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Privacy Policy
平台：Qoder
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📄 上一个版本

2026年05月05日

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2026年05月13日

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分析时间: 2026年05月13日
好的，谨遵您的指令。以下是对您提供的两份政策文件版本进行的严谨、按时间顺序的比较分析。 --- ### 1. 总体评估 本次更新（从 **2026年04月29日** 到 **2026年05月12日**）属于 **实质性条款变更**。尽管政策的大部分文本保持不变，但在“**如何分享您的信息**”这一核心章节中，对用户数据的共享范围进行了显著的扩展，这直接影响了用户隐私的核心权益，构成了一项重要的实质性修改。 ### 2. 详细变更点分析 以下是按时间顺序梳理出的所有实质性变更： 1. **变更类型**：**修改**（范围扩展） * **变更内容**：在“**如何分享您的信息**”章节下的“**第三方**”子条款中，关于与第三方共享的数据类型范围被显著扩大。 * **旧版本** (2026年4月29日) 的描述为：`“We may share your personal data, including Log Information, with third parties...”`（我们可能会共享您的个人数据，**包括日志信息**，给第三方...） * **新版本** (2026年5月12日) 的描述为：`“To the extent necessary to provide the Services, we may share your personal data, including Log Information, Payment Information, and Usage Information, with third parties...”`（为了提供服务的必要程度，我们可能会共享您的个人数据，**包括日志信息、支付信息和** **[使用信息](https://www.baidu.com/s?wd= 使用信息&tn=44004473_33_oem_dg)**，给第三方...） * **潜在影响**：这是一个对用户隐私影响重大的修改。旧版本仅明确列出了“日志信息”会与第三方共享。新版本新增了“支付信息”和“**使用信息**”（具体指用户如何使用服务的行为数据，包括访问时间、浏览历史、点击的链接等）。这意味着用户的行为轨迹和财务数据现在都可能被共享给集成的第三方平台（例如用于登录的Google或GitHub）。用户对数据流向的控制力被削弱，风险增加。 2. **变更类型**：**修改**（范围扩展） * **变更内容**：在“**如何分享您的信息**”章节下的“**第三方**”子条款中，增加了共享行为的触发条件。 * **旧版本**: 直接以 `“We may share your personal data... with third parties”` 开头。 * **新版本**: 在共享声明前加上了一个限定短语 `“To the extent necessary to provide the Services”`（为了提供服务的必要程度）。 * **潜在影响**：这一修改表面上看似一个限制，即共享数据必须有“必要性”。然而，由于“必要性”的定义完全由服务提供商单方面判断，这实际上为更广泛的数据共享提供了法律依据。在某些情境下，公司可以将几乎所有数据共享行为解释为“提供服务所必需”，从而扩大了其操作的灰色地带，而非真正限制了数据共享。 ### 3. 结论 本次政策更新（2026年5月12日）的核心变化是，**Qoder 明确扩大了与第三方平台共享的用户数据范围**，在原有的“日志信息”基础上，新增了“支付信息”和“使用信息”，增加了用户个人信息流向外部平台的风险和不确定性。虽然新增了“服务必要”这一前提，但该措辞的模糊性使得这一“限制”的实际效果存疑。对于注重个人数据隐私，尤其是希望限制自身行为数据和财务数据被用于服务核心功能之外的用户而言，这是一个负面的、值得警惕的变更。 --- *分析由 DeepSeek 提供*
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上一个版本 (2026年05月05日 ) 当前版本 (2026年05月13日)
1 Privacy Policy 1 Privacy Policy
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3 Last updated: April 29, 2026 3 Last updated: May 12, 2026
4 Introduction 4 Introduction
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6 Before using the Services (as defined below), please read this Qoder Privacy Policy carefully to learn how we, BRIGHT ZENITH PRIVATE LIMITED, a Singapore registered entity (“BRIGHT ZENITH”), collect, use, disclose, and protect your personal data. This Qoder Privacy Policy will also provide you with more information about the bases upon which BRIGHT ZENITH may lawfully collect, use, and/or disclose your personal data, where permitted by applicable law. 6 Before using the Services (as defined below), please read this Qoder Privacy Policy carefully to learn how we, BRIGHT ZENITH PRIVATE LIMITED, a Singapore registered entity (“BRIGHT ZENITH”), collect, use, disclose, and protect your personal data. This Qoder Privacy Policy will also provide you with more information about the bases upon which BRIGHT ZENITH may lawfully collect, use, and/or disclose your personal data, where permitted by applicable law.
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8 This Qoder Privacy Policy (“Privacy Policy”) applies to your access and/or use of the services including but not limited to Qoder IDE, websites, software, and related services (collectively, the “Services”) provided by us. By accessing and/or using any Service, or clicking “Agree” on the account registration screen, you agree and consent to BRIGHT ZENITH and its related companies (collectively, the “Companies”) as well as their respective representatives and agents (the “Representatives”) (the Companies and the Representatives collectively referred to as “we”, “us” or “our” hereinafter) collecting, using, disclosing, and/or sharing your personal data, and disclosing your personal data to our authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy, subject to any separate consent we need to collect from you under applicable data protection laws. If you do not agree with the terms of this Privacy Policy, you must not access or use any Service. 8 This Qoder Privacy Policy (“Privacy Policy”) applies to your access and/or use of the services including but not limited to Qoder IDE, websites, software, and related services (collectively, the “Services”) provided by us. By accessing and/or using any Service, or clicking “Agree” on the account registration screen, you agree and consent to BRIGHT ZENITH and its related companies (collectively, the “Companies”) as well as their respective representatives and agents (the “Representatives”) (the Companies and the Representatives collectively referred to as “we”, “us” or “our” hereinafter) collecting, using, disclosing, and/or sharing your personal data, and disclosing your personal data to our authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy, subject to any separate consent we need to collect from you under applicable data protection laws. If you do not agree with the terms of this Privacy Policy, you must not access or use any Service.
