Release Date of this Privacy Policy:
March 21, 2025
Effective Date of this Privacy Policy:
March 21, 2025
This is the Privacy Policy of
SPACE
Z TECHNOLOGY PTE. LTD.
, (“
POOKIE
”, “us”, “we”, or “our”) which is incorporated into and is subject to our
Terms of Service
. Please read on to learn more about our data handling practices. Please ensure that you
fully understand the terms of this Privacy Policy and agree with this Privacy Policy before accessing or using
our
POOKIE
mobile application (“App”), www.pookk.com (“Site”) or all of the services available or related to therein (collectively
referred to in this Privacy Policy as the “Service”). If you do not agree with the terms of this Privacy Policy,
please do not use the Service.
When you use our Services, we may collect data from you as described below. When you
register and use your account with us we will collect data from you in order to provide the Services. The types
of data we collect depends on how you use our Services.
When you use our Services, for example, visit and use our Site or App, install the App
on your device, or register for an account with
POOKIE
, some personally identifiable information about you is collected in order for us to be
able to provide you with the Services. Further details about this are set out below.
When you install the Service on your device and/or register for an account with
POOKIE
, personally and/or non-personally identifiable information about you may be collected.
There are two types of Registration and Account Data;
Information you provide (mandatory) - You will be asked to provide your gender,
age, nick
name
, profile photo
and date of birth together with your mobile phone. This is necessary to enable us provide you with the connection and friends
features in our Service.
Information you provide (optional) - You may also choose to provide other personally
identifiable information such as your photos or videos of yourself, description of yourself and information
about your interests. The provision of such information is entirely optional. If you register and log in using
your Facebook, Google account or your mobile phone, you allow us to collect additional information that you make
available to us. For example, if you register with
POOKIE
using your Facebook account (e.g., Facebook Connect), we may collect and store
your Facebook ID and corresponding token on our servers for automatic log in and profile information and, if you
give us your express consent, we will have access to and may collect certain information that you make available
on Facebook (for example, your first and last names, email address, profile picture, birthdays). We will store
it on our servers and use it to facilitate your use of the Service – for example - we may synchronize your
POOKIE
account between different devices which you may use to access our
Service.
We also use your contact information to market to you as
your country’s laws allow – for example if there are new offerings for our Services or updates regarding
changes to our Services and to help others find your account if your settings permit, including through
third-party services and client applications. You can use your settings for email and mobile notifications to
control notifications you receive from us. You can also unsubscribe from a notification by following the
instructions contained within the notification.
When you use our Services we may collect information about your location. With your explicit consent, we may also collect information about your precise location using methods that include
GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers,
and compasses.
We receive information when you view content on or otherwise interact with our Services,
which we refer to as “Log Data”.
For example, when you visit our Site, sign into our Services, interact with our email
notifications, use your account to authenticate to a third-party service, we may receive information about you.
This Log Data includes information such as your IP address, operating system, configuration information made
available by the
POOKIE
app or desktop browser, the referring web page, pages visited, location, your
mobile carrier, device information (including device and application IDs), search terms (including those not
submitted as queries), and cookie information. We also receive Log Data when you click on, view, or interact
with links or make connections on our Services and general information about your communications on
POOKIE
such as the user you have communicated with and the date and duration of your
communications (but not the content of such communications, unless required for safety and security reasons)
including when and if you install another application through our Services. We use Log Data to operate our
Services and ensure their secure, reliable, and robust performance. The purpose for using Log Data is to protect
the security of accounts and to determine what is popular on our services and importantly Log Data is used to
enable you to make connection with new and former connections on
POOKIE
. We also use this data to improve our Services. We also use metadata, which means
information related to items to you have made available through
POOKIE
, such as the date or location that you made a connection via the
POOKIE
App.
We may receive information about you from Corporate Group, third parties such as
partners who help us evaluate the safety and quality of content on our platform, and other services you link to
your account.
We use the information we receive to operate our Services. For integrations that we
formally support, you may revoke this permission at any time from your application settings; for other
integrations, please visit the other service you have connected.
