Privacy Policy

Date of Last Revision: July 1, 2025

Welcome to LAKALAKA(the “Platform” or “LAKALAKA”). The Platform is provided and controlled by Hong Kong Hangna Network Technology Co., Limited (“we” or “us”). This Privacy Policy describes how and why we might collect, store, use, and/or share (“process”) your information when you use our service (“Services”), covering the experience we provide for users age 18 and over on our Platform.

The Privacy Policy was written in English (US). To the extent any translated version of this agreement conflicts with the English version, the English version controls.

If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@lakalaka.live.

WHAT INFORMATION DO WE COLLECT?

We collect information when you create an account and use the Platform. We also collect information you share with us from third-party social network providers, and technical and behavioral information about your use of the Platform.We collect message metadata (e.g., timestamps, sender/recipient) to investigate violations such as illegal transactions or terror-related communications. We also collect information contained in the messages you send through our Platform and information from your phone book, if you grant us access to your phone book on your mobile device. More information about the categories and sources of information is provided below.

Information you choose to provide

For certain activities, such as when you register, upload content to the Platform, make broadcast or contact us directly, you may provide some or all of the following information:

• Registration information, such as age, username and password, language, email or phone number, and social media account.
• Profile information, such as name, social media account information (including your nickname as it appears on your social media profile, your user ID) and profile image.
• User-generated content, such as comments, text, messages, pictures, images, videos, sounds, codes or other data or materials that you upload or broadcast on the Platform (“User Content”).
• Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect the names and phone numbers and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social contacts.
• Payment information, such as PayPal or other third-party payment information (where required for the purpose of payment, we will not retain and collect your credit card name, number or security number).
• Transaction information, such as transaction records and history, date, items, amounts.
• Your opt-in choices and communication preferences.
• Information to verify an account.
• Information in correspondence you send to us.
• Information you share through surveys or your participation in challenges, activities, events, sweepstakes, or contests such as your gender, age, likeness, and preferences.
• When you send feedback via the ‘Contact Us’ feature within the app, we will direct you to the default email application on your device (e.g. Gmail, Outlook). This process does not directly access your email account or the content of your email, but only launches the email client through the standard system interface (mailto protocol). The actual content of the emails you send is handled by the third-party mailbox application of your choice, and its privacy policy will apply.

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number or Facebook Account. Don’t worry! This is only to make sure you are not a robot! We won't use your phone number for marketing purposes.

Information we collect when you use

Once you have created a Profile and used LAKALAKA, you may choose to edit your gender, birthday and other information,however, please note that these are not required and you have a choice. We may collect information related to when and how you used our Services.We collect technical logs including your IP address, device model, operating system, browser type, access times, pages viewed, crash reports, and interaction patterns. These logs are used for security monitoring and service optimization. And we also collect infomation about mobile operators, network information (5G\4G\3G\WIFI). That information helps us identify your physical location so that it can be displayed and shared with other users choosing to view "nearby" users and moments. We may, from time to time, allow our employees to use the product for testing and user engagement purposes.

Camera and Photo Library Access ：When you use our Service, your position, microphone, and phone camera shall be used upon your explicit authorization. If you choose to upload photos or videos from your device's photo library, we may request access to your photo library to facilitate content sharing. Additionally, if you save content (e.g., images or videos) to your device, we may request photo library write access to store such content. The certain log file information shall be uploaded by yourself. All such information allows for more accurate reporting and improvement of the Service.

When you use LAKALAKA, we may ask you for mobile phone status permissions to ensure the arrival rate of push notifications and avoid repeated pushes. We promise not to disclose any of your mobile phone information.

Voice Room Music Playback：To enable music playback functionality in voice rooms, we may request access to your device's media library and local storage to read and play music files. This allows you to select and play music stored on your device during voice room sessions.

Small text files (Cookies). We may use small text files or similar technologies to collect information about how you use our products and their features.

You choose to post and/or publicly display the information. You can post your photos, voice or other materials on our products and share them with others in our products/through our products. The materials you post will remain under your control, and you can still choose whether to post, display or remove them.

When you subscribe or purchase paid services from us directly (not through iOS or Android platforms), you can provide information to us or our payment service providers, such as your signature card or credit card number, or other financial information.

