Privacy Policy
Updated: January 07, 2025
Effective : January 07, 2025
Update Tips:
This version updates the content in accordance with the Personal Information Protection Law, the Law on the Protection of Minors, the Child Safety Standard Policy, and other relevant laws and regulations, and mainly revises “Article 5” to more clearly and explicitly inform you of how we handle children's information and protect minors.
Sada (hereinafter referred to as "we") attaches great importance to the privacy and protection of personal information, and we appreciate your trust in us. We will take appropriate security measures in accordance with legal and regulatory requirements, and endeavor to guarantee the security of your personal information. In view of this, we have made this Privacy Policy (hereinafter referred to as the "Policy" / "Privacy Policy") to explain to you how we collect, use, store, protect and provide your publicize information, and explain your rights.
This policy applies to the software developed and operated by Hong Kong Said Technology Co, Limited, and also applies to other Internet products developed and operated by Hong Kong Said Technology Co., Limited and its affiliates, except that the other products independently set privacy policies and make different provisions for the collection, use and protection of user information, However, if other products have their own privacy policies and have different provisions on the collection, use, storage and protection of user information, the provisions of those products shall apply. This Privacy Policy does not apply to services provided to you by other independent third parties, and this Privacy Policy does not apply to personal information you provide to third parties on our platform when those third parties rely on our platform to provide services to you.
Before using our products or services, please be sure to read and fully understand this Privacy Policy, especially the terms identified in bold, which may involve your important rights, you should focus on reading, after confirming that you fully understand and agree to use the relevant products or services. If you use the products or services provided by us, it means that you have fully understood and agreed to the contents we stated in this policy.
This policy will help you understand the followings：
Article 1 How we collect and use your personal information
Article 2 How we use cookies and similar technologies
Article 3 How we share, transfer, and publicly disclose your personal information
Article 4 How we protect your personal information
Article 5 How we handle minors' personal information and protect minors
Article 6 How your personal information is transferred worldwide
Article 7 Your Rights
Article 8 How this policy will be updated
Article 9 How to contact us
Article 1 [How we collect and use your personal information]
We collect and use your personal information in accordance with the principles of lawfulness, legitimacy and necessity in order to fulfill the features described below in this policy, and when it comes to the sensitive information we may collect , we will bring to your attention by bolding and underlining the followings:
Personal privacy information refers to information involving the user's personal identity or personal privacy, such as the user's real name, ID card, gender, cell phone number, cell phone device identification code, IP address, user chatting records, bank card number, and other such information that can identify the identity of a specific person through the electronic information network technology, either alone or in combination with other information; non-personal privacy information refers to the user's operational status of the Service and the use of habits and other basic record information clearly and objectively reflected on the Sada server, and other general information outside the scope of personal privacy information, as well as users agree to disclose the above privacy information.
We will collect information in accordance with the principles of legality, legitimacy and necessity. The information we collect or ask you to provide will be used to
1. Ensure the implementation of the basic features of the application;
2. Optimize application and improve services.
3. Guarantee the safety of applications, services and users.
4. Follow the provisions of laws and regulations.
Sada will only collect and use your personal information for the following purposes as described in this policy.
(i) Providing you with online services of application
1. Register as a user
In the process of registering for an account or using the Service, users are required to fill in or submit some necessary information: your phone number, nickname, gender,etc. This information is collected to help you complete the Sada account registration, and you need to read and agree to this Policy and the User Agreement before completing your account registration.Once you have registered, you will be able to use real-time voice, sending features and other features on Sada as a registered user. If you do not agree to authorize or refuse our access to the above information, you will not be able to use the features and services of Sada. During the registration process, if you provide the following additional information, it will help us to provide you with better services and experience: avatar, nickname, gender, personal statement, country and region. However, if you do not provide these information, it will not have an effect on the basic features.
2. When you register or log in to Sada through a third-party account (like Facebook, Google), you need to authorize us to obtain the public information (including avatar, nickname, gender) of the third-party account you use to log in, and to bind the account to your Sada account. If you do not agree to authorize or refuse to allow us to obtain the above information, you will not be able to register or log in to the Sada through the third party account, but it will not affect your normal use of other features of application.
