Effective: 2025/05/27
BonShort Privacy Policy
Your privacy and data security are extremely important to us. We are committed to the responsible
management, protection, and use of your personal information.
This Privacy Policy (the “Policy”) serves to explain what information collect, and how we use and protect
your information when you use any mobile applications that we develop.
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1. What Information Do We Collect?
Device information
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- We collect your device and network connection information in order to provide you better experience when
you use our app.
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- This information depends on the context of your interactions with us, the choices you make, including your
privacy settings, and the products and features you use, and may include:
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- SDK/API/JS code version, IP address, platform, timestamp, application identifier, application version,
application distribution channel, independent deice identifier, the terminal manufacturer, the terminal
device operating system version, the location of the language, the time zone and the network state (Wi-Fi
and so on), the CPU, and the battery use, Screen resolution, Memory usage, Storage usage, sim operator, sim
card country, Application release status, Ad loading strategy, Ad platform and advertising
placement id. Phone height and width,sim operator name,os version.
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- We store the information collected through the Android ID tied to the device you are using. In this way,
we can retain your advertising behavior while you are using the app. We will treat this information as
personal information
Data about your use of the Services
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- Number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on
particular pages, the date and time of your request, number of the app opened and some viewed page.
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- Permissions status.
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- Whether the function is running normally, such as whether a virus is detected.
- - Number of apps installed by users.
- - package name
- - first open time timestamp
- - app brand
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- app net status
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- app model
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- sim country
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- system language etc
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- Advertisers may store or read cookies
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- These data only be passed to the certified third-party statistical platform: Firebase, Facebook Analytics
and our self-built data statistics system (ECS).
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- The above information is only used to improve the product experience and will not be sold to any third
parties. We will not use this information for purposes other than improving the product experience and ad
performance.
Monetization and Analytical Information from Other Sources
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Third-party SDKs integrated in our app may access your information, including:
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- Google Advertising ID
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- Demographic data (e.g. determination of your IP address)
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- Data to fight against fraud (e.g. click fraud in advertising)
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- Data associated with your device (e.g. device type, technological information, country)
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- Data to do advertising, marketing and analysis
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- Advertisers may store or read cookies
The information collected by third-party SDKs is governed by the providers of these SDKs and we have no
control over such third parties. The third-parties include monetization partners, such as Google Admob,
Facebook Audience Network, MoPub, Smaato, PubNative, IronSource, ChartBoost, Pixalate etc., and also
analytical tools partners, such as Firebase, Facebook Analytics and our self-built data statistics system
(ECS) . The links to the above-mentioned platforms’ privacy policy are attached in the section “Third-party
Privacy Policy”.
Android Advertising ID
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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 (for
example: SSAID, MAC address, IMEI, etc.).
Other Information
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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.
Designated Countries
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For all information listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any
equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users
located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated
Countries”) based on our contract with you.
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2. How Do We Use the Information?
To improve and optimize the Services
To provide better Services to you, we have a legitimate interest to collect and process necessary data to:
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- Update and develop the Services
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- Develop and improve your experience
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- Manage the relationship with you
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- Customize your service experience
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- Respond to your comments and questions and provide support to you
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- Provide offers in the Services as well as in other websites and services
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- Send related information (e.g. updates, security alerts, support messages) to you
To provide the Services
To provider the Services, we process data necessary to:
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- Allow you to use the Apps and the Services
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- Operate the Services
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- Provide and deliver products and services that you request
To carry out activities related to advertisements and marketing
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To send you personalized advertising and marketing materials, we may use the information collected from you
such as ad identifiers, age, country, region, gender, language, games played by you, information related to
the interaction of you with the Services and with other users, and so forth.
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We may also use various third party advertising and marketing partners to assist us on our behalf and may
share information collected from you with such third parties for this purpose.