Device identifiers, such as device brand, model, operating system version, operating system, browser type, serial number of the mobile device, Internet Protocol (IP) address, mobile operator, screen resolution, language setting, IMEI number, IMSI number, media access control (MAC) address, Android ID, SIM card serial number, device type, geographic location, login IP address, network access method and type, along with other related device information, are used for fraud risk identification.We collect such information to perform bug analysis and take anti-spam measures, to ensure your normal use of Lakalaka, and to safeguard your account security. The information mentioned above is the basic information we need to provide you with our services. If you refuse to provide such device information, we may not be able to provide you with the normal services.We may also use the above mentioned information we collect automatically from your device to improve and optimize our product experience. In such circumstances, we will only process your device information based on your authorization and/or other available lawful basis provided in applicable data protection laws. Additionally, SDK may requires permissions to access the microphone and its settings, Bluetooth connection, and to read phone state.

Advertising Identifiers ：We use mobile advertising identifiers (Apple's IDFA or Google's AAID) to deliver personalized advertisements. These identifiers allow us and our advertising partners to measure ad performance and show ads that may be more relevant to your interests. You can reset or restrict ad tracking through your device's privacy settings.

Storage and access to cookies related to LAKALAKA services is subject to the LAKALAKA Cookie Policy ("Cookie Policy").

Information we obtain from other sources

We may receive the information described in this Policy from other sources, such as:

• Social Media. if you choose to link or sign up using your social network (such as Facebook, Twitter, Instagram, or Google), we may collect information from these social media services, including your contact lists for these services and information relating to your use of the Platform in relation to these services,if you authorize and consent us to do so.
• Third-Party Services. We may collect information about you from third-party services, such as advertising partners, payment partners and analytics providers.However, please note that this Policy does not and will not extend, which shall be subject to the respective third-party’s privacy policies.
• We do not control and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preference on their sites and apps.

HOW DO WE PROCESS YOUR INFORMATION?

We will only use your personal data when applicable local law allows us to. We may only use your information in the following cases to provide you with better services. We may use your information that we received to:

• Help you efficiently access your information after you sign in;
• Remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
• Provide personalized content and information to you and others, which could include customized content , online ads or other forms of marketing;
• User-generated content ("UGC"), such as comments, text, messages, pictures, images, videos, sounds, codes or other data or materials that you upload, distribute or stream on the application when using the LAKALAKA service;
• Provide, improve, test, and monitor the effectiveness of our Service;
• Develop and test new products and features;
• Monitor metrics such as total number of visitors, traffic, and demographic patterns;
• Diagnose or fix technology problems, to fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback;
• Automatically update the LAKALAKA application on your device LAKALAKA or other Users may run contests, special offers or other events or activities ("Events") on the Service. If you do not want to participate in an Event, do not use the particular Metadata (i.e. hashtag or geotag) associated with that Event.
• Function and security: Identify users who do not meet the age limit, diagnose or repair technical problems, detect, prevent and respond to actual or potential fraud, illegal activities or intellectual property infringement;
• May use material that you post in the open access areas of LAKALAKA in advertising and promotional materials on our partner sites and partner products;
• Combine all the information we collect or receive about you for any of the foregoing purposes.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
• We employ automated systems and human review to scan public posts (e.g., photos, videos, text) for prohibited content, including pornography, violent extremism, terrorist propaganda, or graphic harm. Such content will be removed, and accounts may be reported to law enforcement.
• We may use algorithms to analyze your activity (e.g., content preferences) to personalize recommendations or ads. You have the right to object to such processing by contacting us or adjusting ad preferences in your account settings.
• We process your private messages to detect and prevent prohibited activities, including commercial transactions (e.g., buying/selling goods/services, cryptocurrency trading). Such processing is necessary to enforce our community guidelines and comply with legal obligations.

HOW WE SHARE YOUR PERSONAL INFORMATION?

We are committed to maintaining your trust and personal information safety, we will not provide, disclose or share your personal information to or with any third parties unless we have obtained your consent or such provision, disclosure or sharing of personal information is permitted under applicable laws.

Service Providers and Business Partners

In cases where you use the services of our business partner or services provided by service providers, we may share the categories of personal information listed above with service providers and business partners to help us perform business operations and for business purposes, including research, payment processing and transaction fulfillment, database maintenance, administering contests and special offers, technology services, deliveries, email deployment, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing.

