Last updated: November 10, 2024

Welcome to Thinla (the “Platform”). The Platform is provided and controlled by THINLA SG PTE. LTD., (“Thinla”, “we,” and “our”).

We are committed to protecting and respecting your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.

If you have any questions about how we use your personal data, contact us at: support@thinla.com.

SUMMARY

What information do we collect about you?

We collect and process information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform. We also collect information about you if you download the app and interact with the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. We use your information to, among other things, show you suggestions in the Platform, improve and develop the Platform and ensure your safety. Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Platform.

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as THINLA, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise or defence of legal claims.

How will we notify you of any changes to this Privacy Policy?

We will generally notify all users of any material changes to this policy through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

The types of personal data we use

We collect and use the following information about you:

Your Profile Information. You give us information when you register on the Platform, including your username, password, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph or profile video.

Information from Third Parties. You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:

Business Partners

If you choose to register or use the Platform using a third-party social network account details (e.g., Facebook, Tik Tok, Twitter, Instagram, Google) or login service, you will provide us or allow to provide us with your username, public profile, and other possible information related to such account. We will likewise share certain information with your social network such as your app ID, access token and the referring URL. If you link your THINLA account to another service, we may receive information about your use of that service.

Advertisers, Advertising Networks, and Analytic Providers

We use the information collected from you, and your interaction with the Platform and other third-party sites and Apps, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you've visited, apps you've downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our Platform and from similar information received from third parties who advertise on our Platform and whose sites/Apps you visit.

Technical Information we collect about you. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.

Location. We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS).

Proof of your identity or age. We sometimes ask you to provide proof of identity or age in order to use certain features, such as livestream or verified accounts, or when you apply for a Pro Account, ensure that you are old enough to use the Platform, or in other instances where verification may be required

Cookies

We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your devices. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

Privacy Policy - Use of Google User Data

Our application accesses specific Google user data to provide and enhance our services. The following Google OAuth scopes are requested for specific purposes:

• /auth/userinfo.email: Used to access and verify your email address to create and manage your account within the app.
• /auth/userinfo.profile: Used to retrieve basic profile information, such as your name and profile picture, for personalization purposes.
• /auth/gmail.send: Used solely to enable email functionality within the application. This permission is exclusively for sending emails as directed by the user and is not used for any other purpose.
• /auth/youtube.readonly: Used to retrieve your YouTube data in read-only mode, allowing us to display your YouTube information within the app for a seamless user experience.

We adhere strictly to Google’s policies regarding data privacy and security. No Google user data accessed by our app is shared with third parties or used for any purposes other than providing and improving our application's core functionality. User data will not be used for personalized advertising or any form of ad targeting。 We do not use any user data for AI model training or machine learning purposes.

Compliance with Google’s Terms of Service

We fully understand and comply with Google's Terms of Service and Privacy Policy, including limited use requirements. Specifically:

• Purpose of Data Access: User data accessed through Google APIs is used solely for providing personalized features and experiences on our Thinla platform.
• Data Privacy: We do not sell, share, or transmit user data to any third party without explicit user consent or legal requirement. We request only the minimum permissions necessary to deliver our services.
• Transparency: We clearly disclose on our platform how user data will be used and will update relevant policies and notices as necessary.
• Data Retention: Once a service ends, we will delete or fully anonymize user data.

As an application requiring access to sensitive data permissions, we strictly comply with Google’s API Service User Data Policy limited use requirements. User data is limited to internal use within Thinla and will not be shared with third-party applications or platforms. No data will be used for AI model training or any machine learning purposes. We follow all other data use guidelines associated with the requested API scopes.

If any changes in data use are made, we will promptly update our privacy policy and notify users.

Example Disclosure

“The Thinla platform uses user information received from Google APIs, transmits it, and saves it to the Thinla system in accordance with the Google API Google API Services User Data Policy, including limited use requirements.”

How we use your personal data

We will use the information we collect about you in the following ways:

• notify you about changes to our service;
• provide you with user support;
• personalise the content you receive and provide you with tailored content that will be of interest to you;
• enable you to share User Content and interact with other users;
• enable our messenger service to function if you choose to use this function;
• communicate with you;
• to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform;
• ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
• ensure content is presented in the most effective manner for you and your device;
• improve, promote and develop the Platform and promote popular topics, hashtags and campaigns on the Platform;
• carry out data analysis and test the Platform to ensure its stability and security;
• allow you to participate in interactive features of the Platform;
• to ensure that you are old enough to use our Platform (as required by law).
• provide you with personalised advertising;
• provide you with location-based services (where those services are available in your jurisdiction);
• To inform our algorithms
• enforce our terms, conditions and policies;
• administer the Platform including troubleshooting; and
• to facilitate sales, promotion, and purchase of goods and services and to provide user support

How we share your personal data

We share your data with the following selected third parties:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Tik Tok, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.

Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

Payment Providers

If you choose to conduct payment related transactions, we will share data with the relevant payment provider to facilitate this transaction. For Coin transactions, we share a transaction ID to enable us to identify you and credit your account with the correct value in coins once you have made the payment.

