LAST UPDATED: MARCH 2020
EFFECTIVE: MARCH 2020
Xiaoman Inc. (Xiaoman or We) respects your privacy and is committed to protecting it through our compliance with this policy. Please read this policy carefully to understand our practices regarding your information. By installing, subscribing to, accessing or using the Xiaoman Platform, you agree to this privacy policy.
This policy describes (i) the types of information we may collect when you install, subscribe to, access, and/or use the features of Xiaoman Platform; (ii) the types of information we may collect or that you may provide when any advertisement or survey campaign is displayed on Xiaoman Platform or as part of your interaction with any advertisement services provided by Xiaoman or its’ Affiliates, the information collected pursuant to any in-app purchases or transactions made by you; (iii) how we use that information, and the purposes for which we collect it; and (iv) how we disclose such information. As used in this Privacy Policy, “Xiaoman Platform” means and refers to Xiaoman’s proprietary platform (application/software/website/feature or as made available in any other format) which enables end-users to explore and discover content or services through lock-screen including interesting stories, news, events, games, advertisements, products etc. as they unlock their phone. The platform also enables partners to display their content (including advertising, games, promotional, entertainment or informational content) on mobile/smart devices of the end users and sites.
This policy applies only to information we collect through the Xiaoman Platform and in email, text, and other electronic communications sent through or in connection with the Xiaoman Platform. It does not apply to information that we may obtain from other sources (other than Xiaoman Platform) who provide your information based on their privacy policies and your interaction with their offerings. Xiaoman Platform may also be permitted to collect certain information about you from the websites, applications, channels, services or landing pages (“Sites”) you access through Xiaoman Platform by the provider/owner of such Sites, in which case, we will treat such information in accordance with the privacy policies of such Sites in addition to this policy, subject to the terms of the former. This policy does not apply to websites or landing pages you may access through the Xiaoman Platform, nor does it apply to information that you provide to or that is collected by any third party. We encourage you to read any such non-Xiaoman Platform terms, conditions, policies, notices etc. before providing information on or through them including Sites.
For Xiaoman Platform that is made available as a pre-loaded feature or widget within an application or on a smart device, please note that, the provider of the device may incorporate relevant terms of this policy within their own privacy policies or provide for a different version of the Xiaoman platform privacy policy and make the same available to you. Please refer to the settings page of your smart device, or the terms of use of the application in which Xiaoman is bundled to find the relevant privacy policy.
Xiaoman assumes no responsibility for any third-party landing pages you access or your direct interaction with any third party including advertisers, e-commerce partners, reward partners or payment facilitators if you elect to engage with any content such as specific advertisement, product purchase or survey campaign displayed through Xiaoman Platform; we recommend that you review the privacy policies of such third parties that you interact with.
a. Information You Provide to Us
Where you elect to engage with any games through the Xiaoman Platform, you may participate in certain reward-based programs. We urge you to refer the terms and conditions of such participation and the respective policies of any reward partners whom you may interact with.
Xiaoman Platform is meant for general audience and is not targeted towards users below 18 years of age, therefore, we do not knowingly request access to, collect or process personal information of any such user.
b. Automatic Information Collection and Tracking
When you access, and use the Xiaoman Platform including when you view any advertisement or interact with survey campaign displayed on the Xiaoman Platform, it may use technology to automatically collect:
We may also use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).
In the context of advertising displayed on Xiaoman Platform, our customers, partners or vendors (“Ad-Third Parties”) may also disclose to us certain personal or non-personal information they have separately collected about you so that we can effectively provide our services. They do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements and, we will treat such information in accordance with the privacy policies of such Ad-Third Parties in addition to this policy, subject to the terms of the former. We do not use the information they provide to us for any purpose other than for providing or improving our services.
c. Information Collection and Tracking Technologies: The technologies we use for automatic information collection may include:
d. Third-Party Information Collection: When you use the Xiaoman Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include advertisers, ad networks, e-commerce partners, reward partners or payment facilitators, ad servers, attribution partners and analytics companies, your mobile device manufacturer and/or your mobile service provider etc.
These third parties may use tracking technologies to collect information about you when you use the Xiaoman Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. While we contractually require all our partners to comply with applicable privacy laws, please note that we do not control these third parties’ tracking technologies.
