Getui Overseas User Privacy Policy

Last Updated: July 22, 2025

INTRODUCTION  

Daily Interactive Co., Ltd. (“Getui”, “we”, “our”, or “us”) understands that your user information is important to you and will do our utmost to keep it safe and reliable. We are committed to maintaining your trust and strictly abide by all applicable local laws and regulations, implementing appropriate security measures to protect your user information.

Because you do not have a direct contractual relationship with Getui, but are instead an end-user of a mobile application developed or operated by a developer that has registered a valid Getui account and integrated the Getui SDK, we require such developer to inform you—through a privacy policy, service agreement, or other appropriate means—that the application incorporates Getui service modules, and to ensure that you know and consent to the developer’s right to collect and use your user-related information being extended to Getui, so that we may obtain and use the information reasonably necessary to provide the relevant service functions.

We hope this Privacy Policy will help you understand how we process and protect your user information when providing services to you, and will disclose to you the purposes and methods of processing, the categories of personal information processed, the processing rules, and the ways and procedures for you to exercise your statutory rights such as access, duplication, rectification, supplementation, deletion, etc. Please therefore read this Privacy Policy carefully and make sure you fully understand it.

This Policy will help you understand the following:

  1. How We Process Your User Information  
  2. How We Protect Your User Information  
  3. Your Rights  
  4. How We Process Minors’ Personal Information  
  5. Storage and Cross-Border Transfer of User Information  
  6. Updates to This Privacy Policy  
  7. How to Contact Us  
  8. Definitions  

1.HOW WE PROCESS YOUR USER INFORMATION  

Getui will only process your user information for the business functions and purposes described in this Policy, and only after the developer has obtained your separate consent as required by applicable laws.

Please understand that in order to improve Getui’s technology and services, or due to changes in business strategy, the functions of our products and services on this platform may evolve. If the information required for our products or services exceeds the above scope, or if we intend to use the processed information for purposes not stated herein, or if our processing methods change, we will notify you a reasonable period before the change takes place and require the developer to obtain your consent again before use.

To enable full functionality, the Getui service may remain active both when the application is in the foreground and in the background. While the Getui service is active, the reasons, purposes, methods, categories and rules for processing your user information are as follows:

1.1 Collection and Use of Your User Information  

1.Push-SDK Service  

- Device information: device platform, manufacturer, brand, model, OS version, and device identifiers (including IMEI, Android ID, MAC, OAID, Google Advertising ID (GAID), Serial Number, IMSI, ICCID, IDFA, IDFV). These identifiers are used to generate a unique push target ID (CID) and device ID (GID) to ensure accurate message delivery and device identification. Brand, model and OS version are used to optimise channel resources and improve delivery rate and stability.  

- Network information (including IP address, Wi-Fi info, SSID, BSSID, base-station info, carrier info, DHCP): to maintain the stability of network connections and establish long-lived links, we need to understand the device’s network status and changes so as to provide stable and continuous push services.

The above information helps developers build applications better suited to you, improve your user experience, and provide higher-quality services.

2.Indirect Acquisition of Personal Information and Your Consent  

Please note that we already require the developer to ensure that, during the service period, you have confirmed and authorised us to process your user information for the purposes stated herein in compliance with applicable laws.  

We guarantee that processed user information will be de-identified or anonymised in accordance with the law, and the resulting data may be used to optimise data solutions. If we combine non-personal information with other information so that it can identify you personally, or if we combine it with your personal information, we will treat such combined information as your personal information and protect it in accordance with this Privacy Policy.

1.2 Sharing, Transfer and Public Disclosure of Your User Information  

  1. Sharing  

We do not share your user information with any company, organisation or individual outside Getui, except in the following cases:

- With your explicit consent;  

- As required by laws, regulations, or compulsory requirements of judicial or government authorities;  

- With our affiliates: we only share the minimum necessary information, and such affiliates are bound by this Policy. If they wish to change the purpose of processing, they must obtain your consent again;  

- With trusted partners (advertisers, ad networks, media, developers, etc.) solely for the purposes stated herein.  

