TECNO MOBILE LIMITED (hereinafter referred to as "ToneProud Webapp", "we," "us," or "our") is the provider and operator of ToneProud Webapp application software and services (hereinafter referred to as "the Software"). We fully respect your privacy and make every effort to protect your personal information. In the process of providing the products or services (collectively referred to as "the Services"), we may collect and use your personal information with your consent or as required by applicable laws. This Privacy Policy (hereinafter referred to as "the Policy") is intended to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using ToneProud Webapp products or services, your rights with respect to that personal information, and how we safeguard those rights. The Policy applies to all products and services provided by ToneProud Webapp Platform. It shall be specially noted that the Policy is not applicable to the services offered to you by third parties.

Please read the Policy carefully before using our products or services, submitting personal information to us, or granting us consent to collect your personal information.

If you have any questions, please feel free to contact us via privacy@tecno.com

The Privacy Policy will help you understand the following:

1. How We Collect and Use Your Personal Information
2. How We Use Cookies and Other Similar Technologies
3. How We Store and Protect Your Personal Information
4. How We Share, Transfer and Disclose Your Personal Information
5. How Is Your Personal Information Transferred Across Borders
6. Your Rights to Your Personal Information
7. How We Process Children's Personal Information
8. Third-Party Service Providers and Their Services
9. Supplements and Updates to the Policy
10. Joint Controller
11. How to Contact Us

I. How We Collect and Use Your Personal Information

(I) Overview

ToneProud Webapp believes that fundamental privacy rights must apply equally regardless of where you live in the word. We treat any information that relates to an identified or identifiable individual as “personal information”.

We only collect the information necessary for special, specific, explicit, and legitimate purposes. We will request your consent again if we intend to use your personal information for any purposes not specified herein.

You have the right to decide whether to provide your personal information when using ToneProud Webapp products or services or when we request it. We will only collect and use your personal information for the purposes stated herein. The following are examples explaining why we collect your personal information:

(II) ToneProud Webapp's Main Service Functions and Information Collection and Usage Scenarios

We will provide a skin tone coding tool with your authorization. You hereby authorize that by tapping on the button to take photos or using this feature, you agree that we will conduct skin tone analysis and generate an image containing the corresponding skin tone code based on the photo you take or upload. Refusing to provide such information may prevent us from being able to generate the correct skin tone code. We sincerely invite you to capture a photo with your skin tone code in the ToneProud Webapp link. You may download it, share it on social media, or upload it to the website https://268toneproud.com/site. If you opt to upload to the website, we will record the photo you submit and any description you provide (optional). Upon review, this information will be publicly displayed on the ToneProud Web for other users to view and browse.

To deliver these features and services, we will request access to your camera permissions, as well as file and media permissions, to facilitate capturing, uploading, and storing images.

II. How We Use Cookies and Other Similar Technologies

1. What cookies and other similar technologies are

To ensure the smooth operation of the Software, provide you with a more convenient browsing experience, and suggest content or ads of interest to you as our product functions continue to evolve and update, we may store small data files named cookies on your mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. Our websites, online services, interactive applications, emails, and other information services may use cookies and other similar technologies, such as pixel tags and web beacons. As the information collected through cookies and similar technologies does not typically include any of your personally identifiable information, we usually regard it as non-personal information. However, if the laws of a certain country consider Internet Protocol (IP) addresses or similar identifiers as personal information, we will comply with those national legal regulations.

2. Why we use cookies and other similar technologies

We and our partners use cookies or similar technologies to ensure the security of this service.

Type of Cookies	Purpose	Valid Period
Functional cookies	By verifying the XSRF-TOKEN, the server may ensure that the request comes from a legitimate user's browser and is not forged by a malicious website.	120min

We will not use cookies for any purposes other than those stated herein. You can manage or delete cookies according to your preferences. You can manage cookies through your browser settings by deleting them and restoring (clearing) settings (content and data), among other methods.

III. How We Store and Protect Your Personal Information

1. How we store your personal information

We will store your personal information that we collected upon your consent in accordance with the relevant national laws and regulations concerning personal privacy and data protection. We may also store the personal information we collect in countries or regions other than the country in which we do business, provided that local laws and regulations do not prohibit such storage.

Currently, ToneProud Webapp may store your personal information in Singapore. Specifically:

We may use the servers in other areas or countries depending on our business development, and in such cases, we will update the Policy accordingly.

Whether personal information is stored in the country where we do business or in another country or region without violating the law, we will store it in accordance with the relevant laws and regulations regarding data storage. We will take necessary security measures considering the characteristics, scope, purposes of personal information processing, the possible risks in processing personal information, and the serious consequences in case of any damages. We will store the information only necessary for our business development within the minimum retention period unless otherwise permitted by laws or you agree to extend the retention period. We will delete or take other appropriate measures to delete data that exceeds the retention period or that you request us to delete, provided that this does not violate the relevant laws and regulations.

2. How we protect your personal information

We will also take other necessary measures to protect your personal information from misuse, unauthorized access, modification, disclosure, or destruction.

