Woho Privacy Policy

Introduction

Thank you for choosing to use our products and services. We (hereinafter referred to as "we" or "Woho") attach great importance to the personal information and privacy security of our users (hereinafter referred to as "you"). We will take strict measures to protect your personal information in accordance with relevant laws and regulations.

Please read and understand this policy carefully before use, especially the terms marked in bold/bold underline. If you do not agree to any part of this policy, please stop using Woho immediately. Once you use any of our services, it indicates that you agree to our processing of your relevant information in accordance with this policy.

This Privacy Policy applies to Woho products and related services. If our affiliated companies' products or services use Woho account login but do not have a separate privacy policy, this policy also applies to those products or services.

1. Helping You Become Our User

1.1 Registration and Login

When registering, logging in, and using Woho, you need to provide your real-name mobile phone number to create a Woho account. Collecting mobile phone numbers is necessary to comply with national real-name registration requirements.

You can choose to complete your online identity information (such as avatar, nickname, hobbies, etc.) to help us provide you with better services and experience. Not providing this information will not affect Woho's basic business functions.

1.2 Real-Name Authentication

According to relevant regulations, when you apply for withdrawals or use other functions or services that require real-name authentication on the platform, you need to provide your real identity information (such as WhatsApp number, real name, etc.) to complete real-name authentication.

To comply with regulatory requirements, you must ensure that the real-name information you provide is accurate and valid. Meanwhile, to protect minors, the platform does not allow minors to conduct transactions.

1.3 Public Account Information

When registering for Woho, we will generate a Woho UID (User Account) for you, which serves as your public account identifier. Once generated, it is fixed and valid and cannot be changed.

Your following count and following list, follower count and follower list, personal activity information, and exclusive privileges will be publicly displayed on your account's personal homepage.

2. How We Use Cookies and Similar Technologies

2.1 To provide you with a more convenient access experience, when you use Woho products or services, we may collect and store data related to your access to Woho services through various technologies.

2.2 Please note that some services can only be implemented through the use of cookies. If your browser or additional services allow, you can modify your acceptance of cookies or refuse Woho's cookies.

2.3 Web pages may contain electronic images called "single-pixel GIF files" or "web beacons" to help the website calculate browsing users or access to certain cookies.

3. How We Share, Transfer, and Publicly Disclose Your Personal Information

3.1 Sharing

We will not share your personal information with any company, organization, or individual outside of Woho, except in the following circumstances:

• With your explicit consent or authorization
• As required by laws and regulations, for the resolution of litigation disputes, or as requested by administrative, judicial, or other competent authorities
• To the extent required or permitted by law, when it is necessary to provide your personal information to third parties in response to public health emergencies
• For reasonable purposes such as news reporting and public opinion supervision for the public interest
• Sharing with Affiliated Companies

4. How We Store and Protect Your Personal Information

4.1 Storage Guidelines

Currently, we do not transfer or store your personal information across borders or provide it to overseas entities.

4.2 Storage Period

Unless otherwise stipulated by law or relevant regulations, we will retain your personal information for the shortest period necessary to provide you with services.

4.3 Personal Information Protection Measures

4.3.1 Data Transmission: We employ cryptographic technologies such as Transport Layer Security (TLS) protocols and use methods such as HTTPS.

4.3.2 Data Storage: Your information is stored securely, including local storage.

4.3.3 Information Security: We adopt multi-faceted security protection measures.

5. Your Privacy Rights

You are entitled to the following rights regarding your personal data processed by Woho, in line with global data protection standards:

5.1 Access & Data Portability

You can request a complete copy of your personal data we hold. This covers information you provided (e.g., profile details, phone number), your activity records on Woho, and device-related data (e.g., Device ID). To submit a request, send an email to Wohovoice@outlook.com with the subject line "Woho Data Access Request" and include your registered username. We will deliver the data in a structured, machine-readable format (e.g., CSV) within 30 calendar days.

5.2 Correction of Inaccurate Data

If you find any of your personal data to be incorrect (e.g., outdated contact information, wrong profile details), you have the right to request corrections. Most profile data can be updated directly through your Woho account settings. For other data types, email us at Wohovoice@outlook.com with the subject line "Woho Data Correction Request" and clearly state the inaccurate information and correct details. We will review and finalize corrections within 20 calendar days.

