Privacy Policy

Last updated: December2020

Welcome to TETE (the “Platform”). The Platform is provided and controlled by Pa Technology Pty Ltd., with its registered address at 89-97 Jones St ,NSW Australia 2007 (“TETE”, “we” or “us”).

We are committed to protecting and respecting your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform.

If you have any questions about how we use your personal data, contact us at:admin@tete.au

SUMMARY

What information do we collect about you?

We collect and process information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform. We also collect information about you if you download the app and interact with the Platform without creating an account.

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it. We use your information to, among other things, show you suggestions in the ‘For You’ feed, improve and develop the Platform and ensure your safety. Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Platform.

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as TETE, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise, or defence of legal claims.

How will we notify you of any changes to this Privacy Policy?

We will generally notify all users of any material changes to this policy through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use, and process it.

1. The types of personal data we use

We collect and use the following information about you:

Your Profile Information. You give us information when you register on the Platform, including your username, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph or profile video.

User Content and Behavioural Information. We process the content you generate on the Platform, including preferences you set (such as choice of language), photographs and videos you upload and comments you make (“User Content”). In order to improve the upload speed of User Content before clicking “Post” to confirm the upload, we will provide a preload service to upload audio and video in advance. If you cancel or fail to upload the content for other reasons, we will delete the associated audio and video from our server. We collect information through surveys, challenges, and competitions in which you participate. We also collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the ads you view, videos you watch and problems encountered, the content you like, the content you save to ‘My Favourites’ and the users you follow. We also infer your preferences, including your interests, gender, and age for the purpose of personalising content. We process information about your followers, the likes you receive and responses to content you upload, for the purposes of promoting your content to other users and exploring whether your profile presents further opportunities for collaboration. Where appropriate, we will also use this information for the purpose of serving personalised advertising and to tell you about new services and opportunities.

Information from Third Parties. You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third-party data automatically. We have set out further detail on the information we receive from third parties below:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google,Apple), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with your social network such as your app ID, access token and the referring URL. For further information on sharing your Facebook contact list with us,

Advertisers and Advertising Networks

We use the information collected from you, and your interaction with the Platform and other third-party sites, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you've visited, apps you've downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our App and from similar information received from third parties who advertise on our Platform and whose sites you visit.

Technical Information we collect about you. We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes your IP address, browsing history (i.e., the content you have viewed on the Platform), mobile carrier, time zone settings, identifier for advertising purposes and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Location. We use the 'Region' you select in Settings to customise your TETE experience except where we provide location-based services, in which case we collect GPS (where we have your consent).

Find other users and invite your friends. You can choose whether to find other users of the Platform using our 'Find Friends' function. This functionality allows you to see which of your friends from either your telephone's contact list or Facebook friends list is using the Platform and offers you the option to follow them. You can also use this function to invite your contacts to join you on the Platform. We will use the contact information you have for that person, either from within your telephone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third-party message (such as Whatsapp, Facebook (including Facebook Messengeror Twitter) inviting them to view your TETE profile.

Buy TBS. If you reside in certain jurisdictions that offer in-app coin purchases, please note the provisions of our Virtual Items Policy. Your purchase will be made via your Apple iTunes or Google Play account. We do not collect any financial or billing information from you in relation to such a transaction. Please review the relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in TBS, we keep a record of the purchases you make, the time at which you make those purchases and the amount spent.

2. Cookies

We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyse which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your different devices. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies.

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

3. How we use your personal data

We will use the information we collect about you in the following ways:

• notify you about changes to our service;

• provide you with user support;

• personalise the content you receive and provide you with tailored content that will be of interest to you;

• enable you to share User Content and interact with other users;

• enable our messenger service to function if you choose to use this function;

• enable you to participate in the virtual items program;

• communicate with you;

• to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform;

• ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;

• ensure content is presented in the most effective manner for you and your device;

• improve, promote and develop the Platform and promote popular topics, hashtags and campaigns on the Platform;

• carry out data analysis and test the Platform to ensure its stability and security;

• allow you to participate in interactive features of the Platform;

• to enable you to socialise on the Platform, for example, by allowing other users to identify you via the "Find other friends" function or through their phone contacts;

• to ensure that you are old enough to use our Platform (as required by law).

