1.1. Vonvon Inc. recognizes the importance of privacy and is committed to maintaining confidentiality of your personal information. This Privacy Policy applies to engaging contents provided by Vonvon Inc. (hereinafter referred to as „Service“) for its users (hereinafter referred to as “you”, “your”, etc.), including quizzes, personality tests, articles, and casual games.
1.2. This Privacy Policy also applies to the use of our Service via mobile device and/or through mobile-optimized website.
1.3. The Privacy Policy is available to the public at all times, so you may read the full text of the Privacy Policy on Vonvon’s website whenever you need or want to do so. Vonvon will notify you of any changes to the Privacy Policy by posting an amended version or amendments to its website.
2.1. The controller of the personal data is Vonvon Inc., registration no 144-81-35166, incorporated in the Republic of Korea (hereinafter referred to as "we", "us", "our" or "Vonvon"). Our contact information for queries related to personal data processing:
Phone: +82-2-555-8982E-mail: privacy+vv@vonvon.me
3.1. You shall have the right to communicate with our data protection officer in order to obtain information on the processing of your personal data, using the following contact information:
E-mail:privacy+vv@vonvon.me4.1. Personal data are information that can be used to directly or indirectly uniquely identify, contact, or locate you as a private individual (hereinafter referred to as "Personal Data"). The source of collected Personal Data depends on which functionality of the Service you use.
4.2. Basic Personal Data. We may process the following data provided by you: picture stored in mobile phone selected by you, age, your answers to quizzes, taken quizzes ID, quizzes (including pictures and questions) created by you, etc. (hereinafter referred to as "Basic Personal Data").
Source: Personal Data you directly provide to us. Using our Service enables you to disclose us information that may enable us to identify you personally.
4.3. Technical Data. We may process the following technical data: IP address (including location based on the IP address), access-provider, referring URL, date, time, access tokens, browser type and version, operating system, amount and state of transferred data, location data, etc. (hereinafter referred to as "Technical Data").
Source: While you are using our Service, we generate or collect some information from your device automatically via Service logs.
4.4. Personal Data we receive from third parties or through the use of third party solutions. We may process Personal Data provided by third parties mentioned in Section 9 of this Privacy Policy (for example upon creating an account or logging in via Facebook, Instagram, Twitter) (hereinafter referred to as "Third Party Service Provider") and are publicly available on your profile. We may process the following Personal Data provided by third parties: Basic Personal Data, name, username, e-mail address, profile picture, login ID, gender, age range, pictures in your Facebook album, info about the places tagged in them, and the types of reactions they receive, profile information that is available publicly and made accessible by you (see further information about third party log in from Section 9 of this Privacy Policy), etc. (hereinafter referred to as "Personal Data From Third Parties")
Source: Third Party Service Providers that you choose to log in with to use the Service and your publicly available profiles set up with those Third Party Service Providers. If you use a third party to log in or create account for our Service, we will receive personal data via that third party only when you have consented to that third party sharing your personal data with us.
4.5. Cookies. We also use cookies for providing our Services via the Internet. In order to receive more information about cookies and how we use them, please see our cookie policy
5.1. Our legal basis to process your Personal Data depends on the objective and context in which we collect the Personal Data. As we recognize the importance of privacy, we collect a minimum amount of Personal Data which is necessary for providing the Service.
5.2. For easier understanding, we have grouped all objectives for processing your personal data on four legal grounds: performance of a legal obligation, performance of a contract, our legitimate interest and your consent.
5.3. If we refer to our legitimate interest as legal basis for processing your personal data, this means first and foremost the objective of improving, providing, developing and promoting the Service and carrying through marketing analysis. Under legitimate interest we also process and share your publicly available Personal Data From Third Parties with your Facebook friend through our Service, whilst he or she is taking a quiz in our Service which requires friends’ data to generate the answer. Such processing has the objective of providing the Service (especially generating the quiz results).
5.4. If we refer to your consent as legal basis for processing your personal data, this means first and foremost the objective of ensuring an effective user experience by adjusting content, as without your consent we would not be able display personalized marketing adverts nor tailor our Service to meet your habitual preferences.
