CrushKey Privacy Policy

Last updated: September 13th, 2024
Effective date: September 13th, 2024

This Privacy Policy (" Policy ") applies to CrushKey Application (hereinafter, the " APP "), and other functions and services (" Services "). SPARKHUB PTE. LTD. ( "SPARKHUB","we", "us" ,"our") is the service provider and operator of the APP and its Services. We value and respect your privacy, and we are committed to protecting it in compliance with this Privacy Policy and applicable laws and regulations. This Policy aims to provide you (" you ", " User ") with an understanding of our practices concerning the collection, use, share and storage of personal information we collect from or about you when you interact with us, as well as your rights regarding the information you provide and how we safeguard those rights. By accessing and using the Services, you agree to be bound by this Policy. If you do not agree with this Policy, in whole or in part, you should not use the Services. It is important to note that this Policy does not apply to any products, services, websites, or content offered by third parties ("Third-Party Services"). Third-Party Services are governed by their respective privacy policies, and we encourage you to review the privacy statements of any Third-Party Service you may choose to use. We strongly advise you to read this Policy carefully to understand our practices regarding your personal information. We also recommend visiting this Policy frequently to stay informed of any updates. If you have any questions, please feel free to contact us at AIDreamerStudio@outlook.com.

This Policy will help you understand the following contents:
1. What Information We Collect About You
2. How We Use Your Information
3. How We Share Your Information
4. Children’s Privacy
5. Your Rights and Choices
6. Third-Party Service Providers and Services
7. Data Security and Retention
8. International Data Processing & Transfer
9. Update of this Policy
10. How to Contact Us
11. Supplemental Terms - Jurisdiction Specific Terms

1. What Information We Collect About You
We collect information about you through various means when providing the Services. Please note that certain types of information are necessary for us to provide the Services to you. If you choose not to provide us with such information or request its deletion, you may no longer be able to access or use the Services. We collect your information in the following ways:
Information You Provide Directly to Us
- User-generated content. If you create or upload content, such as audio, texts, or pictures (referred to as " User Content "), we collect this content and associated metadata, including details of when, where, and by whom the content was created.
- Transaction information. When you make purchases related to the APP, we collect the order number and information about the services you have purchased. This helps us understand user feedback and analyze consumption patterns.
- Correspondence information. If you contact us for support, we also collect correspondence information to provide a user feedback service to you.
Information We Obtain Automatically
We automatically collect certain information from you when you access and use our Services, including your Internet Protocol address ("IP Address") and device identifiers. Here is an overview of the information we collect:
- Device Information. When you start using our Services, we collect information about the mobile device you are using, such as your IP Address, identifiers for advertising purposes, device model, operating system, system language and region, mobile carrier, network type, and app version.
- Log and Usage Data. This includes service-related, diagnostic, and performance information automatically collected when you use our Services, such as your IP address, device details, browser type, activity within the Services (e.g., pages viewed, searches, and feature usage), and device event data like error reports and system activity.
- Push Notifications. We may ask for permission to send you push notifications related to specific features of the application(s). If you prefer not to receive these notifications, you can disable them in your device's settings.
Screen Information. When you use the services of the APP, in order to obtain and recognize your screen results, we will access your screen information after obtaining your explicit consent. Screen information is essential for the APP to function properly, and refusal to provide this information will directly affect your ability to use the APP's core features. Your screen information will only be used temporarily while the APP is operating. The APP will solely conduct text recognition on the screen information, and will not recognize any information unrelated to the functionality of this APP. Screen information will be destroyed in real-time after use. We will never retain or store any of your screen information locally or in the cloud without your permission.
Information We Obtain from Other Sources
We may receive information about you from other sources in accordance with their privacy policies.
- Advertisers and Partners. Our advertisers, measurement partners, and other trusted partners may share information with us about your activities outside of the APP, such as your actions on other websites, apps, or in physical stores. This may include information about products or services you purchased.