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Hence, we have a legitimate interest to process necessary data to:
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- Track the content you access in connection with the Services and your online behavior
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- Deliver, target and improve our advertising and marketing materials
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- Pass the information collected from you to third party advertising and marketing partners
By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and
our advertising and marketing partners collecting and using information about you to personalize advertising
and marketing materials and to improve your experience unless you opt out of receiving this service.
We encourage you to review the privacy policies of our third party advertising and marketing partners so
that you can understand how these third parties collect, use and share your information. We are not
responsible for the privacy policies of any third party whether accessed through the Services or otherwise.
To secure the Services
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Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate
security and technical measures to protect your information from unauthorized access, loss and misuse. To
achieve this purpose, we also request our suppliers who process personal information on our behalf to take
appropriate security measures.
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In order to keep the Service safe, to fight fraud and to ensure acceptable use otherwise, we have a
legitimate interest to process necessary data to
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- Analyze and monitor use of the Services
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- Prevent cheating, crime or fraud
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- Take action against fraudulent or misbehaving users
Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the
security of any of the communication facilities provided by us. We recommend that you exercise caution when
disclosing any information through the Services. In particular, please note that any personally identifiable
information or personally sensitive data that you communicate or disclose to any user in connection with the
Services may be collected and used by others. As such, you should take care of the information shared
online. Please also be reminded that any questions answers, comments, submissions that you post in the forum
will be publicly available.
Designated Countries
For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any
equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users
located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated
Countries”) based on our contract with you.
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3. What Information Do We Share?
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As mentioned above, your personal information may be shared with our third-party partners. We may disclose
your personal information to our business partners, including advertisers, publishers, and data tracking
companies. These business partners may use your personal information to show you advertisements, measure
your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to
improve their services. Such partners’ use of the information that we disclose to them will be governed by
their privacy policies.
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4. What Are the Important Permissions We Request?
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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. The permissions we ask are listed below:
- Storage
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- read the contents of your USB storage
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- modify or delete the contents of your USB storage
All files access
Location
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- approximate location (network-based)
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- precise location (GPS and network-based)
Device ID & call information
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- read phone status and identity
Wi-Fi connection information
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- view Wi-Fi connections
Photos/Media/Files
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- read the contents of your USB storage
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- read the contents of your USB storage
Camera
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- take pictures and videos
Phone
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- read phone status and identity
Other
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- update component usage statistics
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- receive data from Internet
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- notifications
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- full network access
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- full network access
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- measure app storage space
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- install shortcuts
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- view network connections
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- reorder running apps
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- draw over other apps
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- prevent device from sleeping
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- uninstall shortcuts
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- run at startup
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- connect and disconnect from Wi-Fi
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5. Legal Basis of Your Personal Data
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We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal
basis to process personal data includes processing that is: necessary for the performance of the contract
with you (for example, to provide you with the services you request and to identify and authenticate you);
necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to
make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to
manage our relationship with you, to ensure the security of our services, to communicate with you about our
products and services); and based on consent by our customers (for example, to place certain cookies and to
share your information with third parties for advertising purposes).
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In some instances, you may be required to provide us with Personal Data for processing as described above,
in order for us to be able to provide you all of our services, and for you to use all the features of our
apps. of our app.
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6. Your Rights
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We provide you with the rights described below when you use our Services. Please contact us at
info@bonshort.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:
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Where denial of access is required or authorized by law;
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When granting access would have a negative impact on other's privacy;
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To protect our rights and properties; and Where the request is frivolous or burdensome.
Right to withdraw consent
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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.
Right of access and rectification
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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.
Right to erasure (the “Right to be Forgotten”)
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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.
Right to restriction
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You have the right to restrict our processing your personal information where one of the following applies:
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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;
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The processing is unlawful and you oppose the erasure of your personal information and request the
restriction of its use instead;
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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; or
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You have objected to processing, pending the verification whether the legitimate grounds of our processing
override your rights.
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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.
Right to object to processing
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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.
Right to data portability
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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.
Notification to third-parties
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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.
