Privacy Policy

Effective Date:2023-10-30

Please carefully read this Privacy Policy ( the “Policy”), which explains the categories of personal information that Pallar Media Limited ("BALA AI," "we" "us" or "our") collects when you (the “User” or “You”), as the user of BALA AI throughts mobile application (the “Application” or “Service”), how that information is used, with whom it may be shared, and your privacy choices.

1. Data controller and representative

The Data Controller for the BALA AI Services is Pallar Media Limited, which has a principal place of business at FLAT 404A, 4/F, BEVERLEY COMMERCIAL CENTRE, 87-105 CHATHAM RD SOUTH, TST, HONG KONG. You can contact the Data Controller by emailing info@pallarmedia.com.

2. Data Collection and Processing by BALA AI

When the User uses the Application or Service, BALA AI may collect and use personal data as follows:

a.Information you provide to us.

We may ask that you provide certain information to us when you set up an account or profile on the Application or contact us through the Application for information or support. This information may include your email address, account name, or other personal identifier.

b.Information we automatically collect when you use the application.

This information may include your IP address (or other unique device identifier, including one that we may assign); your activities on our Application, including your preferences; and other logging information, such as the date and time of your visit.

c.Information we get from your use of our products.

We collect information about the products that you use and how you use them and your local device information, including but not limited to your device information (e.g. phone model and brand), operating system (system version, ID, and language), IP address, operating, log information (access time, usage time, click operation, crash reports).

d.Third parties may use tracking technologies in connection with our Service, which may include the collection of information about your online activities over time. This Policy does not apply to these third party technologies because we may not control them and we are not responsible for them.

e.Data About Your Accounts on Other Services

If you login to our Services via third-party accounts (including, but not limited to, Google+ and Apple) , we ask for your permission to access certain information about that other account. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. For example, depending on the platform or service we may collect your name, profile picture, gender, info, and birthday. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.

I may update our Terms and Conditions from time to time. Thus, you are advised to review this page periodically for any changes. I will notify you of any changes by posting the new Terms and Conditions on this page.

3. Purpose and legal basis of the processing

BALA AI uses the information we collect about you for the following purposes:

a. Identification and authentication: We use your data to verify you when you access your account (if available) for the Services.

b. Operating our services: We use your data to provide our Services, provide customer support, and to otherwise comply with our contractual obligations to you.

c. Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).

d. Improving our services: We use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).

e. Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.

f. Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.

g. Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.

We may use algorithms and other automated means to implement any of the above.

4. Sharing of Personal Information with Third Parties

a. Service Providers: We may share your personal information with companies that help us to run our business by processing personal information on behalf of us for the purposes identified above. Such companies include server services providers, data analysis services providers, fraud monitoring and prevention providers, email delivery service providers, social media, and other marketing platforms and service providers. We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share with them in accordance with this Policy. At the same time, we will clarify the privacy policy terms of this vendors with you.

Specifically, BALA AI may use third party tracking tools to track the information on how users use the products, such information will be stored in third party servers. Such third party track tools may send the data analysis report to BALA AI for BALA AI’s above mentioned purpose.

BALA AI may store the collected information on the servers leased from providers of third-party server service.

b. In addition, BALA AI may disclose the User’s data to third parties for the following reasons:

i. if BALA AI is under a duty to disclose or share such personal data to comply with any legal obligation, or to protect the rights, property or safety of its business, its customers or others.

ii. in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) ("Requests") that we receive from government authorities or parties to legal proceedings. We handle user’s location Requests under user’s location law. If the Request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both jurisdictions. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

iii. where we reasonably believe that someone's life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person's data with appropriate entities that may have the ability to help.

iv. in situations involving legal claims against us or one of our users. If you challenge such a notice, we may share your response with the complainant.

v. with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such a case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

5. Transfer of personal data

Your personal information may be stored on servers located in, and may be accessed by BALA AI’s employees and contractors located in one or more countries outside of the country in which you reside. And by using an Application or the Services you consent to the transfer of your Information to countries, which may be outside of your country of residence and may provide for different and less stringent data protection rules than in your country. If you object to your Information being transferred or used as described in this Policy, please do not use any Application and immediately delete all Applications from your User Devices.

6. Protection of Personal Information

BALA AI uses commercially reasonable and industry standard security technologies and safeguards to protect the User’s personal data processed by BALA AI against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy. We also expect our service providers to protect information in the same manner. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, can be guaranteed 100% secure. Please note that we cannot guarantee the security of any information you transmit to us.