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10 Unless otherwise specified, this Privacy Policy does not apply to any products and/or services provided by any third party independently through our Services. We are not responsible for the privacy practices of third parties. If you access or use any third party products or services, you should check the applicable third party privacy policy to determine how they will handle any personal data you provide to them or which they collect from you. We are not responsible for any third party’s improper use or disclosure of any personal data. 10 Unless otherwise specified, this Privacy Policy does not apply to any products and/or services provided by any third party independently through our Services. We are not responsible for the privacy practices of third parties. If you access or use any third party products or services, you should check the applicable third party privacy policy to determine how they will handle any personal data you provide to them or which they collect from you. We are not responsible for any third party’s improper use or disclosure of any personal data.
11 What Information We Collect 11 What Information We Collect
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13 For the purposes of the Privacy Policy, “personal data” refers to any information relating to an identified or identifiable natural person. We collect personal data for more efficient operation and to provide you with best usage experience. The ways in which we collect personal data include: (a) where you provide personal data to us; (b) where you access or use the Services; and/or (c) where we obtain personal data from third parties. 13 For the purposes of the Privacy Policy, “personal data” refers to any information relating to an identified or identifiable natural person. We collect personal data for more efficient operation and to provide you with best usage experience. The ways in which we collect personal data include: (a) where you provide personal data to us; (b) where you access or use the Services; and/or (c) where we obtain personal data from third parties.
14 Information Provided by You 14 Information Provided by You
15 Account Information. We collect your personal data, including your name, email address, a display name of your choice, when you sign up for an account to access or use the Services, and where you otherwise provide us with your personal data (such as to receive information on our Services). 15 Account Information. We collect your personal data, including your name, email address, a display name of your choice, when you sign up for an account to access or use the Services, and where you otherwise provide us with your personal data (such as to receive information on our Services).
16 Feedback. We appreciate feedback, including ideas and suggestions for improvement or rating an Output in response to an Input. If you rate an Output in response to an Input—for example, by using the thumbs up/thumbs down icon—we will store the related conversation as part of your feedback. 16 Feedback. We appreciate feedback, including ideas and suggestions for improvement or rating an Output in response to an Input. If you rate an Output in response to an Input—for example, by using the thumbs up/thumbs down icon—we will store the related conversation as part of your feedback.
17 Payment Information. When you seek to access any paid Service, we collect information related to your purchase, including payment details such as your payment method, payment instrument number, billing address, and transaction history. 17 Payment Information. When you seek to access any paid Service, we collect information related to your purchase, including payment details such as your payment method, payment instrument number, billing address, and transaction history.
18 User Content. You are able to interact with our Services in a variety of formats, including but not limited to chat, coding, and agentic sessions (“Inputs”), which generate responses and actions (“Outputs”，together with Inputs, collectively the “User Content”) based on your Inputs. This includes third-party applications you choose to integrate with our Services. If you include personal data in your Inputs, we will collect such information and it could be reflected in the Outputs generated. If you provide Inputs via audio, we will process your audio data solely through algorithmic means to deliver task results based on the specific instructions you input, select, or trigger. Except as described above, we will not process your audio data for other purposes (e.g., voiceprint recognition, Images, Videos), nor will we transfer any personal information contained therein to third parties. 18 User Content. You are able to interact with our Services in a variety of formats, including but not limited to chat, coding, and agentic sessions (“Inputs”), which generate responses and actions (“Outputs”，together with Inputs, collectively the “User Content”) based on your Inputs. This includes third-party applications you choose to integrate with our Services. If you include personal data in your Inputs, we will collect such information and it could be reflected in the Outputs generated. If you provide Inputs via audio, we will process your audio data solely through algorithmic means to deliver task results based on the specific instructions you input, select, or trigger. Except as described above, we will not process your audio data for other purposes (e.g., voiceprint recognition, Images, Videos), nor will we transfer any personal information contained therein to third parties.
19 Communication Information. If you communicate with us, including via email or our pages on social media sites, we will collect personal data, including your name, contact information, and the contents of the messages you send. 19 Communication Information. If you communicate with us, including via email or our pages on social media sites, we will collect personal data, including your name, contact information, and the contents of the messages you send.
20 Other Information You Provide. We may collect other information you may provide to us, such as when you use our beta products or services, participate in our responsible disclosure program or interact with us online or offline. Some of these services may have additional terms. 20 Other Information You Provide. We may collect other information you may provide to us, such as when you use our beta products or services, participate in our responsible disclosure program or interact with us online or offline. Some of these services may have additional terms.
21 Automatically Collected Information 21 Automatically Collected Information
22 Device and Connection Information. When you access and use the Services, we automatically collect certain device and connection information, including your operating system, mobile operator or internet service provider(ISP), mobile network, Internet Protocol (IP) address (including information about the location of the device from your IP address), identifiers (including device identifiers, probabilistic identifiers, and other unique personal or online identifiers), device location. 22 Device and Connection Information. When you access and use the Services, we automatically collect certain device and connection information, including your operating system, mobile operator or internet service provider(ISP), mobile network, Internet Protocol (IP) address (including information about the location of the device from your IP address), identifiers (including device identifiers, probabilistic identifiers, and other unique personal or online identifiers), device location.
23 Log Information. When you access and use the Service, we automatically collect your log information, including service-related diagnostic and performance data, as well as the user ID automatically assigned to you. 23 Log Information. When you access and use the Service, we automatically collect your log information, including service-related diagnostic and performance data, as well as the user ID automatically assigned to you.
