We understand that our users care about how their personal information is used and shared. We work
hard to protect your information and take your privacy seriously.
Policy is meant to help you understand what information we collect, why we collect it, and how
you can review, update, manage, export, and delete your information. Our activities of collecting and
processing your data will be done in good faith and be subject to the following principles:
I - purpose: processing done for legitimate, specific and
explicit purposes of which the data subject is informed, with no possibility of subsequent processing that is
incompatible with these purposes;
II - suitability: compatibility of the processing with the
purposes communicated to the data subject, in accordance with the context of the processing;
III - necessity: limitation of the processing to the minimum
necessary to achieve its purposes, covering data that are relevant, proportional and non-excessive in relation
to the purposes of the data processing;
IV - free access: guarantee to the data subjects of facilitated
and free of charge consultation about the form and duration of the processing, as well as about the integrity
of their personal data;
V - quality of the data: guarantee to the data subjects of the
accuracy, clarity, relevancy and updating of the data, in accordance with the need and for achieving the
purpose of the processing;
VI - transparency: guarantee to the data subjects of clear,
precise and easily accessible information about the carrying out of the processing and the respective
processing agents, subject to commercial and industrial secrecy;
VII - security: use of technical and administrative measures
which are able to protect personal data from unauthorized accesses and accidental or unlawful situations of
destruction, loss, alteration, communication or dissemination;
VIII - prevention: adoption of measures to prevent the
occurrence of damages due to the processing of personal data;
IX - nondiscrimination: impossibility of carrying out the
processing for unlawful or abusive discriminatory purposes; and
X - accountability: demonstration by the agent of the adoption
of measures which are efficient and capable of proving the compliance with the rules of personal data
protection, including the efficacy of such measures.
Policy applies to the services offered by LARK PLAYER
and does not apply to the information practices of other companies and organizations that advertise our
services or services offered by other companies or individuals, including products or sites that may be
linked to our services.
WHAT INFORMATION DOES LARK PLAYER COLLECT?
information we collect can be generally placed in two categories: 1) data on how the user uses our
Services; 2) aggregate data on the content with which the user engages. We collect information to provide
better Services to you—from figuring out basic stuff like which language you speak, to more complex things
like which ads you’ll find most useful or which LARK PLAYER
videos you might like. The information we collect, and how that information is used, depends on how you use
our services and how you manage your privacy controls.
understand and consent that we may provide and share the information to our partners, so that they,
too, can provide you with an optimal experience, but we never disclose information to a partner in a manner
that would identify you personally.
When you are
not signed in to a valid account, we use the unique identifiers tied to the application or
device you are using to collect information. When you are signed in with a third party account, e.g., your Google Account, we use such a
specific account to collect information.
certainty, whenever you interact with our website or apps, we automatically receive and record
information on our server logs from your browser including your IP address, “cookie” information, and the page
you requested. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to
recognize your computer or device and tell us how and when the Services are visited and by how many people.
You may be able to change the preferences on your browser or device to prevent or limit your acceptance of
cookies, but this may prevent you from taking advantage of some of our features.
interact with LARK PLAYER, we automatically receive and record information on our server logs. The information we
1. Services usage
data. For example, this may include your age and
gender, language you use, terms you search for, videos you watch, views and interactions with content and ads,
voice and audio information when you use audio features, purchase activity, people with whom you communicate
or share content, information regarding the version of our software you are using, the location from where you
downloaded our software, how often you launch our software and which features you use.
2. Data on the
quality of our Services. For example, this may
include the interaction of your devices with our services, including IP address, crash reports, system
activity, and the date, time, and referrer URL of your request and your connection between your phone and your
3. Data on user
downloads. For example, this may include
information regarding which videos you download and your average download speed.
statistics on content. For example, this may include
the number of contacts you have on your phone, how many contacts you have marked as favorites, and the number
of apps, songs, videos, or other content you have on your phone. This information is only collected as
aggregate data, without reference to you or your contacts’ identities.
5. Hardware and
software identification. For example, this may
include the device type, settings and image resolution, operating system, mobile network information including
carrier name and phone number, the version of Android operating system, the size of your device’s screen and
internal storage. We support over 500 different Android devices and this helps us reach decisions as to how to
prioritize support for different kinds of hardware and software.
information. We may collect information about your
location when you use our Services. Your location can be determined by GPS, IP address, sensor data from your
device, information about things near your device, such as Wi-Fi access points, cell towers, and
few features to note:
1. If you're using our software
and it crashes, the crash report sent to our server may contain some information about the operating system
that you use.
2. If you download content via our
desktop software, we store a copy to your computer so that the next time you connect your phone you don't have
to download it again.
