Echo Room Privacy Policy

Privacy Policy

Last updated: December 25th, 2024

DOL Internet Information Pte. Ltd. (“Company”, “we”, “us” or “our”) operates the application of Echo Room and provides the services available to you on the Echo Room (“Service”).

In the Privacy Policy, we explain how we collect, use, share, retain and transfer information. We also let you know your rights.

PLEASE READ THIS POLICY CAREFULLY AS IT DESCRIBES OUR PRIVACY POLICIES AND PRACTICES. IF YOU DO NOT AGREE WITH OUR PRIVACY POLICIES AND PRACTICES, DO NOT DOWNLOAD, INSTALL, REGISTER WITH, OR USE THE SERVICE.

BY DOWNLOADING, INSTALLING, REGISTERING WITH, OR USING THIS SERVICE, YOU WILL BE REQUIRED TO CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO COMPLY WITH THIS POLICY.

OUR CONTACT INFORMATION

DOL Internet Information Pte. Ltd.

718A GEYLANG ROAD SINGAPORE (389630)

If you have any questions about how we use your personal data, please contact echoroom@global-app.net.

PERSONAL DATA WE COLLECT

We must collect some of your personal information to provide, support, improve, and market the Service. Some of the ways that we may collect personal information includes the followings.

(i) Personal Data You Provide

Your Account Information. You must provide your mobile phone number and basic information (including a profile name of your choice) to create an Echo Room account. If you don’t provide us with this information, you will not be able to create an account to use our Services. You can add other information to your account, such as a profile picture and “about” information.

Customer Support And Other Communications. When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of our Services, including copies of your messages, any other information you deem helpful, and how to contact you (e.g., an email address). For example, you may send us an email with information relating to app performance or other issues.

Preferences. When you set your preferences using your settings, we collect that information so that we can respect your preferences.

(ii) Personal Data We collect

Usage Information. We collect information about your activity on our Service including:

Purchase and payments. To allow you to make a payment using our features or services, including through an intermediary, we may receive information about your transaction such as when it was made, your payment method and amounts paid.

Device Information. We collect information from and about the devices you use to access Echo Room, including:

Location Information. When you use our Service, we collect some information about your approximate location to provide the service you expect, including showing you relevant ads. You can also choose to share your current precise location or places by enabling these settings in your account.

Log Information. We may receive information when you view content on or otherwise interact with our Services, even if you have not created an account or are signed out, such as:

Advertisements. When you view or interact with ads we serve on or off Echo Room, we may collect information about those views or interactions (e.g., watching a video ad or pre-roll, clicking on an ad, interacting with reposts of or replies to an ad).

Cookies and similar technologies. Like many websites, we use cookies and similar technologies to collect additional website usage data and to operate our services. Cookies are not required for many parts of our products and services such as searching and looking at public profiles. You can learn more about how we use cookies and similar technologies here.

Interactions with our content on third-party sites. When you view our content on third-party websites that integrate our content, such as embedded timelines or post buttons, we may receive log information that includes the web page you visited.

DO NOT PROVIDE SPECIAL CATEGORIES OF PERSONAL DATA

Please do not send us, and do not disclose, through our Service, any “special categories of personal data” as defined in the GDPR (information related to racial or ethnic origin, political opinions, religious or physiological beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership or data concerning data subject's sex life or sexual orientation).

If you are an EU resident, should you provide “special categories of personal data” using our Services, you understand that you have expressly consented to the collection, use and disclosure of such data in accordance with this Privacy Policy.

WHAT'S PUBLIC AND WHAT'S NOT?

Information you voluntarily transmit via our Services is publicly accessible and may be viewed and used by others without any restrictions. We do not control such uses of your personally identifiable information when you share with third parties using our Services. By using our Services, you assume the risk and acknowledge that the personal data provided by you may be viewed and used by third parties and by us for any number of purposes.

