Privacy Policy

Effective date: April 3, 2020

At Magic Crystal, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Magic Crystal Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@mojing.im.

If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data. Please refer to our GDPR Privacy Notice for EU Residents for more details.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services, including without limitation the following products and services.

Mojing App: Magic Crystal App is an open and mobile messenger built with email technology, available in iOS and Android and can be downloaded from the Apple App Store and Google Play Store. For more information, please refer to https://mojing.im/..
Measurable AI Product (“MAI Product”): MAI Product is an enterprise facing database and platform available at https://measurable.ai/, which provides alternative data (that doesn’t include any Personal Data) to enable its subscribers to use, review, analyze such data to gain consumer/business insights and visualize market/industry trends.

“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Categories of Personal Data We Collect

Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

“You”
- When you provide such information directly to us. For example, when you register for the Services, we may require you to provide certain information, such as contact information (e.g. your name, username, and email address).
- When you connect your email accounts with third party email service providers to the Magic Crystal App (see the subsection titled “Information Collected from Connected Email Accounts” below).
- When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled “Information Collected Automatically” below).

“Third Parties”
- Third parties that provide us with Personal Data about you. Third Parties that share your Personal Data with us include:
  - Email service providers. If you connect your email accounts with third party email service providers to the Magic Crystal App, some content and/or information in those accounts may be transmitted into your account with us.
  - Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

Categories of Personal Data

The chart in this section details the categories of Personal Data that we collect and have collected over the past 12 months:

1. Category of Personal Data	2. Personal Data We Collect	3. Source(s) of Personal Data	4. Categories of Third Parties With Whom We Share this Personal Data for a Business Purpose:
Personal identifiers	Name Username Email Address IP Address	IP Address	Service Providers
Commercial information	products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies Commercial Messages (as defined in subsection “Information Collected from Connected Email” below)	You (as described in subsection “Information Collected from Connected Email” below)	Service Providers

In addition to the categories of Personal Data listed above, we also collect and process information, which may include Personal Data, from (i) email accounts you decide to connect with the Magic Crystal App (as described in the subsection “Information Collected from Connected Email Accounts” below), and (ii) Cookies (as defined below, and further explained in the subsection “Information Collected Automatically”).

Information Collected from Connected Email Accounts

To use the services of Magic Crystal App, you’ll need to connect your email accounts to the Magic Crystal App (“Connected Email Account”). With your permission at sign-up or use of the Magic Crystal App, you authorize us to access and process email messages in your Connected Email Accounts in order to provide the Magic Crystal App Services to you, and for other purposes as explained in this Privacy Policy. We may collect Personal Data including without limitation the following:

your first and last name
email address
third-party account credentials (for example, your log-in credentials for Gmail or other third party email accounts).
Third Party Account Information (as defined and explained below)
IP Address

If you provide your third-party account credentials to us, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. For example, when you connect your email account (e.g. Google Gmail, Yahoo Mail, iCloud) to the Magic Crystal App, you agree that we may access, receive, and/or collect the following information, if the third party service provider(s) and your account settings allow such sharing:

your email address;
commercial and transactional email messages that are sent or forwarded from businesses or merchants to your email accounts about your purchases and other transactions, such as purchase receipts, reservations, bills, subscriptions, order confirmations, sign-ups or cancellations (collectively, “Commercial Messages”)
personal, relationship or other email messages that are sent to your email account or you sent out from your email account, other than Commercial Messages (collectively, “Non-Commercial Messages”);
email meta data, including sender’s name, recipient’s name, subject line, email time chop, email contents and email attachments;
and/or email contact list.
IP Address

The information we receive will depend on the policies and your account settings with the third party services.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Performance/Analytical Cookies . Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:

To meet or fulfill the reason you provided the information to us.
To communicate with you about the Services, including Service announcements, updates or offers.
To provide support and assistance for the Services.
To create and manage your Account or other user profiles.
To process orders or other transactions.
To respond to user inquiries and fulfill user requests.
To improve and develop the Services, including testing, research, analysis and product development.
To de-identify and aggregate your Personal Data so that you are not identified as an individual, and use such de-identified and aggregated information to develop de-identified and aggregated data feeds, database, and products or provide such de-identified and aggregated information to our partners. You have the choice to opt out from such use. Please see the subsection “Information that’s been de-identified” below for more details.
To personalize website content and communications based on your preferences.
To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at privacy@mojing.im.

Information that’s been de-identified

For the purpose of this subsection on “Information that’s been de-identified”, we use Commercial Messages from your Connected Email Account for the de-identification and/or aggregation purposes as explained below, but we do not use any Non-Commercial Messages in doing so. We only access and process Non-Commercial Messages in your Connected Email Accounts as authorized by you to convert such email messages to text messages, to enable you to enjoy the functionalities and services provided by our Magic Crystal App, and to provide the Magic Crystal App Services to you.