Service Providers

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place and service providers that assist us in marketing the Platform.

Analytics providers

We use analytics providers to help us in the optimisation and improvement of the Platform. Our third-party analytics providers also help us serve targeted adverts

Advertisers and Advertising Networks

We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We share your device ID with measurement companies so that we can link your activity on the Platform with your activity on other websites; we then use this information to show you adverts which may be of interest to you.

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

• comply with legal obligation, process or request;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Public Profiles

Please note that if your profile is public, your content will be visible to anyone on the Platform.

Sale or Merger

We will also disclose your information to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

Where we store your personal data

The personal data we collect from you may be stored on a server located in Singapore/China or the United States, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

Your Rights and Choices

You can access and edit most of your profile information by signing into THINLA. You can delete the Content you uploaded. We also provide a number of tools in Settings that allow you to control. You may delete your entire account in Settings. You may also be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. If you have any questions on how to use the above tools, want to know about what rights you may have or want to exercise them, or have any requests, inquiries, or complaints, please contact us at: support@thinla.com.

The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

We take your privacy and data protection very seriously. In order to further enhance the control and protection of your personal information, we provide the following data deletion instructions.

Scope of data deletion

Users can perform data deletion in the privacy settings. The data deletion operation will clean up all third party data related to the user's account, including but not limited to browsing records, search records, order records, evaluation records, etc.

How to delete data

After logging in to your account, enter the "Privacy Settings" page and click the "Delete My Data" button. The system will pop up a confirmation window, and users need to confirm the deletion operation again. After the deletion is completed, users will not be able to recover the data again, so please be careful.

Timeliness of data deletion

We will process the deletion request submitted by the user as soon as possible and complete the data deletion operation within 30 working days.

User rights protection

We will actively protect the user's right to data deletion and ensure that the user's data is effectively deleted. If you encounter any problems or difficulties in the process of data deletion operation, please contact our customer service team and we will solve it for you as soon as possible.

How long we keep your personal data

We retain your information for as long as it is necessary, for example, to comply with our contractual relationship or to provide you with our service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, as may be allowed by applicable laws. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

Information relating to children

THINLA is not directed at children under the age of 13. In certain cases this age may be higher due to local regulatory requirements, please see your local privacy policy for more information. If you believe that we have personal data about or collected from a child under the relevant age, contact us at: support@thinla.com.

Complaints

In the event that you wish to make a complaint about how we process your personal data, contact us immediately at: support@thinla.com. We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

Changes

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy and providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

Contact

If you have questions, comments, or requests regarding this policy, please email us directly at: support@thinla.com.

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Brazil

If you are using the Platform in Brazil, the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

Parental and Guardian Consent.If required by Brazilian data protection laws, (i) if you are over the age of 16 but under the age of 18, you can only use and register for an account with the assistance of your parent or legal guardian and you declare and represent that you had such assistance to use the Services and to agree to the Policy; (ii) if you are over the age of 13 but under the age of 16, you can only use and register for an account with the representation of your parent or legal guardian, and you must obtain the consent from your parent or legal guardian to the use of the Services and acceptance of this Privacy Policy.

Exercise of data protection rights.Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

I. confirmation of whether your data are being processed;

II. access to your data;

III. correction of incomplete, inaccurate or outdated data;

IV. anonymization, blocking or erasure of data;

V. portability of personal data to a third party;

VI. object to the processing of personal data;

VII. information of public and private entities with which we shared data;

VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. withdrawal of your consent.

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through the form "Contact". If you have any questions about the processing of your personal data, we would like to clarify them.

DPO: If you wish to reach the THINLA Data Protection Officer, please email us directly at: support@thinla.com.

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 6 months, in order to comply with legal obligations.

Egypt

If you are using our services in Egypt, the following additional terms apply.

• You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged THINLA's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

India

If you are using our services in India, the Platform is provided and controlled by THINLA SG PTE. LTD. THINLA is our brand for providing and promoting the services.

Indonesia

If you are using our services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall apply.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:

• you must obtain approval from your parent(s) or legal guardian(s); and
• your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iv) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.
• If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.
• Your Choices. You may withdraw your consent to THINLA's disclosure of personal data to third parties. Upon your request, we will ease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of THINLA features and functionality.

You may request THINLA to (i) disclose history of personal data that we have collected; and/or (ii) erase and dispose your personal data that we have collected on our server. Please note that by requesting us to erase and dispose your personal data, you may not be able to use some of THINLA features and functionality.

To exercise any of your rights, please email us directly at: support@thinla.com.

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

Israel

If you are using our services in Israel, the following additional terms apply.

• You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged THINLA's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

Mexico

If you are using our services in Mexico, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

How we use your personal data.

Almost all purposes of processing stated in Section 3 of the main Privacy Policy are necessary purposes. However, the following are secondary purposes:

• Provide you with personalized advertising.