3. If you provide us with your
name and email address, we will use this information for the purpose of contacting you regarding our services
and products. You may opt out of such communications at any time by unsubscribing through our Website or
contacting us through one of the methods listed at the end of this policy.
not knowingly collect or solicit Personal Information from children under the applicable age
in your country or knowingly allow such persons to register unless it is upon the specific and highlighted
consent of at least one of the parents or the legal representatives of the child. If you are a child as
defined by any applicable law, please do not attempt to register for the Website or send any information
about yourself to us without the permission of your parents or legal representatives, including your name,
address, telephone number, or email address. No child may provide any personal information
to the Company
or on the Website without necessary permission from its parents or legal representatives. We will use
commercially reasonable efforts to verify that the consent referred to above was given by the child’s
representatives, considering available technologies. When we learn that we have collected personal
information from a child without verification of parental consent, we will delete that information as
quickly as possible. Children’s personal data may be collected without the consent mentioned above when
collection is necessary to contact the parents or the legal representatives, used one single time and not
stored, or for their protection, and under no circumstances shall the data be passed on to third parties
without consents as provided herein. If you believe that we might have any information from or about a
child, please contact us at
The data we
collect is sent to the Company servers in the USA in aggregate form and added to our system for
analysis. Our Services will not collect the following information without your specific consent or satisfying
the preconditions required by applicable laws:
or your friends’ phone numbers
• Any of the content
of your text messages, either sent or received
• Your music, photos,
video, or any contents you download via our Services
• Your sensitive
personal data concerning racial or ethnic origin, religious belief, political opinion, trade union or
religious, philosophical or political organization membership, data concerning health or sex life, genetic or
biometric data, when related to a natural person
generally retain information for as long as required, allowed or for as long as we believe it useful.
Even if the processing of personal data is terminated, we may continue to use and disclose your Personal
applicable laws for purposes of a) compliance with a legal or regulatory obligation by the controller; b)
transfer to third parties; or c) exclusive use of the controller, with access by third parties being
prohibited, and provided the data has been anonymized.
We do not
to help you understand our general practices. This policy is not a promise that your information will never be
disclosed except as described above. For example, third parties may unlawfully intercept or access information
transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone
might access, abuse or misuse information, despite a lack of permission. Although we use what we believe to be
commercially reasonable practices to protect your privacy, that does not mean, and you should not expect it to
mean, that your information or communications will always be private or protected.
WHY DOES LARK PLAYER COLLECT INFORMATION?
Be the Visionary in the Field of Content Discovery and Entertainment
Evolution, we do our best to execute our core values: Kaizen
Create Value for Our Users. The information we collect from all
our services is for the purposes of providing better services to you.
Maintain, Improve and Develop our Services.
We use your information to deliver our Services, and to ensure our Services are working stable, faster and
better. We also use the information we collect in existing Services to help us develop new ones to better suit
our users’ needs.
Personalized Services/Advertising. We may use
information we collect to customize our services for you, including providing recommendations
and personalized content. We don’t show you personalized ads based on sensitive categories, such as racial or
ethnic origin, religious belief, political opinion, trade union or religious, philosophical or political
organization membership, data concerning health or sex life, genetic or biometric data, when related to a
natural person. Also, we don’t share or use information that can personally identify you. You can control the
personalized advertising within the ad setting section in your device.
We use data for analytics and measurement to understand how our Services are used, which will help us to know
the pros and cons of particular features and the performance of advertisers’ ad campaigns as well. The ability
to measure our performance is an essential part of Kaizen.
with You. We may use
the information we collect to contact you, which enables us to make sure the services we provide
are safe and without interruption, e.g. when there’s any abnormal actions of your account or any important
events that you need to know. It also enables us to respond to your request as soon as possible if there is a
Public Policy. We use
information to help improve the safety and reliability of our services. This may include: a) for
compliance with a legal or regulatory obligation by the controller; b) by the public administration, for the
processing and shared used of data which are necessary for the execution of public policies provided in laws
or regulations, or based on contracts, agreements or similar instruments, subject to the provisions of Chapter
IV of Brazilian General Data Protection Law, the Law No. 13,709, of August 14, 2018; c) when necessary for the
execution of a contract or preliminary procedures related to a contract of which the data subject is a party,
at the request of the data subject; d)for regular exercise of rights in judicial, administrative or
arbitration procedures; e) for the protection of life of physical safety of the data subject or a third party;
f) to protect health, in a procedure carried out by health professionals or by health entities; g) when
necessary to fulfill the legitimate interests of the controller or a third party, except when the data
subject’s fundamental rights and liberties which require personal data protection prevail; or h) for the
protection of credit, including as provided in the pertinent legislation.
processing of personal data is a precondition for the provision of our Services or for the exercise
process your information for these purposes, such as automated systems that analyze your content to provide
you with things like customized search results, personalized ads, or other features. And we analyze your
content to help us detect abuse such as spam, malware, and illegal content. We also use algorithms to
recognize patterns in data.