In particular, in relation to targeted advertising, we use third-party advertising companies to serve ads when you use our app. These companies may use information about your visits to this and other websites in order to provide advertisements about goods and services of interest to you.

Within Our Corporate Group

We may share your information with a parent, subsidiary, or other affiliate of our corporate group for better service. We will take measures to have our group companies with which the personal information is shared comply with this Policy.

Succession of business

If there is any transaction between companies pertaining to our business to which this Policy is applicable, such as acquisition, merger or change of business entity, personal information may also be transferred to the successor of the business to the extent permitted under applicable laws.

Users who share your information

If you share information with other users, we cannot control the actions of other users. You share information with other users who use an application, service or website (including through Forums), and we cannot control your information, and we cannot and cannot control how other users will use or share the information. We are not responsible for the third party's circumvention of our security measures.

Sensitive information

We require that you do not transmit any personal sensitive information to us, nor disclose such information (such as race or ethnicity, political opinions or other beliefs, health status, sexual orientation, criminal background, or past) through an application, service, or website. This also includes organizational backgrounds and other relevant information, including union memberships.

Link to other websites or applications

When you click on links to any other website, mobile application or third-party content through the LAKALAKA service, you will be directed to another website or other mobile application, and another entity may collect your information or information about you. We cannot control, do not censor or be responsible for these third-party websites or mobile applications or their content. Please note that the terms of this privacy policy do not apply to these third-party websites or mobile applications or content, nor to any information collected by you clicking on links to these third-party websites, mobile applications or content.

For Legal Reasons

LAKALAKA also wishes to maintain a healthy community, and we will cooperate with all third parties to enforce their intellectual property or other rights.

We may disclose your information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of LAKALAKA, the Platform, our affiliates, users, or the public. We may also share your information to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law in our discretion.

We will also cooperate with law enforcement enquiries from within or outside your country of residence. When we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us.

With Your Consent

We may share information for various purposes with your consent or as directed by you.

If you access third-party services, such as Apple, Facebook, Google, or Twitter, to login to the Platform or to share information about your usage on the Platform with others, these third-party services may be able to collect information about you, including information about your activity on the Platform, and they may notify your connections on the third-party services about your use of the Platform, in accordance with their privacy policies.

Third party SDK provider: Lakalaka may incorporate third-party SDKs or similar applications. By using these third-party services on our platform, you consent to their direct collection and processing of your information, which may occur via embedded code or widgets. The information handling practices of these providers are governed by their own privacy policies, not this Policy. We, however, strive to assess these third parties for access qualifications and require compliance with legal, secure, and privacy standards. To best safeguard your information, we recommend reviewing each third-party provider’s privacy policy before using their SDKs. For your lawful rights and interests, if you identify any potential risks in these SDKs or applications, we encourage you to discontinue use immediately and contact us.

When you use a third-party email client through an in-app email feature (e.g., `Contact Us'), the content of the email, the recipient's address, and related metadata (e.g., time of delivery) will be processed by the email application of your choice. We do not monitor, store or intervene in this process, but may keep a record of your unsolicited communications to our support mailboxes (e.g. `contact@lakalaka.live`).

We may share aggregated information with such parties as Facebook that includes your personal information (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services.This may also include sharing your account information (such as your account information, purchase orders, purchase history, and your device ID) with third-party payment channels for the purpose of processing refunds.

LAKALAKA will not disclose your email and mobile phone number to anyone. When you use Google Pay, Apple Pay to pay or log in using third-party methods such as Facebook, Twitter, Instagram, they may ask you to enter your email or mobile phone number. For more information, you need to read their privacy policy.

To ensure you get to meet as many people as possible on LAKALAKA, other users will have chance to check your information you post on Profile, including photos if you select the Public' access setting. If you choose to engage in public activities on the Platform, You should be cautious to disclose personal information while engaging. We are not responsible for the information you choose to submit. Any information you choose to provide should reflect how much you want other LAKALAKA users to know about you. And you should be aware that any information you share may be read, collected, or used by other users. But you can also choose to restrict visibility scope of your information in the "Settings" page.

