Privacy Policy

Last update: April 1st, 2024

Welcome to Cici!

Introduction
This privacy policy ("Privacy Policy") applies to the personal information that Cici processes in connection with Cici apps, websites, software, and related services (the “Service”), that link to or reference this Privacy Policy. The Service enables you to create and interact with chatbots.
Data Controller: The Service is provided and controlled by SPRING (SG) PTE. LTD., with its registered address in Singapore (“we”or “us”). If you have any questions about how we use your personal data, please contact feedback@ciciai.com.

What Information We Collect
We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.

Information You Provide

• Profile Information. We collect information that you provide when you set up an account, such as your date of birth (where applicable), username, email address and/or telephone number, and password. You can add other information to your profile, such as a bio or a profile photo.
• User Content. When you interact with our Service, we may collect text, audio, uploaded files, feedback, chat history, or other content that you input or otherwise provide to our Service("User Content").
• Surveys, Research, and Promotions. We collect information you provide if you choose to participate in a survey, research, promotion, contest, marketing campaign, or event conducted or sponsored by us.
• Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, feedback or inquiries about your use of the Service or information about possible violations of our Terms of Service (our “Terms”), Community Guidelines ("Guidelines") or other policies.

Automatically Collected Information

• Technical Information. We collect certain device and network connection information when you access the Service. This information includes your device model, operating system, keystroke patterns or rhythms, IP address, and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.
• Location Information. We automatically collect information about your approximate location (e.g. country, state, or city) based on your Technical Information (such as SIM card and IP address).
• Usage Information. We collect information about how you engage with the Service, including information about the content you view, the duration and frequency of your use, your search history and your settings.
• Content Characteristics and Features. We detect and collect characteristics and features about the videos, images, and audio recordings that are part of your User Content. We do this, for example, for content moderation and to provide appropriate output.
• Inferred Information. To provide a more personalised interaction with the chatbots, we may infer your attributes (e.g. age, gender, job) and interests (e.g. hobbies, topics of interest) based on your chats with the chatbots. We also use these inferences, for example, to keep the Service safe, and for content moderation.
• Cookies. We use cookies and similar tracking technologies to operate and provide the Service. For example, we use cookies to remember your language preferences, and for security purposes. We will obtain your consent to our use of cookies where required by law. To learn more about our use of cookies, please see our Web Cookies Policy.
• Payment Information. When you make a payment on or through the Service (e.g. purchasing a subscription), we collect information about the payment, such as the date and time of transaction, currency and transaction amount. We do not collect your payment card information – that is processed by Apple Pay or Google Pay (depending on your app store).

Information From Other Sources

• Log-in, Sign-up, or Linked Services. Where available, if you choose to sign-up or log-in to the Service using a third-party service such as Apple or Google, or link your account to a third-party service, we may collect information from the service, such as access token.
• Advertising, Measurement and Other Partners. Advertisers, measurement, and other partners share information with us about you and the actions you have taken outside of the Service, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Service.

How We Use Your Information
We use your information to operate, provide, develop, and improve the Service, including for the following purposes.

• Provide and administer the Service, such as enabling you to chat with various chatbots , to use different tools, and provide user support. This includes helping you to create your own voice style to be used for your chatbots. If you choose to have a more personalised experience, your historical conversations can be accessed by the chatbots to better inform the output responses.
• We provide services to you through multiple related products that are closely connected in functionality. Such related products include BagelBell, Coze and Cici. Some products may not be available in your region. In order to ensure a consistent service experience and to guarantee interconnection between products, these related products use a unified account service to collectively collect and process your account information (i.e. nicknames and IDs) across the aforementioned products. The account you register for using this product will also allow you to use a unified account service to log in synchronously, use related products, and access these services.
• Enforce our Terms, and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.
• Notify you about changes to the Services and communicate with you.
• Maintain and enhance the safety, security, and stability of the Service by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
• Review, improve, and develop the Service, including by monitoring interactions and usage across your devices, analyzing how people are using it, and by training and improving our technology.
• Facilitate research conducted by independent researchers that meets certain criteria.
• Promote the Service or third party services through marketing communications, contests, or promotions.
• Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information
Service Providers
We engage service providers that help us provide, support, and develop the Service and understand how it is used. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services. Following are the service providers currently engaged:
We use large language models, including GPT 3.5/4 (provided by Microsoft), to provide chatbot services for you. We will provide third parties with your personal information to get output responses.

