Privacy Policy

Master Flower STUDIO

Effective Date of Current Policy: May 1, 2020

1. Purpose

This Privacy Policy is incorporated by reference into the Master Flower STUDIO Terms of Service (the “Terms”). The terms “Master Flower STUDIO,” “we,” and “us” include Master Flower Entertainment Hong Kong Limited and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. All other terms not defined in Section 14 or otherwise herein will have the meanings set forth in the Terms.

2. Scope

This Privacy Policy applies to Personal Information that is Processed by Master Flower STUDIO in the course of our business, including on Master Flower STUDIO websites (each a “Site” or “Sites”), mobile applications, forums, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Master Flower STUDIO, the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Master Flower STUDIO are expected to protect that data by adherence to this Privacy Policy.

3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Master Flower STUDIO and the requirements of applicable law. Some of the ways that Master Flower STUDIO may collect Personal Information include:

You may provide Personal Information directly to Master Flower STUDIO through interacting with the Services, participating in surveys, during events, such as sweepstakes, and requesting Services, or information.

As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect

Master Flower STUDIO collects Personal Information regarding its current, prospective, and former customers, users, visitors, guests, and Employees (collectively “Individuals”).

Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Master Flower STUDIO, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Communications with Us. We may collect Personal Information from you, such as email address, phone number, or mailing address when you choose to request information about our Services, to request to receive customer or technical support, or otherwise to communicate with us.

Surveys. From time to time, we may contact you to participate in online and/or offline surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Services and in any manner consistent with the policies provided herein.

Posting in the Services. Master Flower STUDIO may offer publicly accessible Services, such as pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in Master Flower STUDIO’s Services, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Services, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

Registration for Sweepstakes or Contests. Occasionally, Master Flower STUDIO may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.

Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services, such as preferences.

Information Submitted Via Services. You agree that Master Flower STUDIO is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Master Flower STUDIO will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) or Social Networking Sites (“SNS”), such as Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Master Flower STUDIO and to enhance our ability to provide you with information about our business, products, and Services.

4. Human Resources Data

Master Flower STUDIO collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a Curriculum Vitae or application form, language abilities, contact information of a Third-Party in case of an emergency, or contact information of a beneficiary under any insurance policy. We may also collect Sensitive Human Resources Data, such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information, such as race, which helps us achieve our diversity goals.

We acquire, hold, use, and Process Human Resources Data for a variety of business purposes including:

Workflow management, including assigning, managing and administering projects;

Human Resources administration and communication;

Payroll and the provision of benefits;

Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;

Job grading activities;

Performance and employee development management;

Organizational development and succession planning;

Benefits and personnel administration;

Absence management;

Helpdesk and IT support services;

Regulatory compliance;

Internal and/or external or governmental compliance investigations;

Internal or external audits;

Litigation evaluation, prosecution, and defense;

Diversity and inclusion initiatives;

Restructuring and relocation;

Emergency contacts and services;

Employee safety;

Compliance with statutory requirements;

Processing of Employee expenses and travel charges; and

Acquisitions, divestitures, and integrations.

5. Onward Transfer—Master Flower STUDIO May Disclose Your Information

5.1 Information We Share

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services.

Business Partners. Master Flower STUDIO may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Master Flower STUDIO may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Master Flower STUDIO. Master Flower STUDIO requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Master Flower STUDIO provided them.

Displaying to Other Users. The content you post to the Services may be displayed in the Services. Other users of the Services may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.

Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, Master Flower STUDIO may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Master Flower STUDIO related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, and other account information and content, if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours, ours or others’ rights, property, or safety; (iv) to enforce Master Flower STUDIO policies or contracts; (v) to collect amounts owed to Master Flower STUDIO; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Master Flower STUDIO will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

5.2 Data Transfers

All Personal Information collected via or by Master Flower STUDIO may be stored anywhere in the world, including but not limited to, in the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Master Flower STUDIO, you consent to the storage of your Personal Information in these locations.

6. Opt-Out (RIGHT TO RESTRICT PROCESSING)

6.1 General

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Master Flower STUDIO’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting privacy@Master Flower STUDIO.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities in our Services and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

6.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding Master Flower STUDIO and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

6.3 Mobile devices

Master Flower STUDIO may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Master Flower STUDIO may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.

You can change or disable the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device operating system’s privacy settings. For more information on how to change the advertising identifier privacy settings on your device, please visit http://www.networkadvertising.org/mobile-choice or http://youradchoices.com/appchoices.

6.4 Human Resources Data

With regard to Personal Information that Master Flower STUDIO receives in connection with the employment relationship, Master Flower STUDIO will use such Personal Information only for employment-related purposes as more fully described above. If Master Flower STUDIO intends to use this Personal Information for any other purpose, Master Flower STUDIO will notify the Individual and provide an opportunity to opt out of such uses.

6.5 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

6.6 Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile advertisements via their device settings.

The online advertising industry also provides websites from which you may opt out of receiving targeted advertisements from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt out, these cookie-based opt outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

7. Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether Master Flower STUDIO is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to privacy@Master Flower STUDIO.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Master Flower STUDIO. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Master Flower STUDIO makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Master Flower STUDIO is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Master Flower STUDIO determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Master Flower STUDIO will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

8. Data Retention

Master Flower STUDIO retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice within the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.

10. International Users

By choosing to utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of State of California and the adjudication of any disputes arising in connection with Master Flower STUDIO or the Services will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and People’s Republic of China and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

Some countries (including those in the European Union) have laws that require agreements to be governed by the local laws of the consumer's country or require that their substantive laws, including privacy laws, apply. This section does not override those laws.

11. Children’s Privacy

The Services are not directed to children under 13, and Master Flower STUDIO does not knowingly collect Personally Identifiable Information from children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. If you learn that your child has provided us with Personal Information without your consent, you may alert us at linxue880520@gmail.com. If we learn that we have collected any Personal Information from children under 13 (and in jurisdictions under the age of 16 in the European Union), we will promptly take steps to delete such information and terminate the child’s account.

12. Redress/Compliance and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact Master Flower STUDIO by email at privacy@Master Flower STUDIO.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

13. Other Rights and Important Information

13.1 Changes To Our Privacy Policy and PRactices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Master Flower STUDIO will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Master Flower STUDIO will endeavor to comply with the law or contract.

14. Definitions

The following capitalized terms shall have the meanings herein as set forth below.

“Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, Master Flower STUDIO or to which Master Flower STUDIO discloses Personal Information for use on its behalf.

“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Master Flower STUDIO or its subsidiaries worldwide.

“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Master Flower STUDIO or Master Flower STUDIO’s Agents.

15. Revision history

Title (Effective Date)

Master Flower STUDIO Privacy Policy Effective: 2/21/2021

Updated Master Flower STUDIO Privacy Policy Effective: 5/25/2021