Please be aware that we may process your personal information for various legitimate purposes depending on the specific use case.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the internet or information storage technology can be 100% secure. Therefore, we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. While we strive to protect your personal information, transmitting personal information to and from our Services is at your own risk. You should access the Services only in a secure environment.

To protect our community, we utilize AI moderation tools and hash-matching technologies to identify and block known child sexual abuse material (CSAM), terrorist content, or illegal transactions. Suspected violations are reviewed by our safety team and escalated to authorities when required by law.

You must not disclose or share your password with any third parties. If your password is lost or compromised, your personal information may be at risk. In such cases, please report it to Support via Feedback immediately and change your password via your “Settings” page without delay. LAKALAKA is not responsible for the consequences of your failure to maintain password security, which may violate our Terms and Conditions of Use.

DATA RETENTION AND DELETION

You can choose to remove your data anytime you want. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers, subject to any applicable legal or other requirement to maintain certain records of your personally identifiable data. Please note that the deletion of your personally identifiable data from our database may result in us not being able to provide you with the Service.

If you need to delete any data or personal information that we may have, you can simply tap “Me-Settings-Delete account”, but we may ask you to verify your identity or provide additional information before we let you delete your personal information.

When your account is deleted, we will delete all of your personal information unless:
(1)For the purpose of compliance with applicable law: for example your payment information. If you make purchase within LAKALAKA, certain personal data may be kept for our tax and accounting purposes. If you would like to delete your information in the third party payment service provider, you should contact them directly.
Some applicable laws：
Legal Compliance: Retention required under tax laws (e.g., U.S. Internal Revenue Code § 6001), financial regulations, or anti-fraud statutes; Ongoing Legal Matters: Dispute resolution, litigation holds, or government investigations; Security & Fraud Prevention: Retain device identifiers to block banned users.
(2)If there is an ongoing matter, such as outstanding issues, investigations, claims or disputes, that require resolution, we may need to retain the relevant information, including but not limited to your phone number, email address and your geographic information.
(3)Legitimate business interests: To prevent fraud and enhance user safety and security, we may need to retain information. For example, the device ID and the OpenID provided by third parties (e.g. Apple, Facebook, Google, or Twitter) may be kept toprevent a user who has been banned for unsafe behavior or security incidents from opening a new account.

Please note that even if you remove certain information from your profile or delete your Account, it's possible that others may still be able to view or access that information. This could be due to the fact that the information was previously shared with others, or it may have been copied or stored by others. Unfortunately, we have no control over this and cannot be held liable for any such occurrences.

YOUR RIGHTS AND CHOICES

We strive to provide you with rights and choices regarding your personal information, including the right to close your account and delete your personal information.

Your choice

You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of our Website because such information may be required in order for you to register as a member, or purchase products or services, or promotion, or survey, or ask a question.

Permissions Control ：You can manage app permissions (e.g., camera, microphone, photo library, media library, storage) through your device settings. For example:

• iOS: Go to Settings > Privacy > Media & Apple Music / Photos / Camera / Microphone.
• Android: Go to Settings > Apps > LAKALAKA > Permissions.

Disabling certain permissions may limit your ability to use specific features, such as voice rooms or photo sharing. Please note that your choice to disable cookies will be specific to the specific browser or device you use to disable cookies, so you may need to disable cookies separately for each type of browser or device. If you disable or reject cookies, please note that some parts of the website may not be accessible or not function properly.

When you use the ‘Contact Us’ feature, you may be prompted to allow the app to open third-party email apps. This permission is managed by the operating system and you can adjust the setting via the following paths:

• Android: Settings → Apps → Default Apps → Open Links
• iOS: Settings → Mail → Default Mail Apps

Disabling this permission will prevent you from sending emails directly from the in-app button, you can still copy the email address manually to other clients.

You can request to opt out and allow us to send you push notifications at any time by adjusting the permissions in your mobile device.

If you don't want to share, you can turn off GPS location, microphone, camera or other similar functions on your mobile device. You can also hide your location, uploaded videos, recent activity time and other information by adjusting the "privacy" settings.

You can choose not to provide us with personal information, but this may prevent you from using certain functions of the LAKALAKA service, because you may need such information to register as a user, purchase paid services, participate in promotions, surveys, draw or complain.