RIGHTS OF YOUR PERSONAL INFORMATION
assured ownership of her/his personal data, with the fundamental rights of freedom, intimacy and privacy
You have the
right to obtain the following from the controller, namely the Company, regarding your
information being processed by the controller, at any time and by means of express request of you or your
legally constituted representative to the processing agent, to the extent allowed by applicable laws:
of the existence of the processing.
You may at any time confirm the processing of data by reviewing the terms and policies of the Company, emailing us or any other means provided by us.
When you are signed in, you can review and manage your basic personal data as well as data regarding your use
of the applications. When you are signed out, you can also manage your information associated with your
browser or device.
of incomplete, inaccurate or out-of-date data.
If you find out there is any incomplete, inaccurate or out-of-date information about you, you can contact us
at any time regarding these issues and we will correct the information in accordance with what you reasonably
blocking or deletion of unnecessary or excessive data or data processed in noncompliance
with the provisions of applicable laws. You can at
any time expressly request us to anonymize, block or delete certain information which you
believe is unnecessary or excessive for data processing and is not in compliance with applicable laws through
of the data to another service or product provider. By means of
an express request and subject to commercial and industrial secrecy, you can export a copy of
content in your Account if you want to back it up or use it with a service outside of LARK PLAYER
by emailing us, pursuant to the regulation of the controlling agency. This does not include data that have
already been anonymized by the controller.
personal data processed with the consent of the data subject. You can
choose to delete your personal information by emailing us unless the use and/or disclosure of the
information is for purposes of a) compliance with a legal or regulatory obligation by the controller; b)
transfer to third parties; or c) exclusive use of the controller, with access by third parties being
prohibited, and provided the data has been anonymized.
about public and private entities with which the controller has shared data.
During the collection and processing of your information, we may share or disclose your personal data to third
parties. The processor shall carry out the processing according to the instructions provided by the
controller, which shall verify the obedience of the own instructions and of the rules governing the subject.
You are entitled to know information about either public or private entities with which we have shared data by
about the possibility of denying consent and the consequences of such denial.
You can choose to give or deny your consent to the processing of your information. As listed in this Privacy
Policy, we collect and process certain information for certain purposes. The denial of consent will lead to
the failure of such purposes such as providing certain services to you or improving our products. If you have
any questions about the denying of consent such as the possibility of denying consent and the consequences of
such denial, please contact us at any time as you wish.
You can at any time revoke your consent, by express manifestation, through a facilitated and free of charge
procedure to the processing of your information to the extent allowed by applicable laws. We provide various
means for such revocation, e.g. through emails or privacy settings in the applications or your
SHARING YOUR INFORMATION
manifestly make your information become public, your consent is deemed to be made through your
action and we no longer need further consent from you to the extent allowed by applicable laws.
We may only
share your information with companies, organizations, individuals or other third parties outside LARK
with your consent. We reserve the rights to provide information to our affiliates and other trusted partners
applicable laws. We will also share your data outside LARK PLAYER
if we have abovementioned needs to Protect Public Policy.
better and personalized services for you, you understand and agree that we may share necessary information
INTERNATIONAL TRANSFER OF INFORMATION
information may be processed on servers located outside of the country where you live. Though the data
protection laws vary among countries, we try our best to comply with all applicable laws. Regardless of where
your information is processed, we apply the same protections described in this policy as well as comply with
all applicable laws, including without limitation, the Brazilian Data Protection Law.
is built with reliable security features that continuously protect your information. We keep detecting and
automatically blocking security threats from ever reaching you.
We work hard
to protect you from unauthorized access, alteration, disclosure, or destruction of information
we hold, including:
encryption to keep your data private while in transit
We review our
information collection, storage, and processing practices, including physical security
measures, to prevent unauthorized access to our systems
access to personal information to our employees, contractors, and agents who need that
information in order to process it. Anyone with this access is subject to strict contractual confidentiality
obligations and may be disciplined or terminated if they fail to meet these obligations.
We try to
ensure that our services protect information from accidental or malicious deletion. Because of
this, there may be delays between when you delete something and when copies are deleted from our active and
CHANGES TO THIS POLICY
information in ways that comply with it as well as applicable laws. We will not reduce your rights under this
clearly identified. If changes are significant, we’ll provide a more prominent notice, including, for certain
E-mail us at
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