Privacy Policy

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.

1. Information We Collect and How We Collect It
   
   We collect information from and about users of our Xiaoman Platform: Directly from you when you provide it to us and Automatically when you use the Xiaoman Platform.

   a. Information You Provide to Us

   When you install, launch, access and/or use the Xiaoman Platform on your mobile device, whether by downloading it from a mobile application store or using Xiaoman Platform that is pre-installed on your mobile device, we may ask you to provide certain account information, content/category preferences, network preference, name, age, gender, location, areas of interest, language, region preferences etc. in order to customize the experience for you. Some of these data sets may be considered to be personal information, in which case, we ensure compliance with applicable privacy laws in our collection, processing or use of the same, to the extent applicable in such jurisdictions including certain data subject rights that you may enjoy under such applicable laws. We do not collect sensitive information such as biometric data, sexual preference, medical information, credit card and other banking related information, etc.

   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: 

   • Usage Details. When you access and use the Xiaoman Platform, we may automatically collect certain details of your access to and use of the Platform, including interaction data, logs, and other performance data and the resources that you access and use on or through the Platform, stories/videos/content you read, view, watch, interact with or otherwise access.
   
   
   • Device Information. We may collect information about your device and internet connection, including but not limited to, the one way hashed unique device identifier shared by OEMs, advertising identifier, IMEI, GPID, GAID, device make, IP Address, display features, operating system, browser type, mobile network information. Some of these data sets may be considered to be personal information and in which case, we ensure compliance with applicable privacy laws in our collection or use of the same, to the extent applicable in such jurisdictions.
   • Location Information. The Xiaoman Platform collects information about the location of your smart device if you grant it permission to do so. You can choose whether or not to allow the Xiaoman Platform to collect information about your device’s location by turning off the location settings on your device. If you block the use of location information, some parts of the Xiaoman Platform may then be inaccessible or not function properly.
   • Usage of the device in general: The Xiaoman Platform may collect data related to your access of other apps/widgets, etc. used, by you, if you grant it permission to do so, to the extent such permission is required under privacy laws applicable in such jurisdictions.

   • Third party data: This is information provided by our partners such as device manufacturers or carriers or telecom partners issuing smart devices, other application developers, data enrichment partners etc. The information provided in those cases follows the respective privacy policies of such third parties.

   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:

   • Cookies or pixels (or mobile cookies/pixels). A cookie is a small file placed on your smart device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smart device. However, if you select this setting you may be unable to access certain features of the Xiaoman Platform.
   • Web Beacons. Pages of the Xiaoman Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Xiaoman, for example, to count users who have visited those pages or for other related statistics (for example, recording the popularity of certain application content and verifying system and server integrity).

   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.

2. How We Use Your Information
   
   We may use information that we collect about you or that you provide to us, to:

   a. Provide you with the Xiaoman Platform features and its contents, such as location-based news, events, featured stories, offers, products or services and any other information.
   b. Provide advertisements and promotions that may be of interest to you or to run survey campaigns including targeted advertisements and monetization activities through Xiaoman Platform and/or advertising channels of its Affiliates or media partners.
   c. Notify you about your subscription to the Xiaoman Platform, including expiration and renewal notices.
   d. Notify you when any relevant Xiaoman Platform updates or upgrades are available and requires notification.
   e. Estimate our audience size and usage patterns.
   f. Speed up your searches.
   g. Frequency capping of content displayed.

   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.

3. 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:

   a. To our key shareholders, Board, subsidiaries and Affiliates for lawful purposes. “Affiliate” as used herein means, with respect to Xiaoman, an entity that directly or indirectly controls, is controlled by or is under common control with Xiaoman.
   b. If an advertisement or monetization transactions are made available to you through advertising channels of Xiaoman and/or its Affiliates, Xiaoman may share your data obtained by Xiaoman with such Affiliates for such advertising purposes.
   c. To contractors, customers, data partners, brands, measurement companies, service providers, and other third parties we engage with for providing the Xiaoman Platform and its services.
   d. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, due diligence, financing, acquisition, or other sale or transfer of some or all of Xiaoman assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Xiaoman about Xiaoman Platform users is among the assets transferred.
   e. To third parties to market their products or services to you if you have not opted out of these disclosures.
   f. To fulfil the purpose for which you provide it.
   g. For any other purpose disclosed by us when you provide the information or for purposes stated in this policy.
   h. With your consent.
   i. To comply with any court order, law, or legal process, including to law enforcement authorities and legal advisors or to respond to any government or regulatory request.

   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.

4. 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.

   a. Location data collection: You may opt out of the location data collection by Xiaoman Platform by turning off the location settings on your device. Note, however, that opting out of the Xiaoman Platform’s collection of location information will cause its location-based features to be disabled.
   b. Interest-based advertising: You can opt out of receiving certain targeted ads by visiting the third parties’ websites; however, please note that these links may not reach all of our advertising partners and certain advertising may still be displayed to you. If you want to be certain that no interest-based advertisements will be sent to you, please use “Opt out of interest-based ads” on your Android device or “Limit Ad Tracking” on your iPhone or iPad or such other opt-out mechanisms made available on your Device. Please note that if you opt-out of interest-based advertising you will still receive “generic” ads from Xiaoman.
   c. Surveys: Each survey that you participate in would provide for clear opt-out instructions including option to skip, which if elected will ensure that we do not include your device for that very survey Please note that if you opt-out of a survey you will still receive other survey requests.
   d. Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent or use your settings to disable certain features or opt out of targeted advertising etc. If you so disable or refuse cookies or block the use of other tracking technologies, some parts of the Xiaoman Platform may then be inaccessible or not function properly.
   

5. 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.

6. 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.

7. 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.

8. 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 .

9. 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.