Ping!'s Privacy Policy

Welcome to "Ping!"(the "Platform" or "Ping!"). The Platform is provided and controlled by NexaConnect INC("we" or "us"). We are committed to protecting and respecting your privacy.

This Privacy Policy (the “Policy”) covers the experience we provide for users aged 18 and older on our Platform. IF YOU ARE UNDER THE AGE OF 18 OR THE AGE OF MAJORITY AS DETERMINED BY THE LAWS OF YOUR COUNTRY, PLEASE DO NOT USE OUR SERVICES.

This Policy is written in English. To the extent any translated version of this agreement conflicts with the English version, the English version controls.

The full legal bit

We know that other people’s use of your personal data is a big concern for social network users, so we have developed this Policy to let you know how we use your personal information (or "personal data").

Our Policy applies to your use of "Ping!". When you access or use "Ping!", it indicates your agreement to our "Terms and Conditions" and "Privacy Policy", and you consent to our collection, storage, use, and disclosure of your personal information in accordance with this Policy. By installing, using, registering to or otherwise accessing the services, you agree to this Policy and give explicit and informed consent to the processing of your personal data in accordance with this Policy.

IF YOU DO NOT ACCEPT AND AGREE WITH OUR "TERMS AND CONDITIONS" AND "PRIVACY POLICY", PLEASE DO NOT ACCESS OR USE "Ping!".

"Ping!" reserves the right to change our Policy at any time to address Services updates, legal changes, and other factors. We will make commercially reasonable endeavours to notify all the users uniformly of any changes to this Policy that may materially and substantially affect your rights, for example through notices or pop-ups on the Platform. We also recommend you regularly review this Policy to check for any changes. We will indicate the Last Update date at the top of the Policy and your continued use of our Services after the update date signifies your agreement to the updated Policy. If you do not agree with the updated version of our Policy, please do not use our Services.

The Summary

Here are the topics that we cover:

I. What information do we collect

II. How we use your information

III. How we share your information

IV. Your rights

V. Data Storage and Transfer

VI. Security

VII. Cookies and other technologies

VIII. Minors Information

IX. Child Protection

X. Disclaimer

XI. Contact

I. What information do we collect

Personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified. We collect personal data from a variety of sources, including you directly provide, we directly collect when you use, and information we collect about you from other sources.

Information you choose to provide

• Registration information, such as nickname, age, gender, username, avatar, and phone number(including verification code and password).

• Profile information, such as your height, weight, occupation, location, nationality. These pieces of information are not mandatory; you may choose whether or not to provide them.

• User-generated content, including comments, pictures, text and voice messages, photographs, videos, and virtual item videos that you choose to upload or broadcast on the Platform (“Content”).

• Facial data, if you plan to become one of our certified streamers, or want to complete real person certification (including gender authentication and avatar authentication) for obtaining more benefits, we will collect and compare your profile picture and facial-recognition video for authenticity verification on the premise of your approval. This authentication can protect you from impersonators and fake accounts and protect the legitimate rights and interests of other users. We do not retain your face recognition video in our servers, such video is merely for verifying, and will not be used for any other purpose.

•Purchase Data. When you make a purchase, we keep the details of the transaction (e.g., what you purchased, the date of the transaction, and the price). The exact data depends on the payment method you choose. When you pay directly with us (rather than through a platform such as iOS or Android), you provide your debit or credit card number or other financial info.

Marketing, Survey and Research Data. We sometimes run (i) surveys, focus groups, or market studies for research purposes and (ii) promotions, events, or contests for marketing purposes. When you choose to participate, you give us information to process your entry and participation, as well as your responses to our questions and your feedback, including your email and phone number so that we can conduct follow-up research.

Customer Support Data. When you contact us, you provide us with information that may be necessary to help address your inquiry. Other people may also submit queries or reports involving you. Finally, our moderation tools and teams can collect additional data as part of their investigations.

Information we obtain from other sources

We may receive the information described in this Policy from other sources, such as:

• Social Media. If you choose to link or sign up using your third-party social network platform (such as Facebook, X, Instagram, or Google), we may collect information from these social media services, including your nickname as it appears on your social media profile, your user ID and your profile image, this depends on the policy of the social media platform and your privacy settings.

• Third-Party Services. We may collect information about you from third-party services, such as advertising partners, payment partners and analytics providers. However, please note that this Policy does not and will not extend to how the third-parties collect and process your information, which shall be subject to the respective their own privacy policies.

II. How we use your information

We may use your personal information for the following purpose:

• Services Provision and Operation: To provide you with "Ping!" Services and maintain the normal operation of the services, such as interactive communication between users, discovering friends, and your other activities through "Ping!";

• Identification and Authentication: To verify your identity and create a profile for you when you register with us, identify your device, access and use our Services, or otherwise engage with us, and to ensure the security of your personal data;

• Contractual Obligations: To carry out our contractual obligations to you under the Terms and Conditions or to take steps at your request before entering into such agreement;

• Service Improvements and Analyse: To continually improve the user experience, identify network status, monitor account anomalies, and understand the suitability of products and services;

• Security: To keep users’ activities and accounts security;

• Recharge Services: To support and verify user payment behavior;

• Communications and Customer Service: Respond to your requests to us and notify you of changes to "Ping!" services and this Policy;

• Advertising and Marketing: To understand your preferences, and to help determine which marketing materials would be of interest to you. Where required by law, we will obtain your consent before sending such marketing materials;

• Exercising our Rights and Complying with our Obligations: Exercise our legal rights where it is necessary, for example to detect, prevent, and respond to infringement claims or violations of law. We may process your personal data to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.

