PRIVACY POLICY PRIVACY POLICY FOR INSAIT JOY / JOY BASKETBALL USERS Welcome to INSAIT JOY's Privacy Policy. Thank you for taking the time to read it. We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information.  We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design, and others to make sure that no decision is taken without respect for your privacy. We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices! We work hard to keep your information secure We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information. 1.INTRODUCTION - WHO ARE WE ? The company that is responsible for your information under this Privacy Policy (the “data controller”) is: Gengee Technology Co., Ltd. (“we,” “us,” or “our”)A3-128, No.132, Huachang Rd.Huli District, 361001Xiamen, China We respect your privacy and is committed to complying with the privacy principles contained in the applicable privacy laws and regulations for the places where we do business. 2. WHERE THIS PRIVACY POLICY APPLIES? This Privacy Policy applies to websites, apps, events and other services operated by INSAIT JOY. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services. Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy -- not this Privacy Policy -- applies. 3. WHAT TYPE OF INFORMATION DO WE COLLECT OR PROCESS? The type of information we collect or process from or about you will depend on how you or your organization interacts with us. Generally, we collect or process the following types of information, along with the corresponding basis for collection: 3.1 The information you give us  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 email and password, your profile name, gender, nationality and region, height and weight, and date of birth.  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 choose to participate in our promotions, events or contests, we collect the information that you use to register or enter. For our customers, we collect your name and contact details and information related to our professional work with you. Our legal basis for collection, use, and processing of this information is that we collect, use, and process the information types listed above to perform our legitimate business and services we provide to you. 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. Of course, we also process the content you publish, as part of the operation of the services (for example, sharing on social media your performance results or videos you’ve made). 3.2 Other Users  Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you. 3.3 Social Media or Third-Party Login You may be able to use your social media login (such as Facebook Login) to create and log into your INSAIT JOY account. This saves you from having to remember yet another username and password and allows you to share some information from your social media account with us and other users, and vice-versa.  However, please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. 3.4 Other Partners We may receive info about you from our partners, for instance where INSAIT JOY ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success). 3.5 Information collected when you use our 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: 3.5.1 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).  We collect your sports performance data during times when the INSAIT JOY product is activated, such as your performance in the drills or matches, your performance rankings and daily records. Our ability to collect, process, and use this information for the reasons stated in this document is a key part of the functionality of the INSAIT JOY product, without it the INSAIT JOY product cannot be considered fully functional. 3.5.2 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. 3.5.3 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). 3.5.4 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 INSAIT JOY, do not currently respond to DNT signals. 3.6 How do we collect your personal information? When you directly use our products or services, you, or someone on your behalf can enter information about yourself into the INSAIT JOY software, our websites, or other services. We will always try to collect your personal information directly from you where possible. Regardless of how your personal information is collected – whether it is directly from you, from your interactions with us or from third parties – we will deal with your personal information in accordance with this policy. 4. HOW DO WE USE YOUR INFORMATION? The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Generally, we use your information for:To administer your account and provide our services to youCreate and manage your accountProvide you with customer support and respond to your requestsComplete your transactionsCommunicate with you about our services, including order management and billingShow your user profile and your performance ranking/activity rankings to other usersTo ensure a consistent experience across your devicesLink the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.To provide new INSAIT JOY services to youRegister you and display your profile on new INSAIT JOY features and appsAdminister your account on these new features and appsTo serve you relevant offers and adsAdminister contests, discounts or other offersDevelop, display and track content and advertising tailored to your interests on our services and other sitesCommunicate with you by email, phone, social media or mobile device about products or services that we think may interest youTo improve our services and develop new onesAdminister focus groups and surveysConduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)Develop new features and services (for example, we may decide to build a new interests-based drill from requests received from users).To prevent, detect and fight fraud or other illegal or unauthorized activitiesAddress ongoing or alleged misbehavior on and off-platformPerform data analysis to better understand and design countermeasures against these activitiesRetain data related to fraudulent activities to prevent against recurrencesTo ensure legal complianceComply with legal requirementsAssist law enforcementEnforce or exercise our rights, for example, our Terms and ConditionsPerform data analysis to improve the quality of our drillsUnderstand better the way you play footballTroubleshoot and protect against errorsConduct auditsTo process your information as described above, we rely on the following legal bases: Provide, improve and develop our service to you. Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, we need to use your information to enable you to track your training and gameday activity, to give you customer support and for performance ranking within the INSAIT JOY community. We use the information we collect to improve our services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services. Communicate with You. We use your information when needed to send you notifications and respond to you when you contact us. With respect to INSAIT JOY product, we also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in your phone settings or via the “Unsubscribe” link in an email. We use your information to provide customer service or assistance to you or your organisation about their instances of our products and services. Promote Safety and Security. We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies. Internal Business Purposes. We use the information that we collect from our customers for our internal business purposes, including (as applicable) to better operate our business and to communicate with customers and prospects. Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy. 5. HOW WE SHARE YOUR INFORMATION? Since our goal is to help you improve your football skills, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services and, in some cases, legal authorities.  We will do our best to ensure that we do not disclose your personal information to a third party if you have not approved it. Your consent to the disclosure of your personal information may be given expressly, or it may be implied from your interaction with us. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy. Read on for more details about how your information is shared with others. 