We sign strict confidentiality agreements with any entity with whom we share information, requiring them to process the shared information in accordance with our instructions, this Policy, and appropriate security measures.

     2.Transfer  

We will not transfer your user information to any company, organisation or individual, except:  

- With your explicit consent;  

- In connection with a merger, acquisition or bankruptcy liquidation, in which case we will require the new controller to obtain your consent again and inform you of the transferee’s name, contact details, processing purposes, methods and categories of personal information.

     3.Public Disclosure  

We will only disclose your user information:  

- With your explicit consent; or  

- When required by laws, regulations, legal proceedings, litigation or government authorities.

     4.Exceptions  

In accordance with applicable laws, we may process your user information without your consent when:  

- It is necessary for the performance of a contract to which you are a party;  

- It is necessary for compliance with a legal obligation;  

- It is necessary to respond to a public-health emergency or to protect life, health or property in an emergency;  

- It is for the public interest in news reporting or supervision;  

- It concerns information that you have made public or that has been lawfully disclosed;  

- Other circumstances stipulated by laws and administrative regulations.

2.HOW WE PROTECT YOUR USER INFORMATION  

2.1 We use industry-standard security measures to protect your user information from unauthorised access, disclosure, use, modification, damage or loss. Examples include SSL encryption for data exchange between your browser and our services, HTTPS for intl-dev.getui.com, encryption technology, trusted protection mechanisms, access-control systems, regular staff training, and an emergency response plan for personal-information security incidents.  

2.2 Certifications obtained: Class-3 Information-Security Level Protection, ISO 9001, ISO 27001, ISO/IEC 27701.  

2.3 Data-security capability: In accordance with the Data Security Law, Cybersecurity Law, Personal Information Security Specification, etc., we have completed Class-3 security protection certification, data classification and grading, data脱敏, storage standards, and formulated documents such as Security Master Policy, Data Classification & Grading Standards, Security Incident Management Standards, etc., building a corporate “firewall” covering the entire data life-cycle. We have also appointed a Data Protection Officer (DPO) to ensure compliance with the Personal Data Protection Act (PDPA).  

2.4 We retain your user information only for the period necessary to achieve the purposes stated herein, unless an extension is required or permitted by law.  

2.5 The Internet is not absolutely secure; please do not send information via unencrypted email or instant messaging.  

2.6 We conduct regular compliance audits and personal-information protection impact assessments (PIPIAs), and keep records for at least three years for any processing activity that may significantly affect your rights.  

2.7 Although we implement all reasonable and necessary measures, we cannot guarantee that your user information will be completely free from illegal access, theft, alteration or destruction. Please understand and voluntarily assume the above risks.

2.8 In the event of a personal-data breach, we will immediately take remedial measures and notify you by email, letter, telephone, push notification, etc. If notification is impossible on an individual basis, we will issue a public announcement. We will also report to the competent authority as required.  

2.9 We will instruct developers to include in their privacy policies a requirement that you consent to our Privacy Policy. Any claim, demand or complaint arising from collection, use or disclosure under this Policy shall be resolved by the developer.  

2.10 Where a developer offers services in an EU member state, we will remind it to ensure an appropriate legal basis for processing and to inform you of your right to object, restrict processing, access, rectify, erase, port your data, and to withdraw consent at any time. If you believe the developer violates applicable law, you may lodge a complaint with a supervisory authority. Please understand that we do not exercise actual control over the developer’s app; we can only remind the developer of its obligations, and we assume no liability for any infringement by the developer.

3.YOUR RIGHTS  

Because you are not Getui’s direct customer, we recommend that you send any request to the app provider, who will forward it to us. We require developers to provide easy-to-use mechanisms for you to exercise your rights of access, rectification, deletion, withdrawal of consent, etc.  

If you still choose to contact Getui directly, we will require you to provide proof of identity and relevant supporting documents. After verification with the app provider, we will handle your request in accordance with this Policy. Under applicable laws, you have the following rights:

3.1 Access, duplication, rectification and supplementation  

You may contact us through the channels listed in Section 7. We may ask you to provide sufficient information to verify your identity.

