Privacy Policy
This Privacy Policy discloses the privacy practices for the Colors web site and mobile service owned and operation by So Media Inc (collectively, the "Service" located at www.spinthecolors.com). So Media Inc, an Hong Kong corporation, the provider of the Service (referred to as "us" or "we"), is committed to protecting your privacy online. Please read the following to learn what information we collect from you (the "User" or the "End User") and how we use that information. If you have any questions about our privacy policy, please email us. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND TO ALL THE TERMS OF THIS PRIVACY POLICY AND OUR SERVICE TERMS OF USE. IF YOU DO NOT AGREE TO THESE TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE SERVICE.
1. Changes to Privacy Policy
If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of notice on our home page.
2. Types of Information Collected and Uses of Collected Information
We collect two types of information about our Service Users: Personally Identifiable Information and Non-Personally Identifiable Information.
Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific End User. When you engage in certain activities of the Service, such as ordering a product or service from us or our partners, submitting content and/or posting content in discussion forums, entering a contest or sweepstakes sponsored by us or our partners, filling out a survey, posting a review, sending us or our partners feedback, requesting information about our services, submitting an affiliate agreement, applying for a job, posting a video or signing up for special offers from third parties through the Service (collectively, "Identification Activities"), we may ask you to provide certain information about yourself. It is optional for you to engage in an Identification Activity. If you elect to engage in an Identification Activity, however, we may ask you to provide us with certain personal information about yourself, such as your first and last name, mailing address (including postal/zip code), email address, telephone number and date of birth. When you order products or services, we may also ask you to provide us with your credit card number, expiration date and authentication codes or related information. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.
We use Personally Identifiable Information to provide products and services to you, administer sweepstakes and contests, enhance the operation of the Service, improve our marketing and promotional efforts, analyze Service use, improve our product and service offerings, and to tailor your experience with third parties as provided in Item 3 of this Privacy Policy. For example, if you send our customer service an email we may use your comments and feedback to tell others about our services, and may post your comment in our marketing materials or on our Service. Your comments may contain personal information such as your name; we will obtain consent from you to post your name along with your comment prior to posting your comment for public view. In addition, if you use our Service to send information or a product to another person, we may store your personal information. We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Service Terms of Use and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.
Non-Personally Identifiable Information. Non-Personally Identifiable Information is information that does not identify a specific End User. This type of information may include things like the Uniform Resource Locator ("URL") of the website you visited before coming to our Service, the URL of the website you visit after leaving our Service, the type of browser you are using and your Internet Protocol ("IP") address. We, and/or our authorized Third Party Service Providers and Advertisers, may automatically collect this information when you visit our Service through the use of electronic tools like Cookies and Web beacons or Pixel tags, as described in Items 4 and 8 of this Privacy Policy.
We use Non-Personally Identifiable Information to troubleshoot, administer the Service, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third Party Service Providers and Advertisers to measure the overall effectiveness of our online advertising, content, and programming.
3. Release of Personally Identifiable Information
We will not share, sell, rent, or trade your Personally Identifiable Information with other parties except as provided below:
We may share your information with Colors Merchants. From time to time, we provide offers from particular merchants (referred to as "CC Merchants") who, as part of the offer, request information on Colors customers who purchased the offer in order to aid redemption. In those cases, we share some of your Personally Identifiable Information with CC Merchants. Sharing this Information may allow a CC Merchant to market directly to you should they choose to do so. However, we will only share Personally Identifiable Information with a CC Merchant if you engage in an Identification Activity, and then only to the CC Merchant involved in that Identification Activity. We specifically disclaim any responsibility or liability for the actions of such CC Merchant. While we inform them that they are only permitted to communicate with you for the purposes of the specific promotion with Colors, we do not have any responsibility for the actions of the CC Merchant, and the actions of the CC Merchant are not in our control.
We may share your information with Authorized Third Party Service Providers. We provide services and products through third parties. These "Third Party Service Providers" perform functions on our behalf, like sending out and distributing our administrative and promotional emails. We may share your Personally Identifiable Information with such Service Providers to fulfill orders, deliver packages, send postal or email, administer contests or sweepstakes, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the Service, troubleshoot, and provide customer service. We may also collect personal information from individuals and companies ("Affiliates") with whom we have business relationships and may share your information with Service Providers to accomplish our administrative tasks. For example, when you order a service, we release your credit card information to the card-issuing bank to confirm payment for the service and, if applicable, release your address to the delivery service to deliver the service. Likewise, we may release an Affiliate's information to our bank to send out a payment. We encourage CC Merchants and Third Party Service Providers to adopt and post privacy policies. However, the use of your Personally Identifiable Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
We may remarket your information. Remarketing is a way for us to connect with users, based upon your past interactions with the Colors website. Third-party marketing vendors may be hired by So Media Inc to perform remarketing services. As a result, third-party vendors, including Google, may show Colors ads on sites on the internet. Third-party vendors, including Google, use cookies to serve ads based on a user's prior visits to Colors's website. Users may opt out of Google's use of cookies by visiting the Google advertising opt-out page at http://www.google.com/privacy_ads.html. This information is used only for remarketing purposes and will not be used by them for any other purpose.