Your user profile and most of the content you create when using our Services, such as your moments, public chats, posts, as well as your fanning and gifting activity is publicly displayed to other Echo Room users. Most of the data that Echo Room collects about your Echo Room activity (“metadata”) is not publicly available. The number of Diamonds you hold is also not made publicly available, but other users may be able to see that you hold some Props. 

HOW WE USE PERSONAL DATA

Breaking down how we use the information we collect is not simple because of the way the systems that bring our services to you work. For example, the same piece of information may be used differently for different purposes to ultimately deliver a single service. Below are the purposes for which we will use your Personal Data:

To install the App and register you as a new App user;

To process in-App purchases and deliver Services including managing payments and collecting money owed to us;

To manage our relationship with you including receiving and responding to your feedback and notifying you of changes to the App or any Services;

To enable you to participate in a prize draw, competition or complete a survey;

To administer and protect our business and this App including troubleshooting, data analysis and system testing;

To deliver content and advertisements to you;

To make recommendations to you about goods or services which may interest you;

To measure and analyse the effectiveness of the advertising we serve you;

To monitor trends so we can improve the App;

To prevent activities we determine to be potentially illegal, harmful or not in the public interest; 

DISCLOSURE OF PERSONAL DATA

Although Echo Room makes every effort to preserve user privacy, we may need to disclose personal data as detailed below. These are also the categories of third parties with whom we have disclosed personal data:

Regulatory or Legal Requirements. We may need to disclose your personal data in response to a subpoena, regulatory investigation or court order, or to law enforcement authorities or regulators who have demonstrated their lawful authority. We may also disclose personal data for the public interest or in good faith to prevent harm to individuals. Keep in mind we also share personal data with trusted third parties in order to effectively provide our Services to users.

In addition to responding to law enforcement or regulator requests for personal data, Echo Room will disclose personal data to report suspected illegal activity. For example, we may share certain information to the extent necessary with the National Center for Missing and Exploited Children when we discover or receive report on some child sexual abuse materials on our platform.

We may also disclose personal data to enforce our policies or respond to claims that any content violates the right of others. In all cases, such information will be disclosed in accordance with applicable laws and regulations.

Service Providers. Echo Room may also share your personal data with third parties performing services on our behalf that have agreed to keep such information confidential (for example, payment services providers those that provide fraud detection services). 

Affiliates. Our affiliates may also have access to Users’ personal information for the purposes set out in this Privacy Policy.

Merger and Acquisition. We may also transfer Users’ personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.

INTERNATIONAL TRANSFERS

The personal data we collect may be transferred to, stored at and processed by us and our affiliated third parties outside of the country in which you reside.

When transferring your personal data to our group companies outside of the jurisdiction in which you reside, we ensure your personal data is protected by requiring all our our group companies follow the same rules when processing your personal data.

Whenever we transfer your personal data to external third parties outside of the jurisdiction in which you reside, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

SECURING PERSONAL DATA

Echo Room has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful processing of the data we collect. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by our Services reduce the likelihood of a data security breach.

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your account by ensuring no one else uses your computer or mobile device when you are logged in, by logging off from our Services when not in use and by keeping your passwords confidential.

Here are some examples of the data security controls in place at Echo Room (this is not an exhaustive list):

NOT FOR CHILDREN UNDER EIGHTEEN

This Service is a general audience Service, which is neither designed nor intended to collect personal data from children who are under the age of eighteen (18). We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that Personal Information of persons under 18 has been collected on or through our Services, we will take appropriate steps to delete this information. If you believe that we have inappropriately collected Personal Information from young user under 18, please contact us at echoroom@global-app.net.

ACCURACY OF INFORMATION COLLECTED

Echo Room wants to keep the personal data we store about you as accurate and complete as possible. We rely on the user to provide accurate information and we also have protocols in place to promote data integrity.

The information that we collect from you is the same information that you have previously provided to Facebook, Google or relevant portions thereof. By updating the information in one of these social media accounts, you may be automatically updating the information in your Echo Room account the next time that you log in. You can access and modify your Echo Room account information directly by logging into Echo Room and clicking the Help function, as well as make any changes to any express consents that you may have given with respect to us contacting you for Echo Room news or promotions.