7. Duration of the storage

BALA AI will seek to minimize the amount of personal information that it collects and maintains and will delete personal data once it is no longer needed for the purpose for which it was collected. BALA AI will store the collected personal data for the duration of the contract and 180 days after the termination of the contract. Unless we have received your request to delete your information, we will use the following criteria to determine the period for which we will keep your information:

—our contractual obligations and rights in relation to the information involved;

—legal obligations under applicable laws and regulations to retain data for a certain period of time;

—statute of limitations under applicable laws;

—our legitimate business purposes.

8. User’s rights

To the extent required by the law of your jurisdiction, you may have one or more of the below rights. Before you exercise any of the below rights, you may consult your legal counsel if the laws of your jurisdiction stipulate below rights. You can exercise any of the below rights by submitting a support form, by emailing info@pallarmedia.com.

a. The right to be informed

The User has the right to be provided with clear, transparent and easily understandable information about how BALA AI collects and uses personal data and its rights. This is the reason why BALA AI is providing the User with the information in this privacy policy.

b. The right of access

The User has the right to obtain access to its personal data (if BALA AI is processing it), and other certain information (similar to that provided in this privacy policy). You may request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year.

c. The right to rectification

The User is entitled to have its personal data corrected if it’s inaccurate or incomplete.

d. The right to erasure or deletion

This right to be forgotten enables the User to request the deletion or removal of its personal data where there’s no compelling reason for BALA AI to keep using it. This is not a general right to erasure; there are exceptions.

e. The right to restrict processing

Under certain circumstances, the User has the rights to ‘block’ or suppress further use of its personal data.

f. The right to opt out of the sale of your personal information

The user has the right to ‘opt out’ from the sale of their personal information to a third party.

g. The right to data portability

The User has the right to receive their personal data maintained by BALA AI in a structured, commonly used and machine readable format and has the right to transmit that data to another controller.

h. The right to object to processing

The User has the right to object, on grounds relating to its particular situation, at any time, to the processing of its personal data.

i. The right to lodge a complaint

The User has the right to lodge a complaint about the way BALA AI handles or processes its personal data with its national supervisory authority.

j. The right to withdraw consent

If the user has given its consent for a specific processing of its personal data implemented by BALA AI, the User has the right to withdraw its consent at any time. In case the User does so, it does not mean that anything BALA AI has done with the User’s personal data with its consent up to that point is unlawful but BALA AI will not use the user’s personal data for that purpose in the future.

k. The right to define instructions

The User has the right to define general or specific instructions regarding storage, deletion and use of its personal data after death.

9. Deletion of your account

You can delete your account from within BALA AI. Deleting your account is an irreversible process, which we can't revert even if you perform it by accident.

a. To delete your account

i. Open BALA AI.

ii. Tap Mine > Settings > Delete account.

b. Deleting your account will:

i. Delete your account from BALA AI.

ii. Erase your message history. If you delete your account, you can't regain access to your account.

iii. We may retain certain log data in our databases even after you delete your account, but such data will be disassociated from any identifying information such that it can no longer be linked to your account. To do this, on a regular basis, we wipe certain identifying information from this log data, and we replace any instance of your account ID with a replacement identifier which cannot be linked back to your account once it is deleted.

iv. We may also keep your information for things like legal issues, terms violations, or harm prevention efforts.

10. Children's Privacy

We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 13 years of age, or the age of majority in your jurisdiction (whichever is greater), to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian's account and with their involvement. In accordance with the Child Online Privacy Protection Act, in the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you are believes BALA AI may have collected personal information regarding your child, you may ask us to delete such information by using our support form.

11. Revision of this Privacy Policy

Occasionally, we may change this privacy policy (or other documents related to privacy policy) to allow BALA AI to use or share your personal data differently. If we do, the links to the policy on our applications will indicate that the policy has been changed. For new users, the change will become effective upon posting. For existing users, if the change is significant, it will become effective after posting. We encourage you to periodically review the privacy policy for the latest information on our privacy practices.

12. Contacting BALA AI

If the user needs to contact BALA AI for any reason (including to exercise any of its rights concerning data protection as set out above) please contact info@pallarmedia.com. BALA AI will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case BALA AI may charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested), or refuse to act on the request.