Xiaoman Platform may facilitate promotion of certain products or services. If you elect to purchase, the providers of such products or services (e-commerce partners or other advertiser partners) may ask for your information such as name, email, phone number, shipping address etc. and may further engage other payment partners for processing such transactions. Such payment partners may also obtain your information as part of such processing. While we contractually require all our partners to comply with applicable privacy laws, please note that we do not control these third parties’ data processing practices. We encourage you to read their terms, policies, notices etc. before providing information. Further, such partners may share certain transaction data with Xiaoman such as transaction ID, status, product, checkout price, timestamp. For avoidance of any doubt, Xiaoman does not provide any payment related services.
e. Information about advertisements presented on your Xiaoman Platform: Xiaoman also collects some or all of the following information about an ad presented on your device: (i) the content type of the ad (what the ad is about, e.g. games, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the site on which the ad appears); and (iv) certain information about post-click activity in relation to the ad including user interaction with such ad.
f. Information provided through surveys displayed on your Xiaoman Platform: Xiaoman Platform may display certain marketing surveys or survey related applications to users such as yourself where you are requested to fill in a survey for services or products that you use or request provide your opinion regarding certain products or services. Where you participate in our marketing or opinion-based surveys, you may voluntarily elect to provide certain data such as your age, name, email address, phone number, gender, income range, family size, occupation, preference for brands, modes of travel, choice of food or such other consumer choices. These surveys help the brands improve their products and services offered to you. Certain surveys may also provide certain reward options for your valuable feedback as clearly articulated in such surveys. To the extent any such information may be considered to be personal information, we ensure compliance with applicable laws in our collection or use of the same, to the extent applicable or required in such jurisdictions including certain data subject rights that you may enjoy and implement reasonable technical measures to ensure prevention of unauthorised disclosure of such personal information in our custody.
How We Use Your Information
We may use information that we collect about you or that you provide to us, to:
The information we collect helps us to improve our services, attribution and to deliver a better personalized experience which may include interest-based advertising customised to individuals’ inferred interests, preferences and locations and to perform analysis aimed at improving your user experience.
Advertisements may be customised to the users’ interests and geographic locations, which Xiaoman may derive or infer from information that it collects about how those users interact with such sites, over the top applications and apps (this type of advertising is often called “interest-based advertising” or “targeted advertising”). The information Xiaoman collect from your device also helps to provide filtering options to manage ads appearing on the Xiaoman Platform, and to provide targeting options for advertisers. Further, Xiaoman may also obtain user data from our data partners, advertisers and/or advertisers’ partners for optimising digital advertising and/or analytical purposes including to provide relevant advertising and reporting.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose information that we collect, or you provide:
j. To execute our obligations and enforce our rights arising from or in relation to any contracts including with respect to billing, collection, disputes.
k. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Xiaoman, its Affiliates, our customers or others.
You acknowledge that some of the recipients of your information may be located outside your country of residence. Where we transfer your information to such third parties, we will endeavour to ensure that your information remains secure from unauthorized disclosure or theft. To the extent required under data privacy laws of the applicable jurisdiction, we may transfer such information pursuant to consent or through applicable data protection agreements or other mechanisms permitted under such laws.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information. You may elect to uninstall or unsubscribe from the Xiaoman Platform. In the event, the Xiaoman Platform is pre-loaded in your mobile device, please visit the settings page on your device to disable ‘Xiaoman’ or ‘Xiaoman Experience’ as made available in the such settings page.
Data Security
We have implemented commercially reasonable measures designed to protect the security of your personal information.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted through the Xiaoman Platform. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Data Retention Period
Xiaoman may retain the information relating to your device collected for a period of up to 36 months, unless otherwise required by law or applicable contract.
Xiaoman may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey, Xiaoman will only retain your personal data for as long as necessary to fulfil the purposes it collected it for.
After the applicable retention period, Xiaoman may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes (including billing) and enforce agreements.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users’ information, we will post the new privacy policy on this page and attempt to notify you.
The date the privacy policy was last revised is identified at the top of the page. Subject to requirements of express consent under any applicable data privacy laws which we comply with, your continued use of the Xiaoman Platform after we make changes is deemed to be acceptance of those changes, so please check the applicable policy(ies) periodically for updates.
Contact Information
To ask questions, exercise applicable data subject rights or comment about this privacy policy and our privacy practices, please e-mail us at privacy@Xiaoman.com .
To the extent you may enjoy any data subject rights as per privacy laws applicable to you, you may reach out to our data protection office at dpo@inmobi.com .
Order of Prevalence:
Subject to applicable laws, the English language version of this policy will prevail over any other language version issued by us for your benefit.