DupDub Privacy Policy

DupDub Privacy Policy

Last Updated: August 2, 2023 (This Policy will be taken effect as of August 2, 2023)

Thank you for using DupDub!

Your privacy is important to us. DupDub respects your right to privacy. This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Policy applies to personal information that we collect through DupDub websites (collectively referred as "DupDub services" or "services of DupDub").

When this Policy mentions "DupDub", "We", "Us", or "Our", it refers to the HK SmartMV Limited that is responsible for your information under this Privacy Policy (the Data Controller).

Quick links

We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link below to jump to that section.

1. What Does Mobvoi Do

HK SmartMV Limited and all affiliated companies is an artificial intelligence company, but with group companies all around the world. Our Services based on core voice-based technologies enable DupDub and our authorised partner to serve you with audio editing platform services.

(i) To help you successfully register a DupDub account and further provide you with DupDub services, you need to provide us with your email address or authorize us log in to a third-party account.

(ii) When you use Text to Speech of DupDub services, in order to synthesize relevant audios, and at the same time to facilitate your own management, query, edit and deletion of your files, we will save the text content you actively uploaded.

(iii) To facilitate preview and modification of your Text to Speech files, we will save the audio files you created using DupDub services.

(iv) When you use Productivity Tools of DupDub services, you may need to type or upload the corresponding video links, video files, audio files or text files to perform corresponding actions. However, for your privacy and security considerations, we recommend that you do not upload any files that may contain personal or private information.

(v) When you use Face/Voice Model Training of DupDub services, you may need to upload or record the corresponding image files, video files, audio files or text files to perform corresponding actions. However, for your privacy and security considerations, we recommend that you do not upload any files that may contain personal or private information.

(vi) When you purchase DupDub membership services, in order to count sales and provide you with after-sales support, we will collect your order time, payment amount and etc through the third-party payment platforms.

(vii) To optimize product experience and understand how you access and use DupDub services, we will collect your usage log data (such as click data) and search records. For marketing purposes, we and our partners may use these data for analysis, to notify you about updated or upgraded services and features, to provide customer support, to notify you of the latest events, promotions and etc. However, these data do not contain any of your private information.

For more information about DupDub, please see the "Contact Us" section of our Website at https://www.dupdub.com/contact.

2. Legal Basis for Processing Personal Information

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us by dupdub-support@mobvoi.com.

3. How We Collect Your Personal Information

When you use the services of DupDub, we ask for and collect the following your personal information.

1. 3.1 Information that you provide voluntarily

   For using DupDub services, we may ask you to provide personal information voluntarily. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. You do not have to provide your personal information to DupDub, but in some cases, the non-provision of certain personal information will cause the inability to provide you with some related products or services.

   Information that is necessary for the use of the DupDub services

   This information is necessary for the adequate performance of the services provided by DupDub. Without it, we may not be able to provide you with all the services requested by you.

   • Account Information. When you sign up a DupDub account, we require certain information such as name, email address and/or phone number, contact information.

   Personal Information you choose to share with us

   You may choose to provide us with additional personal information in order to have a better user experience when using services of DupDub. This additional information will be processed based on your consent.

   • Additional profile information. You may choose to provide additional information as part of your DupDub profile (such as nickname).
   • Share Information refers to your information or information related to you shared voluntarily on Mobvoi services. The share information can include the information you posted on Mobvoi accounts (including your publicized personal information, your Mobvoi account name, and Mobvoi account user photo, Bluetooth, video and recording obtained from the camera and/or radio sensor in your device with your prior consent). The share information also includes the information related to you shared by other users who use the services of Mobvoi (including location data and log information).
   • Face data is utilized specifically for generating a live portrait, also known as a talking head photo. When you use the "Talking Photo" function, we will ask you to take the initiative to upload the original face data information, we will process the face data information you uploaded, this kind of information is the information that must be collected in order to provide this function, and we will take strict encryption measures in accordance with the requirements of the law for the process of collecting, transmitting and storing this kind of information of yours We will take strict encryption measures for your such information during collection, transmission and storage in accordance with legal requirements to ensure the security of your information. We only provide real-time portrait video services, we will not extract identifying information, use it for identification purposes, or share it with third parties, and upon completion of the service, the system will automatically delete the aforementioned information without retaining it. When uploading the aforementioned information, we will ask you to authorize the permissions of your camera and file system.

