PRIVACY STATEMENT
Effective Date: December 9, 2019

This Privacy Statement (“Privacy Statement ”) explains how Creativefun Technology Ltd. (“InFunt ,” “us ,” “our ,” and “we ”) uses your information and applies to all who use our app, mobile applications, touch technologies, electronic services, social networking sites, interactive features, online services – or any of our described online activities we own or control, including any online activities owned, controlled, or operated by InFunt Affiliates, (collectively, the “Site ”). In addition, please review the Site’s Terms of Use which governs your use of the Service, and includes, among other things, grants of rights from you, limits on our liability and your remedies, mandatory arbitration, and waiver of jury trial and class actions.By using our Site, you agree to our Terms of Service and consent to our collection, use and sharing of your information and data, and other activities, as described below.

By using the Site, you agree to the terms of this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your personal information or interact with the Site.

We may modify this Privacy Statement at any time. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of notice on the Site prior to the change becoming effective. You can determine when this Privacy Statement was last revised by referring to the "Effective Date” above.

This Privacy Statement is organized as follows:

  1. How InFunt Collects Information 
  2. How InFunt Uses Information 
  3. When and Why InFunt Discloses Personal Information 
  4. Security of Personal Information
  5. Your Rights Regarding Personal Information
  6. Your Choices 
  7. Social Networks 
  8. Privacy Practices of Third Parties 
  9. Business Transfers and Corporate Changes 
  10. Notice to Residents of Countries outside the Canada
  11. Children’s Privacy 
  12. Contact Us
  13. Glossary of Terms 

1. Types of Information We Collect

We will collect information, including Personal Information andNon-Identifying Information,when you interact with us and the Site, for example when you:

We collect the following categories of Personal Information:

Network Activity Information: information about your browsing behavior and internet history.

2. How InFunt Collects Information

You provide us with yourPersonal Informationwhenyou register, subscribe, create an account, make a purchase, or otherwise when you provide us with yourPersonal Informationduringyour interaction with the Site andOther Programs. If you make purchases without creating a password, we link these purchases to your email address and create a secure account in our systems. If you create a password at a later date, you will be able to see past purchases made with a particular email address. We also collectPersonal Informationwhenyou contact us online for customer service and other support using self-help tools, such as email, text, or by posting to anOnline Community.

We also receivePersonal Information and other online and offline information fromOther Sources. InFunt will use such information in accordance with applicable laws. Such information, when combined with Personal Information collected as provided in this Privacy Statement, will also be handled in accordance with this Privacy Statement. We also use cookies, tags, web beacons, local shared objects, files, tools and programs to keep records, store your preferences, improve our advertising, and collectNon-Identifying Information, includingDevice Data and information about your interaction with the Site and ourBusiness Partners' web sites.

We useCookies andDevice Data that allow us to connect your Site activity with other information we store about you in your profile or as related to your interactions with the Site. For more information on how InFunt usesCookies, including instructions on how to opt out of interest-based advertising.

Device Data may be collected automatically, and as soon as your device interacts with the Site and InFunt, even if you are not logged into the Site using your device. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

We collect your location information, including precise real-time geolocation, such as through look up based on IP address, GPS, Bluetooth, or WiFi signals, consistent with your choice of mobile device settings. We may also collect the precise location of your device when the app is running in the foreground, background, or even if you are not directly using the application depending on your device and its settings. Your device, as well as the InFunt mobile app, provides you with options to control how and when we collect your geolocation. You may be able to disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for the InFunt application.

3. How InFunt Uses Information

We (or ourVendorson our behalf), use information collected as described in this Privacy Statement to:

We also may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.

InFunt uses your geolocation, including your precise geolocation, consistent with this Privacy Statement as described inSection 5below to deliver location-based offers, products or services that may be of interest to you.

If you use any features on the Site to send information about a product or service to another person (e.g., a friend, a colleague, a professional associate, etc.), we will also collect thePersonal Information of that other person to the extent disclosed by you and may contact them using the information you provided us.

4. When and Why Groupon Discloses Information

We (or ourVendorson our behalf) may share yourPersonal Information as required or permitted by law:

We encourageBusiness Partners to adopt and post privacy policies. However, their use ofPersonal Information obtained through InFunt is governed by their privacy policies and is not subject to our control.

We may also discloseNon-Identifiable Information :

We do not sharePersonal Information withThird-Party Ad-Servers; however,Third-Party Ad-Servers may automatically collectNon-Identifying Information about your visit to the Site and other websites, your device address, your Internet Service Provider and the browser you use to visit the Site. They do this by usingCookies, clear gifs and other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visits to the Site and the other websites tracked by these third parties. This Privacy Statement does not cover the collection methods or use of the information collected byThird-Party Ad-Servers, and InFunt is not responsible forCookies or clear gifs in third party ads. We encourage you to review the privacy policies or statements of these third party advertising companies to learn more about their use ofCookies and other technologies.

5. Security of Personal Information

InFunt has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguardPersonal Information. For example, we use industry-standard encryption technology to secureFinancial Account Information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.

6. Your Rights Regarding Personal Information

You have certain rights with regard to your Personal Information:

In addition to the above rights, you can update or remove Financial Account Information as well. You can also deactivate your InFunt account.

7. Your Choices

We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to InFunt, and you can limit the communications that InFunt sends to you.