We implement security measures designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical and physical safeguards to protect your personal information by considering the nature, processing methods, and security of the personal information. We will continuously strive to improve these measures to keep your personal data secure.

It should be noted that no measures can absolutely guarantee the avoidance of data storage security incidents. In the event of a security breach, we will report to the appropriate regulator in accordance with the requirements of relevant laws and regulations, and provide the type of personal data involved in the data breach, the number of data subjects, the possible consequences of the data breach, and the remedial measures we intend to take in accordance with the requirements of the supervisory authorities. We will take all possible measures to remedy or mitigate the damages and consequences caused by a data breach. If permitted or required by laws, we will promptly inform you of the consequences or significant damage that may be caused to you as a result of a data breach, so that you can take appropriate measures to protect your rights to the greatest extent.

Since no website, Internet transmission, computer system, or wireless connection is absolutely secure, in addition to the necessary security measures we take, users need to be more aware of privacy and security risks. If you find that certain content, advertisements, or features of our website, products, or services may be provided by third parties and may endanger your privacy and security, please contact us promptly and we will give priority to dealing with them in accordance with the law.

IV. How We Share, Transfer and Disclose Your Personal Information

We will share, transfer, and disclose your personal information to the minimum extent and only when it is necessary for operations or required by laws. We will not share, transfer, or disclose your personal information unless otherwise required or permitted by applicable laws and regulations in the following circumstances:

1. How we share your personal information

We do not sell any personal information to third parties. To offer you timely service, we may share your personal information with ToneProud Webapp's affiliates. We will only share your information with ToneProud Webapp's affiliates for lawful purposes clearly stated and only as necessary to provide the Services subject to the purposes stated in this Privacy Policy. For any purposes not covered herein, we will make explicit statements in the privacy policy or notice for the specific product or service.

We may share necessary personal information with authorized third-party partners to perform certain functions or provide you with better service and user experience. Our technical service providers will assist us in processing and storing the images you provide. We will share that information to the minimum extent and only when it is necessary for operations or required by law. Before sharing, we will sign stringent confidentiality agreements with our authorized partners, requiring them to take relevant confidentiality and security measures to process personal information in accordance with the Policy and the applicable laws of your jurisdiction. Moreover, we will require them to provide data security functions and information security qualifications.

2. How we transfer your personal information

ToneProud Webapp will not transfer your information to any other party without:

(1) your express consent is obtained

(2) posting a prominent notice via email and/or our website or by means of another appropriate method to inform you of any changes in your ownership of, rights to, and choices regarding your personal information when ToneProud Webapp is involved in a merger, acquisition, or sale of all or part of its assets that may affect your personal information.

(3) the transfer has been stated in the Privacy Policy or otherwise notified to you.

3. How we disclose your personal information

ToneProud Webapp may disclose your personal information as required by law, legal procedures, litigation, and/or government departments and authorities. We may also disclose your personal information if the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

In addition, we may share your personal information with the following people:

(1) our lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.

(2) investors and other related third parties, if actual or potential sales or other transactions with another company occur and are related to entities within the TECNO group.

(3) other third parties, for example, when specific information is disclosed to them under your authorization.

V. How Is Your Personal Information Transferred Across Borders

For the purposes described in the Privacy Policy, we may transfer your personal information to the resources or servers mentioned in Section III of the Policy for storage or processing, and we may also transfer your personal information to third-party service providers and business partners, and therefore your data may be transferred to other countries or regions, subject to compliance with applicable laws and regulations in your region and with your authorized consent. The privacy laws in these countries or regions may differ, and the jurisdictions in which these servers are located may or may not protect personal information to the same extent as those in your jurisdiction. However, we will still strive to protect your personal information based on our Privacy Policy and carry out the cross-border transfer and other processing of corresponding information as required by the laws of the country or region where the personal information is located.

If we transfer personal information outside of your jurisdiction, whether to our affiliates or to a third-party service provider, we will comply with the relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers are subject to the requirements of applicable local data protection laws.

VI. Your Rights to Your Personal Information

As a data subject, you have a number of rights with respect to personal information such as confirmation, access, correction, deletion, withdrawal of consent, complaints (hereinafter referred to as "requests"), etc. We fully understand and respect these rights, which are also subject to specific exclusions and exceptions in accordance with applicable law. We will also take active steps to ensure that your rights are effectively guaranteed. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we charge no fees for your legitimate requests. However, for repeated requests exceeding reasonable limits, we will charge a reasonable fee to the extent permitted by applicable laws based on actual administrative costs as appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes in current practices), pose a risk to the legal rights of others or are highly impractical, or violate mandatory legal requirements.

1. Right to confirm and access: We inform you of how we collect and process your personal information via this Privacy Policy or through privacy policies or notices for specific product service scenarios. You have the right to confirm or reject such collection and processing by checking the box or via other methods. However, if you reject the service, some functions that require your express authorized consent before use may no longer be available. The personal information you have provided to us can be accessed directly from the interface of our products or services. In case of failure to access, you can email us at privacy@tecno.com, and we will deal with it promptly.