5.5. If we refer to performance of a contract as a legal basis for processing your personal data, this primarily means the objective of providing you an access to use our Service pursuant to the Terms of Service , since this cannot be achieved without processing your personal data.
| Processing purpose | Legal basis for the processing purpose | Categories of personal data used by us for the processing purpose |
|---|---|---|
| Providing the Service by allowing your log in through Third-Party Service Providers | Performance of the Terms of Service | Personal Data From Third Parties |
| Providing the Service by allowing you to share quiz results via Third-Party Service Provider | Performance of the Terms of Service | Basic Personal Data; Personal Data From Third Parties |
| Providing the Service (including allowing you to create a quiz) | Performance of the Terms of Service or Legitimate interest in providing the basic functionalities of the Service (depending whether you are logged in or not) | Basic Personal Data; Personal Data From Third Parties |
| Operation, security and optimization of the Service | Legitimate interest in providing data security and preventing fraudulent actions | Technical Data |
| Improve, personalise and develop the Service | Legitimate interest in developing and enhancing the Service and the user experience in the course of regular business activities | Basic Personal Data; Technical Data |
| Storing and using automated decision making to profile your preferences (e.g. suggest quizzes) and provide you quiz suggestions, through the usage of cookies and similar technologies | Consent | Basic Personal Data, Technical Data |
| Creating quiz results page when utilising FaceApp (see further information Section 10 of this Privacy Policy) | Consent | Basic Personal Data; Personal Data From Third Parties, Technical Data |
| Sharing your personal data with third parties for marketing purposes, through the usage of cookies | Consent | Basic Personal Data, Technical Data |
| Creating user profile in order to adjust our Service and its contents with your demands, expectations or interests, e.g. for advertisement purposes | Legitimate interest in enhancing the user experience in the course of regular business activities | Basic Personal Data, Personal Data From Third Parties, Technical Data |
| Identifying your location in order to determine the legally permissible minimum age of giving consent in the country from which you use our Service | Performance of a legal obligation | Technical Data |
| Displaying third party content provider’s content to your browser | Consent | Technical Data |
| Sharing your publicly available Personal Data From Third Parties to your Facebook friend also using the Service in order to provide the Service and generate quiz results | Legitimate interest in providing the basic functionalities of the Service | Personal Data From Third Parties |
| Communicate our Terms of Service, Privacy Policy and notify you of changes to them | Performance of a legal obligation | Basic Personal Data, Technical Data |
| Providing customized customer service and direct marketing via e-mails / IP addresses (for US based users only) | Legitimate interest in providing efficient user support and promoting Services in the course of regular business activities | Personal Data From Third Parties, Technical Data |
5.6. We may process your data for other purposes, provided we disclose the purposes and use to you at the relevant time, and that you either consent to the proposed use of your Personal Data or the new purpose is compatible with the original purpose brought out herein.
5.7. We use the information we receive about you in order to adjust our Service and its contents with your demands, expectations or interests, whereby your individual user profile may be created. For this purpose, we use the data that we receive about you as described in Section 4 of this Privacy Policy and then analyze it via algorithmic functions.
6.1. If you are a resident of the European Union or European Economic Area, you have the following data protection rights, which you can exercise by contacting us via contact information referred to in Sections 2 and 3 of this Privacy Policy. You have the right to:
6.1.1. request us to provide access to your Personal Data, rectify them if they are inaccurate, or demand the erasure thereof. We will at any time provide you with information on your personally identifiable data stored by us, free of charge (to the extent obliged by applicable legislation) and without undue delay, taken into account the statutory timeframes.6.1.2. request restriction of the processing of the Personal Data in respect of them, or the right to object to the processing if it is based on our legitimate interest or for the purposes of direct marketing, as well as the right to portability of your Personal Data (transmission of the Personal Data to another legal or natural person), including by electronic means.
6.1.3. lodge complaints to the respective data protection authority if your data protection rights have been violated.
6.1.4. not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce significant effect.
6.1.5. withdraw your consent to the processing of your Personal Data in the cases where the legal basis for Personal Data processing is your consent. For withdrawing your consent, you may use the contact information referred to in Sections 2 and 3 of this Privacy Policy.