5.3 Right to Erasure ("Right to be Forgotten")

You may request the deletion of your personal data, except in cases where retention is required by law (e.g., complying with court orders or regulatory requirements). To exercise this right, email Wohovoice@outlook.com with the subject line "Woho Data Deletion Request" and your username. We will acknowledge receipt within 5 calendar days and complete the deletion (or explain legal exceptions) within 30 calendar days.

5.4 Transparency on Data Sale/Sharing

You have the right to know if your personal data is sold or shared with third parties. Woho strictly does not sell any user personal data. For detailed information on limited data sharing scenarios, refer to the "Third-Party Data Sharing" section below. To obtain a detailed report on data sharing activities, send an email to Wohovoice@outlook.com with the subject line "Woho Data Sale/Sharing Inquiry" and your username.

5.5 Opt-Out of Data Sharing for Marketing

Since Woho does not sell user data, this right applies specifically to data sharing for advertising or marketing purposes. You can opt out of such sharing at any time by following the instructions in the "Opt-Out of Marketing-Related Data Sharing" section below.

5.6 Restriction of Data Processing

You can request to limit the processing of your personal data in specific situations (e.g., when the accuracy of the data is in dispute). To make this request, email Wohovoice@outlook.com with the subject line "Woho Data Processing Restriction Request", your username, and a detailed description of the processing activities you wish to restrict.

5.7 Objection to Specific Data Processing

You have the right to object to certain types of data processing, such as processing for direct marketing or non-essential service improvements. Submit your objection via email to Wohovoice@outlook.com with the subject line "Woho Data Processing Objection", including your username and the specific processing activities you oppose.

5.8 Withdrawal of Consent

You can withdraw any consent you previously gave for data processing (e.g., consent to receive marketing communications) at any time. To unsubscribe from marketing emails, use the "Unsubscribe" link in the email. For other consent withdrawals, email Wohovoice@outlook.com with the subject line "Woho Consent Withdrawal Request" and your username.

5.9 Right to Lodge a Complaint

If you believe Woho's data processing practices violate applicable data protection laws, you have the right to file a complaint with your local data protection authority or relevant regulatory body.

5.10 Third-Party Data Sharing

Woho only shares user personal data with third parties in the following limited scenarios, with strict safeguards to protect data security:

• Service Providers: We may share necessary data with trusted third-party service providers who assist in operating Woho (e.g., cloud storage providers, customer support tools, security service providers). These partners are contractually obligated to only use the data for specified purposes and maintain strict confidentiality.
• Legal Compliance: We may disclose data if required by law, court order, or regulatory investigation, or to protect the legal rights, safety, and interests of Woho, its users, or the public.
• Business Transitions: In the event of a merger, acquisition, or sale of all or part of Woho's assets, user data may be transferred as part of the business transaction, with the acquiring party bound by this policy.

5.11 Opt-Out of Marketing-Related Data Sharing

To opt out of Woho sharing your data with third parties for marketing purposes, you can choose one of the following methods:

• In-App Settings: Navigate to "Privacy Settings" > "Marketing Preferences" in your Woho account, and toggle off the "Allow Data Sharing for Marketing" option.
• Email Request: Send an email to Wohovoice@outlook.com with the subject line "Woho Opt-Out of Marketing Data Sharing" and include your username. We will process your request within 10 calendar days and confirm via email.

Your opt-out will not affect data sharing necessary for Woho's core services or legal compliance.