You may provide us with payment information in order to make purchases
provided as part of our Services. If you make a payment or send money using our features or Services,
including through an intermediary, we may receive information about your transaction such as when it was
made.
If another user uploads their contact list, we may combine information from that
user
’
s contact list with other information we have collected about you.
When you log into
POOKIE
on a browser or device, we will associate that browser or device with your account
for purposes such as authentication, security, and personalization. Subject to your settings, we may also
associate your account with browsers or devices other than those you use to log into
POOKIE
(or associate your logged-out device or browser with other browsers or devices).
When you provide other information to
POOKIE
, including an email address, we associate that information with your
POOKIE
account. Subject to your settings, we may also use this information in order to
infer other information about your identity, for example by associating your account with hashes of email
addresses that share common components with the email address you have provided to
POOKIE
. We do this to operate and personalize our Services. For example, if you log in through
Facebook, we may connect with your age profile there to help maintain the required standards to be on our App
and use the Services.
Device information –
POOKIE
may collect and store information about the device(s) which you use to install and
access the App, such as your device model, unique device identifier, IP address, device capability and
statistics on page views.
Your activity -
POOKIE
may collect and store information about your and others’ usage of and activity
within the App and our Site, including matches, numbers of matches made by members, match durations, text
messaging, usage of messaging service and usage of location service. We require from your device access to use
and to copy your photos for your profile picture and any photos/ media files you choose to share, so they can be
reproduced in the App and on our Site. We require the ability to access your camera / microphone and to record
video/ audio for us to deliver the video and audio, including music files and related files in order for you to
use and enjoy the Services whilst using the App and our Site and also to help us with our compliance
requirements, such as ensuring under 18s are not permitted to use our App or our Site.
Content you shared -
POOKIE
allows you to share your profile, interests, text messages, photos, screenshots,
videos,
audios
and other communications in the App with other users, and if you choose to do so,
your in-App profile, interests, text messages, photos, screenshots, videos, music choices and other
communications will be stored on our servers. In addition, if you choose to share these items with other
POOKIE
users, we may not be able to remove them from our servers or make them unavailable
to anyone you have shared them with. By choosing to share such information, you agree that you may no longer be
able to control how that information is used and that it may become publicly available (depending in part on
your actions or the actions of the other users with whom you have shared the information).
POOKIE
shall not be responsible for any use or misuse of such information that you share
with other users. You may refer to Part 7 below for more information on the parties with whom you may choose to
share your content.
Content you created - We may also collect and store any user content (e.g. photos,
screenshots, comments, interests and other materials) that you create or post on the App (“User
Content”).
Information about transactions made through our Service – In order to complete a
transaction, you will be requested to provide your payment information
.
In that event, we will transmit your information securely directly to a third-party
vendor or merchant who will collect such information in order to process and fulfil your purchase.
POOKIE
may process or store your payment information. However, we may store other
information about your purchases made on the App, which may include the date, time and amount of the
transaction and other behavioural information such as your purchase history.
Error-reporting information – We also collect error-reporting information if the App
crashes or fails to operate properly so that we can investigate the error and improve the stability of the App
for future releases. In general
,
these reports do not contain personally identifiable information, or only
incidentally. These error reports contain information such as the type and version of your device, the device
identifier, the time the error occurred, the feature being used and the state of the App when the error
occurred. We do not use this information for any purpose other than investigating and fixing the
error.
We may use online tracking technology such as cookies, pixel tags, web beacons and other
similar technologies to automatically collect information about:
· your visits to our Site, such as your browsing history, how long you stay on our Site,
and how often you visit; and
· your location information as provided by your mobile or other device when you interact
with our Site, including your IP address and general geographic location; and the device that you use to browse
our Site (e.g. your device ID, operating system, type of device, browser type and version, mobile application
crashes and other system activity, and third party sites you were using before interacting with our
Services).
You have the right to disable any of these online tracking technologies. These help us
ensure you are able to log into your account securely, develop our Services by using data analytics and develop
new services for our users. To learn more about how we use the above data, please see the “Cookie Policy”
section below.
