YoyaHub Privacy Policy

Last Revision Date: January 14, 2025

I. Introduction

At YoyaHub, we are committed to safeguarding your privacy and have established a robust system to protect your personal information, ensuring that every user can enjoy secure and reliable services.

(I) Features of the Privacy Policy

1. Clarity
We present our privacy policy in clear and straightforward language, enabling you to easily understand how your information is handled and protected.

2. Rights Protection
We take all necessary and appropriate measures to effectively safeguard your privacy rights.

3. Respect for Users
We respect your right to make informed decisions, including full control over accessing, managing, and handling your personal data.

4. Minimal Data Collection
We only collect the information necessary to provide you with secure and customized services.

5. Responsive Communication
We are dedicated to addressing your concerns and promptly and attentively responding to any inquiries.

II. Collection and Use of Personal Information

(I) Registration

To register for YoyaHub services, you need to complete the account setup process. You are responsible for protecting your account and should not share your login credentials with others.

(II) Device Information

1. Device Identification and Unique Identifiers
We use this information to ensure the secure and efficient operation of our software and services.

2. Device-related Information
We automatically collect information about your device, including the device ID, brand, model, operating system and its version, the current device status, as well as hardware details, information from your internet service provider or mobile carrier (such as IP address or proxy server). When using the application, we also collect data on the network type, platform, and your interactions with various features within the app.

(III) Data Collection for Analysis

To enhance service quality and user experience, we collect device logs and usage data for analytical purposes. Whenever you interact with our services, our servers automatically record detailed activities, including device configuration, IP address, access times, pages and files viewed, and features used. Additionally, we collect diagnostic data such as system events (e.g., crash reports), hardware settings, and error logs. We may use your device ID and Advertising ID for further analysis to evaluate marketing strategies, improve service performance, and offer more personalized services and promotions.

(IV) Permissions

To provide a richer user experience and ensure the full functionality of our services, YoyaHub may request the following permissions:

1. Photo Library Access
When you intentionally upload photos from your device's photo library, we may request access to the photo library, allowing you to share pictures during chats or update your profile picture.

2. Camera Access
When you initiate photo-taking or start a video call, YoyaHub may request access to your camera for functions such as taking and sharing photos or participating in live video calls.

3. Audio and Video Access
When you choose to make a video call or record audio, YoyaHub may request access to your audio and video features to ensure smooth communication.

4. Bluetooth Access
To ensure a higher-quality audio experience, when connecting to audio devices, YoyaHub may request access to Bluetooth, enabling seamless pairing with Bluetooth devices.

5. External Storage Access
When you save or download content, YoyaHub may request permission to read from and write to your device's external storage to save or manage files such as photos and videos.

6. Advertising IDs
To optimize our marketing efforts, YoyaHub may collect your device's Advertising IDs for analyzing the effectiveness of marketing campaigns and refining our promotions.

These permissions will only be used after you provide explicit consent, and you can manage or change them at any time in your device's settings. We are committed to protecting your privacy, and all personal information will remain confidential and will never be used for any unauthorized purpose.

III. Sharing, Transfer, and Disclosure of Personal Information

(I) Information Sharing

1. With Explicit Permission
Only when we have obtained your explicit consent will we share your personal data with third parties. You have complete control over whether or not your information is shared.

2. To Comply with Legal Obligations
When we are required to comply with legal obligations, such as laws, regulations, or government requests, we may need to share your personal information. However, we will only provide the minimum amount of information necessary to fulfill the legal requirement.

3. With Authorized Partners
We may share your personal information with authorized partners who assist us in providing certain services or performing specific tasks on our behalf. In such cases, we will only share the information that is necessary for these partners to carry out their work. Our partners are strictly prohibited from using your information for any purposes other than those specified by us.

We also collaborate with third-party suppliers, service providers, and partners who support the operation of our services, including but not limited to providing technical infrastructure, analyzing service performance, supporting customer service, processing payments, conducting research, and evaluating the effectiveness of advertising campaigns. For example, we may share data related to application usage, user behavior, and marketing effectiveness with partners like Appsflyer for marketing analysis and attribution, and we may use platforms like Facebook for statistical tracking to analyze user behavior and collect payment information. We have strict data protection agreements with these third parties, requiring them to process your personal information in accordance with our instructions and privacy policy, as well as relevant confidentiality and security standards.

If you do not agree with any part of this policy, we recommend that you discontinue using our services. YoyaHub is dedicated to maintaining a safe and secure community, and sharing specific data is essential to achieving that goal.