You can restrict ad tracking through the privacy settings of your mobile device.

You can change your information by editing your profile in the application, including accessing your information, correcting or updating your information, or deleting your information.

Your rights

To the extent permitted under applicable laws, regarding your personal information that we process, you have the right to access, the right to rectification, the right to erasure, the right to restriction of processing, the right to withdrawal of your consent, the right to data portability, the right to confirm if we process any personal information of yours, and the right to request a review of any automated decisions that may be made as a result of the processing. And, we will not discriminate against you for exercising any rights. However, please note that you just have one chance to change your gender information if you provided it.

Data Portability ：Upon request, we will provide your personal data in a structured, machine-readable format (e.g., JSON/CSV) to facilitate transfer to another service provider.

If you wish to exercise your right against us to process your personal information, correct or delete your personal information that is contrary to facts, notify you of the purpose of use of your personal information, or other rights permitted under applicable laws, you may contact us via contact@lakalaka.live.

After verification of your identity, we will respond to your request within a reasonable period of time, and in accordance with relevant laws. If, however, permitted under applicable laws, we may not be able to respond to your request when any of the following applies:

• Is likely to harm the life, body, property, or other rights or interests of yours or another individual/user;
• Is likely to seriously impede the proper execution of our business;
• Is likely to violate other laws and regulations;
• When you failed to verify your identity;
• When we are otherwise permitted under applicable laws to refuse your request.

COOKIE POLICY AND OTHER TECHNOLOGIES

To make the application work effectively, we sometimes place small data files called cookies on your device. Most applications’ developers do this. A cookie is a small text file that a website saves when you visit the site. It enables the website to remember your actions and preferences, designed to improve your user experience.

You can control whether or not to accept cookies based on settings or by using other tools. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of our services or access all of its functions, which may limit your overall user experience.

Please note that changes you make to your cookies preferences may make using our services a less satisfying experience as they may not be as personalized to you.

You can personalize your device settings to control cookies:

• Apple devices: Go to “Settings” – “Privacy” – “Tracking” and manage your tracking;
• Android devices: Go to “Settings” – “Privacy” and manage your permissions.

If you disable or reject cookies, please note that some parts of the website may not be accessible or not function properly.

We may install modules of other companies in the LAKALAKA to analyze how the service and product have been used or provided. With regard to your personal information that is processed by a third-party through a module provided by such third party, the privacy policy of such third party will apply, and we also encourage you review it (if any). We are not responsible for the privacy practices of these third parties, which are not covered by this privacy policy.

NO RIGHTS OF THIRD PARTIES

We do not sell or rent out any personal information about you to any third party. LAKALAKA discloses aggregated non-personal data for marketing and promotional purposes. That means we do not disclose any information that could be used to identify you. This privacy policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Services.

Third-party information (such as the information of your Facebook account) is usually obtained through the application interface, applications, services, and websites. We may provide links to third-party websites as a service to our customers. When you click on a third party's connection on an application, service, or website, you may leave the application, service, or website. Some of these third-party websites may be cooperative brands with our name/label or the name/label of our relationship enterprise, even if these third-party websites are not operated or maintained by us. This policy does not deal with websites operated by third parties. We are not responsible for websites operated by third parties, whether they are connected to third-party websites by an application, service, or website, or third-party website that can be accessed in other ways from an application, service, or website. The inclusion of a link or access to a third-party website does not mean that we recognize the third-party website.

LAKALAKA will not disclose your email and mobile phone number to anyone. When you use Google Pay, Apple Pay to pay or log in using third-party methods such as Facebook, Twitter, Instagram, they may ask you to enter your email or mobile phone number. For more information, you need to read their privacy policy.

In the following cases, we will delete all open platform data as soon as possible:

• When it is no longer necessary to retain open platform data for legitimate commercial purposes in accordance with these terms and all other applicable terms and policies;
• When we stop operating the products or services previously used to obtain these open platform data;
• When a third party requires us to delete open platform data for the purpose of protecting users;
• When you request to delete your open platform data or cancel the account created in our products or services (open platform data has been aggregated, fuzzy or de-identified, except that it cannot be linked to a specific user, browser, or device), or for a technology provider, when you or the customer requests to delete when its open platform data or the customer cancels the account created in your product or service;
• When required by applicable laws or regulations;
• If applicable laws or regulations require us to retain open platform data, we will retain the proof of the requirements or requests of applicable laws or regulations and provide them to third parties when requested.
• If we receive the open platform data by mistake, we will feedback to the third party, delete the open platform data, and provide the deletion certificate upon request.