We use some tools (e.g. Bing API) to help you write your input and optimize our output. For example, while you are typing, we may suggest words and help to finish your sentences. Your input will be transferred to the service providers to provide these services.
Depending on the nature of your requests submitted to the chatbots, we may use third-party service providers to provide you with your requested information.

Business Partners
Third Party Platforms and Partners. We share limited information which may include Information You Provide, Technical Information, and Usage Information with third party platforms and partners whose platform or services are integrated with the Service. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users. Some examples include if you:

• sign-up or log-in to the Service using your account details from a third party platform (such as Apple or Google), we will share certain Technical Information to facilitate this.

Advertising and Analytics Partners. We may share information collected through your use of the Service with our advertising or analytics partners. These partners help us promote the Service through advertising displayed on other platforms, some of which, in some jurisdictions, may be based on your activity across other sites and services. These partners may also help us and our partners measure the effectiveness of our advertising campaigns.


Our Corporate Group
As a global company, the Service is supported by certain entities within our corporate group (“Corporate Group”). These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us, as necessary to provide certain functions, such as storage, content delivery, security, research and development, analytics, customer and technical support, and content moderation.


Others
We share your information in other limited scenarios as follows:
Users of Our Analytics Services. We provide aggregated statistics and insights to help people and businesses understand how people are engaging with the Service. We create this aggregate information using Information You Provide and Automatically Collected Information.
Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.
Legal Obligations and Rights. We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognised standards,
• protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,
• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or
• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

With Your Consent
Depending on where you live, we may share personal information with the proper authorization or to provide the service you have requested or authorized. For example, if you choose to log in to our Service using a social network account, or share information from our Service to a social media service, we will share that information with those platforms.

Your Rights and Choices
Depending on where you live, you may have certain rights with respect to your personal information, such as a right to know how we collect and use your personal information. You may also have a right to access, change, oppose, request a copy of your authorization, file complaints before the competent authorities, withdraw your consent, or limit our collection and use of your personal information as well as to request that we delete it, and potentially others. Please contact us by emailing feedback@ciciai.com if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

If you request account deletion of any of Coze, BagelBell or Cici, the other two accounts will also be deleted. Once you choose to delete your account, you will not be able to reactivate your account or retrieve any of the content or information (including, but not limited to, your bots, your stories) in connection with your account. In certain circumstances, you may also request additional information about our collection and use of your personal information. Please note that your exercise of certain rights may impact your ability to use some or all of Cici’s features and functionalities.
If you have registered for an account, you may also access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.
Further, your device may have controls that determine what information we collect. For example, you can control whether we can collect your mobile advertising identifier for advertising through settings on your Apple and Android devices. You can opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.


The Security of Your Information
Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.
For security and privacy reasons, we request that you abstain from disclosing personal information, including passwords, credit card numbers, or other confidential data during chat interactions. Our commitment to safeguarding your privacy is unwavering, but the security of personal information also relies on safe user practices.
Third-party content. We may share your data with third parties and the Service may contain links to policies, functionality, or content maintained by third parties we do not control. We are not responsible for the privacy practices of third parties and the information practices of these third parties are not covered by this Privacy Policy.


How Long Do We Keep Your Information
We retain information for as long as necessary to provide the Service and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Service, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.
The retention periods will be different depending on the type of information and the purposes for which we use the information. If you violate our Guidelines or Terms, we may remove your Profile Information and/or User Content from public view immediately but keep your information as necessary to process the violation and as long as permitted by the applicable law.

Where We Store Your Information
The personal information we collect from you may be stored on a server located outside of the country where you live. We store the information we collect in secure servers located in the United States and Singapore. Where we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws.


Information Relating to Children Under 18
The Service is not directed at children under the age of 18. If you believe that we have personal information about or collected from a child under the age of 18, please contact us at feedback@ciciai.com.


Privacy Policy Updates
We may amend or update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you of any material changes to this policy by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy from time to time to stay informed of our privacy practices.