We use information from Commercial Messages collected through your Connected Email Accounts, such as date , merchant, price, or other commercial or transactional information, to create de-identified and aggregated data so that you are not identified as an individual (the “De-identified and Aggregated Data”). We use the De-identified and Aggregated Data to develop alternative data products and for our business purposes, and provide such De-identified and Aggregated Data to subscribers of MAI Product (as further explained below).

MAI Products : We use the De-identified and Aggregated Data to create consumer insights, and to develop analytics and reports for market trends, industry development, and other business intelligence. For example, we scan and identify purchase receipts from Commercial Messages collected from your Connected Email Accounts, aggregate such de-identified information with other de-identified information from our other users of Magic Crystal App to create De-identified and Aggregated Data, which will become part of the database or data feeds we provide to subscribers of the MAI Products. We share the De-identified and Aggregated Data with users of the MAI Products and our other partners for their research, development, or other commercial purposes.

We may also allow partners to collect aggregated or de-identified information from you, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. For example, Google Analytics services may collect aggregated information about our users’ demographics. Again, Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/ .

In all cases where we provide De-identified and Aggregated Data to third party partners, we adopt the following protections:

We will not disclose De-identified and Aggregated Data in a manner that would identify you as an individual person.
All your Personal Data will be removed or obfuscated prior to any such sharing. If we do combine de-identified information with your Personal Data, the combined information will be treated as Personal Data for as long as it remains combined
We prohibit all subscribers of MAI Products to whom we share the De-identified and Aggregated Data from attempting to re-identify you as an individual person.
We endeavor to only include Commercial Messages when creating the De-identified and Aggregated Data that will be shared with any third party partners.
We are not interested in personal correspondence. The data we use to create Data Reports or Aggregated and Anonymized Data is only that identified as commercial/transactional emails.

OPT OUT: You may opt out of sharing information from your Commercial Messages for our use to create De-identified and Aggregated Data at any time by (i) going to https://mailtime.com/optout/optout.html , or (ii) changing the settings in the Magic Crystal App (under “Legal & Privacy). You can continue to use the Magic Crystal App services with no degradation to your experience.

About Gmail Users:

The way we can use the information we receive from your connected email accounts is also subject to the policies imposed by your email service providers and your account settings with them. As you may know, Google recently implemented an updated Google API Services: User Data Policy (https://developers.google.com/terms/api-services-user-data-policy, the “Google API Policy”), which restricts the use of data obtained from certain restricted Gmail APIs, as well as data aggregated, anonymized, or derived from them. In order to comply with the Google Policy, we decide not to include any data that we obtained from those restricted Gmail APIs in our big data products (including MAI). If you have any questions, or would like to learn more about this, please feel free to reach out at privacy@mojing.im. In order to comply with the Google Policy, we will only use the data that we obtained from the restricted Gmail APIs for the specific “Limited Uses” as permitted by the Google Policy.

How We Share Your Personal Data

Categories of Third Parties with Whom We Share Personal Data

We disclose your Personal Data as indicated in the chart above to the following categories of service providers and other parties:

“Service Providers”
- These are third parties that help us provide our Services, including security and fraud prevention providers, hosting and other technology and communications providers, analytics providers.

Disclosures of Personal Data for a Business Purpose

We disclose your Personal Data to service providers and other parties for the following business purposes:

Auditing related to a current interaction and concurrent transactions, including, but not limited to, auditing compliance with this specification and other standards.
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
Performing services on our behalf, including providing customer service, providing analytic services, or providing similar services on behalf of the business or service provider.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture (or that was manufactured for us) or control.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. All Personal Information is transferred via Transport Layer Security (TLS) technology and stored encrypted at rest using AES-256 encryption. All Personal Information stored on our Services is hosted on Amazon Web Services (AWS) and Microsoft Azure, which undergo various third-party independent audits on a regular basis, covering compliance controls for its data centers, infrastructure, and operations. This includes SOC 2 certification and ISO 27001 certification.

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@mojing.im.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@mojing.im.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Please note that uninstalling the Magic Crystal application from your mobile device does not delete your Personal Information we hold in our records. If you want to disassociate your email accounts from our Services and delete the Personal Information, you should submit a Valid Request for deletion. Some information may remain in our records after the deletion, but only in a way that would not identify you personally. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

Call us at: +852-58012345
Email us at: privacy@mojing.im

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@mojing.im.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@mojing.im with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Magic Crystal website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

+852-58012345
https://mojing.im/
privacy@mojing.im
9/F, 118 Wai Yip Street, Kwun Tong, Hong kong