BigLy

Privacy Policy

BigLy is a product offered by Innover Group ("we," "us," or "our")

At Innover Group we provide our users with feature-focused websites, browser extensions & applications that are geared to customized and more specific browsing experiences. Our products facilitate specific functionality and provide ease of access to information and widgets that can be accessed from the new tab, start page and/or via browser search settings.

We are committed to safeguarding the privacy of persons (“you(r)”) who visit, access our website, download, install and/or use our application (the “Application”) for searches on your mobile device.

This document describes our obligations under applicable data protection laws and explains what type of information we are collecting and how we are using this information.

1. What information we process:

In the course of browsing our websites, installing our products and using our product, we capture the following:

  • Information you provide to us. We may collect certain types of information that you explicitly provide to us through your use of the Application, if submitted by you as part of a crash report, error report, or other communication from you to us.
  • Automatically-captured information. We automatically collect information from you in order to optimize the Application and conduct analytics. This includes information regarding the traffic source, your Android advertising ID (which does not identify you),information only about such other applications that are open or in use at the same time when the Application is active or in use (the Application does not collect any usage information about other applications installed on a user device), your interactions with different features of the Application (e.g. location related modifications, app drawer loads, article clicks, ad impressions, clicks, etc.), search queries entered by you within the Application and associated sites, your IP address and certain information we extrapolate therefrom (e.g., your device location, city and the name of your ISP), network type, your user agent and certain information we extrapolate therefrom (e.g., your browser language, type and version and your OS type and version), your device information (device ID, device OS, version, brand,model, manufacturer, etc.), your screen size and resolution, the date/time for relevant events and metrics, and source details (e.g. the URL that redirects the user to install the app), application crash & error reports, install and uninstall flow events and application launch details.
  • Permissions: When you install and/or use the Application, we may, subject to your permission access information including, without limitation, your location, phone state, storage, contacts on your device to provide the functionality of the Application such as showing weather updates, adding contacts to the speed dial list and to reschedule alarms. Please be informed that such information is stored locally on your device. You can manage your permissions for the Application from the settings tab of your device. Please note that the permissions are required to enable us to provide the functionalities offered by the Application and should you choose not to grant the permission(s), some or all the features of the Application may not be available to you.

2. Why we process this information

We use the categories of information we collect to:

  • Create immersive product experiences with an active focus on user-centricity;
  • Perform essential functions to be able to support relevant products like monitor, manage and enhance websites, browser extensions and applications;
  • Tailor utility and output based on customer preferences;
  • Create internal analytics and reports;
  • Run data-based experiments to deliver better usability and functionality;
  • Enable service providers and us to serve relevant content and advertising;
  • Ensure customer service by actively engaging with users and responding to their queries and suggestions;
  • Address complaints, detect and defend against fraudulent, abusive, or unlawful activity;
  • Enforce our terms of service.

3. What we do with the information we process.

  • We process the information we collect in such a way that it cannot be attributed to a specific person. Information that can be used to directly identify you is held separately and securely to ensure you are not identified.
  • We reserve the right to process the information identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, but only to protect or assert legitimate interests, such as our legal rights, your legal rights and/or the legal rights of others.
  • In addition to the specific purposes for which we may process the information set out in this policy, we may also process information where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  • Please do not supply any other person’s personal data to us, unless we prompt you to do so and you have permission from that person.

4. Providing your information to others.

  • We may disclose your information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your information where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Retaining and deleting your information.

  • This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  • Information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • Notwithstanding the other provisions of this Section, we may retain your information where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Security of your information.

  • We will take appropriate technical and organizational precautions to secure your information and to prevent the loss, misuse or alteration of your information.
  • Regardless of where you are located, we will store all your information on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7. Your rights with respect to your information.

