Privacy policy

Updated January 1, 2022

VALOR & TOUGHNESS (collectively, " VALOR & TOUGHNESS", "we") respect your privacy. Therefore, we have developed a Privacy Policy (hereinafter referred to as "this Policy") that covers how we collect, use, disclose, protect, store and transfer your personal data. Please take a moment to read and understand our privacy policy and let us know if you have any questions.

Personal data means any electronic or other information which alone or jointly with other information can be used to identify a natural person or make him/her identifiable. This Policy explains how VALOR & TOUGHNESS processes your personal data, but does not cover all processing scenarios as you will be informed in specific processing activity. Therefore, before using a specific product or service, it is recommended that you read the privacy notice or supplementary policy released by VALOR & TOUGHNESS for that product or service to understand how it processes your personal data, how you can exercise your data subject rights, and how to contact the data controller.

By using VALOR&TOUGHNESS Products and Services, you consent to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Terms of Use for the VALOR&TOUGHNESS Products and Services you use.

How VALOR&TOUGHNESS Collects and Uses Your Personal Data

A. Personal Data Collected by VALOR&TOUGHNESS

Before using VALOR&TOUGHNESS products or services, you may need to provide personal data. You do not have to provide your personal data to VALOR&TOUGHNESS, but in some cases, the non-provision of certain personal data will cause the inability to provide you with some related products or services.

VALOR&TOUGHNESS will collect and use your personal data for the purposes stated in this Policy. Here are some examples of personal data we may collect:

1.Personal data that you provide to VALOR&TOUGHNESS

You need to register a VALOR&TOUGHNESS ID to enjoy certain functions or services. When you register a VALOR&TOUGHNESS ID or log in with a VALOR&TOUGHNESS ID to shop online, download software, or purchase services, we will ask you to provide relevant personal data, such as your name, email address, mobile number, order information, shipping address, and payment mode.

Some VALOR&TOUGHNESS products allow you to communicate and share information with others. When you use a VALOR&TOUGHNESS product to share things with your family and friends, you may need to create a VALOR&TOUGHNESS ID that includes certain information which will be made public, including a nickname and avatar. VALOR&TOUGHNESS may collect information related to those people, such as their names, email addresses, and phone numbers. VALOR&TOUGHNESS will take appropriate and necessary measures to ensure the security of the information that you provide. You must ensure that the people, whose information you provide, have consented to you providing their information to VALOR&TOUGHNESS.

To meet some jurisdictions' requirements on real-name authentication of accounts, prevention of electronic game addiction, or Internet payment, VALOR&TOUGHNESS might ask you to provide a proof of identity issued by the government or relevant card information that can identify you.

2.Information that VALOR&TOUGHNESS collects in your use of services

VALOR&TOUGHNESS will collect data about your device and how you and your device exchange information with VALOR&TOUGHNESS products and services. This type of information includes:

(1) Device and application information, such as the device name, device identifiers (ESN, MEID, and SN), device activation time, hardware model, OS version, application version, software identifier, and device and application settings (such as region, language, time zone, and font size).

(2)  Log information. When you use VALOR&TOUGHNESS services or view VALOR&TOUGHNESS-provided content, VALOR&TOUGHNESS will automatically collect and log some information, such as the time of access, access count, IP address, and information about incidents (such as errors, crashes, restarts, and upgrades).

3. Information from third-party sources

When permitted by law, VALOR&TOUGHNESS will collect information about you from public and commercial sources. VALOR&TOUGHNESS may also obtain certain information from third-party social network services, such as the time when you use a social network account to log in to a VALOR&TOUGHNESS website.

4. Collection and use of non-identifiable data

Non-identifiable data refers to data that cannot be used to identify an individual. Examples of non-identifiable data include statistics on website visits, application downloads, and product sales volume. VALOR&TOUGHNESS will collect statistics information to understand how users use our products and services. By doing so, we can improve our services to better meet your requirements.

We keep your personal data and non-identifiable data separate, and use each independently. Circumstances may arise where VALOR&TOUGHNESS collects, uses, discloses, and transfers non-identifiable data for other purposes at our own discretion.

B. How VALOR&TOUGHNESS Uses Your Personal Data

VALOR&TOUGHNESS may use your personal data for the following purposes:

(1) Register and activate VALOR&TOUGHNESS personal and home products that you have purchased.

(2) Register a VALOR&TOUGHNESS ID so that you can enjoy a wider range of functions and mobile services.