24 Usage Information. We collect information about your use of the Services, including the dates and times of access, browsing history, search, information about the links you click, pages you view, and other information about how you use the Service, and technology on the devices you use to access the Service. 24 Usage Information. We collect information about your use of the Services, including the dates and times of access, browsing history, search, information about the links you click, pages you view, and other information about how you use the Service, and technology on the devices you use to access the Service.
25 Cookies & Similar Technologies. We and our service providers utilize cookies or similar technologies to operate and manage the Service and improve your experience. These technologies help us to recognize you, customize or personalize your experience, market additional products or services to you, and analyze and optimize your use of the Service. To learn more about our use of cookies and other tracking technologies, and how to manage your website privacy settings, please see Section 10 on “How Do We Use Cookies and Similar Technologies” below. 25 Cookies & Similar Technologies. We and our service providers utilize cookies or similar technologies to operate and manage the Service and improve your experience. These technologies help us to recognize you, customize or personalize your experience, market additional products or services to you, and analyze and optimize your use of the Service. To learn more about our use of cookies and other tracking technologies, and how to manage your website privacy settings, please see Section 10 on “How Do We Use Cookies and Similar Technologies” below.
26 Information From Other Sources 26 Information From Other Sources
27 Third Party SNS Account Information. We may offer you an option to log in using your existing account with certain third-party social networking sites (“SNSs”), including Google and GitHub. If you elect to do so, we may obtain your personal data from the SNS pursuant to your agreement with that SNS including your email, SNS ID, avatar url. The personal data we collect may depend on the privacy settings you have set with the SNS. We suggest that you check the privacy and data policies and practices of the SNS to learn how they handle personal data. 27 Third Party SNS Account Information. We may offer you an option to log in using your existing account with certain third-party social networking sites (“SNSs”), including Google and GitHub. If you elect to do so, we may obtain your personal data from the SNS pursuant to your agreement with that SNS including your email, SNS ID, avatar url. The personal data we collect may depend on the privacy settings you have set with the SNS. We suggest that you check the privacy and data policies and practices of the SNS to learn how they handle personal data.
28 Payment and Transaction Fulfillment Information. We receive information about you from payment and transaction fulfillment providers, including payment confirmation details, and information about the Service you purchase. 28 Payment and Transaction Fulfillment Information. We receive information about you from payment and transaction fulfillment providers, including payment confirmation details, and information about the Service you purchase.
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30 If you provide us with any personal data relating to a third party (e.g. your spouse, children, parents, and/or friends), by submitting such personal data to us, you represent to us that you have obtained the consent of such third party to you providing us with their personal data, and for the collection, use and disclosure of their personal data for all purposes set out herein and by or for the benefit of the persons referenced herein. 30 If you provide us with any personal data relating to a third party (e.g. your spouse, children, parents, and/or friends), by submitting such personal data to us, you represent to us that you have obtained the consent of such third party to you providing us with their personal data, and for the collection, use and disclosure of their personal data for all purposes set out herein and by or for the benefit of the persons referenced herein.
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32 You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any Services you have requested. 32 You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any Services you have requested.
33 How We Use Your Information 33 How We Use Your Information
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35 We use, process, and/or disclose your personal data for the following purposes: 35 We use, process, and/or disclose your personal data for the following purposes:
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37 | Purpose / Activity | Types of personal data | Retention | 37 | Purpose / Activity | Types of personal data | Retention |
38 | --- | --- | --- | 38 | --- | --- | --- |
39 | To create, manage, and administer your account | - Account Information - Third Party SNS Account Information - Communication Information - Payment Information - Payment and Transaction Fulfillment Information - Device and Connection Information - Log Information | For as long as you have an account with us. | 39 | To create, manage, and administer your account | - Account Information - Third Party SNS Account Information - Communication Information - Payment Information - Payment and Transaction Fulfillment Information - Device and Connection Information - Log Information | For as long as you have an account with us. |
40 | To facilitate Organization features (including without limitation to allow Administrators to manage your account and/or allow you to share data and materials within your Organization) | - Account Information - Third Party SNS Account Information - Communication Information - Feedback - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us. | 40 | To facilitate Organization features (including without limitation to allow Administrators to manage your account and/or allow you to share data and materials within your Organization) | - Account Information - Third Party SNS Account Information - Communication Information - Feedback - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us. |
41 | To facilitate payment transactions and respond to your payment-related inquiries. | - Account Information - Third Party SNS Account Information - Payment Information - Payment and Transaction Fulfillment Information - Communication Information - Device and Connection Information - Log Information | For as long as you have an account with us. | 41 | To facilitate payment transactions and respond to your payment-related inquiries. | - Account Information - Third Party SNS Account Information - Payment Information - Payment and Transaction Fulfillment Information - Communication Information - Device and Connection Information - Log Information | For as long as you have an account with us. |
42 | To provide and maintain the Services, including its core functionalities as well as any optional features or enhancements made available thereto. | - Account Information - Third Party SNS Account Information - User Content - Feedback - Communication Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us. | 42 | To provide and maintain the Services, including its core functionalities as well as any optional features or enhancements made available thereto. | - Account Information - Third Party SNS Account Information - User Content - Feedback - Communication Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us. |
43 | To debug and repair errors affecting functionality. | - Account Information - Third Party SNS Account Information - Device and Connection Information - Log Information | For as long as you have an account with us. | 43 | To debug and repair errors affecting functionality. | - Account Information - Third Party SNS Account Information - Device and Connection Information - Log Information | For as long as you have an account with us. |
44 | To communicate with you and provide user support in order to maintain and enhance our Services, including notifying you of any modifications to the Service or to our Terms and policies, addressing your queries, requests, complaints, and feedback, and conducting surveys. | - Account Information - Third Party SNS Account Information - Feedback - Communication Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us. | 44 | To communicate with you and provide user support in order to maintain and enhance our Services, including notifying you of any modifications to the Service or to our Terms and policies, addressing your queries, requests, complaints, and feedback, and conducting surveys. | - Account Information - Third Party SNS Account Information - Feedback - Communication Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us. |
