may let you know about upcoming changes or improvements to our services. And if you contact Us, we’ll keep a record of your request in order to help solve any issues you might be facing.


  1. 4   Additional Information We Receive About You

We collect information about our Apps, Site and the browsers and devices you use to access our Apps, Site and Services.

The information we collect includes:

  • Technical information, including the type of mobile device you use, a unique device identifier mobile network information, browser type and settings, device type and settings, operating system, your operating system, mobile network information including carrier name and phone number or time zone setting, and application version number;
  • Log file information such as details of your use of any of our Apps, Services or your visits to our Site, including, but not limited to, traffic data, internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer our Apps, Site and Services, track user’s movements, crash reports, system activity;
  • Cookies, which can be small text files sent by your computer each time you visit our website, or similar technologies to capture log data.

We use data:

  • For analytics and measurement to understand how our Apps, Site and Services are used and to see how you are interacting with them. For example, we can see that a certain Content, page, module or feature is really popular, or that another is rarely viewed or used. This capability allows us to improve the kind of content and functionalities we provide. We also use analytics to measure the effectiveness of our Services;
  • To help improve the safety and reliability of our Apps, Site and Services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm our users, Us, our Apps, Site, Services, or the public

We use different technologies to process your data – including Personal Data – for these purposes. And we analyze your content to help us detect abuse such as spam, malware, and illegal content. We also use algorithms to recognize patterns in data. We may combine the information we collect among our Apps, Site and Services and across your devices for the purposes described above.

We will ask for your consent before using your Personal Data for a purpose that is not covered in this Privacy Policy.


  1.   Links

The links that may appear in our Apps or Site are for your use and reference. We are not responsible for the terms of use or privacy policies on the corresponding websites. You should be aware that the privacy policies of these websites may differ from our own.


  1.   Information We May Share or Disclose (and not)

We do not share your Personal Data with companies, organizations, or individuals outside of Pivot88 except in the following cases:

  • With your consent: we will share personal information outside of Pivot88 when we have your consent. For example, if you are in our emailing list for our newsletter, we may need to share your email address with a Third-Party Service Provider for sending such newsletter;
  • With domain administrators: in order to manage your Account, domain administrators will have access to it. They may be able to:
    • Access and retain information stored in your Account, like your name and email;
    • View statistics regarding your Account;
    • Change your account password;
    • Suspend or terminate your Account access;
    • Receive your Account information in order to satisfy applicable law, regulation, legal process, or enforceable governmental request;
    • Restrict your ability to delete or edit your Personal Data.
  • For external processing: we provide Personal Data to our trusted partners or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use Third Party Service Providers for storage and hosting, and to help us with customer support;
  • For legal reasons: we will share Personal Data outside of Pivot88 if we have a good-faith belief that access, use, preservation, or disclosure of the Personal Data is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request;
  • To enforce applicable terms of Service, detect, prevent and stop potential violations, abuse, or malicious actors on our Apps, Site and Services, including investigation;
  • Detect, prevent, or otherwise address fraud, security, or technical issues;
  • Protect against harm to the rights, property – Including intellectual property – or safety or security of Pivot88, our users, or the public as required or permitted by law;

In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your Personal Data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your Personal Data as transferred to the new entity.


  1. What We do not Share

We will never sell the Personal Data that you provide to Us, including any basic Account information you provide to us, for example name or email.


  1. Pivot88

Pivot88 (Hong Kong) Limited is registered in Hong Kong, with offices at Cyberport 3, Core F, 9th Floor, Room 04, 100 Cyberport Road, Hong Kong, and is an affiliate of Interactive Validated Solutions 88 Inc, in charge of operational matters. The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by staff operating outside Hong Kong who work for Us or a Third-Party Service Provider we collaborate with.

By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

However, nothing in this Privacy Policy is intended to limit any legal challenge or objections that you may have to a third party’s, including a government’s, request to disclose your Personal Data.


  1.   Ways to Manage Your Personal Information with Us

You control the Personal Data you share with us. You can request access or rectification of this Personal Data at any time. Where necessary, you can also request deactivation or closure of your Account. We also provide you tools to object, restrict, or withdraw consent where applicable for the use of Personal Data you have provided to Us, by emailing is at [email protected]. And we make the Personal Data you shared through our services portable, accessible by simple request at the above email address.


  1.   Security of Your Data

We are committed to ensuring the security of your Personal Data, which means choosing legal and security compliant Third-Party Service Providers and maintaining strong internal procedures. These procedures include maintaining the appropriate disciplinary procedures to enforce our employees’ privacy responsibilities, testing and improving the effectiveness of our security measures on an ongoing basis, as well as restricting access to Personal Data to those employees who need to know that information in order to provide Services to you. In the event of a data breach we will inform you.


  1.   Terms of Use

You must be at least 16 years of age to register an Account or to use our Apps or Services. Our Services and Content have not been developed for and are not directed to children or individuals under the age of 16. You must also be old enough to consent to the processing of your Personal Data in your country.


  1.   Ways to Contact Us

If you have any queries or concerns whatsoever regarding this privacy policy, or need to speak to our Data Protection Officer, please contact us at [email protected].


  1.   Changes

We reserve the right to change this Privacy Policy at any time. We will do our best to keep you up to date with any changes by adding a notification inside our Apps, newsletter or Services. Your continued use of our Apps or Services or continued use of our Site, or subscription to our newsletter following the posting of changes to these terms will be acknowledged as your acceptance to those changes. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published, and we offer access to archived versions for your review.


  1.  Definitions
  • Apps– The software applications developed and sold or provided free of charge, as the case may be, by Pivot88 under their account(s) on the Apple iTunes App Store.
  • Content– Information, including but not limited to designs, pages, screens, text, graphics, images, video, opinions, information and other material.
  • Personal Data– Any information relating to an individual person who can be directly or indirectly identified in particular by reference to an identifier.
  • Services– our products and associated services that our users see and experience, that have been developed by Pivot88.
  • Site– The Pivot88 website, accessible at pivot88.com, and the Pivot88 Web platforms for access to and use of the Services
  • Third Party Service Provider– An independent company contracted by Pivot88 to provide a service on behalf of our company, including but not limited to storage or hosting.


Last updated: 14th of December 2018