IV. Protection of Personal Information

We adopt a comprehensive approach to securing your personal information, adhering to industry best practices and regulatory requirements to ensure the confidentiality of your data. We implement a variety of measures to prevent your personal information from being accessed, exposed, or misused without authorization, including anonymizing data whenever possible, employing reliable security systems to prevent malicious attacks, establishing a robust access control mechanism to limit access to personal information (following the principle of least privilege to ensure that only authorized personnel can access sensitive data), and our staff receive regular training to enhance their knowledge of personal information security and best practices.

We limit the collection of personal data to what is relevant and necessary for providing our services, avoiding excessive collection. If you suspect that your personal data has been compromised, such as through unauthorized access to your account, please contact YoyaHub's customer support immediately so that we can take prompt action to protect your information.

Please note that any information you choose to share publicly while using our services, including personal and sensitive details, may be seen by others. Therefore, please be cautious when sharing information on our platform. Additionally, if a security incident involving your personal data occurs, we will report it to the relevant regulatory authorities in accordance with applicable laws.

V. Management of Personal Information

(I) Accessing Personal Information

Subject to legal provisions, you have the right to access your personal data. You can manage it in the following ways:

1. Account Details
Log in to your account and go to [My - Settings] to view or update your account information.

2. Customer Support
If you cannot access your personal data through the settings, contact YoyaHub's customer support. We will respond to your inquiry within 15 days.

3. Other Personal Data
For other personal data generated while using our products or services, we will provide access in accordance with relevant agreements and procedures.

4. Requesting a Copy
If you need a copy of your personal data, you can request one by contacting our customer support team.

(II) Deleting Personal Information

You can delete specific personal data using the steps described in the "Accessing Personal Information" section. Additionally, you can request deletion of your personal data in the following circumstances:

1. If our collection or processing of your data violates applicable laws or regulations.

2. If we process your personal data without obtaining your explicit consent.

3. If our handling of your data breaches our agreement with you.

4. If you no longer use our products or services and wish to delete your account.

5. If we permanently discontinue providing products or services to you.

Once your deletion request is confirmed, we will notify any third parties that have received your personal data to also delete it, unless legally required to retain it or if they have received separate authorization from you.

Please note that due to technical or legal reasons, personal data may not be immediately removed from our backup systems. However, the data will be securely stored and isolated until it can be fully deleted or anonymized.

(III) User Content

The content you share may be retained by other users through screenshots, in-app tools, or other capture methods. Even if you request deletion, digital content may be temporarily recoverable through forensic methods or temporary device storage. Although we strive to delete user data as quickly as possible, we cannot always guarantee immediate removal. In some cases, data may need to be retained for a short period to comply with legal obligations or for backup purposes.

(IV) Managing Your Information

We provide tools to help you control your personal data:

1. Access and Update
You can manage your personal information through the app's settings page. Some requests may be denied if they interfere with the privacy of other users or violate legal obligations. You can submit requests to access, update, or delete your information through our designated process. Additionally, you can delete the app or request account deletion directly from your mobile device.

2. Deletion
You can delete or modify your account ID, but be aware that this could result in the permanent loss of your account data. YoyaHub will stop processing your personal information unless we have valid reasons to continue, such as legal requirements or the need to protect the rights and freedoms of others.

VI. Legal Basis for Data Processing and Your Rights

(I) Legal Basis for Data Processing

We process your personal data in accordance with applicable privacy laws. The legal grounds for processing your personal data include the following:

1. Consent
In certain cases, we will ask for your explicit consent to collect and use your personal data.

2. Contractual Obligations
When processing your personal data, it is necessary to fulfill a contract we have with you, we will rely on this legal basis.

3. Legitimate Interests
We may process your personal data where it is necessary for our legitimate interests, such as ensuring app security, maintaining functionality, and enhancing user experience.

4. Legal Compliance
We may process your personal data to comply with legal or regulatory obligations.

5. Public Interest
In some cases, where processing is required for matters of public interest, we may handle your personal data accordingly.

(II) Your Rights

According to applicable data protection laws, you have the following rights regarding your personal information:

1. Right to Deletion
In specific situations, you have the right to request the deletion of your personal data.

2. Right to Restrict Processing
In certain circumstances, you can request that we restrict the processing of your data.

3. Right of Access
You can request access to the personal data we hold about you at any time.

4. Right to Data Portability
You have the right to request that we provide your personal data in a transferable format to you or a third party.

5. Right to Correction
If your personal data is inaccurate or incomplete, you have the right to ask for corrections or updates.

6. Right to Object
In specific cases, particularly when data is processed based on legitimate interests, you can oppose the processing of your personal data.