(3) Deliver, activate, or verify the products and services you have requested, or perform changes and provide technical support and after-sales services for the foregoing products and services based on your requirements.

(4) Send you OS or application updates and installation notifications.

(5) Provide personalized user experience and content.

(6) Send you information about products and services you might be interested in, invite you to VALOR&TOUGHNESS promotional activities and market surveys, or send marketing information to you. If you do not want to receive such information, you can opt out at any time.

(7) Carry out internal auditing, data analysis, and research; analyze business operation efficiency and measure market shares; and improve VALOR&TOUGHNESS's products and services.

(8) Improve our loss prevention and anti-fraud programs.

(9) Process pursuant to laws and regulations, e.g. tax, authority requests.

(10) Other purposes within specific services or with your consent.

How VALOR&TOUGHNESS Shares Your Personal Data

We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:

(1) Sharing with consent: After obtaining your consent, VALOR&TOUGHNESS will share the information that you have authorized with specified third parties or categories of third parties.

(2) Sharing pursuant to laws and regulations: VALOR&TOUGHNESS may share your information as required by laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law.

(3) Sharing with VALOR&TOUGHNESS affiliates: Your information may be shared within VALOR&TOUGHNESS's affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services. For example, we verify the global uniqueness of accounts before allowing them to be registered.

(4) Sharing with business partners: Some products and/or services are provided to you directly by our partners. VALOR&TOUGHNESS also may share your information with them, they may use your information to provide you with products and/or services you request (e.g., products sold by third-party seller through VALOR&TOUGHNESS's e-commerce platform, video content provided by other companies through VALOR&TOUGHNESS's applications), make predictions about your interests and may provide you with advertisements, promotional materials and other materials.

(5) Sharing with service providers: VALOR&TOUGHNESS also may disclose your information to companies that provide services for or on behalf of us. Examples of these service providers include companies that provide hotline services, send email, or provide technical support on behalf of VALOR&TOUGHNESS. The service providers can use your information only for the purpose of providing services to you on behalf of VALOR&TOUGHNESS.

(6) VALOR&TOUGHNESS will share your information when there is a reasonable requirement to do so, for example, to meet request of applicable law, regulation, legal process or enforceable government.

In scenarios 3 to 6, VALOR&TOUGHNESS will ensure that the lawfulness of this sharing and sign stringent non-disclosure agreements (NDAs) and/or data processing clauses with the companies, organizations, and individuals with whom personal data is shared, requiring them to comply with this Statement and take appropriate confidentiality and security measures when processing personal data.

How VALOR&TOUGHNESS Protects Your Personal Data

VALOR&TOUGHNESS attaches great importance to the security of your personal data and has adopted standard industry practices to protect your personal data and prevent it from unauthorized access, disclosure, use, modification, damage, or loss. To this end, VALOR&TOUGHNESS takes the following measures:

(1) We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal data for no longer than is necessary for the purposes stated in this Statement and privacy notice of specific product or service, unless extending the retention period is required or permitted by law.

(2) We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks.

(3) We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels.

(4) We strictly select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities.

(5) We hold security and privacy protection training courses, tests, and publicity activities to raise employees' personal data protection awareness.

VALOR&TOUGHNESS is committed to protecting your personal data. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure.

To cope with possible risks, such as personal data leakage, damage, and loss, VALOR&TOUGHNESS has developed several mechanisms and control measures, clearly defined the rating standards of security incidents and vulnerabilities and corresponding processing procedures, and established a dedicated Security Advisory and Security Notice page. VALOR&TOUGHNESS has established a dedicated emergency response team to implement security planning, loss reduction, analysis, locating, and remediation, and to perform tracking operations with related departments based on security incident handling regulations and requirements.

How You Can Manage Your Personal Data

A. Access, rectification, deletion, data portability, restriction of processing, objection to processing.

Legislation in some countries and regions to which VALOR&TOUGHNESS provides products and services or from where VALOR&TOUGHNESS processes personal data, provides that data subjects the rights request (hereinafter referred to as "requests") in regard to the accessing, rectifying, deleting or erasure, porting, restricting, and objecting, the processing of related personal data by VALOR&TOUGHNESS retains. In addition you will have the right to data portability.

1. Requesting modes and channels

Data subjects' requests must be submitted in accordance with VALOR&TOUGHNESS designated privacy channels. The requests are valid even when the requester does not specify the laws on which the requests are based.

