Hypic Privacy Policy
Last Updated: July 7, 2023

Introduction
This privacy policy ("Privacy Policy") applies to the personal information that Hypic processes in connection with Hypic applications, software and related services (the “Platform”), that link to or reference this Privacy Policy.
Data Controller: Bytedance Pte. Ltd. with address at 1 Raffles Quay, #26-10, South Tower, Singapore 048583.

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


Automatically Collected Information


Information From Other Sources


How We Use Your Information
We use your information to operate, provide, develop, and improve the Platform, including for the following purposes.


How We Share Your Information
This section sets out how we may share your information with service providers and other partners, which may be located outside of your country.

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, content delivery, and customer and technical support. We may 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.

Third Party Platforms and Partners
We may 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. Some examples include if you:


Our Corporate Group
As a global company, the Platform is supported by certain entities within our corporate group (“Corporate Group”). These entities may 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. We may also share your information with any member of our corporate group (e.g., CapCut) to improve the Platform, allow you to access other services provided by members of our corporate group, or for internal business purposes.

Others
We may share your information in other limited scenarios as follows:

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:


With Your Consent
We may share your information for other purposes with your consent or at your direction. For example, we partner with third-party services (such as Facebook, TikTok, Apple) in some jurisdictions to offer you a seamless sign-up and log-in experience. We may share information about you with these third-party services if you choose to use these features, as described above.

Third-Party Content
The Platform may contain links to policies, functionality, or content maintained by third parties who we do not control. We are not responsible for, and make no representations regarding, such policies, functionality, or content or any other practices or operations of such third parties. If there are links directing to third party websites, please note that these websites are governed by their own Terms and Conditions of Use and Privacy Policy.

Your Rights and Choices
If you have registered for an account, you may also access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities. If you choose to log-in, sign-up, or link to a third-party service, such as Apple, Facebook, or TikTok, you may be able to manage the type of data shared with Hypic through that service’s settings.
As discussed further in the Supplemental Terms - Jurisdiction Specific, you may also be afforded rights in your country under applicable laws, such as the ability to access your information, delete your information, be informed of the use of your data, revoke your consent, file a complaint before the relevant authority, and potentially others. If you have any questions on how to use your settings or want to know about any rights with regard to your personal information you may have in the country where you live, please contact us at hypic.support@bytedance.com and we will respond consistent with applicable law and subject to proper verification. Please note that your exercise of certain rights may impact your ability to use some or all of Hypic’s features and functionalities.

Data Security and Retention
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.
We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We may 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 and User Content. If you violate our Terms, we may keep your information as is necessary to process the violation and as long as permitted by applicable law.

International Data Transfers
The personal information we collect from you may be stored on a server located outside of the country where you live. We store the information we collect in secure servers located in the United States and Singapore. Where we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws.

Information Relating to Minors
Hypic is not directed at children under the age of 13. The minimum age to use the Platform may differ depending on the country or region that you are in. If you believe that we have collected personal information from a minor under the minimum age, please contact us at hypic.support@bytedance.com.

Privacy Policy Updates
We may amend or update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you of any material changes by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy from time to time to stay informed of our privacy practices.

Contact Us
Questions, comments and requests regarding this Privacy Policy should be addressed to:
Hypic, Bytedance Pte. Ltd.
Email: hypic.support@bytedance.com
Address: 1 Raffles Quay, #26-10, South Tower, Singapore 048583

SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction Specific that are relevant to your jurisdiction from which you access or use the Platform, and the rest of the Policy, the relevant jurisdiction’s Supplemental Terms – Jurisdiction Specific will supersede and control.

Australia
Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How we share your information."

Brazil
If you are using the 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:


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.
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

Canada
If you are using the Platform in Canada, the following additional terms apply.
Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.
Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send.
Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States and Singapore, and other foreign jurisdictions where we or our service providers are located. For information about the manner in which we or our service providers (including service providers outside Canada) process personal data, please contact us using the contact information set out below.
Contact. If you are a resident of Canada, you can contact our Privacy Office using the contact information provided in the “Contact Us” section.