The above purposes are not necessary for us to provide the Platform but allows us to provide you with a better experience. We offer you the possibility to take decisions regarding how we use and disclose your personal data. You can always limit the secondary purposes of personalized advertising by using the tools in Settings that allow you to limit certain functions.

We use both human and automated means to process your data.

How we share your personal data.

We may share your personal data to a third party for purposes other than processing on behalf of us. We will obtain your consent for such share as required by applicable laws.

By providing us with your personal data and using our Platform you agree to the transfers that require your consent. You can always revoke your consent and exercise your rights, as stated below.

Your Rights.

You have the following rights with respect to your personal data: access, rectification, cancelation, opposition, consent withdrawal, limitation to the use and disclosure of your data. You can exercise your rights by emailing us directly at: support@thinla.com. To know more about the applicable requirements and procedure to exercise your rights, contact us to the mentioned email address. If you are under 18 years, you may exercise your rights through a parent or guardian. Your rights requests will be resolved as soon as possible according to the nature of your request.

Information relating to children.

You may review our parental consent section in the Terms of Service.

Philippines

If you are using our services in Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

Your Rights.To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Russia

What are legal grounds for data processing. When we process your personal data, we rely on your consent, performance of a contract, our legitimate interest and obligations to process personal data, when we so required by law.

By signing up and using the Platform, you consent to the processing of personal data in accordance with this Privacy Policy.

Where we store your personal data. Your personal data may be transferred from Russia to China or Singapore and stored in that location, outside of the country where you live.

Public profiles.We rely on your consent to public distribution of personal data, when your account settings are 'Public Profile'. You can change your profile to private by changing your settings to 'Private Account' in “Manage my account” settings.

South Africa

If you are using our services in South Africa, the following additional terms apply.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged TikTok's Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

South Korea

If you are using our services in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

• How we share your personal data.In addition to the main text of this policy, in the event we use information such as user-generated content and video content on our Platform as part of our advertising and marketing campaigns to promote the Platform, your personal data contained in such information may be disclosed to the recipients of such advertising or marketing content.
• Customized Ads. We may from time to time provide customized ads on our Platform to provide you our Platform for free.
• Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this privacy policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:
• Act on Consumer Protection in Electronic Commerce
• Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years
• Records on the handling of consumer complaints or disputes: 3 years
• Records on advertisements and labels: 6 months
• Protection of Communications Secrets Act
• Records on your visits to our website: 3 months
• Destruction of Personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department.
• Your Rights.
• Data rights. You have the right to access personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by emailing us directly at: support@thinla.com.
• Data Security. We work hard to protect THINLA and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal data on a need-to-know basis and controlling access to the facilities where personal data is processed.
• Information Relating to Children. THINLA is not directed at children under the age of 14.
• Entrustment and/or Overseas Transfer of Personal Data. We entrust your data to our affiliates, cloud storage providers, IT service providers, and data centers, some of whom are located abroad (See the Korean language Privacy Policy), subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Service, by contacting us at support@thinla.com.
• Local representative pursuant to the Personal Information Protection Act
• Please send your inquiries by contacting us at support@thinla.com.

Turkiye

If you are using our services in Turkiye, the following additional terms apply along with the contents of the foregoing Policy. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Data Controller Representative.You may contact our data controller representative by email us at support@thinla.com.

Legal bases for the processing your personal data. THINLA relies on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:

• processing is explicitly laid down or dictated by laws
• processing of your personal data is necessary provided that it is directly related to the conclusion or fulfilment of the contract between us
• processing is mandatory for us to be able to comply with our legal obligations
• the relevant data is made available to the public by yourself
• processing is mandatory for the establishment, exercise or protection of a right
• processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms
• your explicit consent (Please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above)

Your rights.According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:

• the right to learn whether we process your personal data;
• the right to request information with regard to such processing, if we process your personal data;
• the right to learn the purposes of the processing and whether they are used for such purpose or not;
• the right to know the third parties within or outside the country, to whom we transfer your personal data;
• the right to request correction of incomplete or inaccurate personal data;
• the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law;
• the right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items;
• the right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means;
• the right to claim indemnification for damages incurred due to illegal processing of your personal data.

You may exercise your rights listed above by email us at support@thinla.com.

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

Amendments. The following sections of the Policy do not apply to individuals in Turkiye:

The following sentence at the end of the second paragraph of the introduction section: If you do not agree with this policy, please do not use this Platform.

The following sentence at the end of the Summary section: By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect and process it.

The following sentence at the end of the first paragraph of the Cookies section: By using the Platform, you consent to our use of Cookies.

United Arab Emirates

If you are using the Platform in the United Arab Emirates (“UAE”), the following additional terms apply. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:

How we share your personal data

In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.

Governing law and dispute resolution

By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:

• where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and
• for all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

Vietnam

If you are using our services in Vietnam, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Age, Parental and Guardian Consent.By accessing and/or using this Platform, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:

• you must obtain approval from your parent(s) or legal guardian(s); and
• your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.