CHILDREN'S PRIVACY POLICY

LAKALAKA is not intended for users under the age of 18. You must be at least 18 years old, or meet the legal age requirement in your country/region, to use our services without parental consent. By using LAKALAKA, you confirm that you have the necessary legal capacity to do so.

We do not knowingly collect or maintain personal information from users under the age of 18. If we learn that personal information from a person under 18 has been collected, we will promptly delete this information and deactivate the user’s account.

If you believe we have unintentionally collected personal information from a child under 18, please contact us at contact@lakalaka.live. We will take reasonable steps to deactivate the relevant account(s) and remove the personal data from our records.

Retention of Your Information We will retain your personal information for as long as you maintain your LAKALAKA account. If you wish to delete your account, you can do so by:

Using the app: Go to Me > Settings > Account Management > Delete Account;

Email: Send your request to contact@lakalaka.live.

Upon receiving your request, we will review and delete any data that is not required to be retained for legal, regulatory, or other purposes. Please note that certain data, such as location, device, and usage data, may be retained for a reasonable period for purposes of safety, security, fraud prevention, and research. If there is any unresolved issue preventing deletion, such as an outstanding balance or a dispute, we will resolve the issue and proceed with account deletion.

We strictly prohibit content that sexualizes minors or exposes them to harmful material. Any user content suspected of involving child exploitation will be immediately deleted, reported to the National Center for Missing & Exploited Children (NCMEC), and result in permanent account termination.

REGIONAL PRIVACY DISCLOSURE

We are considered the “data controller” of the “personal data” (as defined under the General Data Protection Regulation) we handle under this Policy, responsible for deciding how to collect, use, and disclose personal data, subject to applicable law. To the extent the laws of the European Economic Area and the United Kingdom apply, our legal grounds for using, sharing, or disclosing your personal data are as follows: Contractual Commitments: We may use, share, or disclose personal data to honor our contractual commitments to you. With Your Consent: Where required by law, and in some other cases, we use, share, or disclose personal data on the basis of your consent. Legitimate Interests: In many cases, we use, share, or disclose personal data on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues. Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations. Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
International Data Transfers ：Your personal data may be transferred to and processed in countries outside your residence (e.g., Hong Kong), where data protection laws may differ. We ensure such transfers comply with applicable laws, using mechanisms like Standard Contractual Clauses (SCCs) or obtaining your explicit consent.
Residents of Nevada, United States. You have the right to opt-out of the sale of certain personal information to unaffiliated parties. You can exercise this right by contacting us as described in the “Contact Us” section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address. We do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. Residents of California, United States. Under the California Consumer Privacy Act (“CCPA”), we also have to provide you with the “categories” of personal information and sensitive personal information we collect and disclose for business or commercial purposes (as “categories” are defined by the CCPA).
A. In the twelve months leading up to the effective date of this Policy, we have collected and disclosed the categories of personal information described in Article 1 for business or commercial purposes. The categories of personal information are: identifiers, payment information, commercial or transactional information, audio or video information (such as pictures and videos you input), other information about you that you may provide to us voluntarily, other information that may identify you, and inferences drawn from the information we collect.
B. We also collect the following categories of “sensitive personal information,” as defined under the CCPA: (i) account log-in and password or other credentials that allow access to your account; and (ii) other sensitive personal information you may voluntarily provide to us in your capacity as an individual user of the Services (e.g. if you voluntarily input information revealing your race, religion, or sexual orientation).
C. We process the categories of personal information identified above for the purposes as described in more detail in Article 2 above.
D. We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) other parties such as other users and through unaffiliated parties.
E. We describe our information disclosure practices in more detail in Article 3 above.
F. The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information. Where we refer to “sell” or “share” (or their variants) in quotes, we are referring to those terms as uniquely defined in the CCPA.
G. We may use third-party analytics services and online advertising services that may result in the “sharing” of online identifiers (e.g., cookie data, IP addresses, device identifiers, general location information, and usage information) with advertising partners to advertise the Services on other websites. If you or your authorized agent would like to opt out of our “sharing” of your information for such purposes, you may do so by using the tools described in the section above on Tailored Advertising, which are also available here.
H. We do not knowingly “sell” or “share” the personal information of children under 18.
I. We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
G. Retention of your personal information: Please see the Data Retention section above.
K. California residents can make requests about their personal information as described in Article 8. The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA. Residents of Virginia, United States. The Virginia Consumer Data Protection Act (hereafter “VCDPA”) provides Virginian consumer residents who reside in Virginia with specific rights regarding their personal data. In addition to the general Privacy Policy herein, this section describes your VCDPA rights and explains how to exercise those rights. The following does not apply to de-identified or aggregated personal data or data publicly available, which are not considered personal information since they do not identify any individual.
A. As a Virginia resident, you have the following rights, subject to some exceptions, regarding your personal data effective as of January 1st, 2023:

• Right to Confirm if a Controller is processing your personal data and to access personal data.
• Right to Correct inaccurate personal data.
• Right to Delete.
• Right to Obtain a copy of personal data in a portable format.
• Right to Opt-Out of the processing of personal data for purposes of targeted advertising, sale, or profiling with legal or other significant effects.
• Right to Appeal – Consumers have the right to appeal a controller's (i.e., business) denial to act within the time outlined in the VCDPA.

B. You may make a verifiable request to exercise your rights by contacting us by emailing us at contact@lakalaka.live. Please note that the above rights depend on a few things, and we may refuse requests if there are exceptions under the applicable law: If we cannot verify you (or your authority to act on behalf of another person) we have the right to deny the requests. While verifying your identity, we generally avoid requesting additional information from you for verification purposes. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used to verify your identity while you are seeking to exercise your rights under applicable law, and for security or fraud-prevention purposes. We delete any new personal information collected for verification as soon as practical after processing your request, except as required to comply with applicable legislation. An "authorized agent" means a natural person or a business entity registered with the Secretary of State that you have authorized to act on your behalf, conditioned you have:
a. Provided the authorized agent written permission to do so, and we could verify this; and
b. Verify your own identity directly with the business. Subsection 1 does not apply when you have provided the authorized agent with a valid power of attorney. We do our best to timely respond to a verifiable individual, and in a portable format unless it is excessive, repetitive, or materially unfounded. If we require more time, we will inform you of the reason and the extension period in writing. We may update this Privacy Policy or change it from time to time, in particular, to address new features and functionality that we offer to our customers. We encourage you to check back here frequently to review what has changed. The most current version of this policy will govern our use of your data when posted and can be found on our website.

MISCELLANEOUS

Copyright Notice

Copyright @ 2024 LAKALAKA. All rights are reserved. All materials in APP are the property of LAKALAKA and are protected by copyright laws all over the world. You are authorized to use LAKALAKA and its contents solely for your personal, non-commercial purpose unless receiving specific written permission from LAKALAKA.

Disclaimer

You can use our instant message function, which allows you to communicate with other users of LAKALAKA. But we recommend and encourage you (and all our users) to consider carefully about the disclosed information of other users. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names, addresses, credit card details, national identity numbers, or drivers’ license details, and other sensitive information in your Profile, which is open to abuse and misuse.

Moreover, please be careful to post sensitive details about yourself on your Profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, there is no obligation to do so. Please remember that any photographs or video clips that you post on LAKALAKA may reveal these kinds of sensitive personal data. When you upload and post these sensitive information about yourself, you are explicitly consenting to our processing of your information. And you will at your own risk to do this. If you post anything which is inconsistent with our Terms and Conditions of Use, we reserve the right to disable your account.

LAKALAKA provides all materials in "as is" basis, and hereby disclaims any representations or warranties (expressed or implied) of any kind, including without limitation, any warranties of merchantability, fitness for a particular purpose, non-infringement, or other violation of rights arising from the use, accuracy, or reliability of materials of the Service or any sites linked out. You acknowledge any information transmitted may be intercepted. LAKALAKA does not warrant that its service or the servers which make the Service available or electronic communications transmitted are free from viruses, worms, Trojan horses, and other items of a destructive nature.