Contact Us
Questions, comments and requests regarding this Privacy Policy should be addressed to: feedback@ciciai.com


Supplemental Terms - Jurisdiction-Specific
Argentina
If you are using our services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Your rights and options
According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. You can exercise your rights by sending your request to feedback@ciciai.com free of charge.
We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos

Brazil
If you are using our Services in Brazil, the following additional terms apply:
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

• confirmation of whether your data are being processed;
• access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or erasure of data;
• portability of personal data to a third party;
• object to the processing of personal data;
• information of public and private entities with which we shared data;
• information about the possibility to refuse providing personal data and the respective consequences, when applicable;
• withdrawal of your consent;
• request an analysis of decisions taken exclusively based on the automated processing of personal data that affect your interests, including decisions taken to define your personal, professional, consumer or credit profile, or aspects of your personality.

Verifying your identity. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights. In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
In case of doubt about your privacy, your rights or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal data, we would like to clarify them.
International Transfer of Data. We share your personal data globally with companies of our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Services or share your personal data with third parties located in other countries. Your personal data may therefore be subject to privacy laws other than those applicable in your country.
Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards to protect your personal data and to ensure that it is processed safely.
Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
DPO. If you wish to contact the Data Protection Officer, please contact us: dpobrasil@bytedance.com

Egypt
If you are using our Services in Egypt, the following additional terms apply:

• You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and Terms of Use and agree to the use by your child of the Service and registration for an account.

Indonesia
If you are using our Services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Age, Parental and Guardian Consent. By accessing and/or using our Services, 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 Services; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Services will not, in any event, result in any violation of applicable laws and regulations relating to child protection.

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 and/or using the Services.
Your Choices. You may withdraw your consent to our disclosure of personal data to third parties. Upon your request, we will 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 Cici’s features and functionality.
You may request that we: (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of Cici's features and functionality.
To exercise any of your rights, contact us at: feedback@ciciai.com
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 five (5) 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 Services and the five (5) 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.

Japan
Welcome to Cici apps, websites, software, and related services ("Service"). This Service is provided and supported by SPRING (SG) Pte. Ltd. ("SPRING", “we” or “us”).
Like many other websites and apps, our Service uses cookies and other similar tracking technologies such as software development kits (“SDKs”) and pixels. These technologies allow us to operate and provide the Service. SPRING may request that the user’s related information recorded on the user’s electronic device be transmitted to SPRING or a third party when providing the Service to you.
Our Privacy Policy describes “What Information We Collect” from you when you use the Service, “How We Use Your Information”, and “How We Share Your Information”. Those sections apply to our use of cookies and other similar tracking technologies on the Service, and this Privacy Policy Addendum supplements those sections with further information. Our Privacy Policy and this Privacy Policy Addendum disclose relevant information regarding the external transmission of user information pursuant to the Telecommunications Business Act of Japan.
Kindly note that this document covers our own first-party tracking technologies, and third-party tracking technologies which we use. Information processed using first-party tracking technologies is received by us.

Cookies used on the Service
Service Functionality
We use tracking technologies to provide our Service and the features you have requested. Our use of tracking technologies may also involve recording information you enter or choices you make, such as your language preference for the Service. We use such technologies for helping to make the Service work more efficiently and enable us to tailor the Service to your preferences.
First-party tracking technologies (set by SPRING):
We use first-party tracking technologies for the following functionality purposes:

• Optimising and improving access to the website
• Preventing fraud and detecting non-human (bot) traffic
• User authentication and secure logins
• Traffic scheduling and network distribution.
• Frequency capping
• Localisation (remembering the country from which you visit our website(s) and your language preferences) .

Third-party tracking technologies (set by our partners):
The third-party tracking technologies we use for the provision of different functionality on our Service are listed below:

Apple (https://www.apple.com/jp/legal/privacy/jp/)

• Information Recipient: Apple Inc.
• Types of Information: Login event
• Purpose: Enables users to sign-up and login to the Service using their Apple account

Performance
We use performance tracking technologies to analyse how you use the Service, including which pages you view most often, how you interact with the content, measure any errors that occur and test different design ideas. The information is used to report and evaluate your activities and patterns as a user of the Service.

First-party tracking technologies (set by SPRING):
We use first-party tracking technologies for analytics and web optimisation purposes.

Third-party tracking technologies (set by our partners):[TM6]
We also deploy tracking technologies from the following third-parties to analyse website usage, including the number of page views and unique visitors.