2. 3.2 Information we automatically collect from your use of the Services of DupDub

   When you use the services of DupDub, we automatically collect the following your information from your device. In some countries, including countries in EEA, this information may be considered personal information under applicable data protection laws.

   Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), contact information and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.

   Collecting these types of information enables us to better understand the users. We use this information to analyse your preference, habit and location, etc. so as to provide more tailored services to you (e.g. provide advertising and promotion information that better meets your needs).

   This information is necessary for the adequate performance of our contractual obligation to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of services of DupDub.

3. 3.3 Information that we obtain from third party

   From time to time, we may receive personal information about you from third party sources (including Google etc.), but only where we have checked that these third parties either have your consent or are otherwise legally permitted to disclose your personal information to us.

   The types of information we collect from third parties include account information and we use the information we receive from these third parties to create/sign up DupDub account and maintain and improve the accuracy of the records we hold about you.

   These third parties will have their own rules about the collection, use and disclose of information. We encourage you to review their privacy policies.

4. 3.4 Collection and use of non-identifiable data

   Non-identifiable data refers to data that cannot be used to identify an individual. Examples of non-identifiable data include statistics on website visits, application downloads, and product sales volume. DupDub will collect statistics information to understand how users use our products and services. By doing so, we can improve our services to better meet your requirements.
   We keep your personal information and non-identifiable data separate, and use each independently. Circumstances may arise where DupDub collects, uses, discloses, and transfers non-identifiable data for other purposes at our own discretion.

4. How We Use Your Personal Information

We use, store, and process your information, including your personal information, to provide, understand, improve, and develop our services of DupDub, create and maintain a trusted and safer environment and comply with our legal obligations.

1. 4.1 Provide, improve and develop DupDub Services

   For providing the services of DupDub (and specific function within services of DupDub). We process this information given our legitimate interest in improving DupDub services with it, and where it is necessary for the adequate performance of the contract with you.

2. 4.2 Create and maintain a safer environment

   • For customer service, security, fraud detection, archive and backup purposes as we provide the services of DupDub which in line with DupDub Terms of Service and other Mobvoi policies.
   • Comply with our legal obligations.

   We process this information given out legitimate interest in protecting services of Mobvoi to measure the adequate performance of our contract with you and to comply with applicable laws.

3. 4.3 Provide, customise, measure and improve our advertising and marketing

   • For the better understanding how you access and use the services of DupDub, improving the services of DupDub and developing new services; and for responding to users’ wishes and preference, including language setting, location setting, personalised support services and instructions; or for giving other responses to you and other DupDub services users.
   • For product presentation, personalised recommendations and sending promotional information, such as service updates, voice updates, promotion information and etc.

   We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your DupDub Account.

4. 4.4 In general, we will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you. We will ask for your consent in advance or if for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes and where this is permitted by applicable data protection laws where published in the relevant jurisdictions.

5. 4.5 The agreement or clauses relating to use personal information in DupDub Terms of Service, if any, is still subject to this Privacy Policy.

5. How We Share, Transfer, Publically Disclose and Retain Your Personal Information

We do not share personal information with other companies, organizations and individuals unless one of the following circumstances applies:

5.1 Sharing with consent

After obtaining your consent, DupDub will share the information that you have authorized with specified third parties or categories of third parties.

5.2 Sharing pursuant to laws and regulations

• Share your personal information to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to protect your vital interests or those of any other person; or (iv) to pursue our legitimate interests where your rights and freedoms do not outweigh these interests.