Third Part Policy check list：
Advertisement platform
Admob https://www.google.co.uk/about/company/consenthelpstaging.html
We will not share any information that we have collected from you.
If any questions will remain unanswered, please contact us at AIDreamerStudio@outlook.com.
- Other Third Parties. In accordance with applicable law, we may obtain your personal information from individuals, business entities, public sources, or other third parties acting on your behalf or in partnership with us. We will explain this to you at the time of collection and obtain your consent.
We may also use other methods to collect additional information about you, your device, or your use of the services. We will explain these methods to you at the time of collection and obtain your consent if required by applicable laws.
Please note that we are not responsible for the privacy practices of our service providers and business partners, and their information practices are not covered by this Policy. We may aggregate or de-identify the information described above, and such aggregated or de-identified data is not subject to this Policy.

2. How We Use Your Information
We use the information we collect from you to ensure the operation, maintenance, enhancement, and development of all features, functionality, and services offered on our Services. Here is an overview of how we use your information:
- Security and Fraud Prevention. We use your information to provide security for our websites, products, software, and applications. This includes preventing fraud and abuse.
- Service Provision and Support. We use your information to fulfill your requests for services, support, and information. This includes internal operations such as troubleshooting, testing, research, statistical analysis, data analysis, and soliciting your feedback.
- Improving and Developing Services. We use your information to improve and develop our Services, ensuring that we continue to enhance the Services based on user feedback and needs.
- Administrative Communications. We may process your information to send you updates regarding our products and services, changes to our terms and policies, and other important administrative details.
- Communication and Feedback. We use your information to communicate with you and respond to your feedback. This enables us to address your inquiries, provide support, and keep you informed about updates and developments.
- Enforcement of Policies. We utilize your information to enforce our Terms of Service and other policies to maintain a safe and positive environment for all users.
- Sales and User Support. We use your information to facilitate sales, promotions, and purchases of goods and services on our Services. Additionally, we provide user support to assist you with any issues or inquiries related to your interactions.
In certain cases, we may seek your consent to process your personal information for specific purposes. If you provide consent, you can withdraw it at any time, and we will cease processing your data for that purpose. You may have other rights depending on the jurisdiction in which you live. Please see Supplemental Terms - Jurisdiction Specific Terms for more information.

3. How We Share Your Personal Information
We do not sell your personal information to third parties. However, we may share your information in the following ways:
Delegation to Affiliates
We may delegate the processing of your personal information to our affiliates to fulfill the purposes described in this Policy. Such delegation will be within the scope of the purposes described, and we ensure that our affiliates comply with the provisions of this Policy regarding the retention of personal information.
Service Providers and Business Partners
We may share certain information with service providers and business partners to assist us in performing business operations and for business purposes. These parties may include website hosting providers, database maintenance providers, data storage and security service providers, payment processors, transaction fulfillment providers, advertising and marketing vendors, and others. We require these parties to process the information in compliance with this Policy, limit its use to the purposes for which it is provided, and implement reasonable confidentiality measures.
Corporate Transactions
In the event of a substantial corporate transaction such as the sale of a website, merger, consolidation, asset sales, or bankruptcy, we may share all the information we collect. Legal Compliance and Protection
We may disclose your information when required by law, subpoena, or other legal process, or when we have a good faith belief that disclosure is reasonably necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, assist government enforcement agencies, enforce our agreements with you, investigate and defend against third-party claims or allegations, protect the security or integrity of our services, or exercise or protect the rights and safety of the APP, our users, personnel, or others. We strive to notify users about legal demands for their personal information unless prohibited by law or court order, or in case of emergencies. We may choose to challenge such demands when we believe they are overbroad, vague, lack proper authority, but we do not guarantee to challenge every demand.
It's important to review and understand the privacy practices of our Third-Party Service Providers and business partners, as their information practices are not covered by this Policy.