The Service is not directed at children or persons under the
age of eighteen (18) and we do not knowingly collect personally identifiable information from children or
persons under the age of eighteen (18) as part of the Service. We do however collect information regarding
your age to ensure underage users are not part of our Services in order to maintain the security of our
Services and use third parties to help us maintain the correct age profile for our App. If we become aware
that we have inadvertently received or collected personally identifiable information from a user under the age
of eighteen (18) as part of the Service, we will delete such information from our records. If you are under
the age of eighteen (18), please do not use the Service.
You can access, control and modify the information you provide for your user profile on
the App (your “Profile”) at anytime. This includes your profile and profile pictures and videos, name,
interests, personal bio, languages you speak and your birthday, all of which can be shared with your
POOKIE
contacts. So please ensure you only share what you want to include in your
Profile. Your Profile will be made available to other users of the App who are connected to you. In addition,
your Profile is discoverable by other App users, for example, through listing of App contacts in the App that
will include your proximity to other users.
You may also choose to “block” any other
POOKIE
user in your contact list in the App which will prevent them from discovering your
Profile at any time. In addition,
POOKIE
may pre-populate your Profile with certain information such as your name and
Facebook profile picture, date of birth, email, gender, Facebook ID if you have logged into your account on the
App using your Facebook account. You can delete and change your Profile information in the App as indicated
below in section 12.
We adopt the data minimization principle when collecting and using your data and ensure
that your data will only be used in accordance with the stated purposes below. We will only process your data in
connection with the Service and for other related business purposes, including:
· to connect you with other users within the App;
· to enable you to share your Profile with other users on the App;
· to provide you with video and audio call functions of the App;
· to allow you to send images and videos through the App;
· to show you the names of persons you communicate with and to show your name to persons
you communicate with on the App;
· to provide you with certain features of the App that may be offered from time to time,
such as our Premium Services (please see our
Terms of Service
) ,play games and share /play music during your video calls
;
· to enable you to contact us
;
· to connect with third parties for payment processing
;
·
to pr
ovide and improve
advertising services, including to serve ads (including personalised ads, where
permitted) and to measure and understand the effectiveness of the ads and other content
; and
· to run analytics to provide you with better and relevant connections, provide you with
additional offers and for the purpose of providing you with updates to our Services.
· creating and updating your account;
· delivering to you any administrative notices, alerts and communications relevant to your
use of the App.
· to facilitate networking opportunities through the Service and provide you with location
or interests information relating to other users of the App.
· to use the information we have to develop, test and improve our Services, including by
conducting surveys, compiling research, statistics and analytics as well as habits and behaviours of users such
as purchase history, online interactions, and testing and troubleshooting new products and features.
· to handle and process any payments for transactions carried out through the Service via
third party service providers.
· to communicate with you about our Services, and let you know about our policies and
terms.
· to also use your information to respond to you when you contact us.
· sharing with third parties and the Corporate Group (see below in section 6) in order to
meet our contractual obligations
· For audit, compliance, controls, security and other risk management purposes, we use the
information we have to verify accounts and activity, combat harmful conduct, detect and prevent other bad
experiences, illegal behaviour, maintain the integrity of our Services, and promote safety and security. For
example, we use a combination of automated detection technology and manual review of the data we have to
investigate suspicious activity or violations of our
Terms of Service
and policies such as this Privacy Policy and enable you to report and contact us
if you have any issues to raise.
· To establish, exercise and/or defend our legal rights.
· To comply with our legal, regulatory and reporting requirements to regulatory
bodies.
· To ensure the safety of users through content moderation.
· In connection with a corporate transaction involving
POOKIE
, such as the purchase or sale of a business unit, an acquisition, merger, sale of
assets, or another similar event.
· To enable us to provide the Services and our contractual commitments to you.
· To enable us to carry out our contractual obligations with our Corporate Group and third
parties.
· We connect information about you and your activities on
POOKIE
with our other Apps and Services provided by us to provide you with a broad
engagement experience and to provide a more tailored and consistent experience with your use of the
Services.