(ii) Providing features or services related to top-up consumption
When you use the consumption features of Sada, we will collect your recharge record and consumption record information, so that you can check your own transaction records. We will try our best to protect your property and virtual property to the greatest extent. The above information is sensitive information, but the collection of the above information is necessary for the use of the relevant features, otherwise it will not be able to complete the transaction.
(iii) Personal information related to the use of some features of the application
Only when you authorize Sada for the implementation of some certain features , will Sada temporarily collect the relevant information. The text, image, voice and video you upload will be stored on our servers, as storage is necessary to implement the relevant features. You can delete the information at any time. We will not make the information available to the public or use it for purposes other than the relevant features, unless you have chosen to do so or unless we are required to do so by law or regulation. Please note that the information you publicly post may involve your or others' personal information or even sensitive personal information. If you choose to upload images that contain personal information, please consider more carefully whether to share or even publicly share the relevant information when using our services.
(iv) Provide personalized recommendation, display or push services
When you use Sada, we collect the following information about you.
1. Follow, search, browse preferences and other information about your operation and usage behavior.
2. Feedback, posting, liking, sending, and other information that you willingly provide will be stored in our servers, as the storage is necessary to implement these features.
3. Location information with your express consent, this information is sensitive information. Refusal to provide this information will only prevent you from obtaining better services, but does not affect your use of other features.
(v)Provide the third-party services
The third-party services in Sada are provided by the third parties outside Hong Kong Said Technology Co, Limited , and Sada is unable to acquire the information generated during your use of such services. A third party may access your information via Sada's APIs upon your explicit authorization. Refusing to provide such information may result in your inability to use the above third-party services, but will not affect your use of Sada’s features.
The Service Provider may process your personal information without seeking your authorized consent in the following circumstances:
a) The information is required for the personal information controller to fulfill their obligations imposed by laws and regulations;
b) The information is directly related to national security or national defense;
c) The information is directly related to public safety, public health, or major public interests;
d) The information is directly related to a criminal investigation, prosecution, trial, or execution of judicial decisions;
e) The collection and use of your information are necessary to protect your or other individuals' legitimate rights and interests, life safety, and property safety and your authorization for collecting such information cannot be obtained for some reason;
f) The information has been made public by yourself;
g) The information is required for entering into and/or fulfilling a contract to which you are either of the parties;
h) The information has been made publicly available in legitimate news coverage, governmental announcements, and other public channels.
i) The information is required for ensuring the safe and stable operation of the provided products or services, such as identifying and/or fixing failures of such products or services;
j) The information is necessary for the legitimate news coverage of the personal information controller which is a news agency;
The main third-party SDKs used by the Sada app are listed below:
(vi) Guarantee the implementation of product features and stable operation
We may request or use permissions related to the operating system.In order to give you a better understanding of these, we will list the relevant operating system permissions that may be requested and used by the product and make further explanation.
Please be aware that we may use third-party software development kits (SDKs) for business and product functionality and security purposes, and that these third parties may also apply for or use your operating system permissions.
The application and use of operating system permissions may change as products are upgraded.We will promptly update these instructions to take account of these changes to ensure that you are kept informed of the application and use of permissions;
In the listed permissions or scenarios, a pop-up window will be displayed to ask for your permissions, and we will not access to them without your permissions.
1.READ_MEDIA_IMAGES
Purpose: to read the image files on your device to customize personalized content.
Scenario: Customize your avatar, personal homepage album,chatting room background, etc.
2.READ_MEDIA_VIDEO
Purpose : to read video files on your device to customize personalized content
Scenario: upload customized gift in chatting rooms
3.READ_MEDIA_AUDIO
Purpose : to read audio files on your device to customize personalized content
Scenario: upload music in chatting rooms
4.READ_EXTERNAL_STORAGE / WRITE_EXTERNAL_STORAGE
Purpose: Read or write to your device's external storage, used by Android SDK 33 or below, or above.
Scenario: Same as READ_MEDIA_IMAGES, READ_MEDIA_VIDEO, READ_MEDIA_AUDIO respectively.