5.3 Our affiliated companies

To enable or support us in providing services of DupDub, we may share your information, including personal information, within our corporate affiliates. We only share the necessary personal information and we are bound by the purpose stated in the Privacy Policy. If the affiliated companies change the purpose of processing personal information, they will ask for your re-authorization and re-consent. Learn more about our affiliates here. The data sharing is necessary for the performance of the contract between you and us.

• We may share some of your personal information with our partners to perform a contract with you. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North America.
• We will share your necessary information to service providers that support our worldwide business for the following purposes: (i) Assisting us in providing the services of DupDub for you; (ii) Assisting us in performing the purpose stated in「How We Use Your Personal Information」section; (iii) Fulfilling our responsibilities and enforce our rights under the DupDub Terms of Service or this Privacy Policy and/or assist in understanding and improving our services; and (iv) Provide the technical infrastructure service, analyse the usage mode of our services, measure the effectiveness of advertisement, services and payment convenience, or conduct academic research and survey.
• For example, communication service providers who send E-mail or push notice on our behalf.
• We will only share your personal information for legitimate, reasonable, necessary, specific, and explicit purposes. And we will only share the necessary personal information to provide services. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

5.4 Authorised advertising and analysis service partners

Only if obtaining your consent, we will not share your personal information with the partners who provide advertisement and analysis service. We will provide these partners with information about their advertising coverage and effectiveness without providing your personal identifiable information, or we may aggregate this information so that it does not identify your identity. For example, if advertisers agree to comply with our advertising guidelines, we may provide feedback about the effect, audience population of the advertisement or the number of people affected by the advertisement to install apps, or non-personal-identifiable demographic information (such as "25-year-old male in France with software development habit ") to assist them understand their audience or customers.

5.5 Business transfers

If DupDub undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g. due diligence). In this event, we will require the new companies or organisations that hold your personal information to continue to be bound by this Privacy Policy, otherwise we will require the companies or the organisations to ask for your re-authorisation and re-consent.

5.6 Aggregated data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymised information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

5.7 Reminder on processing personal information with third parties

If we or our affiliated companies must share your personal information with any third party to help us provide and improve our Services. We also impose strict restrictions on how our partners can use and disclose the data we provide. For example, we will sign a strict confidentiality agreement with that third party and we will use reasonable efforts to ensure the third party to use your personal information only under the following circumstances: (i) comply with this Privacy Policy; And (ii) subject to any other instruction we issued to such third party, including any our implemented appropriate confidentiality and security measure. We may provide these partners with aggregated and anonymised information, or other non-personal-identifiable information.

6. How We Protect Your Personal Information

6.1 We have taken the safety protection measures which conform to the industry standard to protect your personal information that we collect and process about you, and prevent data from suffering from unauthorized visit, public disclosure, usage, modification, damage or loss. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. For example, when you exchange data (such as credit card information) between your browser and “service”, it is protected by SSL encryption; We provide Https-safe browsing way for the website appeared in the homepage of the Privacy Policy; We use the encryption technology to ensure the confidentiality of data; We use the reliant protection mechanism to prevent data from suffering from malicious attack; We deploy the access control mechanism to ensure only authorized person can access the personal information; And we hold the safety and privacy protection training course to strengthen the recognition of our personnel about the importance of personal information protection.

6.2 In the case of a personal information breach, DupDub as data controller is under a legal obligation to notify the supervisory authority without undue delay (normally within 72 hours) unless the breach is unlikely to result in a risk to the rights and freedoms of the individuals.

6.3 We take all reasonable and feasible measures to ensure not to collect irrelevant personal information. We will only reserve your personal information to achieve the purpose stated in the Privacy Policy within the period required, unless such period need permitted by laws to be extended.

6.4 The internet is not an absolutely secure environment, and the email, instant messaging and other forms of communication with other DupDub users are not encrypted. We therefore strongly recommend that you do not to send the confidential information in this way. Please use a complicated password to secure your account.