5.1 Sharing with other users In the case of INSAIT JOY product, your performance data and activity data of the INSAIT JOY product is shared through features in the app which enable comparisons and rankings of player performance. This means your profile (your profile name, age, region, and profile image) is publicly displayed. You may choose to limit the audience for all or part of your profile or for certain content or information about you at any time by contacting us at the address provided at the end of this Privacy Policy. 5.2 Sharing by your choice You may choose to share some other information (for instance, your performance data or training videos you’ve made by yourself) with other users or other people with any sharing features available on INSAIT JOY when you voluntarily disclose information on the service. Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. 5.3 Sharing with third parties Sometimes we’ll need to disclose your personal information to other people or entities that we collaborate with to provide our products or services (third parties) for the purposes set out in this policy. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We may also share information with partners who distribute and assist us in advertising our services. We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations. 5.4 Sharing with other Gengee Technology Co., Ltd. departments Assistance provided by other Gengee Technology Co., Ltd. departments may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings. We may also share information with other Gengee Technology Co., Ltd. departments for legitimate business purposes such as corporate audit, analysis, and consolidated reporting as well as compliance with applicable laws. We may also share user information with other Gengee Technology Co., Ltd. departments to remove users who violate our terms of service or have been reported for criminal activity and/or bad behavior. In some instances, we may remove that user from all platforms. 5.5 Sharing outside your region Sharing of information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or another suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data We may disclose personal information outside your region for the purposes of customer service and product support and consistent with agreement terms in place, for example your INSAIT JOY performance data may be disclosed in different regions as part of the performance ranking within the INSAIT JOY user community. We only allow access of your information outside of your region for reasonable and permitted purposes related to our work with you. If we do allow access to or transferal of your information to persons outside your region we will take steps designed to ensure that such persons handle your personal information with the same level of protection as set out in this privacy policy and in a manner compliant with applicable laws and regulation. 5.6 For corporate transactions We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. 5.7 When required by law or to enforce legal rights We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing. 6. WHAT ARE YOUR RIGHTS? We want you to be in control of your information, so we have provided you with the following tools: Access / Update tools in the service or by contacting us at 4006662260@gengee.cn Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help. Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality. Deletion. You can delete your account by contacting us at 4006662260@gengee.cn We want you to be aware of your privacy rights. Here are a few key points to remember: Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, the right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request at 4006662260@gengee.cn.  Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at 4006662260@gengee.cn.  For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, the other user will have to contact our Privacy Officer at 4006662260@gengee.cn provide their written consent before the information is released. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not collect your performance data. With your consent we may use your personal information, such as your address or contact details, to provide you with information about services that we offer. You may withdraw that consent. If at any time you do not wish to receive any information about these services please feel free to contact us and we will not send you any further material. We will not transfer or allow access to your personal information to any other entity or person for the purposes of allowing them to market their products or services to you. Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities. We may also preserve information for legal reasons or to prevent harm. Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established. If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to 4006662260@gengee.cn. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request. If you need further assistance regarding your rights, please contact our Privacy Officer at 4006662260@gengee.cn, and we will consider your request in accordance with applicable laws. 7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE? We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately by sending an email to 4006662260@gengee.cn 8. FOR HOW LONG DO WE STORE YOUR INFORMATION We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore. In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless: 1) we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);2) we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy, and other similar consents are kept for five years);3) there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or4) the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept in order to prevent a user who was banned for unsafe behavior or security incidents from opening a new account. Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints. We may retain de-identified data for research and product and service development. 9. OUR POLICIES FOR CHILDREN. Protecting children's privacy online is extremely important to us.  INSAIT JOY products and services are intended for general audiences. Persons under the age of 16, or any higher applicable minimum age in the jurisdiction where that person resides, are not permitted to create accounts unless their parent or guardian has consented in accordance with applicable law.  If we learn that we have collected the personal information of a child under the relevant minimum age without parental or guardian consent, we will take steps to secure parent or guardian consent or delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at 4006662260@gengee.cn Please note that if you grant consent for your child to use INSAIT JOY products and services, this may include such general audience communication services as email, instant messaging, and online groups, and your child will be able to communicate with and disclose personal information to, other users of all ages. If you are a parent and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, contact the appropriate by writing to 4006662260@gengee.cn Information collected is secured in a manner consistent with this Privacy Policy. If we make material changes to how we use, collect, or share your child's personal information, we will notify parents by email or by in-app notice in order to obtain verifiable parental consent for the new uses of your child's personal information. We encourage you to talk with your children about communicating with strangers and disclosing personal information online.  Under no circumstances do we condition a child's participation in an activity—like contests—on the child's disclosure of more personal information than is reasonably necessary to participate in the activity. 10. CHANGES TO THIS PRIVACY POLICY We monitor regulations, policies and procedures to ensure that we are up to date with changes in the law and market practices. As a result, we will change this privacy policy from time to time. We will notify you before any material changes take effect so that you have time to review the changes. 11. HOW TO CONTACT US If you have questions about this Privacy Policy, here’s how you can reach us: by email to 4006662260@gengee.cn or by postal service toGengee Technology Co., Ltd.A3-128, No.132, Huachang Rd.Huli District, 361003Xiamen, China LAST REVIEWED: MARCH 30, 2020 EndFragment