Automated individual decision-making, including profiling
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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.
Right to lodge a complaint
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If you believe we have infringed or violated your privacy rights, please contact us
atmontgomeryhuaong@gmail.comso 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.
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7. Third-party Partners’ Privacy Policy
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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. Check the following links to get details
about how user data is collected, used and shared.
8. Google Admob & Firebase
9. Pixalate
10. Facebook Audience Network & Facebook Analytics
11. Mopub
12. Trustlook
13. smatto
14. PubNative
15. InMobi
16. Pangle
17. Pubmatic
18. Fyber
19. Criteo
20. adview
21. admixer
22. AdMob
23. Adjust
24. AppLovin
25. Unity
26. Yandex
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8. California Residents’ Privacy Rights
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We prepare this separate Privacy Notice for California Consumers to comply with the California Consumer
Privacy Act of 2018 (“CCPA”) and other California privacy laws.This notice is designed to supplement the
information described in our and applies solely to users who reside in the State of
California (“consumers” or “you”).
IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS POLICY DOES NOT APPLY TO YOU. PLEASE REFER TO OUR MAIN PRIVACY
NOTICE HERE INSTEAD.
Your Right to Request for Information
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As required by CCPA, you( or your authorized agent) have the right to request us to disclose information to
you about how we collect, use and share your personal information over the past 12 months.These information
include: the categories of personal information we collected; the categories of sources for personal
information we collected; our business purpose for collecting that personal information; the categories of
third parties with whom we share that personal information.
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Your Right to Delete Information
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Under the CCPA, You( or your authorized agent) have the right to opt out of having your information sold or
shared.You (or your agent)have the right to request that we delete your specific personal information that
we collected from you and retained, except in the following cases Such cases include:
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- We need your information to detect security incidents, protect against malicious, or illegal activity;
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- We need your information to identify and repair application errors that impair existing intended
functionality;We need your information to exercise free speech, ensure the right of another consumer to
exercise their free speech rights, or exercise another right provided for by law.
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- We need your information to conduct internal uses that are reasonably aligned with your expectations based
on your relationship with us;and other cases provided by CCPA and other Ca
How You Exercise Your Rights
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To exercise your rights described above, please submit a verifiable consumer request to us by
info@bonshort.com
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Only you or your authorized agent may make a verifiable consumer request related to your personal
information. You may only make a verifiable consumer request for request for information twice within a
12-month period. A verifiable consumer request must:Provide sufficient information that allows us to
reasonably verify you identity and make us confirm we collected personal information about you.Describe your
request with sufficient details that allows us to understand and respond to it.
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We cannot respond to your request accurately if we cannot verify your identity.
How We Respond Your Request
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We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time
(up to 90 days), we will inform you of the reason and extension period by email ,telephone or other
electronic means.
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We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why
we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Such discrimination include:
denying you our services; charging you different prices or rates for our services; providing you a different
level or quality of our services; suggesting that you may receive a different price or rate for services or
a different level or quality of services.
Data collection instructions for minors
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These Services do not address anyone under the age of 13. We do not knowingly collect personally
identifiable information from children under 13. In the case we discover that a child under 13 has provided
us with personal information, we immediately delete this from our servers. If you are a parent or guardian
and you are aware that your child has provided us with personal information, please contact us so that we
will be able to do necessary actions. For users aged 13~16, they have the right to opt in, and if you are
the parent or guardian of users who are aged 13~16, you can also contact us.
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Children's Privacy
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These Services do not address anyone under the age of 13. We do not knowingly collect personally
identifiable information from children under 13. In the case we discover that a child under 13 has provided
us with personal information, we immediately delete this from our servers. If you are a parent or guardian
and you are aware that your child has provided us with personal information, please contact us so that we
will be able to do necessary actions.
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Changes to the Policy
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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.
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Contact Us
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If you have any questions or concerns about the Policy, you may contact us at email: info@bonshort.com