4. Children's Privacy
Our Services are not intended for children under the age of 13, and you may not use our services if you are under the age of 13. In certain cases, this age may be higher due to local regulatory requirements. If you are under 16 and located in the European Economic Area (“EEA”) , United Kingdom (“UK”), or Switzerland, you need to ensure that your parent or guardian agrees to this policy.
If we become aware that a child has provided us with personal information in violation of applicable laws, we will delete the information we have collected and terminate the child's account unless we have a legal obligation to retain it.

5. Your Rights and Choices
We are committed to providing you with rights regarding your personal information, in accordance with applicable laws. We also hope that you will take control of your information by providing you with a number of tools. The details of how you can control your information include:
- You have the right to access the information we have collected about you. As part of your right to know, you are entitled to receive specific details about the personal information we have collected, including the categories of sources from which the information was obtained, the business or commercial purpose for collecting or sharing the information, and the categories of third parties with whom we share the information. You also have the right to request a copy of the information we have collected about you.
- You have the right to correct and update your information. If you wish to access and edit your information, please contact us directly.
- You have the right to delete the information we have collected about you. If you want to delete your account, you could reach out to us using the contact details provided in the "How To Contact Us" section.
- You have the right to withdraw your consent at any time where the Services rely on your consent to process your personal information. If you withdraw your consent, you may not be able to continue to receive some and/or all of the Services. Withdrawal of your consent or authorization will not affect the validity of our prior processing activities based on your consent.
You may have other rights depending on the jurisdiction in which you live. Please see Supplemental Terms - Jurisdiction Specific Terms for more information.
If you cannot or do not want to exercise your rights directly in the App, you may exercise your rights by contacting us at AIDreamerStudio@outlook.com in person or through an authorized agent or representative to act on your behalf, if permitted by applicable law. We will respond to your requests in accordance with applicable law and after verifying your identity. We may request additional information from you to confirm your identity and to ensure that we are providing access to the correct person's information. If you designate an authorized representative, you must provide evidence that the representative has the necessary authority, such as the power of attorney or valid written authorization.
While we generally do not charge a fee for processing lawful and reasonable requests, we may charge a reasonable fee for repeated requests that exceed a reasonable limit, as permitted by applicable law and based on actual administrative costs.
We may refuse to process certain requests or respond to only some of your requests if exceptions apply or if we are otherwise entitled to do so under applicable law. For example, we may not comply with requests that are manifestly unfounded, manifestly excessive, or that require the disclosure of third-party information.
If you disagree with a decision we have made regarding your request, you also have the right to lodge a complaint with a competent data protection authority. It is important to note that we will not discriminate against you based on your exercise of your privacy rights.

6. Third-Party Service Providers and Services
During your use of our Services, you may encounter links to third-party websites or content and services provided by third parties. Some third-party products or services may be accessed through SDKs or other means to provide certain functions and features in our APP. It is up to you to decide whether to visit or accept the offerings of third-party websites, products, and services. Please note that this Policy does not apply to products and services provided by third parties. As we have limited control over third parties, we are not responsible for their collection and processing of your personal information.

7. Data Security and Retention
We employ various managerial, technical, and physical measures to safeguard the integrity and security of your information. The specific measures used may depend on the sensitivity of the information. However, it's important to understand that no security measures or systems can provide absolute guarantee of protection. We evaluate these measures on a regular basis to ensure the security of the processing.
We retain data related to your use of our Services for as long as necessary to fulfill the purposes outlined in this Policy or as required by applicable laws. This may include retaining information for tax and accounting purposes, compliance with contractual and legal obligations, legitimate business interests (such as improving and developing our Services, enhancing safety, security, and stability), and the exercise or defense of legal claims. When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize it. If deletion or anonymization is not possible, we will securely store your information and isolate it from further processing until deletion becomes feasible.

8. International Data Processing & Transfer We operate globally with affiliates, contractors, and service providers situated in various countries. Due to this global presence, we may need to transfer your personal data to jurisdictions other than your country of residence for communication, access, storage, and other purposes. If we share information about you with our affiliates, subsidiaries, partners, or service providers, we take appropriate measures to ensure that such entities adequately protect your information in accordance with this Policy and applicable laws. You may have other rights depending on the jurisdiction in which you live. Please see Supplemental Terms - Jurisdiction Specific Terms for more information.