6.READ_PHONE_STATE
Purpose : to obtain basic information about your device to statistically analyze and provide better service
Scenario:opening or staying at the homepage
7.RECORD_AUDIO
Purpose : to turn on your microphone
Scenario: chatting in voice rooms, sending voice in private talks, customizing voice signature, etc.
8.CAMERA
Purpose : to turn on your camera
Scenario: uploading customized avatar, uploading room background , uploading pictures to the album etc.
9.POST_NOTIFICATIONS
Purpose : for pushing notification messages to your device
Scenario: System Notification
This permission is off by default and is not requested, you need to turn on the notification settings on your own initiative.
The user information and device information obtained from the above permissions will only be used within the application and will not be shared with third parties.
(vii) Devices identification and safety
Sada app collects identifying information about your commonly used devices, such as Android ID, which is used to link the device with account information, ensuring that only specific users logged in on a specific device have access to proprietary data, such as sending new users with additional benefits. Device identification is used for accurate sending as well as anti-cheating purposes.
We have set up strict access control mechanisms in the application. Device IDs are used only in essential functional modules, and we conduct regular security reviews of the relevant code to ensure that the use of device IDs meets the highest security standards.
We attach great importance to your privacy, and we use advanced encryption technology to store the acquired device identifiers and encrypt them during data transmission to keep them from being accessed or used in an unauthorized manner.
We solemnly commit that we will not share your device identification with any third-party organization or individual, and that your device identification information will be used strictly in Sada app.
Article 2 [How we use cookies and similar technologies]
In order to make your access experience easier, when you use Sada products or services, we may collect and store data related to your access to Sada services through the use of a variety of technologies, so that we can identify you when you visit or re-visit Sada services and analyze the data to provide you with better and more services. This includes the use of small data files to identify you in order to understand your usage habits, to save you from having to repeatedly enter your account information, or to help check the security of your account. These data files may be cookies, flash cookies, or other local storage provided by your browser or associated applications (collectively, "Cookie").
Please understand that some of our services are only available through the use of cookies. You may modify your acceptance of cookies or refuse Sada's cookies if your browser or browser add-on service permits, but by refusing Sada's cookies you may not be able to use some of the features of Sada's services that rely on cookies in some cases.
Web pages often contain electronic images, known as "single-pixel GIF files" or "web beacons," which help websites count users browsing a page or access certain cookies.We use web beacons to collect information about your web browsing activity, such as the address of the page you visited and the location of the referring page you previously visited, as well as display settings. We use web beacons to collect information about your web browsing activity, such as the address of the page you visited, the address of the previous page you visited, how long you stayed on the page, your browsing environment and display settings.
Article 3 [How we share, transfer, and publicly disclose your personal information]
(i) Sharing
We do not share your personal information with any companies, organizations and individuals outside of our affiliates of Hong Kong Said Technology Co., Limited, except for the following.
1. Sharing with Explicit Consent: We will share your private information with you after obtaining your explicit consent.
2. Provide users' private information in accordance with laws and regulations or instructions from authorized authorities.
(ii) Transfer
We will not transfer your private information to any company,organizations and individuals, with the following exceptions.
1. Sharing with explicit consent: We will share your private information with you after obtaining your explicit consent.
2. In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of personal privacy information, we will require the transferee to continue to be bound by this policy, or we will require the transferee to obtain a new authorization consent from you.
(iii) Public disclosure
We publicly disclose your personal information only under the following circumstances.
1. With your expressly authorized consent.
2. Disclosure to the public based on national laws and regulations.
3. Disclosure at the request of national judicial and other relevant authorities based on legal procedures.
4. Disclosure to protect your legal rights and interests from being jeopardized.
5. In case of emergency, to protect the personal safety of other users and third parties, disclose.
6. When providing the user's personal identification information at the legitimate request of the user's guardian.
7. Any hacker attacks, computer viruses and other force majeure events leading to the leakage of the user's private information.
Article 4 [How We Protect Your Personal Information]
1. We attach great importance to the security of your personal information and endeavor to take all reasonable security measures (both technical and managerial) to safeguard the security of your private information and to prevent improper use or unauthorized access to, public disclosure of, use of, modification of, damage to, loss of or leakage of the private information provided by you.