Firebase Analytics (https://firebase.google.com/support/privacy)

• Information Recipient: Google LLC
• Types of Information: Log event, Andro Id, GAID, session statistics, approximate location, browser and device information, language, page location, page referrer, page title, screen resolution
• Purpose: Analyze web/app usage

Advertising and analytics
Our Service uses advertising and analytics tracking technologies. These tracking technologies help us and our advertisers to show you relevant advertising and measure the performance of ad campaigns on our website and app. We also use these technologies to promote the Service on other platforms and websites and measure their effectiveness.

First-party tracking technologies (set by SPRING):
We use first-party tracking technologies to improve our marketing campaigns, including to track ad conversions from ads for SPRING, build targeted audiences, optimise SPRING ads on third-party websites and apps for current and future visitors and remarket to people who have already taken action on our websites or on SPRING ads.

Third-party tracking technologies (set by our partners):
We also deploy tracking technologies from the following third parties. These technologies are used for measurement and analytics to track conversions from ads across different channels including third-party websites such as Bing, Facebook, Twitter, Google and LinkedIn, and our own websites and app. We use this information to serve ads and improve our marketing campaigns, including to track ad conversions from ads for SPRING and build targeted audiences, optimise SPRING ads and apps for current and future visitors and remarket to people who have already taken action on our websites or on SPRING ads.
A number of tracking technologies collect information on user agent. The specific user agent information may vary depending on how you access the Service and the tracking technology being used. User agent information includes information such as the name of your browser, the version of the browser and the type of device you are using.

AppsFlyer (https://www.appsflyer.com/privacy-policy/)

• Information Recipient: AppsFlyer Ltd.
• Types of Information: IDFA / GAID, IP address, User Agent, OS
• Purpose: App download attribution, campaign measurement and remarketing services

Contact
If you have questions, comments, complaints or requests regarding this Privacy Policy Addendum, please contact us at: feedback@ciciai.com


Mexico
If you are using our services in Mexico, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
How we use your personal data. We use both human and automated means to process your data.
How we share your personal data. We may share your personal data to a third party for purposes other than processing on behalf of us. We will obtain your consent for such sharing as required by applicable laws.
By providing us with your personal data and using our Service you agree to the transfers that require your consent. You can always revoke your consent and exercise your rights, as stated below.
Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, objection, consent withdrawal, limitation of use and disclosure of your data. You may exercise your rights by sending your request to feedback@ciciai.com. To learn about the applicable requirements and the procedure for exercising your rights, please contact us at the above email address. If you are under 18 years of age, you may exercise your rights through a parent or guardian. Requests to exercise your rights will be resolved as soon as possible according to the applicable data protection law and the nature of your request.

Philippines
If you are using our Services in Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.
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.

South Africa
If you are using our Services in South Africa, the following additional terms apply:
You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and Terms of Use and agree to the use by your child of the Service and registration for an account.

South Korea
If you are using our Services in South Korea, the following additional terms apply:
How we share your information. In addition to the main text of this policy, in the event we use information such as User Content and video content on our Service as part of our advertising and marketing campaigns to promote the Service, your personal information contained in such information may be disclosed to the recipients of such advertising or marketing content.
Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in the Policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:

• Act on Consumer Protection in Electronic Commerce:
• Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years
• Records on the handling of consumer complaints or disputes: 3 years
• Records on advertisements and labels: 6 months
• Protection of Communications Secrets Act
• Records on your visits to our website: 3 months

Destruction of Personal data. We destroy your personal data in a manner that renders it unrestorable by the relevant department.
Your Rights

• Data rights. You have the right to access personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at feedback@ciciai.com
• Data Security. We work hard to protect Cici and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal data on a need-to-know basis and controlling access to the facilities where personal data is processed.alabo
• Information Relating to Children. Cici is not directed at children under the age of 14.
• Entrustment and/or Overseas Transfer of Personal Data. We entrust your data to our affiliates, cloud storage providers, IT service providers, and data centers, some of whom are located abroad, subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Services, by contacting feedback@ciciai.com

United Arab Emirates
If you are using the Services in the United Arab Emirates (“UAE”), the following additional terms apply:
How we share your personal data
In addition to the main text of this policy, by using the Services in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.
Governing law and dispute resolution
By using our Services in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:

• where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and
• for all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

Vietnam
If you are using our Services in Vietnam, the following additional terms apply:
Age, Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old 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 Services; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Services 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 legal guardian(s) is not willing to open the account under their name, you must cease accessing the Services.