7. Right to File a Complaint
If you believe we have violated privacy laws in processing your personal data, you have the right to file a complaint with your local data protection authority.

8. Right to Withdraw Consent
If we are processing your personal data based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

(III) International Privacy Law Compliance

We comply with international privacy laws and regulations applicable to different regions, including but not limited to:

1. PIPEDA (Personal Information Protection and Electronic Documents Act)
Applicable to users in Canada.

2. LGPD (Brazilian General Data Protection Law)
Applicable to users in Brazil.

3. Other regional or national privacy laws
Depending on the applicable laws in your location, such as the CCPA (California Consumer Privacy Act) for residents of California, and the GDPR (General Data Protection Regulation) for users in the European Union (EU) and the European Economic Area (EEA).

VII. Privacy Rights of California Residents under the CCPA

California residents have specific rights under the California Consumer Privacy Act (CCPA). These rights include:

1. Right to Know
You have the right to request details about the personal information we have collected, used, shared, or sold in the last 12 months. You can make this request twice within a 12-month period. This includes:
￮ The categories and specific pieces of personal information collected about you.
￮ The sources from which your personal data was collected (e.g., directly from you, your device, or third parties).
￮ The business or commercial purposes for collecting your personal data (e.g., service improvements, marketing, or fraud prevention).
￮ Categories of personal information disclosed for business purposes.
￮ Categories of personal information sold to third parties, if applicable.
￮ The third parties with whom we have shared or sold your personal information (e.g., ad networks, analytics services).

2. Right to Delete
You have the right to request the deletion of your personal data. Once we verify your request, we will delete your personal data and instruct any service providers or others to do the same unless we are legally required to retain it or for reasons such as fraud prevention or transaction completion.

3. Right to Know If Your Data Is Sold
You can request to know whether your personal data has been sold to third parties. If applicable, we will notify you and provide an option to opt out. You can exercise this right at any time.

4. Right to Opt-Out of the Sale of Personal Information
California law gives you the right to opt out of the sale of your personal information. You can do this by visiting our "Privacy Settings" page and submitting your request. Once you opt out, we will stop selling your personal data, though we may still share information with service providers as needed for operational purposes.

5. Right to Opt-Out of Sharing Personal Information for Targeted Advertising
You have the right to opt out of the sharing of your personal data for targeted advertising. You can exercise this right by visiting our "Ad Preferences" page or contacting us directly.

6. Right to Lodge a Complaint
If you believe your data privacy rights have been violated or are concerned about how we handle your personal information, you have the right to file a complaint with your local data protection authority. We encourage you to contact us first to address your concerns, but this does not affect your right to lodge a formal complaint.

7. Right to Non-Discrimination
You have the right to exercise your privacy rights without facing any form of discrimination. We will not deny services, charge different rates, or alter the quality of services if you exercise these rights. However, if certain necessary data is removed, it may affect the availability of some features or services.

(I) Exercising Your Opt-Out Rights

YoyaHub is dedicated to safeguarding user privacy in accordance with the General Data Protection Regulation (GDPR) and the Virginia Consumer Data Protection Act (VCDPA). To comply with these data protection laws, we provide users with the ability to opt out of specific data processing activities. Here are the options available:

1. Opt-Out of Data Sharing
You can choose not to share your personal data with third parties, particularly when the data is being used for purposes like analytics, marketing, or other activities.

2. Withdraw Consent for Data Processing
If you have previously granted consent for certain types of data processing, you can withdraw that consent at any time, halting the process of the associated data processing.

3. Opt-——Out of Data Analysis
You have the right to opt out of data analysis processes that are used to improve services and provide personalized user experiences.

To exercise any of these opt-out options, please send an email to our privacy team. In your message, clearly state the specific data processing activities you wish to opt out of, along with any relevant details. We will review and handle your request promptly, and you will receive confirmation once the changes have been made.

VIII. LGPD Compliance Notice (Applicable to Brazil)

YoyaHub places a high value on your privacy and is fully committed to safeguarding your personal data in line with the Brazilian General Data Protection Law (LGPD). If you are a resident of Brazil, it is important to understand how we handle your data, from collection and use to storage and sharing. We are committed to being transparent about our data processing practices, ensuring your personal information remains protected throughout.

Under the LGPD, you have the following rights:

1. Right to Access
You can request information on the personal data we hold about you and understand how it is being processed.

2. Right to Correction
If any of your personal data is incorrect, incomplete, or outdated, you can request that we correct it.