III. How we share your information

We are committed to maintaining your trust and personal information safety. We will not provide, disclose or share your personal information to or with any third parties unless we have obtained your consent or such provision, disclosure or sharing of personal information is permitted under applicable laws. The potential circumstances in which we may share your information with necessary third parties are listed in this Policy as below.

Please be informed that when you upload and publish your personal information, posts, comments, videos and other contents, the above contents may be seen by anyone on the platform, and "Ping!" cannot guarantee that your above contents will not be found on other third-party platforms. You should be cautious to disclose personal information while engaging. We are not responsible for the information you choose to submit.

Service Providers and Business Partners

• Cloud service providers: provide basic data storage services;

• Payment service providers: help you process and complete transactions. Any payment sensitive information (such as card number, payment password, CVV number and so on) is collected and processed by the payment processor you choose;

• Advertising and attribution service providers: We may publish ads about third-party advertisers’ products and services on our service, and publish ads promoting our own service on third-party sites and apps. To help improve the relevance of these ads, we provide certain info about you to third parties, including advertising partners, or allow them to collect such data from our services (such as via cookies, SDKs, or similar technologies). Some of our advertising partners enable us to transform your email address, advertising identifiers or phone number into an identifier that can’t be used to identify you personally and then use that unique identifier to either exclude you from our marketing campaigns, or to target our ads at an audience that is similar to you in terms of background, interests or app usage.

• Data analysis and security service provider: count and monitor the number of users, conduct data analysis, identify fraud and ensure user safety.

• Other business partners. We share data with vendors and partners who help us operate, promote and improve our service. They provide us services such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, legal support, and security operations.

Within Our Corporate Group

We may share your information with our parent companies, subsidiaries, or other affiliates of our corporate group for better service. We will take measures to have our group companies with which the personal information is shared comply with this Policy.

Succession of business

If there is any transaction between companies pertaining to our business to which this Policy is applicable, such as acquisition, merger or change of business entity, personal information may also be transferred to the successor of the business to the extent permitted under applicable laws.

For Legal Reasons

"Ping!" wishes to maintain a healthy community, and we will cooperate with all the related third parties to enforce their intellectual property or other rights.

We may disclose your information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of "Ping!", the Platform, our affiliates, users, or the public. We may also share your information to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law in our discretion.

We will also cooperate with law enforcement inquiries from within or outside your country of residence. When we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, or legal process served on us, we may raise or waive any legal objection or right available to us.

IV. Your Rights

To the extent permitted under applicable laws, regarding your personal information that we process, you have the right to access, the right to rectification, the right to erasure, the right to restriction of processing, the right to withdraw your consent, the right to data portability, the right to confirm if we process any personal information of yours, and the right to request a review of any automated decisions that may be made as a result of the processing. And, we will not discriminate against you for exercising any rights.

If you want to exercise your right against us to process your personal information, correct or delete your personal information that is contrary to facts, notify you of the purpose of use of your personal information, or other rights permitted under applicable laws, you may contact us via contact@ping-date.com.

After verification of your identity, we will respond to your request within a reasonable period of time, and in accordance with relevant laws. If, however, permitted under applicable laws, we may not be able to respond to your request when any of the following applies:

• is likely to harm the life, body, property, or other rights or interests of yours or another user / individual;

• is likely seriously impede the proper execution of our business;

• is likely to violate other laws and regulations;

• when we failed to verify your identity; or

• we are otherwise permitted under applicable laws to refuse your request.

If you no longer wish to use "Ping!" or if you withdraw your consent to Ping!'s processing of your personal information which is necessary for us to provide services, you may choose to delete your entire Ping!'s account by the following steps:

• Open "Ping!"

• Tap Me>Settings>Account and Safety>Delete account

• Click "Request deletion" or "Think twice"

Following account closure, we delete your data as laid out below:

•To protect the safety and security of our members, we implement a safety retention window of three months following account closure or one year following an account ban. During this period, we keep your data to investigate unlawful or harmful conduct. The retention of data during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.

•We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction, and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to comply and evidence our compliance with applicable law.

•We maintain limited data on the basis of our legitimate interest: we keep customer care exchanges with you for 6 years from the date of the communication, customer care records and supporting data, as well as imprecise location of download/purchase, for five years in support of our safety efforts, to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent members who were banned from opening a new account for as long as necessary to ensure the safety and vital interests of our members.

•Finally, we maintain data on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep data in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings.

Where and as legally permitted, we may maintain and use data that, by itself, cannot identify or be attributed specifically to you for the purposes described in this Privacy Policy, including improving our service and creating new features, technologies and services and keeping our services safe.

V. Data Storage and Transfer

"Ping!" is a global social app operating through servers located in a number of countries around the world, including the United States. In providing our services, we may store your personal information outside the country or region where you reside. When that happens, we will take measures to ensure your personal information is processed and stored according to the applicable laws. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. We will store your personal information within the reasonable and necessary period prescribed by laws and regulations. We will delete or anonymize the information beyond the above period.

VI. Security

How does "Ping!" protect your personal information?

"Ping!" has implemented reasonable and appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal information. "Ping!" uses reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls. Our technical experts at "Ping!" work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our website, member database and records, you understand that no website or Internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your password) and to log out of your account after use.

We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk. Once we have received your information we have procedures and security features in place to try to prevent unauthorized access.

How do you help keep your information secure?

You may not disclose your password to any third parties or share it with any third parties. If you lose your password or give it out, your personal information may be compromised. If that happens, please report it to Support via our Online Customer Service. You should change your password immediately via your "Settings" page. "Ping!" cannot be held responsible for your failure to keep your password secure and failure to do so may violate our Terms and Conditions.

VII. Cookies and other technologies

To make the application work effectively, we sometimes place small data files called Cookies on your device. Most applications’ developer do this. A Cookie is a small text file that website saves when you visit the site. It enables the website to remember your actions and preferences, designed to improve use experience.

You can control whether or not to accept Cookies by contacting us or your browser settings. If, however, you deactivate Cookies or limit the ability to set Cookies, you may not be able to obtain the full benefit of our services or access all of its functions, which may limit your overall user experience.

VIII. Minors Information

WE DO NOT PROVIDE SERVICES TO MINOR USERS UNDER THE AGE OF 18 (OR THE AGE OF MAJORITY UNDER LOCAL LAW). We do not knowingly or deliberately collect or retain the personal information of individuals under the age of 18 (or the age of majority under local law). If we learn that personal information of individuals under the age of 18 (or the age of majority under local law) has been collected on or through our Services, we will take appropriate measures to delete such information and delete the corresponding account.

PLEASE NOTE THAT AS A PARENT OR LEGAL GUARDIAN, IT IS YOUR RESPONSIBILITY TO SUPERVISE AND MANAGE YOUR CHILD’S USE OF OUR SERVICES. IF A MINOR PROVIDES FALSE INFORMATION AND CLAIMS TO BE OF LEGAL AGE, YOU, AS THE PARENT OR GUARDIAN, WILL ASSUME FULL RESPONSIBILITY FOR ANY CONSEQUENCES ARISING FROM SUCH MISREPRESENTATION. WE STRONGLY ENCOURAGE PARENTS AND GUARDIANS TO EDUCATE THEIR CHILDREN ABOUT THE IMPORTANCE OF ONLINE SAFETY AND TO MONITOR THEIR ACTIVITIES TO ENSURE COMPLIANCE WITH OUR POLICIES AND APPLICABLE LAWS.

If you become aware that your child is using our Services or that we have collected information about your child, please contact us at contact@ping-date.com and we will assist you in deleting all of your child's information and taking action to block the relevant account.

IX. Child Protection

We are deeply committed to the safety and protection of children. To this end, we comply with all applicable laws and regulations and have implemented the following measures to ensure a safe environment:

• Prohibited Content and Practices

We strictly prohibit any dating or companionship advertisements that:

- Promote underage dating.

- Feature imagery or text on landing pages that misrepresent the users to whom the service markets itself.

- Promote compensated companionship, dating, or sexual acts.

- Promote exploitative or deceptive dating services.

- Promote mail-order spouses.

• Preventing Harm to Children

We prohibit the use of our platform for any activities that endanger children. This includes, but is not limited to:

- PSexualization of minors (e.g., imagery that promotes or encourages the sexual exploitation of children).

- Sextortion (e.g., blackmailing a child using intimate imagery).

- Child trafficking (e.g., advertising or soliciting a child for commercial sexual exploitation).

By implementing these policies, we are dedicated to fostering a safe environment that protects and prioritizes the well-being of children. If you suspect a child is at risk or has been subjected to any of the situations mentioned above, please reach out to us at contact@ping-date.com

X. Disclaimer

You can use our instant message function, which allows you to communicate with other users of "Ping!". But we recommend and encourage you (and all our users) to consider carefully about the disclosed information of other users. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names, addresses, credit card details, national identity numbers or drivers' license details and other sensitive information in your Profile, which may open to abuse and misuse.

Moreover, please be careful to post sensitive details about yourself on your Profile such as your religious denomination and health details. You may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, but we never desire to deliberately collect them. Please remember that any photographs or video clips that you post on "Ping!" may reveal these kinds of sensitive personal data. When you upload and post this sensitive information about yourself, you are explicitly consenting to our processing of your information. And you will at your own risk to do this. If you post anything which is inconsistent with our Terms and Conditions or this Policy, we reserve the right to disable your account.

XI. Contact

Questions, comments and requests regarding this policy should be addressed to contact@ping-date.com.