· We may also pseudonymise or aggregate your personal data for analytical purposes. This
helps us develop new and improve existing Services, conduct fraud detection and account safety analysis, analyse
usage trends, and provide third party service providers with basic statistics about how their service is being
used by
POOKIE
users.
There are different legal reasons for processing your data while you are using our
Service. With respect to these legal reasons, we process your data for one or more of the following
basis.
We will not process your personal data without your explicit consent. We will only
process your personal data when you have given us consent to process your personal data for specified purposes, such as to provide our Service and other items requested
by you.
Notwithstanding the foregoing, please note that your personal data may be processed
without seeking your explicit consent in cases where one or more of the following conditions is met:
· It is expressly provided for by the laws;
· It is necessary for the protection of life or physical integrity of you or of any other
person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed
legally valid;
· Processing of your personal data is necessary and directly related to the establishment
or performance of the contract between you and
POOKIE
(i.e.,
Terms of Service
);
· It is necessary for compliance with a legal obligation to which
POOKIE
is subject;
· Your personal data has been made public by yourself;
· Processing of your personal data is necessary for the establishment, exercise or
protection of any right;
· Processing of your personal data is necessary for the legitimate interests pursued by
POOKIE
, provided that this processing shall not violate your fundamental rights and
freedoms.
We may provide your personal data to the Corporate Group, vendors and service providers
who support our business, such as by providing technical infrastructure services, analysing how our Services are
used, providing customer service, security services, facilitating payments, music sharing or conducting surveys
with your explicit consent, unless one or more of the conditions as set out in section 5.2 are met. Besides, if
we share your personal data abroad, we will ensure adequate protection is provided or provide commitment for
adequate protection in writing and obtain authorisation of the applicable authority. Examples of third parties
to whom your personal data may be disclosed or transferred to for any of the purposes mentioned in this Privacy
Policy in order for the Services to be provided to you are:
· Our parent company, subsidiaries, affiliates and/or branch offices (collectively
referred to in this Privacy Policy as the “Corporate Group”) who support the App or Site Services as well as the
integration of your information with our other apps who deliver and perform the Services;
· Any of our or any Corporate Group member’s agents, contractors including, IT companies
who support our website and other business systems, back office service providers, payment service providers,
data management and analytics service providers, data cleansing service providers and advertising service providers (such as Google Ads and Google Marketing Platform)
;
· Any relevant third parties such as telecommunications operators, third party collection
agencies, credit reference agencies, security agencies (including identification verification service
providers), credit providers, banks, financial institutions (including any payment
processors);
· Any professional advisors (including our legal advisors and auditors);
· Any regulatory authorities, law enforcement, courts and other governmental
agencies;
· And any of our actual or proposed assignees or transferees of any part of our business
or operations.
Any information or content that you voluntarily disclose or post on the App, such as
your User Content, becomes available to the public. Once you have shared such User Content or made it public,
that User Content may be viewed and re-shared by others and it may not be possible to prevent the distribution
of that User Content once it becomes public.
Even if you remove any User Content (e.g. screenshots, etc.) that you created or posted
on the App, copies of such User Content may remain accessible in the cached and archived pages of the App, or if
other users or third parties have copied or saved such information.(e.g. from using Facebook, etc.)
Any personally identifiable information that you: (i) share in text messages, photos,
videos or otherwise in or through the App with other users; or (ii) submit via live messaging on the App, can be
viewed and used by others.
POOKIE
is not responsible for any use or misuse of such information that you share or
submit.
You can always control what information you choose to share with us on the App (except
for information which we have indicated as mandatory for you to provide). To do so, you can change your settings
in the App or in your mobile device. Alternatively, you can remove the App from your mobile device
entirely.
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.
