XShare Privacy Policy
This Privacy Policy aims at explaining how XShare uses and protects your information while using the app SHALLTRY displayed in the Google Play Store. Once you use XShare of SHALLTRY , you shall be deemed to have read, agreed and accepted all terms and conditions stated in this Policy as well as all the changes we have made at any time. SHALLTRY respects and protects your personal privacy, please read carefully and understand this Policy before providing your Personal Information to SHALLTRY or allowing SHALLTRY to collect your Personal Information.
What Information Do We Collect?
1.XShare Collects location data to enable features as followed when App is in use
1.1 Open Camera to Scan QR Code for Transfer Connection
When the app is in use, XShare will collects location data to open camera and enable transfer connection, when users scan the QR code with the camera. It is necessary permission required by system camera, so that users devices can decode QR code and users can start transfer files through XShare. However, XShare would never record or upload location information under such circumstance.
1.2 Use Location Permission to Open Bluetooth to Discover Nearby Devices.
When the app is in use, and users receiving files, XShare would collects location data location permission to enable discover of nearby devices through BluetoothManager scanning. It is a crucial step to connect between devices. However, XShare never record or upload location information under such circumstance.
1.3 Use Location Permission to Create wifi Hotspot for Transfer.
When the app is in use, XShare would collects location data location permission to enable creation wifi group or hotspot group for transfer. XShare will never record and store any location information under such circumstance.
1.4 Extend Location data Usage to Ads
Facebook and admob are two third party advising SDK. Aming at improving better experience for users, Xshare would extend the location data usage to support facebook and admob advertising, so that users can receive personalized ads and decrease irrelevant ads when app is in use.
2.XShare Collects Location Data to enable Users Portraits Analysis when app is in the background.
When App is in use, and also when app is in the background, Athena SDK, a self developed SDK for behaviour analysis, would collect user location data to enable users portraits analysis. It does help in differentiating users and providing more appropriated content.
3.XShare Collects Devices Storage When app is in use
When the app is in use, Xshare would read user devices’storage data to enable users to transfer offline files and store video after downloaded video in the app. Besides, Xshare would collect transferred file data (package name，file type）to Athena SDK, a self developed SDK for behaviour analysis.
4.Device information:
We may collect those information and store in our server in order to find out the reason when problem occurs according to your feedback in Google Play.
It may includes but not limited to: Android system version; Device model, Version of android system, version of software and network operator；XShare package name; XShare version number; XShare version name; Language; Gaid
5.Device operation status and logs of operation:
It includes but not limited to CPU load, storage status, device temperature, battery capacity, key words searched in browser or application, mobile data traffic/speed, signal intensity of mobile network, information of daemon, user habit, logs of abnormal operation of the device.
Location information: accurate or ambiguous location information we collect when you use navigation software or search weather conditions, longitude and latitude generated by GPS or Wi-Fi hotspot, community identity or country code, location area code（LAC）,trace area code(TAC), routing area code(RAC), mobile country code (MCC), mobile network code (MNC), ARFCN, UARFCN, EARFCN,etc.
6.Personal Information collected when you use third party’s services or applications
With the purpose of providing appropriate service, we may collect your Personal Information during your interaction with the app.
Here we list the links to the third-party partners’privacy policy. Please note that these policies are governed by the third parties and we have no control over them.
a. Google Admob & Firebase：https://policies.google.com/privacy?hl=en
b. Facebook Audience Network & Facebook Analytics：https://www.facebook.com/about/privacy
c. Athena for behavior analysis：
India：https://ind-dsu.shalltry.com/athena/checkpoint/v3/upload
Non-India：https://ire-dsu.shalltry.com/athena/checkpoint/v3/upload
Athena SDK is used for recording user behaviour data when you use the app and syning to the server as events. It aiming at behaviour analysis and app static analysis, to help us provide better service.
d. TCM：India：ind-api.twibida.com/ Non-India：irl-api.twibida.com
Global（Include India and Non-India）：api.twibida.com
The purpose of TCM SDK is to differentiate users and give push notifications in more precise and comfortable way. With these puroses, TCM SDK would collect your gaid; model type; language; App version; Android version this information etc for user portrait analysis.
e. Vskit SDK：https://api.xshareapp.com
Vskit is a video SDK intergrated for providing online video for users while transferring. It would collect Xshare version name, version code, language and gaid.