6.2. Please note that you will need to provide sufficient information for us to evaluate your request regarding your rights brought out in Section 6.1. of the Privacy Policy and we may ask you to provide additional information prior to authenticating you and as a condition for evaluating your request.
7.1. Only authorised processors and selected recipients have access to the personal data and they may access the data only for the purpose of conducting the assisting in the providing of the Service and resolving issues associated with the Vonvon website.
7.2. We do not disclose any user-related data to any third parties except for:
| Categories of Recipients | Reason for sharing |
|---|---|
| Third Party Service Providers | To provide you possibility to log in to our Service via Third Party Service Provider as described in Section 9 of this Privacy Policy; To provide you the Service as described in 12; Sharing any content via the Service to the social media pages operated by the Third Party Service Providers, as chosen by you when using the Service. |
| Operational service providers (legal advisors, auditors etc. bound to confidentiality) | Ensuring adequate Service and functioning of the Website; enforcing the Terms of Service. |
| Law enforcement and data protection authorities | We will share your data if it is necessary to comply with our legal obligation under applicable law. |
| Purchaser of our business | In case we sell or negotiate to sell our business to a buyer or prospective buyer, we might share your personal data. In such situation we will especially ensure the confidentiality of your personal data and give you notice prior to disclosing your personal data, if it is possible and required. |
| Your Facebook friends who also use the Service | Certain quizzes in our Service need the input from your Facebook profile in the form of publicly accessible information. The foregoing means that in case your friend is the Service user and takes a quiz which requires friends’ data, your publicly available Personal Data From Third Parties will be processed solely in the context of the specific quiz. |
| Third party content providers (e.g. YouTube (Google Inc.)) | Only if you click on third party content displayed on our Service, we will share some of your Technical Data (e.g. IP address) with the third party content provider, because without your Technical Data, they cannot send the content to your browser. |
| FaceApp Inc. | To allow FaceApp generate your quiz result as described in Section 10 of this Privacy Policy. |
7.3. In addition to the third parties brought out in Section 7.2. of the Privacy Policy, we may transfer Personal Data to third party service providers who act as processors and may operate the technical infrastructure that we need to host, store manage and maintain the Service, its contents and the data that we process, also to provide data backup and security. The following depicts a list of authorised processors, their location and their reason for processing:
| Authorised Processor | Processing purpose | Safeguard | Location | Website |
|---|---|---|---|---|
| Cloudflare Inc. | We use Cloudflare (a content delivery network) to help us deliver contents of our Service faster, especially big media files like imager or scripts using a world-wide distributed server network. Protection against and mitigation of DDos attacks | EU-U.S. Privacy Shield | USA | https://www.cloudflare.com/ |
| Amazon Web Services Inc. | Technical infrastructure we need in order to provide the Service (storage) | EU model clauses; EU-U.S. Privacy Shield | USA (databases in Japan) | https://aws.amazon.com/ |
| Google Cloud Platform (Google Inc.) | EU-U.S. Privacy Shield | USA (databases in Belgium) | https://cloud.google.com/ |
7.4. If, within the framework of this Privacy Policy, contents, tools or other means and mediums are used by Third Party Service Providers (including FaceApp in the context of Section 9 of this Privacy Policy) and whose registered office is abroad, it is assumed that your data will be transferred to the countries where the registered offices of the Third Party Service Providers are located. We do not control Third Party Service Providers, thus we encourage you to read their privacy policies so that you understand how they process information about you.
7.5. In some cases, we may transfer your Personal Data outside the European Union or European Economic Area (e.g. merged face picture as a quiz result is stored in Japan), if the respective operational services are provided outside the European Union. We shall opt to use special personal data protection safeguards, in order to provide you the Service safely. You shall have the right to get acquainted with or obtain information on the transferring of your personal data outside the European Union or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in Sections 2 and 3 of this Privacy Policy.
8.1. Your information (all data categories mentioned in Section 4) shall be stored insofar as reasonably necessary to attain the objectives stated in Section 5 of this Privacy Policy, or until the legal obligation stipulates that we do so. The following is a non-exhaustive summary with examples on storing your personal data:
8.1.1. Log-in data, such as login ID, username, gender and age range, profile picture, type of social network service used to log into the Service will be kept for 90 days as of the last usage of Service.8.1.2. Third Party Service Provider log in access token will be kept for 30 days as of logging in or upon you log out of the Service, whichever occurs earlier.