9. Update of this Policy
We reserve the right to periodically update or modify this Policy to reflect changes in our business, technology, and relevant laws and practices. Whenever we make updates to the Policy, we will notify you by updating the "Last Updated" date at the top of the revised Policy, or providing any other notice as required by applicable law. We strongly recommend that you review the Policy frequently to stay informed about our current privacy practices.

10. How to Contact Us If you have any comments, questions, concerns or requests regarding this Policy or our practices related to the protection of personal information, please feel free to contact our Data Protection Officer (DPO) at AIDreamerStudio@outlook.com . Our DPO is responsible for overseeing and implementing our personal information protection
strategy, as well as ensuring compliance with applicable laws and regulations. We will make every effort to review your requests promptly, verify your user identity, and respond within the timeframe required by any applicable law. If your request involves complex or significant issues, we may require additional information.

11. Supplemental Terms - Jurisdiction Specific Terms
In some jurisdictions where you access or use our Services, applicable laws may require us to supplement this Policy with jurisdiction-specific terms. These supplemental terms are an integral part of this Policy. In the event of any conflict between the provisions of the Supplemental Terms and the rest of this Policy, the Supplemental Terms will prevail.

EEA, UK and Switzerland
If you reside in the European Economic Area (“EEA”) , United Kingdom (“UK”), or Switzerland, this section applies to you.
How We Use Your Information
The legal basis for processing your personal data for the above purposes may include the necessity to perform a contract, compliance with legal obligations, your consent, or our legitimate interests in providing and improving our services.
We are required to have a legal basis for processing your personal data, as specified by applicable laws. The legal basis for processing your personal data may be one of the following:
(a) Consent. We may process your personal data based on your consent, which you have provided in relation to this Policy.
(b) Contractual Obligations. We may process your personal data to fulfill our contractual obligations to you, such as providing the services you have requested.
(c) Legal Obligations. We may process your personal data to comply with our legal obligations, such as obtaining proof of your identity to meet fraud prevention and anti-money laundering requirements.
(d) Legitimate Interests. Where permitted under applicable laws, we may process your personal data based on our legitimate interests. This includes purposes such as understanding how you use our services, developing new services, ensuring the stability and security of our Services, preventing crime, fraud, and misuse of our services, providing non-personalized advertising, and improving the user experience.
(e) Separate Consent. In certain cases, we may seek your separate consent to collect and use specific types of personal data, as required by law. If we request your consent, you have the right to withdraw it at any time by contacting us using the details provided in the section “How To Contact Us”.
(f) Other Permissible Grounds. We may also process your personal data if permitted under applicable laws. The provision of your personal data may be necessary for entering into a contract with us or to receive the requested services. In other cases, it may be voluntary. However, please note that if you choose not to provide your personal data, we may not be able to: (a) provide the services you request, or (b) inform you about the services we offer.

Your Rights and Choices
As a user, you have certain rights and choices regarding the personal data that we hold about you, subject to local laws. These rights may include:
(a) Access. You have the right to confirm whether we process your personal data and, if so, request a copy of your personal data as well as information about how it is processed.
(b) Rectification. If your personal data held by us is inaccurate or incomplete, you have the right to request its correction or completion.
(c) Deletion. In certain circumstances, you can request the deletion of part or all of your personal data from our records.
(d) Restriction. In certain circumstances, you can request that we stop processing your personal data.
(e) Objection. If we process your personal data based on our legitimate interests, you have the right to object to such processing. However, we may continue to process your personal data if we have compelling legitimate grounds for the establishment, exercise, or defense of legal claims.
(f) Direct marketing. You have the right to ask us to stop processing your personal data for direct marketing purposes.
(g) Portability. In certain circumstances, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit that data to another data controller.
(h) Withdrawal of consent. If we rely on your consent to process your data, you have the right to withdraw your consent at any time.
(i) Automated decision-making. In certain circumstances, you have the right to request that decisions that significantly affect you and are based solely on automated processing of your personal data are not made.
(j) Complaint. You have the right to lodge a complaint with your local data protection authority. If you are in the United Kingdom, the Information Commissioner's Office (https://ico.org.uk/) is the relevant authority. If you are located in the European Economic Area (EEA), you can find the contact details for data protection authorities in your jurisdiction at (https://edpb.europa.eu/about-edpb/about-edpb/members_en). We also encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. Please note that we may require additional information from you to process your requests.
If you would like to discuss or exercise any of your rights under applicable law, please contact us using the contact details in the section “How To Contact Us”.