45 | To research, develop and improve our Services | - User Content in a de-identified format. | Up to five years from the date of collection | 45 | To research, develop and improve our Services | - User Content in a de-identified format. | Up to five years from the date of collection |
46 | To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, us, or third parties. | - Account Information - Third Party SNS Account Information - Payment Information - Payment and Transaction Fulfillment Information - Feedback - Communication Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us and as required by applicable laws. | 46 | To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, us, or third parties. | - Account Information - Third Party SNS Account Information - Payment Information - Payment and Transaction Fulfillment Information - Feedback - Communication Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us and as required by applicable laws. |
47 | To investigate and/or prevent fraud, illegal activity, or misuses of our Services, violation of these Terms and/or applicable law, and/or to protect the security of our systems and Services. | - Account Information - Third Party SNS Account Information - Payment Information - Payment and Transaction Fulfillment Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us and as required by applicable laws. | 47 | To investigate and/or prevent fraud, illegal activity, or misuses of our Services, violation of these Terms and/or applicable law, and/or to protect the security of our systems and Services. | - Account Information - Third Party SNS Account Information - Payment Information - Payment and Transaction Fulfillment Information - Device and Connection Information - Log Information - Usage Information - Cookies | For as long as you have an account with us and as required by applicable laws. |
48 | To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services. | - Account Information - Third Party SNS Account Information - Device and Connection Information - Log Information - Usage Information | For as long as you have an account with us. | 48 | To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services. | - Account Information - Third Party SNS Account Information - Device and Connection Information - Log Information - Usage Information | For as long as you have an account with us. |
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50 We take steps to remove personal data from your User Content, as permitted by applicable law, before it is used to research, develop, and improve our Services. Depending on your plan, you may opt out of such use at any time by disabling the “Share & Improve” setting, which will prevent your User Content from being used for the purposes described above. Any data already processed for the above purposes prior to disabling this setting may continue to be retained and used in accordance with this section. 50 We take steps to remove personal data from your User Content, as permitted by applicable law, before it is used to research, develop, and improve our Services. Depending on your plan, you may opt out of such use at any time by disabling the “Share & Improve” setting, which will prevent your User Content from being used for the purposes described above. Any data already processed for the above purposes prior to disabling this setting may continue to be retained and used in accordance with this section.
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52 We may also use your information for any other purposes disclosed to you at the time we collect your information, with your consent, or as otherwise permitted by applicable laws. 52 We may also use your information for any other purposes disclosed to you at the time we collect your information, with your consent, or as otherwise permitted by applicable laws.
53 How We Share Your Information 53 How We Share Your Information
54 54
55 We may share your personal data with the recipients or in the scenarios listed below, for the purposes described in this Privacy Policy. 55 We may share your personal data with the recipients or in the scenarios listed below, for the purposes described in this Privacy Policy.
56 Your Organization. If you are a member of an Organization under an Enterprise or Team Plan, we may share your personal data with your Organization, Administrators of your Organization, and/or other users (if applicable) in your Organization. 56 Your Organization. If you are a member of an Organization under an Enterprise or Team Plan, we may share your personal data with your Organization, Administrators of your Organization, and/or other users (if applicable) in your Organization.
57 Service Providers. We may share your personal data with service providers we engage from time to time to provide various services, including cloud infrastructure to host our Services, large language models (such as Alibaba’s Qwen, MoonShoot’s Kimi) to support your coding experience and help generate Outputs, as well as codebase data storage and web search providers that help us provide and deliver the Service. All such Service Providers are contractually required to maintain data protection standards equal to or exceeding those required by applicable laws and regulations, in order to facilitate the delivery of our Services. When you enable the “Bring Your Own Key” (BYOK) feature, your information may be transmitted to third-party service providers designated by you, and such transmission constitutes your own independent action rather than a sharing practice by our Service, and the processing of such data shall be governed by the privacy policies of the respective third-party service providers. 57 Service Providers. We may share your personal data with service providers we engage from time to time to provide various services, including cloud infrastructure to host our Services, large language models (such as Alibaba’s Qwen, MoonShoot’s Kimi) to support your coding experience and help generate Outputs, as well as codebase data storage and web search providers that help us provide and deliver the Service. All such Service Providers are contractually required to maintain data protection standards equal to or exceeding those required by applicable laws and regulations, in order to facilitate the delivery of our Services. When you enable the “Bring Your Own Key” (BYOK) feature, your information may be transmitted to third-party service providers designated by you, and such transmission constitutes your own independent action rather than a sharing practice by our Service, and the processing of such data shall be governed by the privacy policies of the respective third-party service providers.
58 Third Parties. We may share your personal data, including Log Information, with third parties whose platforms or services are integrated with the Service. For example, if you log in using your existing account with third-party SNSs, including Google and Github, we will share certain Log Information to facilitate account registration or log in. 58 Third Parties. To the extent necessary to provide the Services, we may share your personal data, including Log Information, Payment Information, and Usage Information, with third parties whose platforms or services are integrated with the Service. For example, if you log in using your existing account with third-party SNSs, including Google and GitHub, we will share certain Log Information to facilitate account registration or log in.
59 Our Corporate Group. Certain entities within our corporate group ("Corporate Group") receive and process personal data to support the provision of the Services. These entities process Information Provided By You, Automatically Collected Information, and Information From Other Sources for us, as necessary to provide functions such as storage, operation and maintenance of Service, security, research and development, analytics, online payments, customer and technical support. 59 Our Corporate Group. Certain entities within our corporate group ("Corporate Group") receive and process personal data to support the provision of the Services. These entities process Information Provided By You, Automatically Collected Information, and Information From Other Sources for us, as necessary to provide functions such as storage, operation and maintenance of Service, security, research and development, analytics, online payments, customer and technical support.