2. We will use encryption technology that is not inferior to our industry peers, anonymization processing and other reasonably practicable means to protect your personal information and the use of security protection mechanisms to prevent your personal information from malicious attacks.
3. We will establish a specialized security department, a security management system, and a data security process to safeguard the security of your personal information. We adopt a strict data use and access system to ensure that only authorized personnel can access your personal information, and conduct security audits of data and technology at the right time to protect the security of your personal information.
4. We have a rigorous emergency response plan in place to ensure that losses are minimized in the event of an emergency.. Once information security incident (leakage, loss, etc.)occurs, We will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with , the suggestions you can independently prevent and reduce the risk, and the remedial measures for you, etc. We will promptly inform you of the situation related to the incident in the form of push notifications, emails, letters, SMS, etc. When it is difficult to inform you one by one, we will take reasonable and effective ways to publish announcements. At the same time, we will also report the handling of user information security incidents in accordance with the requirements of relevant regulatory authorities.
5. While ensuring the security of your personal privacy information, we also recommend that you raise your awareness of personal privacy information prevention, do not disclose your personal privacy information to others through the Internet, and do not click on links sent by others at will.
6. Your private information (user behavior and speech) will be retained for a long period of time, at least 180 days.
Article 5 [How we handle minors' personal information and protect minors]
5.1 Minor information handling
Sada takes the protection of minors' personal information very seriously and will rely on the personal information provided by users to determine whether they are minors. Any minor under the age of 18 should obtain the prior consent of parents or legal guardian (hereinafter referred to as the "guardian") to register for an account or use the Service.
We will protect the information of minors in accordance with national laws and regulations. If you are the guardian of a minor, please contact us via the contact information in the "How to Contact Us" section if you have any questions about the personal information of a minor under your guardianship. If we become aware that the personal information of a minor has been collected without the prior and verifiable consent of the guardian, we will endeavor to delete the data as soon as possible.
Sada will not use or disclose to any third party the chat records and other private information of minors, except for disclosure in accordance with the provisions of laws and regulations and the instructions of authorized authorities. Sada will not use or disclose the private information of minors to any third party without the prior consent of the guardian, except for the exceptions stipulated in this agreement.
5.2 Child Safety Standards
We are committed to keeping children safe from all forms of sexual abuse, exploitation and related harmful behavior. Our applications comply with all applicable laws and regulations, as well as the Child Safety Standards policy, and we always take the safety and rights of children as our top priority.
We prohibit the use of apps to endanger children. This includes but is not limited to use of apps to promote predatory behavior towards children, such as:
Inappropriate interaction targeted at a child (for example, groping or caressing).
Child grooming (for example, befriending a child online to facilitate, either online or offline, sexual contact and/or exchanging sexual imagery with that child).
Sexualization of a minor (for example, imagery that depicts, encourages or promotes the sexual abuse of children or the portrayal of children in a manner that could result in the sexual exploitation of children).
Sextortion (for example, threatening or blackmailing a child by using real or alleged access to a child’s intimate images).
Trafficking of a child (for example, advertising or solicitation of a child for commercial sexual exploitation).
We will take appropriate action, which may include reporting to legal authorities, if we become aware of content with child sexual abuse materials. If you believe a child is in danger of or has been subject to abuse, exploitation, or trafficking, please contact your local law enforcement.
We regularly update and publicize our policies and initiatives related to child protection, and disclose our implementation status and improvement plans to users through our annual transparency report.
If you are aware of any content or behavior involving child sexual abuse or sexual exploitation, please contact us via means mentioned by article 9.
Article 6 [How your personal information is transferred globally]
Personal information collected and generated in the course of our operations in Hong Kong is stored in Hong Kong, except for the following.
1. The applicable law is clearly defined;
2. Obtain your express authorization;
3. You conduct cross-border transactions through the Internet and other personal initiative behavior;
In such cases, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.
Article 7 [Your rights]
We will comply with the relevant laws, regulations and standards of Hong Kong, as well as the statutory and customary laws of other countries and regions, to protect your right to enjoy the following rights in relation to your personal information..