International Data Processing & Transfer
This will involve transferring your data to a country outside the European Economic Area (“EEA”), such as Singapore. Many of our external third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, that is:
(a) Adequacy Decisions. We transfer your information to countries that have received adequacy decisions from the European Commission under Article 45 of the General Data Protection Regulation (GDPR) or equivalent decisions under other laws. For example, we may transfer your information to countries such as Japan and the Netherlands that have been recognized as providing an adequate level of data protection.
(b) Standard Contractual Clauses. We rely on the standard contractual clauses approved by the European Commission under Article 46 of the GDPR. These clauses allow companies in the European Economic Area (EEA) to transfer data outside the EEA while ensuring an adequate level of data protection. We use these contractual clauses when transferring information to our affiliates and third parties in countries without an adequate decision.
We require our entities outside the EEA or the UK to process information in compliance with applicable privacy laws and implement appropriate security measures to protect your information.
If you would like more information about the safeguards in place or to obtain a copy of such safeguards, please contact us using the contact information provided below.

United State
(1)Colifornia
If you are a California resident, you may have the right, once per calendar year, to request information about the personal information we have shared with third parties for their own direct marketing purposes. This includes categories of user information shared and contact information of relevant third parties. If you would like to exercise this right, please email your request to us using the provided contact information.
Content Removal for Users Under 18. California residents who are under 18 years old and users of our APP may request the removal of User Content they have posted. To request removal, please contact us using the provided contact information and provide a description of the User Content you want to be removed, along with information reasonably sufficient to help us locate the content. Please note that while we will endeavor to remove the requested content, complete or comprehensive removal may not be possible if the content has been republished or reposted by another user or third party.
You also have the right not to be treated in a discriminatory manner for exercising your privacy rights under the California Consumer Privacy Act (CCPA).
(2)Virginia
If you are a Virginia resident, the following additional terms apply.
You have the right to confirm whether or not we are processing your information and to access such information, to correct inaccuracies in your information, to delete your information provided by or obtained about you, to obtain a copy of your information, and to opt out of the processing of your information for purposes of (i) targeted advertising, (ii) the sale of your information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. You can exercise your rights by contacting us at AIDreamerStudio@outlook.com . We will comply with your request and respond to you without undue delay, and in all cases within 45 days of receipt of the request. If we decline to take action regarding your request, we will inform you as soon as possible, of the justification for declining to take action and instructions for how to appeal the decision pursuant to the law.
At your request, we will provide your information provided by us free of charge, up to twice annually. If your requests are manifestly unfounded, excessive, or repetitive, we may charge you a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.
We will not process sensitive information(such information including data in accordance with the federal Children's Online Privacy Protection Act (15 U.S.C. § 6501 et seq.)) concerning you without obtaining your consent. You also have the right not to be treated in a discriminatory manner for exercising your rights under the Virginia Consumer Data Protection Act (VCDPA).
(3)Colorado
If you are a Colorado resident, the following additional terms apply.
You have the right to confirm whether or not we are processing your information and to be informed, to access, to rectification, to erasure, to object/opt out of the processing of your information for purposes of (i) targeted advertising, (ii) the sale of your information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. And you also have the right to obtain a copy of your information processed by us and have the processing of your information for purposes of profiling in furtherance of solely automated decisions, we will provide you such right no more than two times per calendar year. You can exercise your rights by contacting us at AIDreamerStudio@outlook.com . When you exercise certain rights (like rights to be informed, to access, to rectification, to erasure), we may need to verify information that validates your identity. We are unable to authenticate the request to exercise such rights or rights until such you provide additional information reasonably necessary to authenticate. In all cases within a reasonable period of receipt of the request.
(4) Utah
If you are a Utah resident, the following additional terms apply.
You have the right to confirm whether or not we are processing your information and to be informed, to access, to rectification, to deletion, to object/opt out of the processing of your information, to obtain a copy of your information in a format. You can exercise your rights by contacting us at AIDreamerStudio@outlook.com . If you are under 18 years of age, you confirm that you have obtained the consent of your parent or legal guardian to register an account and use the Services.
(5)Connecticut
If you are a Connecticut resident, the following additional terms apply. You have the right to confirm whether or not we are processing your information and to be informed, to access, to rectification, to erasure, to object/opt out of the processing of your information for purposes of (i) targeted advertising, (ii) the sale of your information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. And you also have the right to obtain a copy of your information processed by us and have the processing of your information for purposes of profiling in furtherance of solely automated decisions. You can exercise your rights by contacting us at AIDreamerStudio@outlook.com . When you exercise certain rights (like rights to be informed, to access, to rectification, to erasure), we may need to verify information that validates your identity. We are unable to authenticate the request to exercise such right or rights until such you provide additional information reasonably necessary to authenticate. In all cases within 45 days of receipt of the request. If we decline to take action regarding your request, such as we believe such request is fraudulent, we will inform you as soon as possible, of the justification for declining to take action and instructions for how to appeal the decision pursuant to the law.
At your request, we will provide your information provided by us free of charge every 12 months. If your requests are manifestly unfounded, excessive, or repetitive, we may charge you a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