7.Android Advertising ID
We use your Android advertising identifier in order to provide you with customized advertisement experience. It is used exclusively for advertising and analytics. Please note that the advertising identifier does not contain any user sensitive information that can be used to identify you as a user or your device. It is not connected to personally-identifiable information or associated with any persistent device identifier .
8.Reasonable use of personal data
We process Personal Data for the purposes set out in this Privacy Policy, as described above. And we would not disclose our personal informational unrelated to your interaction and behaviour within the app.
9.Changes to the Policy
Any information that is collected is subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.
10.Other Information
We may collect information that you directly and voluntarily provide to us. The information includes but is not limited to: your email address, the content of feedback, and the content of questionnaire answered by you.
11.Why Do We Use the Information?
To improve and optimize the Services
To provide the Services
To carry out activities related to advertisements and marketing
To secure the Services
Designated Countries
12.How SHALLTRY handle Personal Data of minors
Minors are not allowed to use SHALLTRY products and services without the consent and guidance of his or her legal guardians. In principle, we will not take initiative to collect the Personal Data of a minor and only with the consent of his or her legal guardians, we will collect his or her Personal Data. As to the disclosure of the Personal Data of a minor, we will provide, in principle, only when permission is given by his/her legal guardian, or where the law or relevant government sector legitimately requires. In addition, if you find that a minor sends his or her Personal Data to SHALLTRY without the consent of his or her guardian, please fill out the form attached to this Policy and send to us via email at shtranssion@gmail.com. We will reply to you in time.
13.What Are the Important Permissions We Request?
Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app.
14.How to access, modify and delete your Personal Data
As the user of the products or services, you are obliged to ensure the completeness and accuracy of the Personal Data you provided and carefully keep your Personal Data safe. We will protect and update your Personal Data on time and try our best to ensure your normal use of the products and services.
In accordance with your rights under relevant applicable law, you may exercise: 1) right of access, i.e. the right to have access to your Personal Data held by SHALLTRY and to know whether Personal Data concerning him or her are being processed or not; 2) right to rectification, i.e. the right to request rectification of the inaccurate Personal Data we hold concerning you; 3) right to erasure, i.e. the right to request us to erasure of the Personal Data concerning you; 4) right to restriction of processing, i.e. the right to restrict our processing of your Personal Data; 5) right to object, i.e. the right to object to our processing of your Personal Data; 6) right to data portability, i.e. the right to request us, where technically feasible, to have your Personal Data transmitted to another data controller. To request exercising your rights under the applicable law, please fill out the form attached to this Policy and send to us via email at shtranssion@gmail.com. We will reply to you in time.
While you are exercising your rights under the applicable law, we may investigate the legality and rationality of your request. If we have reasonable grounds or suspect that your request is deceptive, repetitive or infringes upon the rights and freedom of third parties, or if we are unable to get through the investigation, we may ask you to provide further information or may refuse to process your request. You may send your request in written form in order to protect your legitimate rights and interests. After receiving your request, we will process within the period of time as prescribed by applicable law. If you consider that we are in violation of applicable law and have infringed your legitimate rights, you may file a complaint with the authority for the protection of Personal Data in order to resolve the issue.
15.Your Rights
Individual rights for users live in the European Economic Area, United Kingdom, and Switzerland, we provide you with the rights described below when you use our Services. Please contact us at shtranssion@gmail.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:
Where denial of access is required or authorized by law;
When granting access would have a negative impact on other's privacy;
To protect our rights and properties; and Where the request is frivolous or burdensome.
16.Right to withdraw consent
If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
17.Right of access and rectification
If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.
18.Right to erasure (the “Right to be Forgotten”)
You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
19.Right to restriction
You have the right to restrict our processing your personal information where one of the following applies:
You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
20.Right to object to processing
You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
21.Right to data portability
If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
22.Notification to third-parties
If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
23.Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
24.Right to lodge a complaint
If you believe we have infringed or violated your privacy rights, please contact us at shtranssion@gmail.com so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
25.How to contact SHALLTRY
SHALLTRY has appointed a Data Protection Officer. For any questions in relation to the protection of personal privacy, please contact our Data Protection Officer by filling out the form attached to this Policy and sending the completed form to our email adress at shtranssion@gmail.com. If you have any questions or suggestions about this Policy, please contact us by the following information:
If you have any questions or concerns about the Policy, you may contact us at：xshare.feedback@gmail.com