3.2 Deletion  

You may request deletion by emailing support@getui.com when:  

- the processing purpose has been achieved or cannot be achieved;  

- we cease to provide the product or service or the retention period has expired;  

- you withdraw consent;  

- we violate laws, regulations or our agreement with you.  

We may ask you to verify your identity. Deleted information may remain in backups until anonymisation is possible.

3.3 Changing the scope of consent  

You may contact us to withdraw consent. We will process your request within fifteen working days. **Withdrawing consent may affect certain services or functions, but it will not affect processing already carried out.**

3.4 Response to requests  

We may ask you to submit a written request and proof of identity. We will respond within fifteen working days after successful verification. We do not charge for reasonable requests, but may charge for repeated or excessive requests. We may refuse requests that are impossible to fulfil, impose disproportionate technical burden, or endanger others’ rights. **We may also refuse where compliance would violate our legal obligations, harm major public interests, or involve trade secrets.

4.HOW WE PROCESS MINORS’ PERSONAL INFORMATION  

Getui does not allow minors (under 14) to register for or use our products or services.  

If a developer’s application is directed to minors, we will instruct the developer to:  

- adopt special rules for processing minors’ personal information;  

- obtain verifiable parental consent in accordance with Singapore’s PDPA, PDPR and other applicable laws;  

- comply with app-store guidelines for minor-directed apps.  

We will process minors’ personal information only when permitted by law, with explicit parental consent, or when necessary to protect the minor, and will otherwise delete it as soon as possible.  

If we discover that we have processed a minor’s information without verifiable parental consent, we will delete it promptly unless retention is required by law. We assume no liability if we are unable to actively identify such information, but will respond to your request as soon as practicable.

5.STORAGE AND CROSS-BORDER TRANSFER OF USER INFORMATION  

5.1 Storage location  

Your user information will be stored in Singapore. Any cross-border transfer will require your separate consent.  

If a developer uses our products or services outside Singapore, it must comply with Singapore PDPA/PDPR and local data-transfer laws, and must have obtained your separate consent. We will ensure that your user information receives protection equivalent to that in Singapore.

5.2 Retention period  

We retain your user information only for the period necessary to achieve the purposes stated herein and for the minimum period required by law. After the retention period, we will delete or anonymise your information in accordance with our Data Security Technical Implementation Guidelines. We may extend the retention period where required by law or with your separate consent.

6.UPDATES TO THIS PRIVACY POLICY  

We may update this Policy from time to time to reflect changes in our services, legal requirements, or business practices. The updated Policy will be posted on our website and will take effect seven days after publication. If you do not agree to the changes, please stop using Getui services; continued use will constitute acceptance.  

For material changes we will provide prominent notice, including but not limited to changes in processing purposes, categories of information, ownership structure, your rights, or our contact details.  

Archived versions will remain available for your review.

7.HOW TO CONTACT US  

If you have any questions, comments or suggestions regarding this Privacy Policy, please contact us:

Email: business@getui.com  

Tel: +86-4006-808-606  

Fax: +86-571-86473223  

Address: Daily Interactive Building, 100 Jingda Road, Xihu District, Hangzhou, Zhejiang, China  

You may also contact us via https://intl-dev.getui.com or any customer-service hotline.  

Our Data Protection Officer can be reached at support@getui.com.  

If you are not satisfied with our response, you may bring a lawsuit in the People’s Court having jurisdiction over Xihu District, Hangzhou, where Getui is located.

8.DEFINITIONS  

- “Getui” or “we” means Daily Interactive Co., Ltd.  

- “Personal information” means any information recorded electronically or otherwise that can identify a natural person, alone or in combination with other information.  

- “Personal information subject” means the natural person identified by the personal information.  

- “Deletion” means the act of removing information from the systems involved in daily business functions so that it cannot be retrieved or accessed.  

- “Anonymisation” means the process of handling personal information so that it can no longer identify a specific natural person and cannot be restored.  

- “De-identification” means the process of handling personal information so that it cannot identify a specific natural person without additional information.  

- “Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with Getui, or has any other associated relationship (including but not limited to the same legal representative or actual controller, or family relationship).