Canada
If you're using our Services in Canada, the following additional terms apply.
Information Relating to Children and Teens:
Our services are not intended for anyone under 13 years old. We do not knowingly collect personal information from individuals under this age. Furthermore, residents of the Province of Quebec must be at least 14 years old to use the Services.
Your Rights:
You can exercise your rights of access and rectification as described in the Your Rights and Choices section of this Policy or by contacting us at AIDreamerStudio@outlook.com . Depending on your province, you may have additional rights, including data portability, the right to control the disclosure of your personal information, and the right to be informed of and to provide input into automated decision making. We ensure data retention compliance by promptly disposing of personal information when no longer necessary, following outlined retention limits and our secure disposal procedures.
International Data Transfers:
We may collect, transfer, store, and process your personal information in other jurisdictions outside Canada. We ensure compliance with local laws to protect your personal information when sharing it outside your jurisdiction. Complaints:
You may submit inquiries or complaints to our privacy support team or Privacy Officer by e-mail to AIDreamerStudio@outlook.com . You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your local privacy commissioner.

Australia
Overseas Data Handling and Transfers:
We make every effort to ensure that third-party recipients of your personal information located outside Australia adhere to Australian privacy laws, including the Privacy Act 1988 (Cth). However, we must emphasize that we cannot control or accept liability for the actions of these overseas recipients, despite our best efforts to ensure their compliance with privacy laws similar to those in your jurisdiction.
Your Rights:
You have the right to access the personal information we hold about you, including how it is used and who it is shared with. You can access the personal information associated with your account by logging in. If you believe we hold additional personal information about you, please contact us at AIDreamerStudio@outlook.com .
You have the right to correct any inaccuracies in your personal information held by us. You can access and amend your personal details by logging into your account. If you identify inaccuracies in other personal data held by us, please contact us at AIDreamerStudio@outlook.com . Children:
If you are under 18 years of age, you confirm that you have obtained the consent of your parent or legal guardian to register an account and use the Services. Anonymous Transactions:
Where possible, we provide you with the option to remain anonymous or use a pseudonym when registering an account or using the Services. However, please note that if you choose not to provide us with your personal information, certain features or sections of the Services, including social media integration and in-app purchases, may be unavailable to you.