8.1.3. Quiz input data in a form of your public profile created in Third Party Service Provider, such as username, URL of profile picture, profile data will be kept for 30 days as of taking the last quiz of the session.
8.1.4. The quiz you created, including uploaded photos, questions and answer-options inserted by you, will be kept until you delete your Service account or for 3 years as of creating the quiz, whichever occurs earlier.
8.1.5. The quiz you created in style of “Me quiz” (quiz about yourself), including uploaded photos, questions and answer-options inserted by you, will be kept until you delete your Service account or for 30 days as of creating the quiz, whichever occurs earlier.
8.1.6. Following data will be kept for 30 days as of taking the quiz:
8.1.6.1. Your answers to quizzes, taken quiz ID;
8.1.6.2. Quiz results, including picture generated with the FaceApp;
8.1.6.3. Twitter ID, publicly available name, profile picture etc;
8.1.6.4. Facebook ID, name, gender, profile picture, etc. shared with your friend;
8.1.6.5. Uploaded picture or picture chosen from Facebook album or your profile picture used by your friend for taking a quiz; and
8.1.6.6. Uploaded picture or picture chosen from Facebook album for the purposes of using FaceApp function and the quiz generated output picture (see Section 10.2).
8.1.7. Technical Data (excluding IP address for US users) is kept for 30 days as of the creation of an event.
8.1.8. Your e-mail address and IP address will be kept until you delete your Service account or for 3 years as of obtaining your e-mail address and IP address, whichever occurs earlier.
8.2. After the term mentioned in 8.1., we will delete your information immediately.
8.3. If you choose to delete your Service account, your personal data (all categories specified in Section 4 of this Privacy Policy) will be deleted within a day.
9.1. You can log in by using authentication services of Third-Party Service Providers (hereinafter referred to as “authentication by a third-party”). Particularly Facebook, Twitter, or Instagram can be possible authentication service providers.
9.2. As a requirement for the authentication through a Third Party Service Provider, you should be registered at the respective Third Party Service Provider and enter the necessary login details in the appropriate web formula or should be already logged in to one of the following Third Party Service Provider:
9.2.1. Facebook. You can log in using your Facebook account. If you log in using Facebook, you will be redirected to Facebook landing page, where Facebook will ask your consent to share certain information from your Facebook account with us. This includes your Facebook user ID (user identification number), username (Facebook URL), name, profile picture, cover picture, networks (e.g. school or working place), age designation and other publicly available data on your profile (only if these data elements are public according to your Facebook privacy settings).9.2.2. Twitter. You can log in using your Twitter account. If you log in using Twitter, you will be redirected to Twitter landing page, where Twitter will ask your consent to share certain information from your Twitter account with us. This includes your user ID, name, profile picture, account creation date, tweets and the other accounts you are following.
9.2.3. Instagram. You can log in using your Instagram account. If you log in using Instagram, you will be redirected to Instagram landing page, where Instagram will ask your consent to share certain information from your Instagram account with us. This includes your user ID, name, username, profile photo, and your photos.
9.3. The aforementioned information is collected by a respective Third Party Service Provider and is disclosed to us under the terms of Facebook’s Privacy Policy (https://www.facebook.com/policies/) or Twitter’s Privacy Policy (https://twitter.com/privacy) or Instagram’s Privacy Policy (https://instagram.com/legal/privacy You can control the data that we receive from these Third Party Service Providers by changing the privacy and data settings in your respective account. The password that has been entered in the context of the authentication via Third Party Service Provider landing page cannot be seen by us.
9.4. You are asked to keep in mind that your data, which we save, can be compared and synchronized with your user account at the Third Party Service Provider automatically. There is no obligation however for us to update the data.