European Economic Area (“EEA”), Switzerland, and UK
If you are using the Platform in the EEA, Switzerland or the UK (the “European Region”), the following additional terms apply:

Legal bases for processing
We use your personal data only as permitted by law. Our legal bases for processing your personal data described in this Policy are described in the table below.

Personal information categories and processing purposeLegal basis
We use the the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information;
- Log-in, Sign-up, or Linked Services
- User Content and Usage Information;
- Location Information; and
- Technical Information
to provide and administer the Platform such as enabling you to create, edit and share content.
Processing is necessary to perform the contract governing our provision of the Platform or to take steps that you request prior to signing up for an account to use the Platform.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information;
- Log-in, Sign-up, or Linked Services
- User Content and Usage Information;
- Location Information;
- Surveys, Research and Promotions;
- When You Contact Us; and
- Technical Information
to review, improve and develop the Platform, including by monitoring interactions and usage across your devices and analyzing how you are using the Platform, and to train and improve our technology, such as our machine learning models and algorithms.
The processing is necessary for our legitimate interests, namely to improve and develop the Platform.
The categories of information that we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, we use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information
- Log-in, Sign-up, or Linked Services
- User Content and Usage Information;
- Location Information;
- When You Contact Us; and
- Technical Information
to comply with any legal obligation, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
This processing is necessary in order to comply with our legal obligations under European Union or Member State law. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. Similarly, processing may be necessary to respond to regulatory requests requiring the processing of information under Chapters IV and VI of the GDPR.
In other circumstances, the processing is necessary for our legitimate interests, namely, to disclose and share information with regulators or other government entities.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information;
- Log-in, Sign-up, or Linked Services
- When You Contact us; and
- Technical Information
to communicate with you, including to notify you about changes to the Platform, and provide you with user support, including responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
The processing is necessary for the performance of a contract with you.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information;
- User Content and Usage Information;
- Location Information; and
- Technical Information
to send you marketing communications in accordance with your preferences. We may also send you promotions or contests.
The processing is necessary for our legitimate interests, namely to promote the Platform or third party services. We will obtain your consent to send you marketing communications where required by law.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information
- Log-in, Sign-up, or Linked Services
- User Content and Usage Information;
- Location Information;
- Other Sources; and
- Technical Information
to enforce our Terms of Service, guidelines and policies, including to ensure that you are old enough to use the Platform.
The processing is necessary for the performance of a contract with you.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:
- Account Information;
- User Content and Usage Information;
- Location Information; and
- Technical Information
to promote the safety, security, and stability of the Platform, such as by identifying and addressing technical or security issues such as technical bugs and spam accounts and detecting abuse, fraud, and illegal activity on the Platform including by scanning and reviewing User Content and other information.
The processing is necessary for our legitimate interests, namely,
- to ensure that the Platform is safe and secure, to ensure compliance with our Terms of Service, guidelines and other policies, and to identify misuse of the Platform; and
- to ensure the ongoing stability and security of the Platform and to ensure it is continuously available and functioning.
We share the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources> with third parties whose platforms 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, if you:
- sign-up or log-in to the Platform using your account details from a third party platform (such as Facebook, TikTok, or Apple), we will share certain Technical Information to facilitate this.
- share User Content you create on the Platform to other social media platforms, we will share your User Content and related information.
The processing is necessary for our legitimate interests, namely to provide you with a seamless experience, allow your content to be shared on other platforms, and optimise user experience.
In some cases, we may aggregate or anonymise the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources> and use it in a way that is designed to be unable to identify you, for research or other purposes, to the extent allowed by applicable law.The processing is necessary for our legitimate interests, namely to conduct research and protect personal information through aggregation or anonymisation, consistent with data minimisation and privacy by design principles.
We may use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources> where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. The specific types of information we use will depend on the specific situation.The processing is necessary to protect the vital interests of you or other individuals.
We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use <Information You Provide> and <Automatically Collected Information>, although it depends on the specific situation.We process your information where it is necessary to perform a task in the public interest.