Data subjects' requests may be initiated through the official website of VALOR&TOUGHNESS, Support app or VALOR&TOUGHNESS ID app. If a data subject initiates a request via a hotline, email, online customer service, service center, or another channel, we will instruct the data subject to officially raise the request through one of the aforementioned channels to facilitate communication and feedback of progress and results. The dedicated request channels for data subjects are intended to protect data subjects' lawful interests, ensure VALOR&TOUGHNESS's normal operation, and prevent the right to request from being misused or fraudulently used.

2. Validity of requests

Most laws require data subjects to comply with specific requirements when they initiate requests. This Statement requires data subjects to:

(1) Submit requests through dedicated request channels provided by VALOR&TOUGHNESS (namely, the official website of VALOR&TOUGHNESS, Support app, and VALOR&TOUGHNESS ID app).

(2) Provide sufficient information for VALOR&TOUGHNESS to verify their identities (to ensure those who initiate the requests are the data subjects themselves or those authorized by them).

(3) Ensure that their requests are specific and feasible.

There are some circumstances, provided by laws and regulations, in which VALOR&TOUGHNESS may not have to comply with the request in full or at all.

B. Consent withdrawal

You can change the authorized personal data collection scope or withdraw your consent without affecting the lawfulness of the processing activities based on the consent granted prior to such withdraw.

Your rights can be exercised by deleting information, disabling related functions, or setting privacy options on your VALOR&TOUGHNESS product. VALOR&TOUGHNESS will release the methods for withdrawing consent for specific products and services in the privacy notice or supplementary statement of those products and services or upon request according to section A above.

C. Delete a VALOR&TOUGHNESS ID

You can delete your account in VALOR&TOUGHNESS ID-related products. After you delete your account, we will stop providing products and services, and delete your personal data unless otherwise stipulated by law. Your account cannot be restored after deletion. You need to register a new VALOR&TOUGHNESS ID if you want to use related VALOR&TOUGHNESS products or services again. You can delete your VALOR&TOUGHNESS ID in the settings of a device, app, or website on which you have logged in with your VALOR&TOUGHNESS ID.

How VALOR&TOUGHNESS Protects Minors' Personal Data

VALOR&TOUGHNESS's personal and home products are intended for adults. VALOR&TOUGHNESS identifies whether data subjects are children based on the age of majority defined by laws of the local countries and regions.

If VALOR&TOUGHNESS accidentally collects children's personal data without obtaining consent from provable holders of parental responsibility, VALOR&TOUGHNESS will delete the information as soon as possible after becoming aware of it.

Links to Third-Party Websites, Products, and Services

VALOR&TOUGHNESS websites, apps, software, products, and services may contain links to third-party websites, products, and services. VALOR&TOUGHNESS products and services may also use or provide products or services from third parties.

All links to third-party websites, products, and services are provided for users' convenience only. You need to determine your interaction with such links on your own. Before submitting your personal data to third parties, please read and refer to these third parties' privacy policies.

International Transfers of Your Personal Data

Our products and services are delivered through resources and servers located in different places, to offer our products and services, we may need to transfer your personal data among several countries. Authorized VALOR&TOUGHNESS personnel and third parties acting on our behalf may access, use and process personal data collected from you in a country/region that is different from the country/region where you entered the personal data, which may have less stringent data protection laws. When we transfer your personal data to other countries/regions, we will protect that the personal data as described in this statement or as otherwise disclosed to you at the time the data is collected (e.g. via privacy notice or supplementary statement of specific product or service).

VALOR&TOUGHNESS has implemented global privacy practices for processing personal data protected under various data protection laws. VALOR&TOUGHNESS transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data protection laws, including standards and conditions related to security and processing.

With respect to personal data coming from the EU or Switzerland, we comply with applicable legal requirements providing adequate safeguards for the transfer of personal data to countries outside of the European Economic Area ("EEA") or Switzerland. We use a variety of legal mechanisms, such as standard contractual clauses to implement the cross-border transfer of your personal data; or implement security measures like anonymization on the data before the cross border data transfer.

Changes and Updates to this Policy

We may update this Policy from time to time. If we modify this Policy, we will make it available on or through the VALOR&TOUGHNESS Products and Services and indicate the date of the latest revision. We will make reasonable efforts to notify you of the change.

How to Contact Us

If you have any questions, comments, or suggestions, please contact us.

Note: Due to differences in local laws and languages, the local versions of VALOR & TOUGHNESS Privacy Policy may differ from this version. In case of any conflicts. This version shall prevail.

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