60 Corporate Transactions. Your personal data may, to the extent permitted by applicable laws and subject to your consent when required, be disclosed to third parties: In the event that we discuss or negotiate the sale or sell any business or assets, in which case we may disclose your information to the prospective buyer of such business or assets; or 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 including asset sales, consolidations or in the unlikely event of bankruptcy. 60 Corporate Transactions. Your personal data may, to the extent permitted by applicable laws and subject to your consent when required, be disclosed to third parties: In the event that we discuss or negotiate the sale or sell any business or assets, in which case we may disclose your information to the prospective buyer of such business or assets; or 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 including asset sales, consolidations or in the unlikely event of bankruptcy.
61 Legal Obligations and Rights. We may, to the extent permitted by applicable laws, access, preserve, and share the information described in "What Information We Collect" with any competent law enforcement body, regulatory or government agency, court, public authority, or other third party if we have good faith belief that it is necessary to: 61 Legal Obligations and Rights. We may, to the extent permitted by applicable laws, access, preserve, and share the information described in "What Information We Collect" with any competent law enforcement body, regulatory or government agency, court, public authority, or other third party if we have good faith belief that it is necessary to:
62 Comply with applicable laws, regulations, codes of practice, legal process, or governmental guidance or requests as consistent with internationally recognised standards; 62 Comply with applicable laws, regulations, codes of practice, legal process, or governmental guidance or requests as consistent with internationally recognised standards;
63 Protect the rights, property, and safety of our users and others as required or permitted by law; 63 Protect the rights, property, and safety of our users and others as required or permitted by law;
64 Exercise or defend any legal claims, including to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries; 64 Exercise or defend any legal claims, including to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries;
65 Investigate potential violations of and enforce our Terms of Service, or any other applicable terms, policies, or standards; or 65 Investigate potential violations of and enforce our Terms of Service, or any other applicable terms, policies, or standards; or
66 Detect, investigate, prevent, or otherwise address misleading or illegal activities. 66 Detect, investigate, prevent, or otherwise address misleading or illegal activities.
67 With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction. 67 With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.
68 Your Rights and Choices 68 Your Rights and Choices
69 69
70 Depending on where you reside, you may have certain rights and choices when it comes to your information. Depending on where you live, your rights under applicable laws may include the right to access, delete, transfer, or correct your personal data; to be informed of the ways in which we process your personal data; to object to certain processing activities; to file complaints with authorities; and more. Some of your rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations by law. 70 Depending on where you reside, you may have certain rights and choices when it comes to your information. Depending on where you live, your rights under applicable laws may include the right to access, delete, transfer, or correct your personal data; to be informed of the ways in which we process your personal data; to object to certain processing activities; to file complaints with authorities; and more. Some of your rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations by law.
71 71
72 For detailed information about the specific rights available to you in your region, please see the Jurisdiction Specific Addendum below. For information about your cookie-related privacy choices, please see Section 10 on “How Do We Use Cookies and Similar Technologies” below. 72 For detailed information about the specific rights available to you in your region, please see the Jurisdiction Specific Addendum below. For information about your cookie-related privacy choices, please see Section 10 on “How Do We Use Cookies and Similar Technologies” below.
73 73
74 If you have questions or would like to exercise any of your personal data rights, please contact us at intldpo@qoder.com or see the Jurisdiction Specific Addendum below, in case a local contact is available in your region. There may be situations where we cannot grant your request. For example, if you make a request and we cannot verify your identity, we will not be able to comply with the request. We may be unable to comply with your request if we are required to retain your information due to legal or regulatory obligations, such as when the information is necessary to complete a transaction, when fulfilling the request would compromise the privacy of others, or when it would be impractical to do so. 74 If you have questions or would like to exercise any of your personal data rights, please contact us at intldpo@qoder.com or see the Jurisdiction Specific Addendum below, in case a local contact is available in your region. There may be situations where we cannot grant your request. For example, if you make a request and we cannot verify your identity, we will not be able to comply with the request. We may be unable to comply with your request if we are required to retain your information due to legal or regulatory obligations, such as when the information is necessary to complete a transaction, when fulfilling the request would compromise the privacy of others, or when it would be impractical to do so.
75 Data Security 75 Data Security
76 76
77 Security of your information is important to us. We use appropriate technical and organizational measures to protect the personal data that we collect, use, disclose, and process. These measures are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include encrypting your personal data in transit and at rest; developing and implementing an Information Security Programme in accordance with a standard industry framework; employing advance malware protections; implementation of other reasonable security defences (including vulnerability management, access management and recovery/resilience measures). 77 Security of your information is important to us. We use appropriate technical and organizational measures to protect the personal data that we collect, use, disclose, and process. These measures are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include encrypting your personal data in transit and at rest; developing and implementing an Information Security Programme in accordance with a standard industry framework; employing advance malware protections; implementation of other reasonable security defences (including vulnerability management, access management and recovery/resilience measures).
78 78
79 The Service may, from time to time, contain links to policies, functionality, or content maintained by third parties we do not control. We are not responsible for, and make no representations regarding, such third party policies and practices. 79 The Service may, from time to time, contain links to policies, functionality, or content maintained by third parties we do not control. We are not responsible for, and make no representations regarding, such third party policies and practices.
80 Data Retention 80 Data Retention
81 81
82 We retain information for as long as necessary to provide the Service and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with our contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Service, and enhancing its safety, security, and stability), and for the exercise or defense of legal claims. 82 We retain information for as long as necessary to provide the Service and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with our contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Service, and enhancing its safety, security, and stability), and for the exercise or defense of legal claims.