9.5. In the case you decide that you do not wish to further use the connection of your user account at the Third Party Service Provider for the authentication by a Third Party Service Provider, you must cancel this connection within your user account at the Third Party Service Provider and these are deleted
10.1. We use the service of the provider FaceApp (https://www.faceapp.com privacy policy: https://www.faceapp.com/privacy to process pictures uploaded by you to our Service and your Facebook profile pictures, if that is your preference. FaceApp analyzes the pictures and edits them based on the function of the game/quiz in question (e.g. prediction of how the person depicted would look if they were old).
10.2. The processing of your personal data resulting from the picture is carried out by FaceApp for the sole purpose of the selected function. The original picture you provided us is only stored temporarily in FaceApp server and is then deleted within five days. Data other than the picture will not be transferred to FaceApp. The data is transmitted via an interface to FaceApp, so that FaceApp cannot collect your data any further (e. g. no IP address, cookies, etc.). Your picture will be shared with FaceApp only if you provide your explicit consent.
10.3. The use of FaceApp functions is only permitted if you have reached the minimum age required for consent. The minimum age is generally 16 years, but it may be vary depending on the regulations of individual countries. In order to determine the legally permissible minimum age in the country from which you use our Service, we can use your IP address to determine your location.
11.1. We may display third party content such as videos from YouTube, RSS feeds, tests, games, texts, graphics, etc. from other services. Displaying third-party content usually requires implying cookies (e.g. embedded tracking cookies). In case you click on aforementioned third-party content, please understand that you are leaving our Service and any personal data you provide will not be covered by this Privacy Policy. Please read their privacy policies to find out how they collect and process your personal data. For further information about third party content provider’s cookies used on our Service, please see our cookie policy
12.1. If the Service is carried out as a Facebook application, which is operated by Facebook Inc., 1Hacker Way, Menlo Park, CA 94025, USA, your consent is required for us to access your stored data on Facebook.
12.2. You are expressly referred in the context of the Facebook consent dialog to this data collection and the data shared by Facebook with us (e.g., public profile, friends list, e-mail address and "Like" information, among others only if these data elements are viewable by the public according to your Facebook privacy settings) through the Service.
12.3. We may use the requested data anonymously for statistical purposes. I.e., if we may access the data on your Facebook chronic, posts or likes, we may evaluate how often a posting was shared or liked in order to help us improve our Services and its contents like our quizzes and personality tests. We perform the evaluation anonymously, meaning independently of your personally identifiable data we received on the basis of your consent (e.g. without the Facebook-ID). These evaluations are just for us only, without any transfers of this data to third parties.
12.4. Our Service uses social plugins (“plugins”) provided by Facebook. The plugins are usually identifiable by a Facebook logo (e.g., letter f on blue background or a thumb up icon). For a full list of all social Plugins, please see http://developers.facebook.com/doc/plugins/ .
12.5. When you visit a page of our Service that contains a social plugin, your browser establishes a direct connection to Facebook servers. Facebook directly transfers the plugin content to your browser that embeds the latter into the Service, enabling Facebook to receive information about you accessing the respective page of our Service. Thus, we have no influence on the data gathered by the plugin and inform you according to our state of knowledge: The embedded plugins provide Facebook with the information that you have accessed the corresponding page of our Service. If you are logged into Facebook, your visit can be assigned to your Facebook account. If you interact with the plugins, for example by clicking “Like”, the corresponding information is transmitted from your browser directly to Facebook and stored by it. Even if you are not logged into Facebook, there is possibility that the plugins transmit your IP-address to Facebook.
12.6. For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook’s privacy policy: https://www.facebook.com/about/privacy/. In case you want to opt out of being subject to Facebook's use of your data for marketing purposes please use Facebook's opt-out settings provided within your user profile: https://www.facebook.com/settings?tab=ads.
12.7. You are referred to Facebook’s privacy policy https//www.facebook.com/about/privacy/your-info-on-other for more information about the consent process, consent granted and ways of revoking such consent within your Facebook profile.
12.8. You have the option in the Facebook application settings to end using the Service through Facebook at any time: www.facebook.com/settings?tab=applications.
13.1. We have the right to amend or modify this Privacy Policy from time to time and, in such case, we will make a public notice of it on this Privacy Policy page and obtain consent from the users, if required by relevant laws. Please check back periodically, and especially before you provide any new personally identifiable information.