Privacy Policy

Last Updated: September 15, 2023

Introduction

Welcome to Dreamina. This Privacy Policy applies to the Dreamina website and related services (the “Platform”). This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users and other individuals in connection with our Services. It does not apply to other products or services that display or reference a different privacy policy. If you do not agree with this policy, you should not use the Platform.
The Platform is provided and controlled by Bytedance Pte. Ltd. with its registered address at 1 Raffles Quay, #26-10, South Tower, Singapore 048583 (“we” or “us”).
What Information We Collect
We may collect the following information from and about you, including information that you provide, automatically collected information, and information from other sources.
Information You Provide
For certain activities, such as when you register, upload content to the Platform, or contact us directly, you may provide some or all of the following information:

Automatically Collected Information
We automatically collect certain information from you when you use the platform, including when you are using the web without an account. Such information includes:

Information From Other Sources

How We Use Your Information
We will use your information in order to:

How We Share Your Information
This section sets out how we may share your information:
Our Corporate Group
We may share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, or companies that we control, are controlled by or under common control, and our service providers and strategic business partners, in each case in or outside your country, for the purposes set out in this Policy, as permitted by applicable law, to assist in the improvement and optimization of the Platform, or for our internal business purposes.
Law Enforcement
We may share your information with law enforcement agencies, public authorities or other entities if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

Sale or merger
We may also disclose your information to third parties:

We may share all of the information we collect in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy. Finally, we may share information with third parties with your consent or at your direction.
With your consent
Finally, we may share information with third parties with your consent or at your direction.
International Data Transfers
The information that we collect from you may be transferred to, and stored at, a destination outside of your country. It may also be processed by staff operating outside your country 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 and applicable law.


Location of Processing European Personal Data. We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections,please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
Your Rights and Choices
You can access and edit most of your profile information by signing into your account. We also provide a number of tools in Settings that allow you to control your information. Should you choose to do so, you may delete your entire account by contacting us at dreaminaglobal@bytedance.com.
See the Cookie Policy for choices about cookies.
If you have any questions on how to use those tools, or want to know about any rights you may have in the country where you live, please contact us at dreaminaglobal@bytedance.com.
Data Security
We take reasonable and appropriate technical and organizational measures to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
Data Retention
We generally retain your information for as long as it is necessary to serve the purpose(s) for which such information was collected, including to provide you with the Platform or the Services. However, there are occasions where we are likely to keep this information longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims. After you have terminated your use of our Platform or Services, we may store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we may also retain any information as reasonably necessary to comply with our legal obligations such as to allow us to resolve and litigate disputes, and to enforce our agreements.
Information Relating to Minors
This Platform is not directed at children under the age of 13 (14 in Canada) or equivalent minimum age in the relevant jurisdiction. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at dreaminaglobal@bytedance.com
Privacy Policy Updates
We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any 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 Platform 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 Platform.
Contact Us
Questions, comments and requests regarding this policy should be addressed to dreaminaglobal@bytedance.com.
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 dreaminaglobal@bytedance.com and we will endeavor 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.
Supplemental Terms - Jurisdiction Specific
Australia
Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How we share your information."
Brazil
If you are using our Services in Brazil, the following additional terms apply:
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.


We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:



Verifying your identity. For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.


Limitations to your rights. In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.


In case of doubt about your privacy, your rights or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal data, we would like to clarify them.


International Transfer of Data. We share your personal data globally with companies within our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Services or share your personal data with third parties located in other countries. Your personal data may therefore be subject to privacy laws other than those applicable in your country.


Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards to protect your personal data and to ensure that it is processed safely.


Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.