83 83
84 The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, we retain your Account Information for as long as you have an account. If you violate our Terms of Service, we may immediately remove your access to the Service but retain your information as necessary to investigate the violation, to the extent permitted by applicable laws. 84 The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, we retain your Account Information for as long as you have an account. If you violate our Terms of Service, we may immediately remove your access to the Service but retain your information as necessary to investigate the violation, to the extent permitted by applicable laws.
85 85
86 When we have no further legitimate need or legal reason to retain your personal data, we will either delete it in a secure manner or deidentify it such that can no longer be associated with you. 86 When we have no further legitimate need or legal reason to retain your personal data, we will either delete it in a secure manner or deidentify it such that can no longer be associated with you.
87 International Data Transfers 87 International Data Transfers
88 88
89 Depending on where you are located and the features of our Services which you access or use, your personal data may be transferred out of and processed on a server located outside of your country of residence. We process and store the information we collect in secure servers located in the United States, Singapore and Japan. We may also, and to the extent permitted by applicable laws, transfer your personal data internationally for one or more of the purposes described in this Privacy Policy. Please note that the data protection laws in the locations where we transfer or process data may differ from those in your area. We take appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Policy and applicable laws and we only transfer your data overseas in accordance with applicable law and legally valid transfer mechanisms. 89 Depending on where you are located and the features of our Services which you access or use, your personal data may be transferred out of and processed on a server located outside of your country of residence. We process and store the information we collect in secure servers located in the United States, Singapore and Japan. We may also, and to the extent permitted by applicable laws, transfer your personal data internationally for one or more of the purposes described in this Privacy Policy. Please note that the data protection laws in the locations where we transfer or process data may differ from those in your area. We take appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Policy and applicable laws and we only transfer your data overseas in accordance with applicable law and legally valid transfer mechanisms.
90 Minimum Age and Minors 90 Minimum Age and Minors
91 91
92 Our Service is not directed at, and shall not be used by, minors or otherwise lacks legal capacity under applicable law, including but not limited to persons under the age of 18. Additionally, all users are strictly prohibited from uploading, transmitting, emailing, or otherwise making personal data from children or minors as defined under applicable law available to us or other users or using them for any of our Services. If you believe that we have collected personal data from or about a minor under the minimum age, please contact us at intldpo@qoder.com. 92 Our Service is not directed at, and shall not be used by, minors or otherwise lacks legal capacity under applicable law, including but not limited to persons under the age of 18. Additionally, all users are strictly prohibited from uploading, transmitting, emailing, or otherwise making personal data from children or minors as defined under applicable law available to us or other users or using them for any of our Services. If you believe that we have collected personal data from or about a minor under the minimum age, please contact us at intldpo@qoder.com.
93 How Do We Use Cookies and Similar Technologies 93 How Do We Use Cookies and Similar Technologies
94 a. Cookies and similar technologies we used 94 a. Cookies and similar technologies we used
95 95
96 We may use cookies and similar technologies to gather information resulting from access and/or use of our Services. The technologies we use may include: 96 We may use cookies and similar technologies to gather information resulting from access and/or use of our Services. The technologies we use may include:
97 Essential Cookies 97 Essential Cookies
98 98
99 These cookies are crucial for the core functions of the website and must be enabled to ensure the proper operation of the service: 99 These cookies are crucial for the core functions of the website and must be enabled to ensure the proper operation of the service:
100 100
101 | Cookie Name | Purpose | Category | 101 | Cookie Name | Purpose | Category |
102 | --- | --- | --- | 102 | --- | --- | --- |
103 | qoder\session\cookie | Maintains user login status | Essential (Functionality) | 103 | qoder\session\cookie | Maintains user login status | Essential (Functionality) |
104 | qoder\csrf\token | Prevents Cross-Site Request Forgery (CSRF) attacks | Essential (Security) | 104 | qoder\csrf\token | Prevents Cross-Site Request Forgery (CSRF) attacks | Essential (Security) |
105 | acw\_tc | Web Application Firewall (WAF) protection management | Essential (Security) | 105 | acw\_tc | Web Application Firewall (WAF) protection management | Essential (Security) |
106 | \c\WBKFRo | Alibaba Cloud Captcha 2.0 | Essential (Security) | 106 | \c\WBKFRo | Alibaba Cloud Captcha 2.0 | Essential (Security) |
107 | \nb\ioWEgULi | Alibaba Cloud Captcha 2.0 | Essential (Security) | 107 | \nb\ioWEgULi | Alibaba Cloud Captcha 2.0 | Essential (Security) |
108 Preference Cookies 108 Preference Cookies
109 109
110 These cookies are used to store user personalisation settings and can be enabled or disabled at the user’s discretion: 110 These cookies are used to store user personalisation settings and can be enabled or disabled at the user’s discretion:
111 111
112 | Cookie Name | Purpose | Category | 112 | Cookie Name | Purpose | Category |
113 | --- | --- | --- | 113 | --- | --- | --- |
114 | qoder\_locale | Records user language preferences | Non-essential (Preference) | 114 | qoder\_locale | Records user language preferences | Non-essential (Preference) |
115 | qoder\_theme | Records user theme preferences | Non-essential (Preference) | 115 | qoder\_theme | Records user theme preferences | Non-essential (Preference) |
116 Third-Party Data Collection Explanation 116 Third-Party Data Collection Explanation
117 117
118 This Services may include third-party tools, whose cookie policies comply with their respective data protection regulations: 118 This Services may include third-party tools, whose cookie policies comply with their respective data protection regulations:
119 119
120 Google Analytics 120 Google Analytics
121 121
122 Used for anonymous analysis of website traffic and experience optimisation. Cookies set by Google include: 122 Used for anonymous analysis of website traffic and experience optimisation. Cookies set by Google include:
123 123
124 Cookie Name: ga, ga\ and others 124 Cookie Name: ga, ga\ and others
125 Purpose: To collect anonymous statistics (such as page views, traffic sources, device types, time spent on site, etc. 125 Purpose: To collect anonymous statistics (such as page views, traffic sources, device types, time spent on site, etc.