  • In this Section, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
  • Your principal rights under data protection law are: (i) the right to access; (ii) the right to rectification; (iii) the right to erasure; (iv) the right to restrict processing; (v) the right to object to processing; (vi) the right to data portability; (vii) the right to complain to a supervisory authority; and (viii) the right to withdraw consent.
  • You have the right to confirm as to whether or not we process your information and, where we do, access to the information, details of the purposes of the processing, the categories of information concerned, and the recipients of the information.
  • In some circumstances, you have the right to the erasure of your information without undue delay. Those circumstances include: (i) the information is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing under certain rules of applicable data protection law; (iv) the processing is for direct marketing purposes; and (v) the information has been unlawfully processed. However, there are exclusions on the right to erasure. The general exclusions include where processing is necessary: (x) for exercising the right of freedom of expression and information; (y) for compliance with a legal obligation; or (z) for the establishment, exercise or defense of legal claims.
  • In some circumstances, you have the right to restrict the processing of your information. Those circumstances are: (i) processing is unlawful but you oppose erasure; (ii) we no longer need your information for the purposes of our processing, but you require your information for the establishment, exercise or defense of legal claims; and (iii) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your information. However, we will only otherwise process it: (w) with your consent; (x) for the establishment, exercise or defense of legal claims; (y) for the protection of the rights of another natural or legal person; or (z) for reasons of important public interest.
  • You have the right to object to our processing of your information on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (ii) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
  • You have the right to object to our processing of your information for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your information for this purpose.
  • You have the right to object to our processing of your information for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • To the extent that the legal basis for our processing of your information is: (i) consent; or (ii) that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your information from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
  • If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
  • To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8. Third-party websites and services.

  • Our website includes hyperlinks to and details of third-party websites, as well as software (including, but not limited to, APIs and widgets).
  • We have no control over, and are not responsible for, the privacy policies and practices of third parties. Once you leave our Services or are redirected to a third-party website or application, you are no longer governed by the terms of this Privacy Policy or our Terms of Service.

9. Push Notifications.

  • We may request your consent to send you push notifications regarding marketing and advertising material which may be of interest to you and to update you about changes that we make to our Applications. You can choose to opt-out of receiving such notifications by managing your permissions for push notifications from the settings page of your device.

10. Personal data of children.

  • The Application is targeted at persons over the age of 18.
  • If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Additional notice to and rights of residents of California

1. Shine the Light:

  • We do not sell your personal data to third parties. Section 1798.83 of California’s Civil Code permits you—if you are a California resident—to request further information about our disclosure of personal data to third parties for their direct marketing purposes, where applicable. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.

2. California Consumer Privacy Act (CCPA)

  • If you are a California resident, please read the following section to understand the type of information we collect, how we use this information and your rights under the CCPA

Types and Sources of Information Collected by the Application

  • We collect information (“Personal Information”) that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular device or person (“user”). The categories of Personal Information include the following:
Category Examples Sources
A. Identifiers Name, email address, Internet Protocol address, Android advertising ID, user searches, other similar identifiers Directly from the user or (in the case of Internet Protocol address) indirectly from the users’ activity
B. Geolocation Device location Indirectly from the users’ activity
C. Internet / other network activity Type of OS, version, network type, screen resolution, brand and model of device; traffic source of installation; application crash and error reports; application install/launch/uninstall events; in-app engagements; other applications used or opened simultaneously when the Application is use on a device Directly from the user and/or indirectly from the users’ activity

Use of Personal Information

Except as otherwise set forth at the time we collect your Personal Information, we may use or disclose the above-listed types of Personal Information for one or more of the following business purposes (the “Purposes”):

  • To provide the product or service for the which you expressly provide your Personal Information
  • To provide responsive information that you request about our products or services
  • To create and maintain an account on your behalf (should you expressly request that we do so)
  • To determine the number of visitors to the Application
  • To communicate with you about our and any third-party products and/or services that may be of interest to you, to better display and tailor information to you, and to respond to your inquiries (e.g., opt out requests)
  • To deliver and market relevant content to you and measure the effectiveness of such efforts;
  • To comply with the Application’s Terms of Service
  • To improve and make enhancements to our website, products and/or services
  • To the extent necessary to evaluate a proposed reorganization or dissolution of the Company and/or a sale of its assets
  • To the extent necessary to respond to a feedback form, crash report, enhancement suggestion or other communication from you to us
  • As necessary or appropriate to protect our rights, your rights, the rights of our clients
  • To respond to legal process including law enforcements requests, court orders, and applicable law

Apart from Personal Information that you expressly provide, we will erase all Personal Information within six (6) months of its collection. We will update this notice should we need to collect other types of Personal Information or use the Personal Information we do collect for materially different reasons.