5.12 Woho Data Retention Guidelines

Woho retains user personal data only for the minimum period required to fulfill the purposes for which it was collected, with clear timelines based on data type:

• Profile Data (including phone number): Retained for the duration of your Woho account's active status. Upon account deletion, all profile data will be permanently deleted within 30 calendar days, unless longer retention is mandated by law.
• Device ID & Device Information: Retained for 18 months after your last use of Woho services. This retention supports technical troubleshooting and security protection. After 18 months, Device ID will be anonymized and no longer linked to any personal identifiers.
• Chat & Communication Content: Regular chat content is retained for 90 days after the last message in a conversation, then automatically archived. Archived chats are permanently deleted 1 year after archiving, unless you have enabled the "Save Chat History" feature in your Woho settings (in which case chats are retained until account deletion).
• Activity Data (e.g., feature usage, interaction records): Retained for 2 years to optimize Woho's service functionality, enhance user experience, and personalize features. After 2 years, the data is aggregated and anonymized to remove all personal identifiers.
• Customer Support Inquiries: Retained for 12 months to ensure consistent and effective support services. After this period, all inquiry records are permanently deleted.

5.13 California Consumer Privacy Act (CCPA) – Exclusive Rights for California Residents

As a California resident, you hold distinct privacy rights under the CCPA, independent of Woho's general privacy framework:

• Transparency in Data Practices: You may request a comprehensive disclosure of all personal data Woho collects (categories and specific pieces), the sources of such data, the business purposes for collection/use, and the categories of third parties with whom data is shared. Woho explicitly prohibits the sale of user personal data.
• Right to Erasure: You can demand the deletion of your personal data held by Woho, excluding data exempted by law (e.g., data necessary to maintain service functionality, comply with legal obligations, or protect against security risks).
• Opt-Out of Cross-Context Behavioral Advertising: You have the right to opt out of Woho sharing your data with third parties for cross-context behavioral advertising. This opt-out is permanent unless you later choose to reauthorize such sharing.
• Protection Against Discrimination: Woho shall not penalize you for exercising CCPA rights. This means no denial of services, increased fees, reduced service quality, or other discriminatory actions based on your request to exercise these rights.

How to Exercise CCPA Rights: Submit your request via email to Wohovoice@outlook.com with the subject line "CCPA – [Your Woho Username] – [Right Being Exercised]" (e.g., "CCPA – User123 – Right to Erasure"). Include:

• Your full name and registered Woho username
• Proof of California residency (e.g., current billing address, utility bill with California address, or state-issued ID)
• Clear description of the right you're exercising and any relevant details (e.g., specific data you want disclosed or deleted)

5.14 Virginia Consumer Data Protection Act (VCDPA) – Tailored Rights for Virginia Residents

Virginia's VCDPA grants you robust control over your personal data, with rights designed to align with state-specific privacy standards:

• Comprehensive Data Access: You may obtain a detailed report outlining all personal data Woho processes about you, including the purposes of processing, categories of data, and the identities of third parties receiving the data.
• Precision in Data Correction: You have the right to demand correction of any inaccurate, incomplete, or outdated personal data. Woho will verify and update the data or provide a written explanation if correction is not feasible.
• Controlled Data Deletion: You can request the permanent erasure of your personal data, except where retention is required by law, necessary for Woho's legitimate business purposes, or to fulfill a contract with you.
• Opt-Out of Targeted Advertising & Profiling: You may opt out of Woho using your data for targeted advertising, automated profiling that produces legal or similarly significant effects, or sharing data with third parties for these purposes.
• Seamless Data Portability: You are entitled to receive your personal data in a universally usable, structured, machine-readable format (e.g., JSON, CSV) that allows easy transfer to another data controller.

How to Exercise VCDPA Rights: Send your request to Wohovoice@outlook.com with the subject line "VCDPA Request – [Your Woho Username]". Attach:

• Your Woho username and contact information
• Valid proof of Virginia residency (e.g., residential lease, voter registration card, or official document showing Virginia address)
• Specific details about the data or right in question (e.g., "Request correction of my phone number" or "Opt out of targeted advertising")

5.15 General Data Protection Regulation (GDPR) – Fundamental Rights for EU Residents

If you reside in the European Union (EU), the GDPR provides you with extensive, legally enforceable rights regarding your personal data:

• Right to Access & Transparency: You can obtain confirmation that your data is being processed, along with a copy of the data and full details of the processing (e.g., legal basis, retention periods, third-party recipients in/outside the EU).
• Right to Rectification: Woho must promptly correct any inaccurate personal data and complete incomplete data (e.g., by requesting additional information from you if needed).
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your data if processing is no longer necessary, you withdraw consent, or processing violates the GDPR (subject to legal exceptions).
• Right to Restriction of Processing: You can limit how Woho processes your data (e.g., if you dispute the data's accuracy, or if processing is unlawful but you don't want deletion).
• Right to Data Portability: You can receive your data in a structured, commonly used, machine-readable format, or request direct transfer to another controller where technically feasible.
• Right to Object: You may object to processing based on Woho's legitimate interests, public interest, or statistical purposes – Woho must cease processing unless it can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: You can withdraw any consent for data processing at any time, with no formalities. Withdrawal does not affect the lawfulness of processing before withdrawal.
• Right to Lodge a Complaint: You have the right to file a complaint with your local EU data protection authority (DPA) if you believe Woho violates the GDPR.

How to Exercise GDPR Rights: Submit your request via email to Wohovoice@outlook.com with the subject line "GDPR – [Your Woho Username] – Request for [Specific Right]". Include:

• Your Woho username and a valid form of identification (to verify your identity)
• Clear description of the right you're exercising and any relevant context (e.g., dates of relevant interactions, specific data concerns)

5.16 Data Controller & Request Resolution Protocol

• Data Controller: Woho Team
• Primary Contact for All Regional Rights Requests: Wohovoice@outlook.com

Request Handling Timeline:

• Acknowledgment: Woho will confirm receipt of your request within 5 business days, providing a unique request reference number.
• Verification: We may request additional information to verify your identity (to protect against unauthorized access to your data) – this will not unduly delay request processing.
• Resolution: Most requests will be resolved within 30 days of verification. If a request is complex or involves large volumes of data, we may extend this timeframe by up to 30 days, notifying you in writing with the reason for the extension.
• Notification of Outcome: You will receive a detailed written response explaining the actions taken, including any exceptions applied (with legal basis) if your request is denied in part or full.

5.17 Data Protection Officer (DPO) Information

• Name of Data Protection Officer (DPO): William
• Contact Information for DPO: Wohovoice@outlook.com

• You may contact the DPO for any inquiries, concerns, or requests related to the processing of your personal data, as well as compliance with relevant data protection laws such as the GDPR and VCDPA.

6. Protection of Minors

6.1 Our products, website, and services are primarily aimed at adults. Woho will rely on the personal information provided by users to determine whether a user is a minor.

6.2 We especially recommend that you and your guardian carefully read this policy and use our products or services only with your guardian's consent.

6.3 If you are the guardian of a minor, and you have any questions regarding the protection of the personal information of the minor under your guardianship, please contact us.

6.4 Special Note on Minors

Woho is not intended for users under the age of 18. If we discover that we have collected personal data from a minor without verifiable parental consent, we will promptly delete such data. If you believe a minor's data has been collected in error, please contact us at Wohovoice@outlook.com with the subject line "Woho Minor Data Removal Request".

7. How to Manage Your Personal Information

7.1 Inquiry and Access

You can inquire about or access your relevant personal information in our products and/or services, including:

• Account Information: You can log in to your personal account through the relevant product page
• Usage Information: You can view usage information through the relevant product page
• Other Information: If you encounter operational problems during access, contact us

7.2 Cancel Your Account

You can apply to cancel your account through the Woho APP. The operation path is: [My] - [Settings] - [Security Settings] - [Cancel Account].

8. Notification and Revision of Privacy Policy

8.1 To ensure you receive better service and to address platform business adjustments and future developments, this policy will be updated accordingly.

8.2 For significant changes, Woho will also provide more prominent notification methods. Significant changes referred to in this policy include, but are not limited to:

• Significant changes to our service model
• Significant changes to our ownership structure and organizational structure
• Changes to the main recipients of shared, transferred, or publicly disclosed personal information
• Significant changes to your rights regarding personal information processing and how to exercise them

9. Contact Us

9.1 If you have any questions, comments, or suggestions regarding this policy, you can contact us through the following methods, and we will respond to you within 15 days.

• In-site Customer Service: Consultation through 【My】-【Help & Feedback】
• Official Customer Service Email: Wohovoice@outlook.com