DPO. If you wish to contact the Data Protection Officer, please contact us: dpobrasil@bytedance.com
Canada
If you are using the Services in Canada, the following additional terms apply.
Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.
Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send. You can also adjust your preferences regarding certain types of personalized advertising by using the Ads tools in your Settings.
Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States and Singapore, and other foreign jurisdictions where we or our service providers are located. For information about the manner in which we or our service providers (including service providers outside Canada) process personal data, please contact us using the contact information set out below.
Contact. If you are a resident of Canada, you can contact our Privacy Office using the contact information provided in the “Contact Us” section.
European Economic Area (“EEA”), Switzerland, and UK
If you are using the Services in the EEA, Switzerland or the UK (the “European Region”), the following additional terms apply:
Legal bases for processing
We use your personal data only as permitted by law. Our legal bases for processing your personal data described in this Policy are described in the table below.

Personal information categories and processing purposeLegal basisWe use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>,
for example:



To enable us to administer and provide you with the Services including enabling you to create, edit, modify and share User Content and interact with other users, and to allow you to participate in interactive features of the Services, when you choose to do so; We also use this information to promote content or to provide you with tailored or personalized information or content that may be of interest to you.Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services.We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:



To understand how you use the Services, and to improve and develop the Services, including to train and improve our technology, such as our machine learning models and algorithms, The processing is necessary for our legitimate interests, namely, to improve and develop the Services.We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, and share such information with third-party advertising partners, for example:

to provide you with personalized advertising.We or our third-party advertising partners ask for your consent to serve you with personalized ads based on your combined activity on the Services and across unaffiliated apps and websites.

We use the <Information You Provide> and <Automatically Collected Information>, and share such information with third-party advertising partners, to provide you with non-personalized advertising. We or our third-party advertising partners serve you non-personalized advertising. This processing is necessary for our legitimate interests, namely to show non-personalised ads to keep the Services free of charge. We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>,and share such information with third-party advertising partners, to measure and understand the effectiveness of advertising.This processing is necessary for our legitimate interests, namely to grow our business and to enable us, our advertisers, and our advertising partners to understand how their ads performed and the audience that viewed or interacted with their ads. This is so that they can make informed decisions (such as what kinds of ad campaigns they may want to run, the type of audience they want to reach and the types of ads that users enjoy the most). This helps keep the advertising we show users relevant and entertaining, and keeps the Services free for all users.The categories of information that we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, we use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:

To comply with any legal obligation, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.

This processing is necessary in order to comply with our legal obligations under European Union or Member State law. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. Similarly processing may be necessary to respond to regulatory requests requiring the processing of information under Chapters IV and VI of the GDPR.


In other circumstances, the processing is necessary for our legitimate interests, namely, to disclose and share information with regulators or other government entities.We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:

To communicate with you, on service related matters, respond to and process your queries, requests, applications, complaints, and feedback, and notify you about changes to the Services, including changes to our terms and policies.

The processing is necessary for the performance of a contract with you.

We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:

We may use this information to send you marketing communications in accordance with your preferences.

The processing is necessary for our legitimate interests, namely to promote new developments and features of our Services. We will obtain your consent to send you messages where required by law.

We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example:

To enforce our Terms of Service and other conditions and policies, including to ensure that you are old enough to use the Services.

The processing is necessary for the performance of a contract with you.

We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>,, for example:

To detect abuse, fraud, illegal activity, to ensure your safety and security, including scanning, analysing and reviewing User Content and associated metadata for violations of our Terms of Service and other conditions and policies, if permitted by applicable law.


We may also use this information to conduct troubleshooting, data analysis, testing, and research.

The processing is necessary for our legitimate interests, namely,


In some cases, we may aggregate or anonymize the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, and use it in a way that is designed to be unable to identify you, for research, statistical, or other purposes, to the extent allowed by applicable law.The processing is necessary for our legitimate interests, namely to conduct research and protect personal information through aggregation or anonymisation, consistent with data minimization and privacy by design principles.We may use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. The specific types of information we use will depend on the specific situation.The processing is necessary to protect the vital interests of you or other individuals.We may use <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>,for any other purposes authorised by you. The actual information we use depends on the factual circumstances.We process your information when you have given us your consent to do so.