3. Right to Erasure
Where legally allowed, you can request that your personal data be deleted from our systems.

4. Right to Information
You have the right to know which organizations we share your data with, the reason for doing so, and the scope of this data sharing.

5. Right to Revoke Consent
You can withdraw your previously granted consent for specific data processing activities at any time.

6. Right to Object
You have the right to object to the processing of your personal information based on legitimate interests.

7. Right to Data Transfer
You have the right to request that we transfer your personal data to yourself or a third party of your choosing.

8. Right to File a Complaint
If you believe your data protection rights have been violated, you can file a complaint with the National Data Protection Authority (ANPD).

We are fully committed to respecting your privacy rights and adhering to the legal obligations set forth by the LGPD to ensure the safety and proper handling of your data.

IX. Compliance Interpretation of Data Collection Based on VCDPA

Under the strict user privacy protection framework of YoyaHub, we further refine the privacy-related regulations in accordance with the Virginia Consumer Data Protection Act (VCDPA) to ensure a comprehensive, compliant and worry-free privacy protection environment for you. When collecting your personal data, YoyaHub always adheres to the principles of transparency and necessity as required by the VCDPA. We only collect data that is crucial for realizing the core service functions of YoyaHub. For example, during the user registration process, in order to complete account creation, verify your identity and ensure the precise delivery of subsequent services, we may collect basic information such as your name, contact details (like email address and mobile phone number), and age. The collection of such information is entirely based on your voluntary provision, and before collection, you will be informed of key elements such as the purpose of the data, the recipients, and the storage period through clear and explicit prompts, fully safeguarding your right to know, which strictly complies with the provisions regarding the data subject's right to know in the VCDPA.

X. Protection of Minors' Personal Information

Our services are not designed for, nor intended to be used by, individuals under the age of 18. We do not knowingly collect any personal data from children or users below this age threshold. To enforce this policy and safeguard our platform, we gather age-related information to prevent minors from accessing the service. Additionally, we may rely on third-party services to verify users' age and ensure that our platform maintains appropriate user profiles. If we discover that personal information from users under the age of 18 has been inadvertently collected, we will act swiftly to remove such data from our systems. If you are under 18, you are strictly prohibited from using our services.Should you discover that a minor under your supervision has had their personal information collected by us, please reach out to us immediately. We will verify the situation and ensure the removal of such data as soon as possible.

XI. Changes to This Privacy Policy

We may update our privacy policy from time to time to reflect changes in our practices or legal requirements. Any changes that could affect your rights under this policy will be heard of clearly, and we will not reduce your rights without obtaining your explicit consent. For major updates, you will receive prominent notifications, such as announcements within the app or through visible pop-up notices. We encourage you to review the policy periodically to stay informed about any changes.

Key updates to this policy may include, but are not limited to:

1. Significant changes to our service offerings, including new purposes for processing personal data, changes in the types of data we collect, or shifts in how we handle and use your personal information;

2. Corporate restructuring or ownership changes, such as mergers, acquisitions, or other forms of control transitions;

3. Modifications in how we share or disclose personal data, particularly with third parties, or updates to the types of entities we partner with for data processing;

4. Changes in your rights regarding personal data, including updates on how you can exercise these rights or access your data;

5. Adjustments in how personal information security is managed, including contact details for the responsible for data security, as well as new communication or complaint channels;

6. Important findings in personal data security risk assessments, which may trigger additional security protocols or warnings.

By continuing to use our services after receiving notification of any changes, you indicate your acceptance of the revised privacy policy. If you do not agree with the updated terms, you may opt to limit your usage of the platform to guest mode without sharing personal data.

For your convenience, previous versions of our privacy policy will be archived and available for review. If you would like to access older versions, please contact us using the provided contact information.

XII. Data Protection Officer (DPO)

If you have any questions, requests, or concerns regarding the processing of your personal data, or if you'd like further information about your privacy rights, please contact our Data Protection Officer (DPO), Ethan Walker, at debendronathmanik@gmail.com.

XIII. Controller Information

The controller responsible for managing your personal information in relation to this service is YoyaHub. We are in charge of the collection, usage, storage, and disclosure of any personal data you provide while using our services. For any inquiries regarding your personal data, feel free to reach us at debendronathmanik@gmail.com.

Address：Bangladesh，Sadi, Mandalerhat-5620, Ulipur, Kurigram

XIV. Contact Us

You can contact us in the following ways, and we will respond to your request within 15 days:

If you have any questions, comments, or suggestions about the content of this policy, you can contact our official customer service in the YoyaHub application or send an email to our service mailbox at debendronathmanik@gmail.com.