Welcome to Topbuzz/Topbuzz Video (the “Platform”). The Platform is provided or controlled by Bytedance Inc. (“we” or “us”). We committed to protecting and respecting your privacy.

We are registered in the State of Delaware, United States of America under company number 5943290 and have our registered office at 1013 Centre Road, Suite 403-B and our primary business location at Building No. 1, Zhong Hang Plaza, No. 43, North 3rd Ring Road West, Haidian District, Beijing, People’s Republic of China.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you are accepting and consenting to the practices described in this policy. Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Service.

1. The Types of Personal Data We Use

We may collect and use the following information about you:

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to enhance your experience using the Platform. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

We use the following Cookies:

If for any reason you wish to not take advantage of Cookies, you may disable Cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of the Platform and we will no longer be able to offer to you personalised content. Unless you opt out of Cookies, we will assume you consent to the use of Cookies.

“Do-not-track” signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to “do-not-track” signals in your web browser.

3. How We Use Your Personal Data

We will use the information in the following ways:

It is in our legitimate interests to promote the Platform, and by agreeing to comply with this policy you agree that we may use information that you give to us, such as user-generated content and video content that you may choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform.

4. How We Share Your Personal Data

We may share your personal data with selected third parties in or outside your country, including:

We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above (“How We Use Your Personal Data”). For Japanese personal data only, Bytedance Inc. continues to be primarily responsible for protection of your information.

We may share your information with law enforcement agencies, public or tax authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

We may also disclose your information to third parties:

5. Where We Store Your Personal Data

The information that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”), specifically, to third party servers in the United States and Singapore. It may also be processed by staff operating outside your country or the EEA who work for us, for one of our suppliers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy.

6. The Security of Your Personal Data

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

7. Data Retention

After you have terminated your use of our services, we may store your information in an aggregated and anonymised format. Notwithstanding the foregoing, we may also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

8. Information Relating to Children

The Platform is not directed at children under the age of 16 (or to persons under the age of: (i) 13 in the United States; (ii) 18 in Brazil; and (iii) 20 in Japan). Users under the relevant age are not allowed to use the Platform or register an account on the Platform without the consent of their parent of guardian. If we become aware that personal data has been collected from a person under such age in the relevant jurisdiction and parental or guardian consent has not been provided, we will delete this information and terminate the person’s account. If you believe that we may have personal data about or collected from a child under the specified age in the relevant jurisdiction without the consent of their parent or guardian, please contact us at contact@topbuzz.com.

9. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at contact@topbuzz.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.

10. Changes

We will use commercially reasonable efforts to generally notify all users of any material changes to this policy, such as through a notice on our Platform, however, you should look at this policy regularly to check for such changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

11. Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to contact@topbuzz.com.

12. Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Brazil. If you are using our services in Brazil, the following additional terms apply:

Japan. If you are using our services in Japan, the following additional terms apply:

United States. If you are using our services in the United States, the following additional terms apply: