Privacy Policy

Effective date: October 14, 2024

JoYio respects and values users' personal privacy. We promise to handle your personal information in a reliable and secure manner and comply with relevant laws, regulations and industry standards. By using JoYio's products and services, you acknowledge and agree to the terms of this Privacy Policy. If you have any questions, comments or suggestions about this policy, please contact us through the contact information we provide.

1. Privacy commitment

At JoYio, we promise to handle your personal data with transparency, clarity, and responsibility. We will take all reasonable measures to ensure the security of your data, while providing you with convenient control so that you can manage, view, and delete your information.

We will always adhere to the following principles:

• Transparency : We clearly state what information we collect and how it is used.

• Minimization of data : We collect only the minimum information necessary to provide you with the services.

• User control : You have the right to decide how your personal data is used and shared.

2. How we collect and use your information

By using our services, you understand and agree to the following:

2.1 Scope of products and services

The types and scope of personal information we collect may vary depending on the specific product or service you choose. Different users may experience a personalized data collection process tailored to their needs. For detailed data collection, you can refer to the specific product or service you use.

2.2 Continuous improvement

We continuously optimize our products and services, which may introduce new features or improve existing ones, requiring additional personal information or changing the way data is used. We will notify you by updating our Privacy Policy, pop-ups, or in-app prompts, and obtain your consent. Your information can only be collected and used after obtaining your affirmative consent. If you have any questions or feedback during this process, please feel free to contact us through the channels provided.

Special Note: User Registration

In order to access the JoYio service, you must complete the account registration process. You need to keep your account info safe and not share it with others.

Permission request

In order to provide a richer user experience and ensure the integrity of the service, JoYio may request the following permissions:

• Photo Gallery Access : Allows you to upload pictures from your device's photo gallery when sharing pictures in chat or updating profile pictures.

• Camera access : for taking photos, video calls, only enabled when you initiate a photo shoot or video call.

• Audio Access : For video calls, use this permission only if you choose to initiate a call or record audio.

• Bluetooth access : Used to improve sound quality, may request Bluetooth access to connect audio devices.

• External Storage Access : Allows reading and writing to the device's external storage for managing photos and videos, enabled only when you save or download content.

• Advertising ID : We may collect the advertising ID of your device to analyze marketing effectiveness and optimize our promotions.

All permissions are only used with your affirmative consent, and you can manage or change these permissions at any time in your device settings. We are committed to protecting your privacy, and all personal information will remain confidential and will never be used for unauthorized purposes.

Device information collection

JoYio will automatically collect your device information to ensure the best performance of the application. This includes device ID, brand, model, operating system and its version, and current status. We also collect identifiers related to the device and your Internet Service Provider or mobile operator information (such as IP Address or proxy server). During the use of the application, we may collect data on network type, platform, and your interaction with various functions.

Data Analysis and Improvement

In order to improve service quality and User Experience, we collect device logs and usage data for analysis. Whenever you interact with our services, the server automatically records activities, including device configuration, IP Address, access time, browsing pages, and features used. We also collect diagnostic data, such as system events (such as crash reports), hardware settings, and error logs.

In order to further analyze and optimize marketing effectiveness, we may use your device ID and advertising ID. This data helps us evaluate marketing strategies, improve service performance, and provide you with more personalized services and promotional content.

You can adjust the opening of permissions on your phone at any time, but it may cause some functions to be unavailable.

3. Protection of your personal information

At JoYio, we attach great importance to the security of your personal information and always follow industry standards and regulatory requirements to ensure that your data is fully protected. We take multi-level security measures to prevent unauthorized access, leakage or abuse, ensuring that your information is effectively protected on our platform.

1. Data minimization: We only collect personal data that is directly related to and necessary to provide the service, avoiding the collection and storage of any redundant data, thereby reducing the risk of data leakage.

2. Access Control: We strictly restrict access to personal information and only allow authorized personnel to process sensitive data under the principle of least privilege. To further protect your information security, we use anonymization technology (where applicable) and verified security systems to prevent malicious attacks. In addition, we regularly conduct personal information security training for employees to ensure that they are up-to-date with the latest security policies and practices.