6.5 We will make our best effort to ensure the security of any information you send as the internet environment is not absolutely secure. In the unfortunate event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations, including the basic situation of such incident, its possible impact, the treatment measures we have taken or will take, suggestions on how to prevent and reduce risks and remedial measures for you, etc. We will timely inform you of the relevant situation of events by E-mail, letter, telephone and pushing notice. If there is any difficulty to inform the personal information owner individually, we will take reasonable and effective ways to issue an announcement. Meanwhile, in accordance with the requirements of the regulatory authorities, we will actively report such authorities the development of the personal information security events.

7. Your Rights to Manage the Personal Information

Legislation in some countries and regions to which DupDub provides products and services or from where DupDub processes personal information, provides that data subjects the rights request in regard to the accessing, rectifying, deleting or erasure, porting, restricting, and objecting, the processing of related personal information by DupDub retains. In addition you will have the right to data portability.

7.1 Right of access

You have right to access your personal information except for prohibited by laws and regulations. If you want to exercise the access right, you can access it per se in following ways:

1. a) Account information -- you can access or edit the personal data information and payment information in your account, change your password, add safety information or close your account, etc. You can perform such operations by accessing “Voice Studio→Profile→Account”.
2. b) Audio files -- you can access your files by accessing “Voice Studio→Text to Speech→Files”

If you cannot access this personal information through above links or you wish to access information about you that are not provided on the links above, you can send E-mail to dupdub-support@mobvoi.com and we will reply your access request without undue delay and in any event within one month of receipt of the request.

We will provide other personal information to you that arises from your use of our products or services, only if it is not overmuch time-consuming. If you want to exercise data access, please send an email todupdub-support@mobvoi.com.

7.2 Right to rectification

a) If you find there is an inaccurate or incomplete personal information when we are processing your personal information, you have right to require us to correct it. You can correct it on your own through “Voice Studio→Profile→Account”.

b) You can edit your audio files by accessing “Voice Studio→Text to Speech→Files.

If you cannot correct this personal information through above links, you can send E-mail to support@mobvoi.com to file a correction request. We will process your correction request without undue delay and in any event within one month of receipt of the request.

7.3 Right to erasure ('Right to be Forgotten')

In the following circumstances, you can request us to delete your personal information:

1. a) If we process personal information in violation of laws and regulations;
2. b) If we collect and use your personal information without your consent;
3. c) If we process personal information in violation of our agreement;
4. d) If you no longer use our products and services, or you cancel your Mobvoi account;
5. e) If Mobvoi no longer serves you.

You can make a request to erasure your personal information by sending E-mail to dupdub-support@mobvoi.com and we will reply your request without undue delay and in any event within one month of receipt of the request.

When you delete the information from DupDub services, we may not immediately delete the corresponding information from the backup system; we will yet delete such information when the backup system is scheduled on updates.

7.4 In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by sending E-mail to support@mobvoi.com and we will reply your request without undue delay and in any event within one month of receipt of the request.

7.5 Change the scope of your authorization and consent

Each business function requires some basic personal information to be completed (see Section 3 of this Privacy Policy). You may give or withdraw your consent at any time of the collection and use of your personal information other than minimums use/set.

When you withdraw your consent, we will not process the corresponding personal information. However, your decision to withdraw consent will not affect personal information processing based on your previous authorization, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

7.6 Right to out-put of marketing communications we send you at any time.

You can exercise this right by clicking on the “unsubscribe” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us by sending E-mail to dupdub-support@mobvoi.com .

7.7 Right to data portability

You have the right to obtain your personal information copy. You can perform such operations by sending E-mail to dupdub-support@mobvoi.com and we will process your request without undue delay and in any event within one month of receipt of the request.

If technology measures permit, such as the data interface is compatible, we can also send a copy of your personal information to your designated third party directly at your request.