126 Data Controller: Google (please refer to Google’s privacy policy) 126 Data Controller: Google (please refer to Google’s privacy policy)
127 b. More information about cookies 127 b. More information about cookies
128 128
129 For more information about cookie and instructions on how to set up your browser to accept, delete or disable cookies, see www.allaboutcookies.org. 129 For more information about cookie and instructions on how to set up your browser to accept, delete or disable cookies, see www.allaboutcookies.org.
130 Privacy Policy Updates 130 Privacy Policy Updates
131 131
132 We may amend or update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last Updated" date at the top of the new Privacy Policy, posting the new Privacy Policy, or by providing other notice as required by applicable laws. We recommend that you review the Privacy Policy from time to time to stay informed of our privacy practices. 132 We may amend or update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last Updated" date at the top of the new Privacy Policy, posting the new Privacy Policy, or by providing other notice as required by applicable laws. We recommend that you review the Privacy Policy from time to time to stay informed of our privacy practices.
133 Contact Us 133 Contact Us
134 134
135 If you have any questions about this Privacy Policy, or have any questions, complaints or requests regarding your personal data, you can contact our Data Protection Officer (DPO) via the contact details set out below: 135 If you have any questions about this Privacy Policy, or have any questions, complaints or requests regarding your personal data, you can contact our Data Protection Officer (DPO) via the contact details set out below:
136 Attention: DPO 136 Attention: DPO
137 Email address: intldpo@qoder.com 137 Email address: intldpo@qoder.com
138 138
139 Please note that if your personal data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf. 139 Please note that if your personal data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.
140 United States Addendum 140 United States Addendum
141 141
142 This is an addendum to the Qoder Privacy Policy in relation to US data subjects (this “US Addendum”) and should be read in conjunction with the Privacy Policy. 142 This is an addendum to the Qoder Privacy Policy in relation to US data subjects (this “US Addendum”) and should be read in conjunction with the Privacy Policy.
143 143
144 Residents of certain US states have additional privacy rights disclosures regarding their personal data. 144 Residents of certain US states have additional privacy rights disclosures regarding their personal data.
145 Additional Rights: 145 Additional Rights:
146 146
147 Depending on where you reside, US residents may have additional rights: 147 Depending on where you reside, US residents may have additional rights:
148 Know the categories and/or specific pieces of personal data collected about you, including the categories from which the personal data is collected, the business purpose for collecting the personal data, whether your personal data was disclosed to third parties, the categories of personal data, if any, that we disclosed to third parties, the categories of and/or the third parties to whom your personal data was disclosed 148 Know the categories and/or specific pieces of personal data collected about you, including the categories from which the personal data is collected, the business purpose for collecting the personal data, whether your personal data was disclosed to third parties, the categories of personal data, if any, that we disclosed to third parties, the categories of and/or the third parties to whom your personal data was disclosed
149 Access or obtain a copy of the specific pieces of personal data we retain about you 149 Access or obtain a copy of the specific pieces of personal data we retain about you
150 Request deletion of your personal data 150 Request deletion of your personal data
151 Request correction of inaccurate personal data. 151 Request correction of inaccurate personal data.
152 152
153 Authorized Agents. Your authorized agent may submit a request to exercise any of the above rights on your behalf. We may request additional information to verify their authority to act on your behalf before processing any requests. 153 Authorized Agents. Your authorized agent may submit a request to exercise any of the above rights on your behalf. We may request additional information to verify their authority to act on your behalf before processing any requests.
154 154
155 Please submit requests by emailing intldpo@qoder.com. 155 Please submit requests by emailing intldpo@qoder.com.
156 156
157 No Sale of Personal data, Sharing for Cross-Context Behavioral Advertising, and Targeted Advertising 157 No Sale of Personal data, Sharing for Cross-Context Behavioral Advertising, and Targeted Advertising
158 158
159 We do not “sell” or “share” personal data for cross-contextual behavioral advertising, and we do not process personal data for “targeted advertising” purposes (as those terms are defined under applicable US state privacy laws). 159 We do not “sell” or “share” personal data for cross-contextual behavioral advertising, and we do not process personal data for “targeted advertising” purposes (as those terms are defined under applicable US state privacy laws).
160 160
161 Do Not Track. Our websites and apps are not designed to respond to "do not track" requests from browsers. 161 Do Not Track. Our websites and apps are not designed to respond to "do not track" requests from browsers.
162 Singapore Addendum 162 Singapore Addendum
163 163
164 This is an addendum to the Qoder Privacy Policy in relation to Singapore data subjects (this “Singapore Addendum”) and should be read in conjunction with the Privacy Policy. This Singapore Addendum applies if you are based in Singapore during your interaction with us. 164 This is an addendum to the Qoder Privacy Policy in relation to Singapore data subjects (this “Singapore Addendum”) and should be read in conjunction with the Privacy Policy. This Singapore Addendum applies if you are based in Singapore during your interaction with us.
165 Consent to collection, use, disclosure and/or processing of personal data 165 Consent to collection, use, disclosure and/or processing of personal data
166 166
167 By providing us with your personal data, you consent to us collecting, using, disclosing and/or processing your personal data as set out in this Privacy Policy, unless an exception under the law permits us to collect, use, disclose and/or process personal data without consent. 167 By providing us with your personal data, you consent to us collecting, using, disclosing and/or processing your personal data as set out in this Privacy Policy, unless an exception under the law permits us to collect, use, disclose and/or process personal data without consent.
