Effective Date: December 2, 2022

PRIVACY POLICY

1. This Privacy Policy describes how your personal information is collected, used, and shared when you visit https://360-studios.com (the “Site”, “Webpage”, 360-STUDIOS.COM) or where JingYu Trading Limited otherwise processes your data.
2. COLLECTION OF PERSONAL DATA
   1.     2.1.When you visit 360-STUDIOS.COM, we automatically collect certain data and  information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.
   2.     2.2.We collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
   3.     2.3. JingYu Trading Limited collect Device Information using the following technologies:
      1. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;
      2. “Log files” track actions occurring on 360-STUDIOS.COM, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps;
      3. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse 360-STUDIOS.COM;
      4. “Personal Information” includes both “Device Information” and “Order Information”.
3. PERSONAL INFORMATION MODE OF USE
   1.     3.1.To communicate with you; and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
   2.     3.2. We use the Device Information that we collect to help us improve and optimize our Site (for example, by generating analytics about how our users browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
   3.     3.3.All data collected on our public-facing Site will never be used this information to identify individual users or to match it with further data on an individual user. This policy differs from our login-only application.
4. SHARING YOUR PERSONAL INFORMATION
   1.     4.1.We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our users use the Site — you can read more about how Google uses your Personal Information here:
      https://www.google.com/intl/en/policies/privacy/.
   2.     4.2.We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
5. BEHAVIORAL ADVERTISING
   1.     5.1.As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
   2.     5.2.You can opt- out of targeted advertising at the following links:
      FACEBOOK – https://www.facebook.com/settings/?tab=ads
      GOOGLE –https://www.google.com/settings/ads/anonymous
6. PLATFORM DATA PROCESSING
   1.     6.1.The Data Controller of the personal data we process is: JingYu Trading Limited. You may contact us using the details at the end of this Policy, and our representative in the EU is:
      1. The purposes of our data processing are as follows:

1. Please note that our clients may also enter certain personal data into our systems (e.g. in relation to particular influencers they work with, or because influencers have directly agreed to give them greater access). We are a data processor and not a controller of this data. We will normally need to pass any questions in relation to this data on to the relevant client for action or response.
2. Authentication of Data from Social Network Platforms:

Via the Links Accounts Page of your Account, you may choose to opt-in and allow JingYu Trading Limited to connect to one (1) or more of your Social Network Accounts so that JingYu Trading Limited may access data from the applicable Social Network platforms on your behalf (such data collectively, the “Authenticated Data”).

1. JingYu Trading Limited may use Authenticated Data to improve the Services for you (e.g. by using such data to deliver more accurate statistical data) and to improve the Services overall. Authenticated Data used to improve JingYu Trading Limited Services will be aggregated and anonymized and used for purposes such as producing market estimations. If you have opted into an agreement with an JingYu Trading Limited client, JingYu Trading Limited may grant access to some of your Authenticated Data, for the purpose of ensuring that all of your post or video activity is correctly attributed to you within JingYu Trading Limited Services). You may revoke JingYu Trading Limited ability to collect your Authenticated Data at any time through the opt-out feature in the Links Accounts Page of your Account (see Your Choices below). If you opt into authenticating any of your Social Network Accounts with JingYu Trading Limited, JingYu Trading Limited will:
   1. Never post on your behalf to any of your authenticated Social Network Accounts (e.g. your Facebook Page or YouTube Channel).
   2. Never manage any of your Social Network Account ad campaigns (e.g. Facebook ad campaigns or YouTube ad campaigns) and will never alter any of your Social Network ad settings.3. The recipients of the data are as follows:

6.3. We provide data to other companies in our corporate group and technical service providers inside and outside the Hong Kong that require access to data in order to assist us in providing our services. In particular, we work with reputable external data processors, to which we provide certain data which may include personal data, in order to provide our platform and services, including for the purposes of storage, analysis, development, testing etc.

6.4. In each case we have in place safeguards that enable transfers from the Hong Kong to happen in a way that ensures that data is handled in accordance with similar standards to those applicable in Hong Kong.

6.5.We present posts and data received from the social networking platforms to our clients via our platform, as well as email addresses where you have made them publicly available.

6.6. Where data (which may include personal data of users or influencers) is entered by our clients we enable clients’ authorized users to access, update and process the data provided by that client.

6.7. If any state body or regulator validly requested data from us, then we would normally comply with such request without having to notify you or other users.

6.8. We retain the data only as long as necessary for the purposes described in this Privacy Policy. When we no longer need to use the data for such purposes (or for us to comply with our legal or regulatory obligations), then we will either remove it from our systems or delete all personally identifying elements so that the data cannot be traced back to you or any other identifiable person.

6.9. EU data subjects have various legal rights in relation to their data including:

6.9.1. To ask for access to it;
6.9.2. To ask for errors in it to be corrected;
6.9.3. To ask for it to be erased (the “right to be forgotten”);
6.9.4. If not erased, then to ask us to restrict its processing;
6.9.5. To object to its processing for specific purposes;
6.9.6. To ask for a copy to take to another service provider.

6.10. Where we process any data based on consent that you have given in the past, then you are always allowed to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal).

7. CONTACT

7.1. If you are a social media user or influencer who would like to opt-out of inclusion in 360-STUDIOS.COM platform, please our form, posted at https://360-studios.com.

7.2. For any other purposes, please use:

JingYu Trading Limited

景瑜貿易有限公司

Company registration No.: 3212321

Address: ROOM 6, 11/F, CHEUNG HING BUILDING, 540-544 NATHAN ROAD, YAU MA TEI, KOWLOON, HONG KONG

1. CORRESPONDENCE
   1.     8.1. Correspondence between you and JingYu Trading Limited can be maintained via e-mail or postal and delivering services. E- mails or other correspondence, sent from the above addresses are official and are subject to obligatory execution. In case an e-mail was sent by JingYu Trading Limited, the latter is not obliged to subsequently send the document on paper.