We may share your information in a Business Transfer. As with any other business, we could merge with, or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including Personally Identifiable Information. However, Personally Identifiable Information would remain subject to this Privacy Policy.
We may share all audio/video content created as a result of using the Colors Spin Story. Players acknowledge that all video content created via the Spin Story option is the exclusive property of Colors and So Media Inc. Player acknowledges by playing Colors they have agreed to and accepted all terms and conditions including the full release of all their rights to videos created using the Spin Story Option. Players further acknowledges that Colors may use the created audio/video files using the Spin Story for promotion, marketing, Colors Feed or any other means required.
4. Release of Non-Personally Identifiable Information
We may disclose or share Non-Personally Identifiable Information with Partners, Affiliates and Advertisers. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) with "Third Party Advertisers" or "Third Party Advertising Companies" and other parties as provided below:
We use Third Party Advertising Companies to serve ads when you visit our Service. These companies may use Non-Personally Identifiable Information about your visits to this and other websites in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you. Some of these Third Party Advertising Companies may be advertising networks that are members of the Network Advertising Initiative ("NAI"). If you would like more information about any NAI member company, or you would like to opt-out of targeted advertising from any NAI member company, click here.
We also use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our Users to administer our Service and constantly improve its quality. We may also publish this information for promotional purposes or as a representative audience for Advertisers. Please note that this is not Personally Identifiable Information, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.
5. Updating and Correcting Information
We believe that you should have the ability to access and edit the Personally Identifiable Information you provide us. You may change any of your Personally Identifiable Information by sending us an email at info@uso.com.hk or writing to us at ROOM 2103 21/F., NEW VENTURE CENTRE 18-22 LAM TIN STREET, KWAI CHUNG, N.T., HONG KONG.. Please indicate your name, address and email address, and what information you would like to update when you contact us.
We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on the Service. In addition, in may be impossible for us to completely delete all of your information because we periodically backup information.
6. User Choices on Collection and Use of Information
As discussed above, you can always choose not to provide information, although it may be required to engage in a certain activity on the Service.
As a condition of purchase of our products and services, we will send you Administrative and Promotional emails. We will send you information regarding your account activity and purchases as well as updates about our products and promotional offers. You cannot opt-out of Administrative Emails. "Administrative Emails" relate to a User's activity on the Service, and include emails regarding a particular User's account, requests or inquiries, and purchases of products and services. In contrast to Administrative Emails, however, you do have a choice with respect to Promotional Emails. Promotional Emails advertise our products and services, including exclusive sales and other offers, and/or the products and services of our Advertisers and Affiliates. If you do not want to receive Promotional Emails from us, you may elect to opt-out of receiving Promotional Emails at any time after registering by e-mailing us at info@uso.com.hk, by writing to us at the address contained herein, or by hitting the "unsubscribe" button at the bottom of any of our e-mails. When contacting us, please indicate your name, address, email address, and what Promotional Emails you do not want to receive.
7. Security of Information
We take security seriously and take numerous precautions to protect the security of Personally Identifiable Information. You can access your Personally Identifiable Information on our Service through a password and your email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to. We encrypt certain sensitive information (such as credit card information) using Secure Socket Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted to or from Service, and are not responsible for the actions of any third parties that may receive any such information.
8. Data Tracking
We may use other industry standard technologies like pixel tags and web beacons to track your use of our Service pages and promotions, or we may allow our Third Party Service Providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Service, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on our Service, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our Affiliates and/or Marketing Partners for the same purposes.
9. Privacy Policies of Third Party Websites
This Privacy Policy only addresses the use and disclosure of information we collect from you on www.spinthecolors.com. Other websites that may be accessible through this Service have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you review the website's privacy policy. We are not responsible for the policies or practices of third parties.
10. Miscellaneous Privacy Issues
Children. Minors under the age of 18 may not use the Service. We do not knowingly collect personal information from anyone under the age of 18, and no part of the Service is designed to attract anyone under the age of 18. So Media Inc does not sell products for purchase by children. In certain instances, we sell children's products for purchase by adults.
Facebook Connect. The Colors Site allows users to access Facebook Connect to interact with friends and to share on Facebook through Wall and friends' News Feeds. If you are logged into Facebook, when you click on "Tell Your Facebook Friends about this Deal" your profiles will merge if the email addresses match. By proceeding you are allowing the Colors Site to access your information and you are agreeing to the Facebook Terms of Use in your use of Colors Sites.
11. E-mail Newsletters
From time to time, we send e-mail messages to all registered users of our app. We use these messages to announce new updates and other Colors app related news.
Every e-mail message that you receive includes a link where you can unsubscribe instantly, if you wish to be removed from our mailing list. In that case, we will promptly remove your name and e-mail address.
12. Contacting Us
Whether you're a new or loyal customer, restaurant owner, marketer, publisher, media member or job seeker we'd like to stay connected and want to hear from you!
Corporate Address
So Media Inc. (d/b/a Colors)
ROOM 2103 21/F., NEW VENTURE CENTRE 18-22 LAM TIN STREET, KWAI CHUNG, N.T., HONG KONG.