7.8 Right to complaint

You have right to compliant a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

7.9 How we respond to your request

To protect the security, you may need to provide the request in written or in other ways for your identity verification, then we can proceed. For your request, we will reply without undue delay and in any event within one month of receipt of the request.

In principle, we do not charge of your reasonable requests. However, we will charge a certain amount of cost for the requests that are repeated multiple times and exceed reasonable limits. We may reject requests if it is unreasonably repeated or requires overmuch time-consuming technical approach (such as a need to develop new systems or fundamentally change current practices) or poses a risk to the others legal rights and interests or is unrealistic (such as involving information stored on backup tapes/hard disks).

8. Our Notice

8.1 Notices and other types of communications

When you use the DupDub service, we can use your personal information to send emails, text messages, or push notifications to your device. If you do not wish to receive these newsletters, you can choose to have the "Cancellation Notice" (if any) on your device or contact us at dupdub-support@mobvoi.com .

8.2 Service-related announcements

We may from time to time send you service-related announcements in necessary (for example, when we suspend the DupDub service for maintenance). You are not entitled to cancel such announcements as it is service-related but not promotion-related.

9. Third Party Partners & Integrations

DupDub services may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services ("Third Party Partners"). DupDub doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, DupDub, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

10. Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

11. Global Operations and International Data Transfers

We operate globally to bring you our services. Where the laws of your country allow you to do so, you authorise us to transfer, store, and use your personal data in the United States, Mainland China and any other country where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country.

Specifically, our servers are located in Mainland China, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

When we transfer personal data outside of the EEA, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles.

DupDub has implemented global privacy practices for processing personal information protected under various data protection laws. DupDub transfers personal information between the countries in which we operate in accordance with the standards and conditions of applicable data protection laws, including standards and conditions related to security and processing.

Our Standard Contractual Clauses can be provided on request by sending email to dupdub-support@mobvoi.com We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

12. How We Use Cookies and Other Tracking Technologies

We use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.

13. How We Dispose the Personal Information of Children

13.1 DupDub's personal and home products are intended for adults. However, for the use of DupDub products and services by children, we are fully aware of the importance of taking extra preventive measures to protect privacy and security. DupDub identifies whether data subjects are children based on the age of majority defined by laws of the local countries and regions.

13.2 When children's personal information is collected based on the consent of the holders of parental responsibility, we will only use or disclose the information as permitted by law, explicitly consented to by the holders of parental responsibility, or required for protecting the children. Holders of parental responsibility who need to access, modify, or delete the personal information of their children and people under guardianship can contact us via the channels provided in "IV. How DupDub Protects Your Personal information."

13.3 If DupDub accidentally collects children's personal information without obtaining consent from provable holders of parental responsibility, DupDub will delete the information as soon as possible after becoming aware of it.

14. Privacy Policy Update

14.1 We may update our Privacy Policy from time to time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the website and update the "Last Updated" date at the top of this Privacy Policy.

14.2 We will give you the opportunity to review the revised Policy before you choose to continue using our Services. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the DupDub services will be subject to the revised Privacy Policy.

14.3 For the material changes, we may also provide the more prominent notice illustrating the specific changes in the Privacy Policy depending on the circumstances.

14.4 Material changes including but not limited to:

• The material changes in our service mode, such as the purpose of processing personal information, the type of personal information processed and the use of personal information, etc.;
• The material changes in our ownership structure and organization structure, such as owner change due to business adjustment or bankruptcy or merger & acquisition, etc.;
• Changes to the main object in personal information sharing, transfer or public disclosure;
• The material changes in your rights relating to how you are participating in personal information process and ways to exercise such rights;
• The change of responsible department or contact information or complaint channels relating to personal information security reasonability;
• The time of high risk indicated by personal information security assessment report.

15. How to Contact Us

If you have any inquiry, comments or suggestions about this Privacy Policy or want to discuss this Privacy Policy or any relative, please contact our data protection officer at dupdub-support@mobvoi.com. The data controller of your personal information is stated at the preamble of this Privacy Policy.