168 Transfer of personal data outside of Singapore 168 Transfer of personal data outside of Singapore
169 169
170 Where we transfer personal data outside of Singapore, we will do so in accordance with the Personal Data Protection Act 2012 (SG PDPA) and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the SG PDPA. 170 Where we transfer personal data outside of Singapore, we will do so in accordance with the Personal Data Protection Act 2012 (SG PDPA) and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the SG PDPA.
171 Access and correction of personal data 171 Access and correction of personal data
172 172
173 You have the right to request access to your personal data held by us (or on our behalf) and to request for correction of such personal data. 173 You have the right to request access to your personal data held by us (or on our behalf) and to request for correction of such personal data.
174 Withdrawal of consent 174 Withdrawal of consent
175 175
176 You may withdraw consent and request that we stop using and/or disclosing your personal data for any of the purposes listed under Section 3 of the Privacy Policy by submitting your request in writing to the Data Protection Officer, in respect of personal data collected, used or disclosed in Singapore. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. 176 You may withdraw consent and request that we stop using and/or disclosing your personal data for any of the purposes listed under Section 3 of the Privacy Policy by submitting your request in writing to the Data Protection Officer, in respect of personal data collected, used or disclosed in Singapore. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
177 177
178 In general, we shall seek to process your request as soon as possible and within a reasonable timeframe. While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to to continue providing our goods and services to you and we shall, in such circumstance, notify you before completing the processing of your request. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under the SG PDPA. 178 In general, we shall seek to process your request as soon as possible and within a reasonable timeframe. While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to to continue providing our goods and services to you and we shall, in such circumstance, notify you before completing the processing of your request. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under the SG PDPA.
179 Data Protection Officer 179 Data Protection Officer
180 180
181 Any questions regarding this Privacy Policy may be directed to our Data Protection Officer at the contact details set out below: 181 Any questions regarding this Privacy Policy may be directed to our Data Protection Officer at the contact details set out below:
182 Email address: intldpo@qoder.com 182 Email address: intldpo@qoder.com
183 Australia Addendum 183 Australia Addendum
184 184
185 If you are located in Australia, you acknowledge that BRIGHT ZENITH is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal data, please contact our DPO at the address set forth in the section 12 above, who will review your complaint and respond within a reasonable period. If you are dissatisfied with the handling of your complaint or concern, you may contact the Office of the Australian Information Commissioner: 185 If you are located in Australia, you acknowledge that BRIGHT ZENITH is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal data, please contact our DPO at the address set forth in the section 12 above, who will review your complaint and respond within a reasonable period. If you are dissatisfied with the handling of your complaint or concern, you may contact the Office of the Australian Information Commissioner:
186 Office of the Australian Information Commissioner: GPO Box 5218 Sydney NSW 2001 186 Office of the Australian Information Commissioner: GPO Box 5218 Sydney NSW 2001
187 Telephone: 1300 363 992 187 Telephone: 1300 363 992
188 Email: enquiries@oaic.gov.au 188 Email: enquiries@oaic.gov.au
189 The Philippines Addendum 189 The Philippines Addendum
190 190
191 This is an addendum to the Privacy Policy in relation to Philippine data subjects (this “Philippines Addendum”) and should be read in conjunction with the Privacy Policy. 191 This is an addendum to the Privacy Policy in relation to Philippine data subjects (this “Philippines Addendum”) and should be read in conjunction with the Privacy Policy.
192 Location and Storage of Personal Data 192 Location and Storage of Personal Data
193 193
194 Your personal data will be stored in Singapore. Your personal data may however be transferred to or accessed by our officers, employees, support staff, agents, Third Party Service Providers (and their sub-processors, if any), and our affiliate companies (and their designated Service Providers and the latter’s sub-processors, if any), which may be located in several other jurisdictions. 194 Your personal data will be stored in Singapore. Your personal data may however be transferred to or accessed by our officers, employees, support staff, agents, Third Party Service Providers (and their sub-processors, if any), and our affiliate companies (and their designated Service Providers and the latter’s sub-processors, if any), which may be located in several other jurisdictions.
195 Rights of Data Subjects 195 Rights of Data Subjects
196 196
197 In addition to the above-discussed rights as provided under Section 5 of the Privacy Policy, You have the right to be informed of the processing of your personal data, the right to object to the processing of your personal data (in which case, you may have to cease using our services), and the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, and the right to obtain a copy of your personal data, which has been stored in electronic or structured format. If you believe that your right as a data subject has been violated, you may also file a complaint with the Philippine National Privacy Commission. 197 In addition to the above-discussed rights as provided under Section 5 of the Privacy Policy, You have the right to be informed of the processing of your personal data, the right to object to the processing of your personal data (in which case, you may have to cease using our services), and the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, and the right to obtain a copy of your personal data, which has been stored in electronic or structured format. If you believe that your right as a data subject has been violated, you may also file a complaint with the Philippine National Privacy Commission.
198 Contact Information of Data Protection Officer 198 Contact Information of Data Protection Officer
199 199
200 If you have any questions regarding this Privacy Policy or want to exercise any of your rights as provided in this Privacy Policy or pursuant to Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its implementing rules and regulations, any relevant issuance of the Philippine National Privacy Commission, and other privacy laws and regulations in the Philippines (as may be amended from time to time), you may reach us through our Data Protection Officer as set in Section 12 of this Privacy Policy. 200 If you have any questions regarding this Privacy Policy or want to exercise any of your rights as provided in this Privacy Policy or pursuant to Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its implementing rules and regulations, any relevant issuance of the Philippine National Privacy Commission, and other privacy laws and regulations in the Philippines (as may be amended from time to time), you may reach us through our Data Protection Officer as set in Section 12 of this Privacy Policy.