RETENTION AND STORAGE OF THE INFORMATION WE COLLECT

We will retain your information as long as you are an active Echo Room user, to permit us to use it for the purposes that we have communicated in this Privacy Policy. Echo Room has implemented retention schedules to avoid indefinitely storing personal data that has been collected indirectly (for example, about an Echo Room user's social connections).

Personal data that is no longer required for administrative or business purposes, and that does not need to be archived by Echo Room, will be overwritten or scrambled such that it no longer identifies an Echo Room user. We may in some circumstances use such scrambled or agrregated data (which no longer identifies the Echo Room user) indefinitely without further reference to you for research or statistical purposes.  Keep in mind that third parties who store data on our behalf have their own retention rules.

YOUR RIGHTS

Some jurisdictions’ laws grant specific rights to Echo Room users, which are set out in this section. You may have all or some of the following rights set forth below according to applicable laws. We will respond to your request consistent with the applicable laws as soon as practicable, normally within one month, after proper verification procedures. Your exercise of these rights is usually free of charge, unless we deem it is chargeable under the applicable laws.

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Withdraw Consent to processing your personal data, at any time, where the processing is based on your consent. If you do that, we will still process certain information on legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.

Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.

Right to Restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

Right to Opt-out. You can opt-out from receiving interest-based advertising or behavioural advertising on supported devices following the guideline below.

Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device, we will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.

Your mobile web browser may also provide a “Do Not Track” browser setting. When you have enabled this setting in your browser, we will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests.

You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the NAI (https://optout.networkadvertising.org/) or for users in the European Economic Area, the EDAA opt-out portal at http://www.youronlinechoices.eu/. You may still receive ads after limiting processing of information for interest-based advertising, but those ads may be less relevant to your interests.

ACCEPTANCE OF THIS PRIVACY POLICY

By using our Services, accessing our App, you are consenting to the practices relating to personal data collection and use that are described in this Privacy Policy.

Please note that our Services are controlled and offered by Echo Room from its facilities in Singapore. The laws of other countries may differ regarding how personally identifiable information must be handled by Echo Room. Echo Room makes no representations that our Services are appropriate or available for use in other locations. Those who access or use the Service from other jurisdictions do so at their own volition, and consent to Echo Room's collection, storage and use of their personally identifiable information as set forth in this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time in order to better reflect our current data handling practices. Thus, we encourage you to review this Privacy Policy frequently. The “Last Updated” date above indicates when this Policy was last changed.

Any material change to this Privacy Policy will be clearly displayed on App. Personal data collected by us will be dealt with in accordance with the provisions of our Privacy Policy which were in effect at the time of collection. Your continued use of our Services following the posting of any changes to this Privacy Policy means you accept such changes. Should you not agree, you should no longer use our Services and go to your Privacy Settings to terminate your account.

FOR USERS IN THE EUROPEAN UNION

If you are in the EU, you have the rights under the GDPR:

If you wish to exercise any of rights herein or under GDPR, contact us at echoroom@global-app.net. or use Help or Feedback function on Echo Room.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

FOR USERS RESIDING IN U.S.

if you are a California resident or a resident of U.S. states that have enacted comprehensive consumer privacy laws including Colorado, Connecticut, Virginia and Utah, you may request to know, disclose, access, correct or delete your data, collected in the last 12 months. If you wish to request information about the collection of your personal information, please send an email to us via echoroom@global-app.net. If you wish to delete your personal information, please send an email to echoroom@global-app.net. or you may request deletion of your account on the setting page.

Please note that certain information may be exempt from such requests under California law and that, depending on your data choices, certain services may be limited or unavailable.

No sale of personal information. In the twelve months prior to the effective date of this Disclosure, Echo Room has not sold any personal information of you, as those terms are defined under the California Consumer Privacy Act.

No discrimination. Echo Room will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.