If you suspect that your personal information has been compromised (for example, your account may have been accessed by unauthorized personnel), please contact JoYio Customer Support immediately and we will provide you with quick assistance. Please note that any content you share publicly through our platform may be seen by other users, so please consider carefully when sharing information.

In the event of a security incident involving your personal data, we will report it to the relevant regulatory authorities as required by law.

4. Sharing, transmission and disclosure of your personal information

We will not disclose your personal information to external companies, organizations or individuals (excluding suppliers who provide services to JoYio), except in the following special circumstances:

1. With your active authorization : We will only share your personal data with third parties with your affirmative consent. You always retain control over information sharing and may adjust or withdraw your authorization at any time.

2. Legal or Regulatory Requirements : We may need to share your personal information as required by law, regulation, judicial or government entities. In these cases, we will only provide the minimum information necessary to comply with legal requirements.

3. Working with trusted partners : In some cases, to fulfill our service commitments or assist us in completing related tasks, we will share your personal information with reviewed and trusted partners. These partners can only obtain the minimum information needed to complete the task, and strictly limit the purpose of their data use and cannot be used for other purposes.

In addition, in order to ensure the normal operation of the service and improve the User Experience, we may cooperate with third-party service providers. These partners include but are not limited to technology infrastructure service providers, Data Analysis companies, payment platforms, and Client Server support. We have signed strict data protection agreements with all partners to ensure that they process data in accordance with our Privacy Policy and relevant Non Disclosure Agreements.

In terms of marketing and performance analysis, we collaborate with Appsflyer and Facebook third-party platforms to help optimize our marketing activities. These partners will handle data related to application usage and user behavior according to strict security standards and protocols to ensure information security.

If you do not agree with the terms of this Privacy Policy or have concerns about the sharing of specific data, you can choose to stop using our services. JoYio is committed to creating a secure and transparent community environment. In some cases, data sharing is crucial to providing high-quality services and ensuring the smooth operation of the platform.

5.Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this privacy policy, or as required by applicable law. The retention period may vary depending on the type of data and the specific regulatory or legal obligations we must comply with. Once the retention period has expired, or if the data is no longer needed for legal or business purposes, we will securely delete or anonymize the personal data.

If you request deletion of your personal data, we will follow the process outlined in the Right to Deletion section and ensure your information is removed unless retention is required for compliance with legal obligations or the exercise or defense of legal claims.

6. Managing your personal information

You have full control over your personal information and we offer several ways to help you view, update and control it. Please refer to the following options to manage your data:

Access to your personal information

You can view and manage your personal data in the following ways:

• Account info : Log in to your account and visit the "My - Settings" page where you can view or modify your profile and other account-related information.

• Contact us : If you are unable to access certain personal data through the App, you can contact JoYio's customer support team directly. We promise to respond and assist you in resolving the issue within 15 days of receiving your request.

• Additional data access : If you generate other forms of personal data in the course of using our services, we will provide reasonable access rights in accordance with the agreement and applicable laws.

• Data copy request : If you need a copy of your personal data for backup or other purposes, you can request it at any time through customer support.

Delete your personal information

You have the right to request the deletion of your personal data in the following specific circumstances:

1. We have collected or processed your data without a legal basis or in violation of the law.

2. You have not authorized us to use your personal data, and we are still processing this information.

3. Our use of your data does not comply with the agreement between the parties.

4. You decide to stop using our services and wish to clear your account and all related data.

5. We stop providing the service and no longer need to retain your personal information.

Once your deletion request is confirmed, we will simultaneously notify the partners who have shared data with us to delete your relevant data, unless otherwise required by law or they have obtained your separate authorization. Please note that due to technical reasons, some data may not be completely deleted from the backup system immediately, but this data will be securely encrypted until it can be completely removed or anonymized.