International data transfers
If you normally reside in the European Region, the personal data that we collect about you may be further transferred to, and stored at, a destination outside of the European Region (for instance, to our service providers and partners). For example, we may store the information that we collect in secure servers located in the United States and Singapore.
When we transfer your information outside of the European Region, we ensure it benefits from an adequate level of data protection by relying on:

If you wish to enquire further about these safeguards, please contact us at: dreaminaglobal@bytedance.com.


Your rights
You have the following rights:



Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.
Please send an email to us if you would like to exercise any of your rights: at dreaminaglobal@bytedance.com.


GDPR Representatives
If you are based in the United Kingdom, our designated GDPR representative is:
Cosmo Technology Private Limited
2 Temple Back East
Temple Quay
Bristol
United Kingdom
BS1 6EG


If you are based in the EEA or Switzerland, our designated GDPR representative is:
Mikros Information Technology Ireland Limited
Mespil Business Centre
Mespil House
Sussex Road
Dublin 4
Ireland
Mexico
If you use our services in Mexico, the following additional terms apply. In the event of a conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.


Data Controller: Bytedance Pte. Ltd.1 Raffles Quay, #26-10, South Tower, Singapore 048583


How we use your personal data. Almost all of the purposes of the processing data indicated above in the main section of this Privacy Policy are necessary purposes. However, the following are secondary purposes:



The above purposes are not necessary to provide the Services, but allow us to provide you with a better experience. We offer you the ability to make choices about how we use and disclose your personal data. You can always limit the secondary purposes of personalized advertising by using the tools in the Settings that allow you to limit certain features.


We use both human and automated means to process your data.


How we share your personal data. We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.


By providing us with your personal data and using our Services, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights as outlined below.


Language. The Policy may have been prepared in the English language and in the Spanish language. If you are a user located in Mexico, you shall refer to the Spanish version, which shall prevail.


Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, objection, consent withdrawal, limitation of use and disclosure of your data. You may exercise your rights by sending your request to dreaminaglobal@bytedance.com. To learn about the applicable requirements and the procedure for exercising your rights, please contact us at the above email address. If you are under 18 years of age, you may exercise your rights through a parent or guardian. Requests to exercise for your rights will be resolved as soon as possible according to the applicable data protection law and the nature of your request.


Information relating to minors. You may review our parental consent section in the Terms of Service.


Cookies
We will, unless exempt, obtain your consent to the use of cookies. For more information about cookies, please visit our Cookie Policy.
Philippines
If you are using our Services in Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.


Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.
United States
If you are using the Services in the United States, they are provided and controlled by Bytedance Pte. Ltd. And the following additional terms apply:


Your Rights and Choices
Depending on where you live, you may be entitled to certain rights with respect to your personal information, as described below:



You may exercise these rights by submitting your request via the following methods:
Email: dreaminaglobal@bytedance.com
Address: 1 Raffles Quay, #26-10, South Tower, Singapore 048583


You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.
You may appeal any decision we have made about your request by replying to the communication you receive from us communicating your decision. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on theServices may change or no longer be available to you.
You may also have the right to opt out of the sale of your personal information and the use or disclosure of your personal information for purposes of serving you advertisements based on your activity across other sites and services (“cross-context behavioral advertising” or “targeted advertising”). Although Dreamina does not sell your personal information for money, we do process and disclose your personal information collected in the Dreamina app to third parties for cross-context behavioral or targeted advertising purposes. You may opt-out of the use and disclosure of your personal information for these advertising purposes by navigating to “Your Privacy Choices” in your settings and switching off the applicable toggle. Dreamina does not knowingly sell or share personal information for cross-context behavioral advertising or targeted advertising of users under 16 where restricted by applicable law.
Although some of the information we collect may be considered sensitive personal information, we only process such information in order to provide the Services and within other exemptions under applicable law, such as when we process your sensitive personal information in order to perform the services or provide the goods you request from us.
Other California Rights

Vietnam
If you are using our Services in Vietnam, the following additional terms apply:
Age, Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:



If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Services.