We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential, or punitive damages relating to this privacy policy.

E-mails sent through the ‘Contact Us’ function may contain your e-mail address, device information (e.g. IP address) and self-addressed content. Although we do not actively collect this information, third-party email service providers may record this data. We recommend that you regularly clear the cache of your email client to reduce the risk of information retention.

Links to Third Party Sites

There might be links direct you to third-party websites, these links are provided solely as a convenience for you. LAKALAKA does not endorse or make any representations or warranties about the contents, products, services available, or the security at such third-party websites.

Safe Harbor Provision

The information you obtain while using LAKALAKA may contain certain forward-looking statements, plans, and objectives with respect to the financial condition, operation, and business of LAKALAKA and/or any of its affiliate. The forward-looking statements are only predictions and are not guarantees of future performance. The forward-looking statements shall be subject to risks, uncertainties, and other uncontrollable factors including, but not limited to, levels of consumer and business spending in major economies, the levels of marketing and promotional expenditures by LAKALAKA and its competitors, raw materials and employee costs, changes in future exchange and interest rates, changes in tax rates, and technical changes, which could cause actual results materially different from those expressed or forecasted in the forward-looking statements.

Limitation of Liability

Lakalaka will not be liable for any damages of any kind arising out of or relating to the use or the inability to use the App, its content, or links, including but not limited to damages caused by or related to errors, omissions, interruptions, defects, delay in operation or transmission, virus, application failure, and all other direct, indirect, special, incidental, exemplary, or consequential damages, even if Lakalaka has been advised of the possibility of such damages. Lakalaka’s total liability to you for all losses, damages, and causes of action, including but not limited to those based on contract, tort, or otherwise, arising out of your use of the App, its content, or links, shall not exceed the amount of USD 200 dollars.

Governing Laws

This Policy shall be governed by the most applicable laws to that event, which shall be decided by LAKALAKA. The jurisdiction and venue of any actions arising out of, or relating to, or in any way connected with your access and/or use of this site shall be exclusively.

Prohibited Usage

You will not use the Service for any purpose that is unlawful or not allowed by LAKALAKA. You may not use our Service or its contents in any manner which could damage, disable, overburden, or interfere with any person to use this Service. You may not attempt to gain unauthorized access to the Service, other accounts, computer systems, or networks connection through hacking, password mining, or any other means. You may not use or attempt to use this Service through any means unanticipated or intentionally made available by LAKALAKA.

IP Protection

LAKALAKA respects intellectual property laws and has adopted the following policy toward intellectual property infringement on its products/services. Reporting Instances of Intellectual Property Violations: If you believe that any materials or contents in LAKALAKA’s APP infringe copyrights, trademarks, patents, or trade secrets (collectively “IP Right”), please send a notice of IP Rights infringement to LAKALAKA's agent with a physical signature of the owner of the IP Right that has been allegedly infringed.

Identification of the material that is claimed to be infringing, including its location on the LAKALAKA network, with sufficient detail so that LAKALAKA is capable of finding the material and verifying its existence. Please address your intention to remove the alleged infringed materials.

Contact information, including your name, address, telephone number, and email address.

A statement by you that you have a good faith belief that the disputed use is not authorized by the IP Right owner, its agent, or law.

A statement by you that the above information in your Notice is accurate and that, under penalty of perjury, you are the IP Right owner or authorized to act on the IP Right owner's behalf.

Agree to undertake compensation responsibility to LAKALAKA for any false and incorrect information addressed in the above statements.

CONTACT US/REPORT VIOLATIONS

If you have any questions or criticism about this policy or our privacy practices, or report any violation of this privacy policy, or report abuse of an application, service, or website, please contact us at contact@lakalaka.live.

CHANGE THIS PRIVACY POLICY

We may change our privacy policy at any time, and we will post any modifications on this website. Please check this policy regularly for updates. In some cases, we may also provide additional forms of notice for modifications or updates.

If you do not agree with any modifications to this privacy policy, your only option is to immediately and completely stop using all of our applications, services, and websites. Your continued use of any application, service, or website after we post and modify this privacy policy indicates that you accept the revised policy. Please note that no employee or agent of LAKALAKA has the authority to change any part of our privacy policy without formal amendment and publication on this website.