International data transfers
If you normally reside in the European Region, the personal data that we collect about you may be further transferred to, and stored at, a destination outside of the European Region (for instance, to our service providers and partners). For example, we may store the information that we collect in secure servers located in the United States and Singapore.
When we transfer your information outside of the European Region, we ensure it benefits from an adequate level of data protection by relying on:


If you wish to enquire further about these safeguards, please contact us at: hypic.support@bytedance.com.

Your rights
You have the following rights:


Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.
Please send an email to us if you would like to exercise any of your rights (see the “Contact Us” section).

Representatives
If you are based in the United Kingdom, our designated GDPR representative is:
Cosmo Technology Private Limited
2 Temple Back East
Temple Quay
Bristol
United Kingdom
BS1 6EG
If you are based in the EEA or Switzerland, our designated GDPR representative is:
Mikros Information Technology Ireland Limited
Mespil Business Centre
Mespil House
Sussex Road
Dublin 4
Ireland

Egypt
If you are using our Platform in Egypt, the following additional terms apply:


Indonesia
If you are using our Platform in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Age, Parental and Guardian Consent. By accessing and/or using the Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:


If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing and/or using the Platform.
Your Choices. You may withdraw your consent to our disclosure of personal data to third parties. Upon your request, we will display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of Hypic’s features and functionality.
You may request that we: (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of Hypic's features and functionality.
To exercise any of your rights, please contact us (see the “Contact Us” section)
Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.
Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.
After you have terminated your use of our Platform and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

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

Argentina
If you are using our services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Your rights and options. According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. 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.
We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site:https://www.argentina.gob.ar/aaip/datospersonales/derechos.

Mexico
If you use our services 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.
Data Controller. Bytedance Pte. Ltd. with address at 1 Raffles Quay, #26-10, South Tower, Singapore 048583.
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:


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, objection, consent withdrawal, limitation of use and disclosure of your data. You may exercise your rights by sending your request to hypic.support@bytedance.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 applicable data protection law and the nature of your request.
Information relating to minors. You may review our parental consent section in the Terms of Service.

Philippines
If you are using our Platform in Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.
Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

South Korea
If you are using our Platform in South Korea, the following additional terms apply:
How we share your information. In addition to the main text of this policy, in the event we use information such as User Content on our Platform as part of our marketing campaigns to promote the Platform, your personal information contained in such information may be disclosed to the recipients of such marketing content.
Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in the Policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:


Destruction of Personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department.
Your Rights


Türkiye
If you are using our Platform in Türkiye, the following additional terms:
Data Controller Representative. You may contact our data controller representative in Türkiye by email or mail to handle questions and complaints in connection with the processing of your personal data if you are in Türkiye.
Legal bases for processing your personal data. We rely on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:


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


If you would like to exercise your rights, please contact us at hypic.support@bytedance.com.
The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.
Language. This policy is available in English and Turkish. If there is any inconsistency or different interpretation between the English and Turkish versions, the Turkish text shall prevail.

United Arab Emirates
If you are using the Platform in the United Arab Emirates (“UAE”), the following additional terms apply:
How we share your personal data
In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.
Governing law and dispute resolution
By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:


United States
If you are using our Platform in the United States, the following additional terms apply:
Your Rights and Choices
Depending on where you live, you may be entitled to certain rights with respect to your personal information, as described below:


For United States users, the Platform does not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising or targeted advertising where restricted by applicable law.
Although some of the information we collect may be considered sensitive personal information, we only process such information in order to provide the Platform and within other exemptions under applicable law, such as when we process your sensitive personal information in order to perform the services or provide the goods you request from us.
You may exercise these rights by submitting your request via email to: hypic.support@bytedance.com
You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.
You may appeal any decision we have made about your request by replying to the communication you receive from us communicating your decision. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on this Platform may change or no longer be available to you.

Other California Rights


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 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:


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.