2. Right to correct and delete: When your personal information changes, or when you find that the information we collected and processed is inaccurate or incomplete, you have the right to request that we make corrections or additions. You have the right to request us to delete your personal information when we have achieved the purpose of collecting your personal information or it is no longer necessary, or when you find that we have collected or processed your personal information in violation of the provisions of laws and regulations or the terms of the Privacy Policy. For any information that you have no access to correct or delete, you can email us at privacy@tecno.com to request for correction or deletion.

If otherwise stipulated by law, we may not approve your request for such deletion. Please also note that if you request the deletion of your information from our products and services, due to certain applicable local laws and technical limitations, we may not immediately delete the corresponding information from our backup systems, but we will securely store your personal information and prevent its further processing until the backup systems are updated and your information can be deleted or anonymized.

3. Right to withdraw consent: you may withdraw consent previously granted to us for specific purposes, including the collection, use, and/or disclosure of your personal information in our possession or control, by withdrawing the consent request. You can email us at privacy@tecno.com for relevant operations. We will process your request within a reasonable time after you send it, and then will not collect, use, and/or disclose your personal information according to your request.

Withdrawing your consent may result in an inability to continue to access certain and/or all ToneProud Webapp product and service functions. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.

4. Right to complain: You have the right to email us at privacy@tecno.com for a complaint. We will respond promptly to your complaint. If you are not satisfied with our response, especially if our personal information processing practices have harmed your legitimate rights and interests, you may also file a complaint or report to the local statutory personal data protection authority, or file a lawsuit with a court of competent jurisdiction.

5. Right to control your privacy settings: You have the right to control your privacy settings, which allow you to restrict our collection, use, disclosure, or processing of your personal information. You may enable or disable the function and permission of Camera as well as File and Media, or change your decision by contacting us at privacy@tecno.com.

6. Right in some jurisdictions: Please pay attention that you may have the following data subject rights under applicable laws in certain jurisdictions:

(1) Right to restriction of processing. You have the right to request our restriction on your personal information processing. We will review the reasons for your request. If the reasons are in accordance with applicable data protection laws, we will process your personal information only to the extent permitted by such laws and will notify you before lifting the restriction on processing.

(2) Right to data portability. You have the right to request the transfer of your personal information to another data controller in a structured and commonly used format.

While we also have the right to refuse to process your request, we may reject some of your requests where an exemption applies or where we comply with applicable laws. For example, some requests are manifestly unfounded or excessive or require disclosure of third-party information.

VII. How We Process Children's Personal Information

ToneProud Webapp does not provide its products and services for children under the age of 14 or the equivalent legal age under the laws in your jurisdiction (the age of a child varies from country to country, and we will define a child based on the laws and regulations of the country or region in which we do business). We do not actively collect personal data from children and do not use it for marketing purposes. If you find that you have transferred information about such children to us, email us at privacy@tecno.com, and we will remove the information as soon as possible. If we find that we have collected children's personal information, we will also remove the relevant content as soon as possible.

VIII. Supplements and Updates to the Policy

We reserve the right to update or modify the Policy from time to time as our business, technology, applicable laws, and operations change. For any changes to the Policy, we will notify you by posting the updated policy here (on this page), by posting it on our website at https://www.tecno-mobile.com, or by sending it to you as a separate notice. Please regularly check this page or the notifications we send you to stay informed of updates to the Privacy Policy. The Privacy Policy is subject to change, but we will not diminish your rights under the Policy without your express consent.

We will seek your express consent as required by applicable laws before we collect other information from you or use or disclose your information for a new purpose. If you continue to use products and services on the website, mobile device, and/or any other devices, you will be bound by the updated Privacy Policy.

The content of ToneProud Webapp products or services stated in the Agreement may change depending on the type of product and system version you are using, or the requirements of local laws and regulations.

IX. Joint Controller

SHENZHEN TECNO TECHNOLOGY CO.,LTD will be responsible for processing your personal information together with us as joint controllers. TECNO MOBILE LIMITED and SHENZHEN TECNO TECHNOLOGY CO.,LTD have clarified their respective responsibilities for joint processing under applicable laws, including the GDPR. To contact us for more information about joint control, please see Section X How to Contact Us.

X. How to Contact Us

If you have any suggestions, questions, or concerns about our Privacy Policy or practices regarding the protection of personal information, contact us at:

Email: privacy@tecno.com (Note: The email is used for receiving emails related to our Privacy Policy or our information protection only)

We will review your request regarding privacy or personal information as soon as possible and reply to you within 15–30 days after verifying your user identity. If your request involves complex or significant issues, we may ask you for further information.

If you are not satisfied with our response, especially if your legitimate interests have been violated by us, you can seek a solution from the relevant data protection supervisory authority in your jurisdiction. If you make the above inquiry to us, we will provide you with information on the relevant complaint channels that may apply to your case.

Thank you for your time to read our Privacy Policy!