PRIVACY POLICY

This policy sets out:

(1) the information we collect about you when you visit our website, use our products or services, or otherwise interact with us;
(2) how we use, share, store, and secure the information; and
(3) how you may access and control the information.
In this policy, “Top Ease Asia Investment Limited” or “we” refers to Top Ease Asia Investment Limited of 12/F 3 Lockhart Road, Wan Chai, Hong Kong SAR and “Platform” means our website athttps://getserenityapp.com.

In this policy, “personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services, that relates to an identifiable individual.

WHAT INFORMATION WE COLLECT ABOUT YOU
1. We collect the following types of information about you:
  - (a) account and profile information that you provide when you register for an account or sign up for our products or services, for example It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below. Information you give us You choose to give us certain information when using our services. This includes: When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth. When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information. When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information. When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials. When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter. If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service. If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request. Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details: Usage Information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive). Device information We collect information from and about the device(s) you use to access our services, including: hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses.(collectively, “Account Data”);
  - (b) information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
  - (c) communication, marketing, and other preferences that you (collectively, “Preference Data”);
  - (d) details of any transactions, purchases, or orders that you've made with us (collectively, “Transaction Data”);
  - (e) payment information, for example payment information, for example We may offer products and services for purchase (“in app purchases”) through iTunes, Google Play or other application platforms authorized by Tinder (each, a “Software Store”). If you choose to make an in app purchase, you will be prompted to enter details for your account with your Software Store (“your IAP Account”), and your IAP Account will be charged for the in app purchase in accordance with the terms disclosed to you at the time of purchase as well as the general terms for in app purchases that apply to your IAP Account. Some Software Stores may charge you sales tax, depending on where you live. If you purchase an auto-recurring periodic subscription through an in app purchase, your IAP Account will continue to be billed for the subscription until you cancel. After your initial subscription commitment period, and again after any subsequent subscription period, your subscription will automatically continue for an additional equivalent period, at the price you agreed to when subscribing. If you do not wish your subscription to renew automatically, or if you want to change or terminate your subscription, you will need to log in to your IAP account and follow instructions to cancel your subscription, even if you have otherwise deleted your account with us or if you have deleted the Tinder application from your device. Deleting your account on Tinder or deleting the Tinder application from your device does not cancel your subscription; Tinder will retain all funds charged to your IAP Account until you cancel our subscription through your IAP Account. (collectively, “Financial Data”);
  - (f) information about your device or connection, for example When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details: • Usage Information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive). • Device information We collect information from and about the device(s) you use to access our services, including: o hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); o information on your wireless and mobile network connection, like your service provider and signal strength; o information on device sensors such as accelerometers, gyroscopes and compasses. • Other information with your consent If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services). • COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES • We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools. • Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including our service, do not currently respond to DNT signals. • and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data”); and
  - (g) Information about your use of or visit to our Platform, for example When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details: • Usage Information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive). • Device information We collect information from and about the device(s) you use to access our services, including: o hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); o information on your wireless and mobile network connection, like your service provider and signal strength; o information on device sensors such as accelerometers, gyroscopes and compasses. • Other information with your consent If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services). • COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES • We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools. • Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including our service, do not currently respond to DNT signals. • (collectively, “Usage Data”).
2. We collect the above information when you provide it to us or when you use or visit our Platform. We may also receive information about you from other sources, including:
  - (a) our personnel, agents, advisors, consultants, and contractors based in Hong Kong SAR of China, India, Germany in connection with our operations or services, for example our staff engaged in the fulfilment of your order, processing of your payment, and provision of support services;
  - (b) other services linked to your account, for example If you register / log ing your account using Facebook, we receive your name, e-mail address other info through Facebook. So does Instagram.;
3. We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.
HOW WE USE INFORMATION WE COLLECT
1. We only use your personal information where the law allows us to. We use your personal information only where:
  - (a) we need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to provide customer support and personalised features, and to protect the safety and security of our Platform;
  - (b) it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests
  - (c) you've given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
  - (d) we need to comply with a legal or regulatory obligation.
2. If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us (please refer to paragraph 8.for contact information), but please note this will not affect any use of your information that has already taken place.
3. We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.
4. For visitors to or users of our Platform who are located in the European Union, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this policy.
HOW WE USE INFORMATION WE COLLECT
1. We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.
2. If you use any third-party software in connection with our products or services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software
3. Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.
4. We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
5. If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.
HOW WE STORE AND SECURE INFORMATION WE COLLECT
1. We use data hosting service providers based in __________to host the information we collect.
2. We have adopted the following measures to protect the security and integrity of your personal information:
  - (a) information is encrypted using TLS/SSL technology;
  - (b) access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and
  - (c) our information collection, storage, and processing practices are reviewed regularly.
3. We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
4. While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.
5. We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After declaration by user to delete his account along with the personal information, we permanently delete all the personal information of the user like name, password, email, phone. We shall keep the access data of the users for analytics and reporting purposes. . We periodically review the basis and appropriateness of our data retention policy.
YOUR RIGHTS
1. You have the right to:
  - (a) be informed of what we do with your personal information;
  - (b) request a copy of personal information we hold about you;
  - (c) require us to correct any inaccuracy or error in any personal information we hold about you;
  - (d) request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
  - (e) object to or restrict the processing by us of your personal information (including for marketing purposes);
  - (f) request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
  - (g) withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).
2. You may opt out of receiving marketing materials from us For all the transactional or marketing emails, users can opt-out of receiving mails from system by using the unsubscribe link in our communications, by updating your preferences within your account on our Platform, or by contacting us.. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.
3. As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.
4. Any request under paragraph 5.1will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.
5. We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.
CHANGES TO THIS POLICY
- We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.
POLICY TOWARDS CHILDREN
- Our products and services are not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If we become aware that an individual under 18has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 18.

- Please contact us at enquiry@topeaseintl.comor submit any written request to:
- Top Ease Asia Investment Limited
- 12/F 3 Lockhart Road, Wan Chai, Hong Kong SAR
- Attn: Officer, Digital Marketing Research / Development

Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed.
Last updated: 19th April 2021
COOKIES POLICY
Cookies are small text files that are placed on your device by a web server when you access our Platform. We use cookies to identify your access and monitor usage and web traffic on our Platform to customise and improve our products and services.
We use both persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session lasts (usually the current visit to a website or a browser session).
We use the following types of cookies:
(a) Strictly necessary cookies – these are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our website.
You can block cookies by activating the setting on your browser that allows you to refuse the use of all or some cookies. However, if you do so, you may not be able to access all or parts of our site.

LEGAL BASES TABLE

Processing purpose	Type of data processed	Legal basis
To register you as a user on our Platform	Account Data	To perform our contract with you
To enable you to use our products and services	Account Data, Transaction Data, Support Data, Technical Data [and User Content]	To perform our contract with you
To process your payments	Account Data, Transaction Data, Financial Data	To perform our contract with you
To collect overdue amounts	Account Data, Transaction Data, Financial Data	Account Data, Transaction Data, Financial Data
To notify you about changes to our products, services, or terms	Account Data	To perform our contract with you
To administer and maintain safety and security of our Platform	Technical Data	To perform our contract with you
To study usage of our products or services	Transaction Data, Support Data, Technical Data, Usage Data	Legitimate interest to improve our Platform, products, and services
To gather feedback on our products, services, or features	Account Data	Legitimate interest to improve our Platform, products, and services
To provide information on products or services that may be of interest to you	Account Data, Preference Data	Consent, which you may withdraw any time