(i) Access, correct and supplement your information
You have the right to access, correct or supplement your information. You may do this by yourself-Contact Sada Customer Service: [My]-[Online Customer Service]-input "Human Customer Service" to operate.
You need to submit appropriate supporting documents as required, such as name, ID number, clear front photo of your ID, clear back photo of your ID, and hand-held photo of your ID to help us confirm your valid identity and assist you in changing your identity information.
(ii) Delete your information
You may make a request to us to delete personal information in the following circumstances.
1. If our handling of personal information violates laws and regulations.
2. If we collect or use your personal information without your explicit consent.
3. if we process personal information in material breach of this policy.
4. If you voluntarily cancel your account.
Once we have assisted you in deleting the relevant information, we may not be able to immediately delete the corresponding information from our backup systems because of applicable laws and security techniques, and we will securely store your personal information and isolate it from any further processing until the backups are available.
to clear or achieve anonymity.
(iii) Change the scope of your authorized consent
Some features may require some of your personal information in order to be completed, and when you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.
(iv) Cancel your account
You can request to cancel your account by self-application :
[My]-[Account Settings]-[Account & Security]-[Logout].
To cancel your Sada account, you need to fulfill the conditions for cancellation. You need to confirm the cancellation in person, and logging in again within 7 days after the confirmation of cancellation will be regarded as withdrawal of the cancellation. After 7 days, Sada will delete all the information of your account and you will not be able to recover it.
(v) Automated decision-making in constraint information systems
In some business features, we may only make decisions based on information systems, algorithms and other non-human automated decision-making mechanisms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will provide a reasonable explanation without infringing on Sada's trade secrets or the rights and interests of other users, the public interest, and the national interest.
(vi) Responding to your request above
For security purposes, you will be required to provide the above requested materials or otherwise prove your identity before your request can be processed, and we will not be able to respond to your request if you refuse to provide the appropriate supporting materials.
We will respond within 72 hours.
We will not be able to respond to your request if we are required by law or regulation to do so in the following circumstances.
3. Related to the criminal investigation, prosecution, filing, trial and enforcement of sentences for crimes;
4. There is sufficient evidence that the personal information subject has subjectively maliciously colluded to prevent third parties from exercising their legal rights or abusing their rights to seriously damage the legal rights of other individuals and organizations;
5. Involving trade secrets.
Article 8 [How this policy will be updated]
This Policy will be updated to ensure that you receive a better service and to keep pace with the restructuring and future development of the Platform. However, when updating, we will obtain your authorization in a separate and visible way, otherwise we will maintain the rights granted to you under this Policy.
We remind you of updates in a reasonable, appropriate and visible manner after an updated version of the application or official website or after an official announcement, so that you can be more quickly informed of the change of your rights.
For major changes, we will also provide a more prominent means of notification (we will express the updated content of the policy to you by means including, but not limited to, emails, text messages, announcements, homepage, or special alerts on the browsing page).
Material changes referred to in this policy include, but are not limited to.
1. Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;
2. We experience significant changes in our ownership structure, organizational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions, etc.; and
3. Changes in the primary recipients of personal information shared, transferred or publicly disclosed.
4. Significant changes in your rights to participate in the processing of personal information and the manner in which they are exercised.
5. When there is a change in the department responsible for handling the security of personal information, our contact information and complaint channels;
6. When the security impact assessment report of personal information indicates that there is a high risk.
We will also archive an older version of this Privacy Policy for your review.
Article 9 [How to contact us]
If you have any questions, comments or suggestions about this policy, you may contact us as follows .
If you wish to correct or delete your personal information or withdraw your consent to the collection of your personal information, you may contact us as follows.
Complaints and reports about the security of personal information can be made by contacting us or to the relevant authorities in the following ways.
E-mail: help@veryok.team
Contact Sada Customer Service: [My]-[Online Customer Service]-Enter "Customer Service" to inquire.
We will respond to you within 7 business days.
The laws of Hong Kong shall apply to the validity, interpretation, modification, execution and dispute resolution of this Agreement. All disputes arising out of this Agreement shall be dealt with in accordance with the laws of Hong Kong. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the People's Court where Hong Kong Said Technology Co, Limited is located.