To delete your data please feel free to contact us via hello@pookk.com
Protecting your privacy and personal data is a top priority for
POOKIE
. We protect the privacy and security of all personally identifiable information you
provide to us. We run stress tests on our systems to help us improve. Access to all personally identifiable
information is strictly restricted to
POOKIE
and Corporate Group employees, contractors, agents and Third-Party Partners and
service providers who need to know that information in order to provide, operate, develop, maintain, support or
improve the Service or otherwise carry out any of the purposes as set out in this Privacy Policy.
POOKIE
implements appropriate technical and physical security measures, such as using
password protection, access logs, and system monitoring to maintain the confidentiality and security of all
users’ information against any loss or unauthorised disclosure, use and modification.
However, due to the inherent nature of the Internet and related technology, we do not
guarantee the protection of information under our control against any loss, misuse or alteration.
Your personal data may be stored and processed in any country in which
POOKIE
or Corporate Group or their service providers maintain facilities. In this regard,
or for purposes of sharing or disclosing data as described in this Privacy Policy,
POOKIE
reserves the right to transfer your personal data outside of your country.
POOKIE
and the Corporate Group share infrastructure, systems and technology to provide an
innovative, relevant, consistent and safe experiences across all of the Corporate Group Apps, such as the App
you use. We also process information about you across the Corporate Group for these purposes, as permitted by
applicable law and in accordance with their terms and policies.
When we transfer personal data internationally, we put in place safeguards in accordance
with applicable law. If you would like to know more about our personal data transfer practices, please contact
us at the contact details set out under the “Contact Information” section.
We will keep your personal data only for so long as is necessary to fulfil the purposes
outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer
need your personal data, we will either irreversibly anonymise or securely delete it from our
servers.
POOKIE
would like to make sure you are fully aware of all of your data protection rights.
In particular, you are entitled to the following rights:
(1) to learn whether your personal data are processed by
POOKIE
or not,
(2) to demand for information as to if your personal data have been processed by
POOKIE
,
(3) to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
(4) to know the third parties to whom your personal data are
transferred by
POOKIE
in your country or abroad,
(5) to request the rectification of the incomplete or inaccurate data, if any. For example, if you entered incorrect age or gender, we can assist you. Please
submit a report at
www.
POOKIE
live.com
or contact us
via Contact Us section through email
and we will handle your request,
(6) to request the erasure or destruction of your personal data in the event that the reasons for the processing no longer exist
or as required by law,
(7) to request reporting of the operations carried out pursuant to
sub-paragraphs (5) and (6) above to third parties to whom your personal data have been transferred by
POOKIE
,
(8) to object to the occurrence of a result against you by analyzing the data processed
solely through automated systems,
(9) to claim compensation for the damage arising from the unlawful processing of your personal data.
This section explains how we collect, use, store, share, and delete any face-related
data ("Face Data") that you voluntarily provide when using certain features of the App, such as generating a
personalized avatar.
When you voluntarily upload a photo for the purpose of generating an avatar or using our
AI Story features (such as generating polaroid photos or movie atmosphere), we may collect the following
data:
· Static facial images that you choose to upload.
· Facial feature points or facial embeddings, generated from your uploaded image
solely for avatar creation and AI content generation.
We do not collect:
· 3D face scans
· Depth information
· Live camera feed
· Biometric identifiers used for identity verification
· Any face data in the background without your knowledge
All Face Data is provided voluntarily by you.
We use your Face Data only for the following purposes:
· To analyze your uploaded photo and generate a personalized cartoon-style
avatar.
· To process your photo through our AI Story feature to generate customized content such
as polaroid photos and movie atmosphere based on your selections.
· To display the generated results to you within the App.
We do not use Face Data for:
· Identity recognition or identity verification
· Facial matching with other users
· Advertising or marketing
· Analytics or profiling
· AI model training (unless you separately opt-in in the future)
Your Face Data is never used for any purpose other than avatar generation and AI content
generation.
Face Data may be processed:
· On secure cloud servers, or
· On your device, depending on the specific feature and technical
requirements.
All processing is performed in accordance with applicable privacy and security
standards.
We follow a strict minimum-retention policy:
· Original facial images uploaded by you are deleted immediately after the
avatar generation or AI content process is completed, typically within seconds or minutes.