• provide you with personalised advertising;

• provide you with location-based services (where those services are available in your jurisdiction);

• enforce our terms, conditions and policies; and

• administer the Platform including troubleshooting.

4. How we share your personal data

We share your data with the following selected third parties:

Business Partners

If you choose to register to use the Platform using your social network account details (e.g., Facebook, Twitter, Instagram, Google,Apple), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as WhatsApp, a link to the content will be shared.

Payment Providers

If you choose to Buy TBS, we will share data with the relevant payment provider to facilitate this transaction. We share a transaction ID to enable us to identify you and credit your account with the correct value in TBS once you have made the payment.

Service Providers

We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Platform is a safe and enjoyable place.

Analytics providers

We use analytics providers to help us in the optimisation and improvement of the Platform. Our third-party analytics providers also help us serve targeted adverts

Advertisers and Advertising Networks

We share information with advertisers and third party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We share your device ID with measurement companies so that we can link your activity on the Platform with your activity on other websites; we then use this information to show you adverts which may be of interest to you.

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

• comply with legal obligation, process or request;

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues; or

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Public Profiles

Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. Alternatively, you can change your profile to default private by changing your settings to 'Private Account' in “Manage my account” settings.

Sale or Merger

We will also disclose your information to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or

• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Where we store your personal data

The personal data we collect from you may be stored on a server located in Australia or the United States, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

6. Your Choices

You can access and edit most of your profile information by signing into TETE. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your videos, send you messages, or post comments to your videos. Should you choose to do so, you may delete your entire account in Settings. If you have any questions on how to use those tools, or want to know about any rights you may have in the country where you live, please contact us at:admin@tete.au.

7. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

9. Information relating to children

TETE is not directed at children under the age of 13. In certain cases, this age may be higher due to local regulatory requirements, please see your local privacy policy for more information. If you believe that we have personal data about or collected from a child under the relevant age, contact us at:admin@tete.au.

10. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at:admin@tete.au and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

11. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

12. Contact

Questions, comments and requests regarding this policy, contact us at:admin@tete.au.

Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:

• you must obtain approval from your parent(s) or legal guardian(s); and

• your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iv) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

Your Choices. You may withdraw your consent to TETE's disclosure of personal data to third parties. Upon your request, we will ease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of TETE features and functionality.

You may request TETE to (i) disclose history of personal data that we have collected; and/or (ii) erase and dispose your personal data that we have collected on our server. Please note that by requesting us to erase and dispose your personal data, you may not be able to use some of TETE features and functionality.

To exercise any of your rights, contact us at:admin@tete.au.

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for Three (3) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform and the Three (3) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Last Updated: This Supplementary Terms of this Policy was last updated on December 21, 2020 and is effective on the same date.

Purposes for the processing your personal data. Our purposes for processing your personal data categories as mentioned under “1. The types of information we collect” are; (i) complying with our legal obligations, (ii) fulfilling our obligations stemming from the Terms and Conditions, (iii) processing for all legitimate purposes including providing you the services set forth in the Terms and Conditions, (iv) complying with the retaining, reporting and notifying obligations set forth in the legislation and determined by the relevant regulatory authorities and other authorities; and all other obligations provided in the laws, (v) retaining your personal data based on the statute of limitations set out in the relevant laws and (vi) processing of your personal data which are already made public.

Your rights. According to Article 11 of the Data Protection Law, you are entitled to request the following with respect to your personal data by submitting a written request:

• to learn whether the personal data relating to you are being processed,

• if it is processed, to request information with regard to processing,

• to learn purposes of the processing and whether they are used for such purpose or not;

• to know the third persons within or outside the country to whom the personal data are transferred,

• to request correction of the personal data if the data is processed incompletely or inaccurately,

• to request deletion or destruction of the personal data under the conditions set forth in Article 7 of the Data Protection Law,

• to request notifying third persons to whom the personal data are transferred, about the processes completed within the scope of the foregoing two items,

• to object to negative consequences about you that are concluded as a result of analysis of the processed personal data exclusively by automatic means,

• to claim indemnification if the you suffered damage due to illegal processing of your personal data.

You may exercise your rights listed above by contacting us at:admin@tete.au.

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge.

Language. This policy is written in the English language.