Last update: [2023/09/25]
Welcome to ChatWiz.
Introduction
This privacy policy ("Privacy Policy") applies to the personal information that ChatWiz processes in connection with ChatWiz browser plug-ins apps, websites, software and related services (the “Platform”), that link to or reference this Privacy Policy.
Data Controller: The Platform is provided and controlled by OpenFront Pte. Ltd.,with its registered address in Singapore (“we”or “us”). If you have any questions about how we use your personal data, please contact [contact@chatwiz.com]
What Information We Collect
We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.
Information You Provide
When you create an account, input content, contact us directly, or otherwise use the Platform, you may provide some or all of the following information:
• Your profile information. We collect information that you provide when you create an account, such as your age, username.
• User Content. When you interact with our Platform, we may collect text, audio, uploaded files, feedback, or other content that you input or otherwise provide to our Platform ("User Content").
• Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, feedback or inquiries about your use of the Platform or information about possible violations of our (our “Terms”) or other policies.
Automatically Collected Information
• Technical Information. We collect certain device and network connection information when you access the Platform. This information includes your device model, operating system, keystroke patterns or rhythms, IP address, and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.
• Location Information. We automatically collect information about your approximate location (e.g. country, state, or city) based on your Technical Information (such as SIM card region and IP address). Also, where you enable location services for the ChatWiz app within your device settings, we collect approximate location information from your device.
• Usage Information. We collect information about how you engage with the Platform, including information about the bots you chat with, the duration and frequency of your use, your chat and search history and your settings.
• Inferred Information. We infer your attributes (such as age-range and gender) and interests based on the information we have about you. We use inferences, for example, to keep the Platform safe, and for content moderation.
• Cookies. We use cookies and similar tracking technologies to operate and provide the Platform. For example, we use cookies to remember your language preferences, make sure you don’t see the same content more than once, and for security purposes. We also use these technologies for marketing purposes.
Information from Other Sources
• Log-in, Sign-up, or Linked Services. Where available, if you choose to sign-up or log-in to the Platform using a third-party service such as Apple, Facebook, Google, and TikTok, or link your account to a third-party service, we may collect information from the service–for example, your public profile information such as username, email, and profile picture.
• Advertising, Measurement and Other Partners. Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform with your ChatWiz account.
How We Use Your Information
We use your information for the period required to operate, provide, develop, and improve the Platform, including for the following purposes.
• Provide and administer the Platform, such as enabling you to chat with various robots, to use different tools, and provide user support.
• Enforce our Terms, Guidelines, and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.
• Maintain and enhance the safety, security, and stability of the Platform by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
• Review, improve, and develop the Platform, including by monitoring interactions and usage across your devices, reviewing and analyzing User Content, and training and improving our technology, such as our machine learning models and algorithms.
• Share your information with third party platforms to provide you with features, such as the User Content you input when using the platform when you use chatbots.
• Promote the Platform or third party services through marketing communications, contests, or promotions.
• Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.
How We Share Your Information
Service Providers
We engage service providers that help us provide, support, and develop the Platform and understand how it is used. They provide services such as cloud hosting, customer and technical support, content moderation, marketing, and analytics. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.
Many of our AI-powered services rely on service providers. For example, we use Microsoft Azure to help provide chatbot services powered by generative AI models such as large language models. We share the User Content you input into the Platform with these service providers in order to generate responses referred to as outputs. We also share your voice inputs with Microsoft to process your voice into text using automated speech recognition to improve your experience using the Platform.
Business Partners
Third Party Platforms and Partners. We share limited information which may include Information You Provide, Technical Information, and Usage Information with third party platforms and partners whose platform or services are integrated with the Platform. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users. For example, we will share certain Technical Information if you sign-up or log-in to the Platform using your account details from a third party platform such as Apple, Facebook, Google, or TikTok.
Advertising and Analytics Partners. We may share information collected through your use of the Platform with our advertising or analytics partners. These partners help us promote the Platform through advertising displayed on other platforms, some of which, in some jurisdictions, may be based on your activity across other sites and services. These partners may also help us and our partners measure the effectiveness of our advertising campaigns.
Our Corporate Group
As a global company, the Platform is supported by certain entities within our corporate group (“Corporate Group”). These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us, as necessary to provide certain functions, such as storage, content delivery, security, research and development, analytics, customer and technical support, and content moderation.
Others
We share your information in other limited scenarios as follows:
Other Users and the Public. Based on your privacy settings, your Profile Information may be visible to other users and the public. Your profile and content may also be visible to third parties, such as search engines, content aggregators, and news sites. You and other individuals may be able to share your User Content both on and off the Platform, depending on the choices you make in your privacy settings.
Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.
Legal Obligations and Rights. We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:
• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards,
• protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,
• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or
• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.
With Your Consent
Depending on where you live, we may share personal information with the proper authorization or to provide the Platform you have requested or authorized. For example, if you choose to log in to our Platform using a social network account, or share information from our Platform to a social media service, we will share that information with those platforms.
Third-party content. As noted above, we may share your data with third parties and the Platform may contain links to policies, functionality, or content maintained by third parties we do not control. We are not responsible for the privacy practices of third parties and the information practices of these third parties are not covered by this Privacy Policy.
Your Rights and Choices
Depending on where you live, you may have certain rights with respect to your personal information, such as a right to know how we collect and use your personal information. You may also have a right to access, change, oppose, request a copy of your authorization, file complaints before the competent authorities, withdraw your consent, or limit our collection and use of your personal information as well as to request that we delete it, and potentially others. In certain circumstances, you can also ask us to provide additional information about our collection and use of your personal information. Please note that your exercise of certain rights may impact your ability to use some or all of ChatWiz's features and functionalities.
If you register for an account, you may be able to access, review, and update certain personal information you have provided to us by logging into your account directly and using available features and functionalities. For example, you can control, access or delete some of your personal information directly through your in-app settings.
Please contact us by using the contact information provided in the “About Us” section if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.
Data Security
Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.
Data Retention
We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.
The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Platform, we keep this information for as long as you have an account. This information includes your Profile Information and User Content. If you violate our Terms, we may remove your Profile Information and/or User Content from public view immediately but keep your information as necessary to process the violation.
International Data Transfers
We store the information we collect on secure servers located in Malaysia. Where we transfer any personal information out of the country where you live, including for one or more of the purposes set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws.
Information relating to children under 18
The Platform is not directed at children under the age of 18. If you believe that we have personal information about or collected from a child under the age of 18, please contact us at [contact@chatwiz.com].
Privacy Policy Updates
We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you when required to do so by updating the date at the top of the new Privacy Policy, posting the new Privacy Policy, or by providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Platform to stay informed of our privacy practices.
Contact Us
Questions, comments and requests regarding this Privacy Policy should be addressed to:[contact@chatwiz.com].
Supplemental Terms - Jurisdiction-Specific
Brazil
If you are using our Platform in Brazil, the following additional terms apply:
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:
• confirmation of whether your data are being processed;
• access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or erasure of data;
• portability of personal data to a third party;
• object to the processing of personal data;
• information of public and private entities with which we shared data;
• information about the possibility to refuse providing personal data and the respective consequences, when applicable;
• 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.
In case of doubt about your privacy, your rights or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal data, we would like to clarify them.
International Transfer of Data. We share your personal data globally with companies of our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Platform or share your personal data with third parties located in other countries. Your personal data may therefore be subject to privacy laws other than those applicable in your country.
Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards to protect your personal data and to ensure that it is processed safely.
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 Platform 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 Platform and acceptance of this Privacy Policy.
Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
DPO. If you wish to contact the Data Protection Officer, please contact us: dpobrasil@bytedance.com
Japan
If you are using our Platform in Japan, please refer to our Japanese language Privacy Policy for further information on our compliance with the Telecommunications Business Act.
Mexico
If you use our Platform in Mexico, the following additional terms apply. In the event of a 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 of the purposes of the processing data indicated above in the main section of this Privacy Policy are necessary purposes. However, the following are secondary purposes:
• To provide you with personalized advertising.
The above purposes is/are not necessary to provide the Platform, but allows us to provide you with a better experience. We offer you the ability to make choices about how we use and disclose your personal data. You can always limit the secondary purposes of personalized advertising by using the tools in the Settings that allow you to limit certain features.
We use both human and automated means to process your data.
How we share your personal data. We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.
By providing us with your personal data and using our Platform, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights as outlined below.
Language. The Policy may have been prepared in the English language and in the Spanish language. If you are a user located in Mexico, you shall refer to the Spanish version, which shall prevail.
Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, opposition, revocation of consent, limitation of use and disclosure of your data. You may exercise your rights by sending your request to [contact@chatwiz.com]. To learn about the applicable requirements and the procedure for exercising your rights, please contact us at the above email address. If you are under 18 years of age, you may exercise your rights through a parent or guardian. Requests to exercise for your rights will be resolved as soon as possible according to the nature of your request.
Vietnam
If you are using our Platform in Vietnam, the following additional terms apply:
Age, Parental and Guardian Consent. By accessing and/or using the Platform, you represent that you are at least 18 years of age or not under guardianship. If you are below 18 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.