(a) Commercial E-mails

You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send or by logging into your account and adjusting your e-mail preferences. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your account and your transactions on the Site. You may update your subscription preferences at any time.

(b) Cookies and Other Technologies

You may manage how your browser handlesCookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.

Currently, we do not alter our data collection and use practices in response to Do Not Track signals.

(c) Device Data

You may manage how your mobile device and mobile browser share certainDevice Data with InFunt, as well as how your mobile browser handlesCookies by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

When you first visit or use the Site we may request permission to collect and use your device’s precise geolocation. You can opt not to permit the collection of this information, or permit it only when using the mobile app, but it may limit certain functions or features of the Site. You can control how and whether we collect your precise geolocation information through your device’s settings.

(d) E-mails from Business Partners

If you wish to opt out of receiving offers directly from ourBusiness Partners, you can follow the opt-out instructions in the emails that they send you.

8. Social Networks

Social Community Areas

The Site may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. Prior to posting in these areas, please read ourTerms of Use  carefully. All the information you post may be accessible to anyone with Internet access, and anyPersonal Information you include in your posting may be read, collected, and used by others. We recommend that you do not post anyPersonal Informationin the social community areas.

Social Networks

You may log in to the Site using certain social network credentials. To manage the sharing of certainPersonal Information with us when you connect with us through social networking platforms or applications, refer to the privacy policy and settings of the social networking website or application.

You also have the option to link social networks, such as Wechat, to your InFunt account. Once you register with InFunt and connect with the social network, you will be able to automatically post recent InFunt activity back to your social network.

By proceeding through any of the above steps, you grant InFunt permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Statement.

9. Privacy Practices of Third Parties

This Privacy Statement only addresses the use and disclosure of information by InFunt through your interaction with the Site. Other websites that may be accessible through links from the Site andOther Programsmay have their own privacy statements and personal information collection, use, and disclosure practices. OurBusiness Partners may also have their own privacy statements. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

10. Business Transfers and Corporate Changes

InFunt and ourAffiliatesreserve the right to disclose, transfer, or license any and all information related to the Site, includingPersonal Information:

11. Notice to Residents of Countries outside the Canada

If you live outside the Canada, and you use the Site or provide us withPersonal Information directly via the Site, your information will be handled in accordance with this Privacy Statement. By using the Site or giving us yourPersonal Information, you are directly transferring yourPersonal Information andNon-Identifiable Information to us in the Canada. You agree and consent to our collection, transfer, and processing of yourPersonal Information andNon-Identifiable Information in accordance with this Privacy Statement. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use the Site or provide us withPersonal Information. Regardless of where we transfer your information, we still protect your information in the manner described in this Privacy Statement.

12. Children’s Privacy

The Site is a general audience site not directed at children under the age of 13.

By using InFunt, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Site. We will promptly delete information associated with any account we obtain actual knowledge is associated with a registered user who is not at least eighteen years old.

13. Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us online at customerservice.InFunt@95cfun.com. You can reach us via postal mail at the following address:

Creativefun Technology Ltd.
Attention: Privacy Office 
241-8680 Cambie Rd. Richmond, BC CANADA 

14. Glossary of Terms

Affiliate means an entity owned, directly or indirectly, by InFunt or that is controlled by or under common control with InFunt, and also includes joint ventures entered into by InFunt and/or its Affiliates. References in this Privacy Statement to “InFunt,” “we,” or “us” also apply to Affiliates.

Business Partners means, collectively, third parties with whom we conduct business, such as merchants, co-marketers, distributors, resellers, and other companies or organizations with whom InFunt enters into agreements to support its business and operations.

Cookie means a unique identifier, usually made up of small bits of text or code.

Device Data means information concerning a device you use to access, use, or interact with the Site, such as operating system type or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geolocation, including precise geolocation, unique device identifier or other device identifier, advertising identifier, mobile phone carrier identification, and device software platform and firmware information.

Non-Identifiable Information means information that alone cannot identify you, including data fromCookies,Pixel Tags and Web Beacons, andDevice Data. Non-Identifiable Information may be derived fromPersonal Information.

Online Communities means, collectively, our social networking pages or accounts, forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or linked through the Site.

Other Programs means special programs, features and functionality on our Site or other co-branded websites withBusiness Partnersthat we reasonably control and that have special use terms applicable to such special programs, features and functionality.

Other Sources means sources of information that legally provide InFunt with your information, and which are outside the scope of this Privacy Statement at the time of collection.

Personal Information means information about you or your household that identifies, relates to, describes, is capable of being associated with, or could be linked to you or your household, either on its own or when combined with other information we have. This includes the categories of information described in Section 1 of this Privacy Statement.

Pixel Tags and Web Beacons mean tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions.

Sell or Sale means the disclosure of Personal Information to a non-InFunt entity in exchange for money or something else of value.

Third-Party means another business that receives Personal Information from InFunt and is able to use that information for its own purposes.

Ad-Servers means Vendors and Third Parties that provide the technology to place ads on websites and track ad performance.

Vendors means, collectively, third parties that perform business operations on behalf of InFunt, such as transaction processing, billing, mailing, communications services (e-mail, direct mail, etc.), marketing, data processing and analytics, servicing, collections, ad management, or information technology services.