Sharing Personal Information

Absent a request from you to the contrary, we may share your Personal Information with third parties for the Purposes. Such third parties include our affiliates, our service providers, and other third parties with whom we share your Personal Information subject to your authorization. Before doing so, we will execute an agreement with each such third party that (a) describes the Purposes, (b) requires the third party to keep the Personal Information confidential, and (c) prohibits use of the Personal Information it for any purpose other than the Purposes, as you permit or as required to perform the third party’s services. If any such third party wishes to share your Personal Information with anyone else, it is required to provide you with notice and an opportunity to opt-out. To the extent we are aware that a User is less than sixteen (16) years of age, we will not share or sell that User’s Personal Information.

Rights under California Law

Users that reside in California (“you(r)”) have certain rights under the CCPA. This section describes those rights and explains how Users may exercise them.

A. Opt-Out from the Sale of Your Information: You may choose to opt-out from the sale of your Personal Information to third parties, though that may affect your inability to interact with the Application and/or obtain requested products or services.

B. Access to Your Information: You may request a copy of your information collected through the Application in the twelve (12) months preceding your request, including details about how your information is collected and used, such as:

  • The categories of Personal Information
  • The sources of Personal information
  • The purposes for which Personal Information was collected or sold (if at all)
  • The categories of third parties with whom we have shared Personal Information
  • If your Personal Information is sold or disclosed for a business purpose, two separate lists detailing (1) the categories of Personal Information sold and to whom (listed by category) and (2) the disclosures for a business purpose, identifying the categories of Personal Information obtained by each recipient (listed by category)

C. Deletion of Your Information: Subject to certain exceptions, you have the right to request that we delete your Personal Information. Once we receive and confirm a verifiable request, we will delete (and direct third parties to delete) your Personal information, unless we need to maintain your Personal Information in order to:

  • Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
  • Debug to identify and repair errors that impair existing intended functionality
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the Personal Information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our business
  • Comply with a legal obligation
  • Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.

D. Exercising Your Rights: To exercise any of your rights, please submit a verifiable request as follows:

A verifiable request must (1) include information that is sufficient for us to verify your identity, and (2) describe your request in sufficient detail. It must only be made (1) by you or a person registered with the California Secretary of State to act on your behalf, and (2) twice within a 12-month period. We will only use the information in a verifiable request to verify your identity and process your request (to the extent we are able). You will not need to create an account to make a verifiable request.

We strive to respond to all verifiable requests within 45 days, though may take an additional 90 days to respond, in which case we will inform you of the reason and extension period in writing.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; and/or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

12. Additional notice to and rights of residents of Nevada

  • If you are a resident of the state of Nevada, subject to the provisions of Nevada law (SB 220), you can request us to stop the sale of your ‘covered information’, as defined under the abovementioned law, to third parties who may further choose to license or sell that data . Please note that currently , we do not engage in the sale of your covered information. For additional information, please contact us using the contact information provided in this policy.

13. Additional notice to and rights of residents of Canada.

  • If you are a resident of Canada, you are permitted to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes, where applicable. To make such a request, please send an email to [email protected].

14. About cookies.

  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  • We use cookies on our website. Insofar as those cookies are not strictly necessary for the operation of the Application, we will ask you to consent to our use of cookies when you first agree to download and/or install the Application.
  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

15. Cookies used by our service providers.

  • Our service providers use cookies and those cookies may be stored on your computer when you first download and/or install the Application.
  • Specifically, we use Google Analytics to analyze the use of the Application. Google Analytics gathers information about online activity by means of cookies. The information gathered relating to the Application is used to create anonymous reports about the use of the Application. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
  • Some other third-party services used by us include:

    Firebase: – https://firebase.google.com/support/privacy

    Apps Flyer: – https://www.appsflyer.com/privacy-policy/

16. Managing cookies.

17. 'Do Not Track' Signals

  • Certain browsers have activated a "Do Not Track" (DNT) feature that sends signals/notifications to websites. This feature enables users to restrict websites from tracking the users activities. At present, the Application does not respond to DNT signals sent by any browser.

18. Amendments.

  • We may update this policy from time to time by publishing a new version on our website.
  • You should check this page occasionally to ensure you are happy with any changes to this policy.

19. Contact Information.

You may receive further information regarding our privacy practices and/or exercise any of your rights in relation to your information by written notice to:

Innover Group,
Suite 2409,
Everbright Centre,
108 Gloucester Road,
Wanchai,
Hong Kong
[email protected]