· Facial embeddings or feature data, if generated, are stored temporarily (no
longer than 24 hours) for troubleshooting and system performance purposes, then securely
deleted.
· We do not store Face Data for long-term use unless you provide separate explicit
consent.
You may request deletion of any Face Data at any time through the in-App "Delete
My Data" function or by contacting us.
We do not sell or rent any Face Data to third parties.
For Avatar Generation:
Data processed for generating standard avatars is handled on our own secure servers and
is not shared with any third-party external services.
For AI Story Features (Polaroid Photos, Movie Atmosphere):
To provide these specific advanced features, we utilize Application Programming
Interfaces (APIs) provided by trusted third-party artificial intelligence service providers. When you choose to
use the AI Story features, the specific photo you upload is securely transmitted to these third-party providers
solely for the purpose of generating the requested content.
We ensure by contract that these third parties:
· Only use the data to fulfill the requested generation task.
· Do not use your Face Data to train their generalized AI models.
· Delete your data immediately after the processing is complete.
Other than the specific third-party AI APIs required for the AI Story feature mentioned
above, we do not share your Face Data with:
· Advertisers
· Analytics providers
· Unrelated Business partners
We apply strict security and encryption measures to protect all Face Data during
transmission and processing, including:
· Encrypted data transfer
· Secure server environments
· Access control restrictions
· Regular security audits
Face Data is never publicly accessible or available to other users.
You maintain full control over your Face Data. You may:
· Withdraw consent at any time
· Request immediate deletion of all related data
· Decline to provide photos and still use other non-photo features of the App
If you choose to delete your account, all Face Data (including images, embeddings, and
logs) will be permanently deleted.
If you wish to update or delete your personal data submitted, you can update or delete
it via the App. Alternatively, you can send your request to our Customer Service Manager at:
hello@pookk.com
In addition, you have the right to lodge complaints about how
POOKIE
manages your personal data. You can lodge a complaint with
POOKIE
whose contact details are set out under the “Contact Information” section below,
or with a local data protection regulator.
We will conclude demands in your request within the shortest time by
taking into account the nature of the demand and at the latest within thirty (30) days and free of charge. However if the action requires an extra
cost, fees may be charged in the tariff determined by applicable authority. If we refuse your request, we will communicate and explain our
response to you together with justified grounds.
Cookies are small text files that are stored on your browser or device by websites,
applications, online media and advertisements when you visit a website.
We use cookies and other similar identification technologies such as web beacons and
pixel tags on our Site, App, emails and online advertisements for various purposes, including verifying users;
remembering user preferences and settings to enhance your experience when you return to our Site or App;
delivering relevant content and advertisements based on your preferences, location and usage patterns;
monitoring, evaluating and optimising the operation of our Site and App; tracking and measuring the
effectiveness of our advertising campaigns; and analysing traffic on our Site, our App and the websites of our
partners or Corporate Group members.
You can exercise your right to choose whether or not to accept cookies by adjusting your
browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default or prompt
you to accept cookies, but you are free to remove or block all browser cookies. However, if you turn off your
cookies, some of our services may not function properly and you will not be able to receive the most efficient
and personalised experience.
We reserve the right at our discretion to make changes to this Privacy Policy from time
to time. You may review updates to our Privacy Policy at any time via links on our Site. You agree to accept
electronic communications and/or postings of a revised Privacy Policy on the Site, and you agree that such
electronic communications or postings constitute notice to you of the Privacy Policy.
If we make material changes to this Privacy Policy, we will notify you by publishing a
revised Privacy Policy or by means of a notice on our Site, or as a pop up within our App, or as required by
law. You agree to review the Privacy Policy periodically so that you are aware of any modifications. You agree
that your continued use of the Service after we publish a revised Privacy Policy or provide a notice on our
website constitutes your acceptance of the revised Privacy Policy. If you do not agree with the terms of
revised Privacy Policy, you must stop your access or use of our Services.
If you have any questions about this Privacy Policy, please contact our us by email
: hello@pookk.com