Your content management

Even if you delete certain content, it may still be retained by third parties through other means (such as screenshots or user saves). Therefore, even if you apply to delete data, we cannot guarantee that all digital content related to you can be completely removed from all devices and services immediately. Digital files may temporarily exist through recovery technology or caching in some cases.

Data management tools

We offer you a variety of data management tools to ensure you have the flexibility to control and manipulate your personal data:

• Modify and update : You can manage and update your personal information independently through the settings page of the application. If your data request conflicts with the privacy of others or violates relevant laws and regulations, we may refuse some of your requests.

• Deletion and opt-out : You can choose to permanently delete your account data, but please note that account deletion may result in your inability to recover all information related to your account. JoYio will follow legal and compliant requirements when processing such requests, ensuring that your data is stopped without any legitimate reason.

7. Legal basis for data processing and your rights

7.1 Legal basis for data processing

When processing your personal information, we always comply with relevant legal requirements and ensure that processing is based on appropriate legal bases. We process your personal data based on the following legal bases according to different usage scenarios:

• Affirmative consent : In some cases, we will only process your personal data after obtaining your affirmative consent. You will have the opportunity to understand the detailed purposes of data processing and can freely choose whether to give consent. You can withdraw this consent at any time, and the withdrawal of consent will not affect the lawful processing based on consent.

• Performance of contract : where data processing is for the performance of a contract between us and you or for the provision of a service to you, this contract forms the basis for our lawful processing of data.

• Legitimate interests : In some cases, we process your data based on our or a third party's legitimate interests in order to ensure the safe operation of the platform, improve functionality or enhance User Experience. In such processing, we balance these legitimate interests with your personal privacy rights to ensure that your basic rights are not violated.

• Legal obligations : We may process or share your personal data where required by law, such as to comply with regulations, respond to requests from government authorities, or fulfill legal obligations.

• Public interest or significant interest : In certain rare cases, we may also process your data for the purpose of public interest or protection of significant personal interests, especially where required by public safety or law.

7.2 Your data protection rights

As our user, you have several statutory rights that can be exercised under applicable privacy laws. We are committed to respecting and protecting your data privacy rights and providing you with the following rights:

• Right of access to data : You have the right to request access to the personal data we hold about you and to understand how we use it. You can request access to your data and obtain a copy of your personal data by contacting our support team.

• Right to data correction : If you find that the personal information we hold is inaccurate or incomplete, you have the right to request that we immediately correct or update this information to ensure the accuracy and completeness of the data.

• Right to data deletion : In some cases, you can ask us to delete your personal data, especially when the data no longer serves the purpose for which it was collected or is no longer needed. We will respond to and execute your data deletion request where permitted by law.

• Right to restrict processing : If you have concerns about our processing of your personal data, such as questioning the accuracy or legality of the data, you can request that we temporarily restrict the processing of your data until the relevant issues are resolved.

• Right to data transfer : You have the right to request that your personal data be provided to you in a structured, commonly used and machine-readable format, or to request that we transfer this data to a third party designated by you. This right is designed to help you easily migrate data between different service platforms.

• Right to object to processing : In some cases, you have the right to object to the processing of your data by us based on legitimate interests or public interest. If your objection is justified, we will stop processing your data without a legal basis or legitimate reason.

• Right to withdraw consent : If we rely on your consent as a legal basis for processing your data, you have the right to withdraw this consent at any time. Please note that withdrawal of consent will not affect lawful processing based on consent prior to withdrawal.

• Right to complain : If you believe that we have not complied with relevant privacy laws in processing your personal data, you have the right to file a complaint with a data protection authority for an appropriate legal solution.

For your convenience in exercising these rights, you can manage your data preferences at any time through the privacy settings in the application or by contacting our support team. We will process and respond to all your requests within the statutory time and ensure that your personal data rights are fully protected.

7.3 International privacy law compliance

We are always committed to protecting users' privacy and complying with privacy regulations in multiple regions around the world. This includes but is not limited to the following important privacy laws:

• Canada : Processing personal information of Canadian users in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

• Brazil : Ensure the protection of the privacy of users in Brazil in accordance with the General Data Protection Law of Brazil (LGPD).

• California, US : Protect the privacy rights of California residents and provide related rights under the California Consumer Privacy Act (CCPA).

• European Union and European Economic Area (EEA) : Provide comprehensive data protection and privacy protection for European Union and EEA users in accordance with the General Data Protection Regulation (GDPR).

• Other countries or regions : Adjust our privacy practices to ensure compliance with the laws of your country or region.

We will process users' personal data according to the regulatory requirements of different regions to ensure that each user can exercise the privacy rights granted by their region.

8.California Residents' Privacy Rights (CCPA)

According to the California Consumer Privacy Act (CCPA), California residents have a series of privacy rights, and JoYio promises to ensure that these rights are respected and protected. The following are the privacy rights that California residents can enjoy:

8.1 Right to be informed
California residents have the right to know what personal information we have collected, used, shared or sold in the past 12 months. Users can request the following information twice every 12 months:

• Types and specific contents of personal information we collect.

• We collect this information from sources (e.g., directly from users, devices, or third-party services).

• We collect information for commercial or operational purposes (such as improving services, personalized ads, preventing fraud, etc.).

• Categories of personal information disclosed for commercial purposes.

• If so, categories for selling personal information to third parties.

• Third parties who share or sell data with us (such as AD Network, analytics companies, etc.).

8.2 Right to Deletion

California residents may request that we delete the personal information collected. After submitting such a request, we will delete your data after verifying your identity and require the service providers we work with to also delete the relevant information, unless otherwise required by law.

8.3 The right to know about data sales

Users have the right to inquire whether their personal information has been sold to third parties. If there is a sale, we will provide users with relevant information and provide users with the opportunity to opt out.

8.4 Right to opt out of the sale of personal information

According to CCPA, California residents can choose not to sell their personal information to third parties. Users can opt out of this behavior by visiting the "privacy settings" page in our application. Once we receive an opt-out request, we will immediately stop selling your data to third parties. Although we may still share information with certain service providers to maintain the operation of the platform, these service providers will not use the data for sales purposes.

8.5 Right to complain

If you believe your privacy has been violated, you can file a complaint with the California Consumer Protection Regulatory Agency. Although we encourage users to contact us before making a complaint so that we can directly resolve the issue, this does not limit your right to file a formal complaint.

8.6 The right to non-discrimination

California residents will not be discriminated against when exercising their privacy rights. We will not refuse to provide services, charge higher fees, or reduce service quality because users choose to exercise these rights. However, if users request the deletion of certain necessary information, the availability of certain features may be affected.

8.7 How to exercise rights

In order to exercise your CCPA rights, you can manage your preferences at any time through the "privacy settings" page provided by us, or directly contact our privacy team by email. We will respond to your requests promptly and ensure that your rights are fully respected.

LGPD compliance notice (for Brazil)
According to the requirements of Brazil's General Data Protection Law (LGPD), JoYio is committed to protecting the personal data of Brazilian users and ensuring that your privacy rights are fully protected. The following are the main rights that Brazilian users can exercise:

• Right of access : Users can request us to provide details of their personal data and an explanation of how we process it.

• Right to correction : If the user finds that their personal data is inaccurate or incomplete, they can request us to correct or supplement it.

• Right to erasure : Within the framework of applicable law, users may request that we delete their personal data, especially when the data is no longer relevant to the purpose for which it was collected.

• Right to be informed : Users have the right to know with which third parties we share their data, and why and to what extent.

• Right to withdraw consent : Users can withdraw their consent to certain data processing activities at any time. Withdrawing consent will not affect previously lawful data processing based on consent.

• Right to object : Users can object to the processing of personal data based on legitimate interests and request that such processing be stopped, unless we can prove that there are legitimate reasons to continue the processing.

• Data transfer rights : Users have the right to request that we transfer their personal data to designated third parties in order to continue using other services.

• Right to complain : Users may file a complaint with the Brazil National Data Protection Authority (ANPD) if they believe their privacy has been violated.

JoYio promises to respect users' privacy rights and ensure that we strictly comply with LGPD's regulations. You can make relevant requests through our support team at any time, and we will respond promptly in accordance with legal requirements.

VCDPA Compliance Notice (for Virginia Residents)
In accordance with the Virginia Consumer Data Protection Act (VCDPA), JoYio is dedicated to protecting the privacy of Virginia residents and ensuring their rights are fully respected. The following outlines the privacy rights that Virginia residents can exercise under the VCDPA:

Virginia Residents’ Privacy Rights (VCDPA)
Virginia residents have the following rights concerning their personal data:

• Right to Access:
Users have the right to request access to the personal data we have collected and how it is processed. This includes understanding the types of personal data collected, the purposes for processing, and any third parties with whom we share the data.

• Right to Correction:
Users can request corrections to any inaccurate or incomplete personal data we have about them.

• Right to Deletion:
Users may request the deletion of personal data that we have collected. Once a request is made and verified, we will delete the data unless retention is required for compliance with legal obligations or other lawful reasons.

• Right to Data Portability:
Users have the right to obtain a copy of the personal data that they have provided to us in a portable and easily usable format, allowing the data to be transmitted to another entity without hindrance.

• Right to Opt Out of Processing for Targeted Advertising, Sale of Personal Data, or Profiling:
Users can opt out of the processing of their personal data for targeted advertising, sale to third parties, or profiling in furtherance of decisions that produce legal or similarly significant effects. Opt-out requests can be made through the "privacy settings" page within our app, and we will cease such processing immediately upon receipt of the request.

• Right to Appeal:
If a request is denied, users have the right to appeal the decision. JoYio will respond to any appeals within the timeframe specified by the VCDPA. If users remain unsatisfied, they can file a complaint with the Virginia Attorney General’s office.

• Right to Non-Discrimination:
JoYio ensures that users will not be discriminated against for exercising their VCDPA rights. We will not deny services, increase fees, or degrade service quality for users choosing to exercise their privacy rights.

How to Exercise Your Rights
Virginia residents can exercise their rights by visiting the "privacy settings" page in the app or contacting our privacy team via email. We will respond to all verified requests in a timely manner and ensure that your rights are respected in accordance with VCDPA.

9. Juvenile personal information protection

Children's Privacy Statement : Our services are not designed for individuals under the age of 18. We do not knowingly collect personal data from children. To enforce this policy, we collect age-related information and may use third-party services to verify a user's age. If we become aware that we have inadvertently collected personal information from a user under the age of 18, we will take immediate action to delete such data. If you believe that information from a minor under your supervision has been collected, please contact us immediately.

10. Changes to this Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes that affect your rights will be clearly communicated and we will not reduce your rights without your affirmative consent. For significant updates, you will be notified within the app or via visible pop-up notifications. We encourage you to review the policy regularly to stay informed of any changes.

Key updates may include:

1. Our service provision or data processing purposes have undergone significant changes.

2. Company restructuring or ownership change.

3. Modification of the way we share personal data with third parties.

4. Changes to personal data rights.

5. We manage the adjustment of personal information security.

6. Key findings from security threats and risk assessments.

By continuing to use our services after receiving notice of changes, you accept the revised Privacy Policy. If you do not agree, you can limit the use of the platform to guest mode without sharing personal data. Previous versions of our Privacy Policy will be archived and can be reviewed upon request.

11.Controller Information

The controller of this service is Adeniji Adewunmi. We are responsible for the collection, use, storage and disclosure of the personal information you provide when you use our service. Please contact us at vmnlapps@gmail.com.

12.Data Protection Officer (DPO)

If you have any questions, requests, or complaints about processing your personal data or want more information about your privacy rights, please contact our Data Protection Officer (DPO): Adeniji Adewunmi, at vmnlapps@gmail.com.

13.How to Contact Us

You can contact us in the following ways, and we will respond to your request within 15 days:

If you have any questions, comments, or suggestions about the content of this policy, you can contact our official customer service in the JoYio application or send an email to our service mailbox at vmnlapps@gmail.com.